Short answer: look at the "previous price" first
On campaign days like 11.11, the real question is not "what percentage off" but "when was the struck-through price in force, and for how many days?" Keeping a price high for a while and bringing it back down on campaign day is a known pricing strategy that magnifies the sense of a discount; not every price change is made for that purpose, but if the "previous price" in a campaign ad does not reflect reality, it breaches the regulation.
In Turkey the rule has been this since 1 August 2026: under Article 14 of the Regulation on Commercial Advertising and Unfair Commercial Practices, in discount advertising for goods the "price before the discount" is the lowest price applied in the ten days before the discount starts. The earlier rule was 30 days. This article accuses no one and points to no company; it explains how the strategy works, what the rule does and does not catch, and how to check a price. It is not legal advice.
| Question | Short answer |
|---|---|
| Is a price rise made months ago illegal? | Not by itself; but the "previous price" shown in a discount ad must follow the rule |
| Which price counts as the price before the discount? | The lowest price in the 10 days before the discount starts |
| Which channel's price is used? | Only the price in the channel where the discount is made |
| How large is the fine? | Up to 39 million 916 thousand 524 TL, depending on the violation |
Where did 11.11 come from, and why is it here too?
According to KÜRE Encyclopedia, 11 November was first celebrated in 1993 by students at a university in China as a day for singles; the date comes from 11/11 looking like four single people side by side. In 2009 a Chinese e-commerce company turned the day into a large discount event, and over time it was tied to year-round promotional cycles. In Turkey, too, November has turned into a campaign month under names such as "Efsane Kasım", "Black Friday" or "Şahane Cuma" (the Ministry of Trade lists these names).
How does "raise first, discount later" work?
What does the strategy look like step by step?
The following is a fictional example; it is not a real product, price or company:
| Step | Price | What the shopper sees |
|---|---|---|
| 1. Normal period | 1,000 TL | Product at 1,000 TL |
| 2. Weeks earlier | 1,400 TL | Product at 1,400 TL (raised) |
| 3. Campaign day | 1,100 TL | "1,100 TL instead of 1,400 TL, 21% off" |
In the shopper's eyes 1,100 TL looks like a bargain against 1,400 TL, yet the normal-period price was 1,000 TL. This example does not say the price of a product must always stay at 1,000 TL: input costs, exchange rates, stock and demand can move prices for legitimate reasons. The question is whether the "previous price" in the campaign ad is the price the regulation describes.
Why is a struck-through price so effective?
It relates to our tendency to give too much weight to the first number we see (an "anchor"): Tversky and Kahneman's 1974 paper shows that people estimate from a starting value and adjust it insufficiently. A struck-through price is exactly such a starting value. The Ministry of Trade's Advertising Board, when adopting a principle decision on discount advertising in January 2024, also noted that a practice it had examined was used to create an unreal impression of a discount and that this distorted price perception and was misleading.
Does data show how many discounts are really "bargains"?
We could not find a thorough price-history study for Turkey. There is one from abroad, but it describes another market and other product groups: the UK consumer organisation Which? tracked the prices of 175 home, technology and health appliances at eight large retailers from May 2024 to May 2025. According to the result, 83% of products were the same price or cheaper at least once outside the four-week Black Friday period; on Black Friday itself, no product was at its cheapest price of the year. That does not mean the same ratios hold in Turkey, but it shows why comparing a campaign price with price history makes sense.
What does the regulation say?
Article 14 of the Regulation (as amended by Official Gazette no. 33297 of 1 July 2026) sets these rules for discount advertising:
| Paragraph | Rule |
|---|---|
| 1 | An ad with a discount statement must clearly give the price before the discount, the start and end dates, and the quantity if it is limited |
| 2 | Wording and visuals that cause confusion or create the impression of a bigger discount than actually applied are prohibited |
| 3 | For goods, the price before the discount is the lowest price in the 10 days before the discount starts; for perishable goods and services, the price immediately preceding the discounted price |
| 5 | With several sales channels, only the price in the channel where the discount is made counts; a price in one channel cannot be used for a discount in another |
30 days became 10: what changed?
According to an assessment written for Legal 500, the lowest price in the 30 days before the start of the discount used to apply; that period was cut to 10 days. The example in the Ministry's earlier guideline went like this: a product at 100 TL on the 1st was sold at 50 TL with a 50% discount on the 5th; if it was then announced again on the 15th as "60% off 100 TL, now 40 TL", the struck-through price had to be 50 TL, the lowest in the last 30 days, and the discount had to be written as 20%.
