One Store Listed a Higher "Regular" Price on 78% of Its Coffee Options. FTC Guides Say It Has to Be Real.

When we pulled the product catalog for Lifeboost, one of the coffee stores in this guide, 355 of its 453 available coffee options carried a compare-at ("regular") price above the selling price. That's 78%. Every single-bag coffee carried a compare-at price of $39.99.

Crossed-out prices are everywhere in online retail, and they work. In the free product listings we counted in Chapter 15, 36% of cards showed one. But a crossed-out price is a claim, and federal guidance says what it has to mean.

This chapter covers sale prices, Merchant Center promotions and subscriptions: what the FTC requires of a "regular" price, when Google shows a sale badge, the rules for promotions, why the ad and the promotion have to agree, what subscriptions add, and how to handle bidding during a sale. The examples come from the stores in this guide, as examples, not verdicts; we can see their pages but not their price history. Your sale calendar will differ. The rules are the same.

The FTC Says a Crossed-Out Price Should Be One You Actually Offered, for a Reasonably Substantial Period of Time.

The FTC's Guides Against Deceptive Pricing are direct about former prices. A former price is a legitimate comparison if it "is the actual, bona fide price at which the article was offered to the public on a regular basis for a reasonably substantial period of time." If the former price was set high just so it could be marked down, the guides say, the bargain is "a false one."

Our stores listed compare-at prices at very different rates:

• Lifeboost: 355 of 453 coffee options, with "Regular price" $39.99 struck through and "save up to 44%" on its subscription page.
• Lectric: 72 of 115 bike listings, for example "$1,299 $1,752 Save up to $453."
• Ride1Up: 7 of 19 bikes, such as the Roadster v3 at $1,295, was $1,395.
• Aventon: 5 of 21 bike listings.
• Volcanica: 50 of 1,253 coffee options, about 4%, mostly Kona blends.

Cookware stores do it too: Misen's 10-inch pan at $101.15 against $119.00, Caraway's set with an "Original price" of $675, Made In's set with "Save $225."

None of that tells us whether those prices were charged long enough. That's the point. Only the store has its price history, so only the store can answer the question the FTC asks. If a product has been "on sale" for most of the year, the sale price may be the real regular price, and the crossed-out number may not hold up.

Google Shows a Sale Badge Only if the Regular Price Ran 5 of the Last 30 Days or 15 of the Last 200.

Google has its own test before it shows a sale on a Shopping ad. You send the original price in the price attribute and the sale price in the sale price attribute. For Shopping ads in the United States, Google's help lists the requirements:

• The sale price must be lower than the base price.
• The discount must be "greater than 5% and less than 90%."
• The base price must have been charged for 5 days within the past 30, or 15 days within the past 200, whichever comes first. The days don't need to be in a row.
• Both prices should show on the landing page.

Google also says how the page should look: "The active sale price should be the most prominent price on the page. The original price should be less prominent, can be struck through, grayed out, or otherwise displayed to show that it's not currently active."

Google's test is about whether it shows the badge. It isn't the FTC's test, and passing one doesn't mean passing the other. A price charged 5 days a month qualifies for Google's badge but may not be the price "offered to the public on a regular basis." Chapter 14 covered a related setting: automatic item updates can pick up strikethrough prices from your pages, so check what Google read.

Merchant Center Promotions Need at Least $5 or 5% Off, and Google Asks for a Day's Notice Before They Start.

Sale prices change the product. Promotions are offers on top of it, like a percent off the order, a free gift or free shipping over a threshold, shown as a line on your Shopping ads and free listings. Google reviews them first.

The main rules:

• Size. "Discounts must be at least $5 or 5% off."
• Types. Dollar or percent off, tiered discounts, buy one get one, a free gift, a gift card from your own store, and free shipping. Free shipping needs a valid redemption code unless it's combined with another promotion.
• Clarity. "Up to" discounts must state the minimum, and promotions limited to a subset of shoppers, like military or birthday discounts, aren't allowed.
• Timing. Google says to "submit promotions at least 24 hours before they are scheduled to start," and review is "typically completed within 12-24 hours of the promotion effective start time."

