Preisangabenverordnung

The Preisangabenverordnung is the German rule on how prices are stated. 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 translates into three obligations worth writing down.

The first is completeness. What is 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. A figure that grows at the till because something was quoted separately is the failure this rule exists to prevent. The second is timing. The price is stated before the customer commits, not while the invoice is being written, so it is known when the appointment is booked rather than after the sample has been taken. The third is visibility. The price is displayed where the service is actually offered and where a customer would look for it, which in practice means the place in the pharmacy where the service is presented and the page or form used to book it.

The under discussed part is that most existing guidance was written with medicines and goods in mind. Price labelling, unit prices and shelf displays are all worked out in detail, and services are the case that gets less attention. A pharmacy offering a service can only carry the principle across, 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 in large type.

Two neighbours matter here. 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 belongs with your Steuerberater before the first price is printed, since the displayed figure and the invoice have to agree. Services in the apothekenübliche Dienstleistung category are the ones this concerns most directly.