Our reading (not a legal opinion): because the window is shorter, if a price was raised more than 10 days before the discount and stayed at that level, the "price before the discount" can be that high price; so a rise made weeks or months earlier and then maintained is not caught by this rule alone. A discount ad on campaign day is still subject to the paragraph 2 prohibition (the impression of a bigger discount than actually applied) and to the general ban on deceptive practices. Interpreting the rule is for the Ministry of Trade and the Advertising Board; in a doubtful case you can complain to them.
Sanctions and enforcement
The Ministry of Trade announced that it follows November discount advertising across all media and that administrative fines of up to 39 million 916 thousand 524 TL can be imposed, depending on the violation. Enforcement is ongoing: according to the Advertising Board's statement on November 2024 discounts, 64 files on discounts were handled that month, 57 were found to breach the regulation, and administrative fines totalling 27.4 million TL were imposed.
How do you check a price as a shopper?
- Look at the price history. Check whether the struck-through price was really in force from a source that shows the product's prices over recent weeks. The store's own page is not sufficient evidence.
- Take a screenshot. Keep dated screenshots of the price before the campaign and on campaign day; they are evidence if you need to complain.
- Compare channels. Since the rule uses the price in the channel where the discount is made, also check the same product's price at another point of sale.
- Watch the conditions. In conditional campaigns such as "buy 3 pay for 2", a coupon in the basket or instalments with a certain card, read under which condition the price applies.
- Tell products apart. The same model may differ in capacity, colour or bundle; compare by model code.
- Complain. For a suspicious ad there is the Ministry's Alo 175 Consumer Helpline; the Advertising Board reviews discount files on complaint too.
How do you prepare for 11.11 as a business?
For a business running a campaign, the real matter is compliance and evidence. The list below separates sourced rules from our recommendations:
| # | Check | Type |
|---|---|---|
| 1 | Does the ad state the price before the discount and the start and end dates? | Rule (Art. 14/1) |
| 2 | Is the previous price the lowest price of the last 10 days before the discount? | Rule (Art. 14/3) |
| 3 | Is the price tracked per channel (web, mobile, store separately)? | Rule (Art. 14/5) |
| 4 | Is the quantity of a limited-stock product stated in the ad? | Rule (Art. 14/1) |
| 5 | Is every price change recorded with date and channel? | Our recommendation |
| 6 | Is the campaign condition (coupon, card, quantity) written clearly in the ad? | Our recommendation |
| 7 | Is the reason for a price increase (cost, exchange rate) kept on record? | Our recommendation |
To answer "when and in which channel did you apply this price" within minutes during an inspection, the system itself should keep the price history; a hand-kept spreadsheet goes stale in a campaign week. For what to check on the infrastructure side before a campaign, see our Black Friday e-commerce infrastructure checklist; for e-commerce software that keeps price history and campaign rules, see our e-commerce service page and our custom software development page.
Frequently asked questions
How is the price before the discount determined?
Under Article 14/3 of the Regulation, for goods the lowest price applied in the ten days before the start of the discount is used. For perishable goods and services, the price immediately preceding the discounted price is used. The price is determined only by the sales channel in which the discount is made.
Does a price raised months ago count as a "discount" on 11.11?
According to the text of the rule, the reference is the lowest price in the last 10 days before the discount. If the rise is older than that and the price stayed at that level, that higher price can be the reference; this is our reading, not a legal opinion. Even so, an ad must not give the impression of a bigger discount than actually applied (Article 14/2). In a doubtful case, complain to the Ministry.
Where do I report an unreal discount?
You can contact the Ministry of Trade's Alo 175 Consumer Helpline and the Advertising Board. Keep dated screenshots of the price and the ad.
Why did 11.11 become a campaign day in Turkey too?
Since 2009, 11 November has been a date that a Chinese e-commerce company turned into a large discount event; other Chinese e-commerce companies later started similar campaigns, and in Turkey too November is now known for campaigns.
If you would like to think through managing campaign prices, price history and rules in one place, get in touch.
Sources: Regulation on Commercial Advertising and Unfair Commercial Practices, consolidated text (Lexpera; amendment of Official Gazette no. 33297 of 1 July 2026, in force 1 August 2026), Changes to the Regulation on Commercial Advertising and Unfair Commercial Practices (Legal 500, Mondaq), November discount campaigns under the Ministry of Trade's close watch (Ministry of Trade), Advertising Board did not allow consumers to be deceived in November discounts (Ministry of Trade, 18 December 2024), Advertising Board continues to audit discount campaigns (Ministry of Trade, 2024), Guideline on advertisements with price information and discount sales advertisements and commercial practices (Ministry of Trade, 16 January 2024), Don't believe the hype: Most Black Friday deals the same price or cheaper at other times of the year (Which?), 11.11 Global Shopping Festival (KÜRE Encyclopedia), Judgment under Uncertainty: Heuristics and Biases (Tversky and Kahneman, Science, 1974)
Cover photo: Mustafa Turhan / Unsplash