Web Scraping and Time-Stamping for EU Omnibus Legislation Pricing Compliance

The "Omnibus European Legislation about Prices and Promotions" came into effect on May 28th, 2022 and according to Article 6a of the text, it is now mandatory to prove that "any announcement of a price reduction shall indicate the prior price applied by the trader for a determined period of time -no shorter than 30 days- prior to the application of the price reduction".

In this article, we will show you how stabler.tech, in combination with a time-stamping technology such as the one proposed by the APP ("Agence pour la Protection des Programmes") can help you comply with the Omnibus Directive.

An automated approach for accumulating legal proof of pricing

If you are a company running an e-commerce site, selling thousands - or even millions - of products each year, it can be a daunting task to demonstrate that the initial price of each product on promotion was charged more than 30 days ago.

Moreover, if you are a reseller with an affiliation business model, it can be even more complex to verify that your partners and suppliers have applied the initial price, outside of promotion periods.

Our web scraping tool stabler.tech, by extracting on a regular basis data from your own website or, with their prior agreement, from those of your partners, can help you build a database allowing you to follow the evolution of the prices of your products, including the initial price impacted by promotions.

In the event of a control by the relevant authorities related to price compliance, it is crucial to demonstrate two key points about this database:

- Immutability: the scraped data has not been modified nor "forged" after its extraction, and the prices obtained during this extraction correspond to those obtained at the date mentioned in the database.

- Authenticity: the scraped data has been extracted from the same website mentioned in the database.

In order to perform this price verification, the following tasks should be implemented: 

1. Extract on a regular basis the totality of prices charged for each product. This can be done with our stabler.tech tools.
2. Save the extraction information -including the logs- in a "Write Once, Read Many" server (also called WORM)
3. Keep the history of updates of the operators who configured the extraction robots, in order to prove the authenticity of the content and the effort made to deploy a data extraction technology.
4. Work with a time-stamping system like the one proposed by the APP (Agency for the Protection of Programs). At the end of each scraping operation, the logs are transformed into a "hash", a unique signature built by a hashing algorithm, which is stored in the APP servers. If an authority asks you to prove immutability, i.e. that the extracted data have not been modified, you will just have to compare your computed hash and the one stored by the APP. If only one character has changed, the two hashes will be different. 

This way of working allows you to create a solid "beam of proof" in the event of an audit, thus reducing the legal risk. Of course, it will be necessary to refine and adjust this operation to your company's processes, and to include your legal department in the loop.

stabler.tech and APP: a modular technology at your disposal

Today, the risks for companies which are not compliant with the Omnibus regulations are quite important. Indeed, penalties for "dubious commercial practices" may lead to companies being fined up to €300,000 and their legal representatives imprisoned for up to 2 years.

So far, it was almost impossible to find an integrated technology, adapted to industrial uses, that could limit this risk and allow a closer automated price tracking.

That period is over: stabler.tech now combines its state-of-the-art data extraction tools with the time-stamping technologies of the APP, recognized in this field. The APP services are directly connected to our robots in API, guaranteeing a smooth operation and adapted to high extraction volumes. Moreover, our modular architecture will allow us to perfectly respect your data model and to integrate in a few hours with your existing tools for pricing and data visualization.

At stabler.tech, we develop web scraping tools for industrial use. If Omnibus European Legislation compliance is an issue for you, contact us to find out more !

DISCLAIMER

This article is for informational purposes only.

stabler.tech and the APP (Agence pour la Protection des Programmes) do not make or purport to make, and hereby disclaims, any representations, warranties, or covenants in any form to any entity or person, including any representations, warranties, or covenants with respect to the accuracy and completeness of any information presented in this article.

stabler.tech and the APP (Agence pour la Protection des Programmes) accept no liability for damages, whether consequential or indirect, of any kind arising from the use of, reference to, or reliance on the contents of this article.

This article may contain references to third party research, legal materials, data and industry publications. No warranty is given as to the accuracy or completeness of such third party information. Neither the third party information nor its inferences or assumptions have been independently verified.

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