The Preisangabenverordnung is the German rule on how prices are stated, and its logic is simple. A price shown to a consumer has to be the whole price, it has to be unambiguous, and it has to be visible before the consumer decides to buy. Anything that is really part of the price belongs inside the figure rather than beside it.
For a pharmacy selling a service rather than a product from a shelf, that becomes three obligations worth writing down:
- Completeness means the figure shown is the total the customer pays, including tax and including anything the service cannot be delivered without, for example a laboratory charge that is passed on.
- Timing means the price is stated before the customer commits, so it is known when the appointment is booked rather than after the sample has been taken.
- Visibility means the price is displayed where the service is presented in the pharmacy and on the page or form used to book it.
A figure that grows at the till because something was quoted separately is the failure this rule exists to prevent.
Most existing guidance was written with medicines and goods in mind, so price labelling, unit prices and shelf displays are all worked out in detail while services get less attention. A pharmacy offering a service can only apply the same principle, which means one total price per service, stated plainly, stated in advance, at the point where the offer is made. Where a service comes in variants, each variant carries its own total rather than a range with the low end printed in large type.
Two neighbouring rules belong beside this one. Under Privatliquidation the pharmacy sets its own price, which is exactly why the stating of it is regulated, and the figure quoted in advance has to be the figure that appears later on the Rechnung an den Selbstzahler. How the offer is worded, as opposed to how the price is stated, is governed separately by the Heilmittelwerbegesetz.
Whether the total includes VAT and at what rate depends on the service, and it belongs with your Steuerberater before the first price is printed, because the displayed figure and the invoice have to agree. Services in the apothekenübliche Dienstleistung category are the ones this concerns most directly.
This glossary entry is general information about German pharmacy law and practice. It is not legal advice. For binding guidance on your own pharmacy, contact your Landesapothekerkammer.