Eligible promotions in the U.S. can also appear on Google's deals page automatically. That's one more reason to get the details exactly right: the same offer may show in several places at once.

Your Ad Text and Your Promotion Have to Name the Same Discount. One Ad Said $20 Off While Its Promotion Said 20%.

A promotion line and an ad's own text sit next to each other, so they have to agree. In our ad pulls, one Caraway ad's description read "Save $20 On All Orders Over $875," while the promotion line on the same ad read "20% off Sitewide - On orders over $875 - Valid Oct 6 - Oct 7." On an $875 order, those are very different offers: $20 against $175.

We don't know which one was current or why the two differ; ad text often outlives the sale it was written for. But a shopper sees both, and Chapter 8 covered Google's rule against promising offers that aren't available on the page a shopper lands on.

The fix is a routine. When a promotion starts or ends, search your ad text and assets for the old offer, update the landing page and the banner, and check that the promotion's dates match the sale's real dates.

Merchant Center Promotions Can Now Discount a Subscription. State Auto-Renewal Laws Still Decide What Your Checkout Page Has to Tell the Buyer.

Subscriptions are the coffee stores' business model. Volcanica offers "Subscribe & Save 20%," with a bag at $18.39 against $22.99 one-time. Lifeboost's subscriptions run every 1 to 8 weeks, and its "Seasonal Sips club" is charged $126.00 each season.

Google now supports this in promotions. Its Merchant Center changelog says that starting January 2026, "We now support promotions on subscription fees," using the eligibility requirement "Subscribe and save."

The checkout is where the rules get specific, and they come from states, not Google. A few side by side, from each state's statute:

• California: terms "clear and conspicuous" and "in visual proximity" to the buyer's consent; buyers who sign up online can cancel online.
• New York: cancellation "as easy to use as the mechanism that the consumer used to provide consent."
• Illinois: for a free trial or promotion of 15 days or longer, notice "no less than 3 days before the cancellation deadline."
• Virginia: cancellation "at least as easy to use as the mechanism the consumer used to initiate," with no forced call to a live agent.
• Colorado: clear terms before the buyer agrees, and one-step online cancellation.

This isn't legal advice, and the details change. The common thread is simple: show the renewal terms next to the subscribe button, not only in the terms of service, and make canceling as easy as signing up.

Seasonality Adjustments Are Built for Sales of 1 to 7 Days. A Month-Long Sale Calls for a New Target Instead.

A big sale changes how often shoppers buy, and value bidding learns from the past. Google's answer for short events is the seasonality adjustment: you tell the bidding to expect a higher conversion rate for a set window. Google pitches them for events lasting a week or less, and warns they may not work as well once a window runs past two weeks.

They have limits for a store. Google says they need conversion history, so it says to use them only on existing campaigns. They're available for Search, Shopping and Display campaigns on Target ROAS or Target CPA, and for Performance Max. Our reading: a Standard Shopping campaign still on manual bids or on Maximize conversion value without a target can't use them.

For a three-day sale or a holiday weekend, a seasonality adjustment fits. For a month-long promotion, adjust the ROAS target instead, and set it back when the sale ends. Either way, check that the target still sits above the break-even ROAS from Chapter 3: a deep discount lowers the margin on every order, which raises the return the store needs from its ads.

Next: All 16 Chapters in Order, From Counting the Purchase to Running a Sale That Holds Up.

That's the guide. Here it is in the order we'd build a store's account:

1. Count the purchase, not the cart
2. Start with product searches
3. Know your break-even ROAS
4. Send clicks to the category page
5. Seed keyword research with your brands
6. Launch Standard Shopping first
7. Bid on order value
8. Write ad copy from your reviews
9. Check the settings before launch
10. Wait for about 30 sales a month before Performance Max
11. Bring in Demand Gen and YouTube later
12. Run your own brand campaign
13. Turn on AI Max for Shopping last
14. Fix the product feed
15. Earn the stars
16. Run a sale that holds up (this chapter)

Every chapter is also on the guide's home page.

When we run a store's account through Google Ads management, the sale calendar, the promotion setup and the bid targets get planned together. Doing it yourself? Pick your three most-discounted products and check how many days in the last 30 they sold at the crossed-out price.