EGalim SRP+ 2026: the raised loss-making resale threshold for retailers

Quick answer. SRP+ (the raised loss-making resale threshold) prevents a retailer from reselling a food product below its effective purchase price plus 10 %. Created by the EGalim law, this rule and the promotion caps were extended until 15 April 2028 by law 2025-337 of 11 April 2025. It compresses front margins and shifts value creation toward back margins, whose accounting must be mastered.

A store manager no longer sets pricing like a traditional retailer. On branded food, the lowest price that can be displayed is no longer a free decision: it is a floor set by law. Understanding that floor, its exceptions and the effect it has on the margin structure has become a management reflex as much as a compliance matter. Here is how we approach it in the large-retail files we handle.

Reselling at a loss has long been banned in France: a retailer cannot resell a product as-is below its effective purchase price. This old rule already aimed to protect small shops from predatory pricing. The EGalim law, born from the 2018 General Food Convention and reinforced in 2021 and 2023, went further for food products alone: the resale price can no longer fall below the effective purchase price plus 10 %.

The lawmaker's stated goal is twofold: to share value more fairly along the food chain, from producer to retailer, and to limit loss-leader pricing used to draw customers into stores. By artificially raising the resale floor, the State mechanically leaves a wider margin that the chain is supposed to be able to pass back upstream, to suppliers and farmers.

In practice, if a chain buys a product at 1.00 euro excl. VAT, it cannot resell it below 1.10 euro excl. VAT. The retailer therefore loses the aggressive-promotion lever on branded food, and the commercial trade-off shifts elsewhere.

The scheme has never been permanent: it works through renewed experimental periods. Law 2025-337 of 11 April 2025 extended SRP+ and the promotion caps until 15 April 2028. In 2026, the retailer must therefore keep respecting three distinct rules that should not be confused.

The 34 % cap on food deserves particular attention: it is assessed by value and combines the immediate advantage (the discount at the till) and the deferred advantage (loyalty points, vouchers). A "minus 30 % at the till plus 10 % on the loyalty card" offer therefore exceeds the cap, even if each component looks acceptable on its own.

Failing to build these rules into checkout pricing exposes the chain to a DGCCRF audit and an administrative fine. The risk is real: food retail is subject to regular sector investigations.

SRP+ is not absolute. Several situations fall outside the floor, but always on condition of being documented. It is the documentation, more than the principle, that matters in an audit.

• Clearance of products near their use-by date or end of life: once the critical date is reached, the chain may sell below SRP+ to clear stock rather than discard it.
• Promotions funded by an immediate supplier discount: if the supplier absorbs the price cut and formalises it, the effective purchase cost drops accordingly and the SRP+ floor is recalculated lower.
• Private labels: as the retailer is its own supplier, SRP+ does not apply in the same way. This is one of the strategic reasons behind the rise of private labels on the shelves.

Each operation must be supported by a written contract or agreement. This is exactly what the authorities check during their investigations: not the existence of a below-floor promotion, but the absence of a document justifying it.

Hayot Expertise tip. Build an exception file for each promotional operation that goes below SRP+: signed supplier agreement, end-of-life product attestation or internal private-label note. In an audit, the dated document prevails, not the section manager's verbal explanation.

This is the most important side effect for a manager. Because the front margin (the gap between purchase price and displayed sale price) is compressed by SRP+, chains shift toward back margins: year-end rebates, commercial cooperation, promotional contributions. Value is no longer earned on the shelf, it is negotiated off-invoice with the supplier.

This shift has a direct accounting consequence. These off-invoice advantages must be booked as a reduction of purchase cost (account 609), not as income. The classification error is not neutral:

1. booking a rebate as income artificially inflates turnover and distorts gross margin by department;
2. allocating it to a product in account 609 corrects the purchase cost and restores the true profitability of each family;
3. a wrong classification also creates a consistency gap with VAT, a point the authorities know how to spot.

Contractualisation of these advantages runs through the single written agreement of articles L441-3 and L441-4 of the Commercial Code, which sets the annual framework of the supplier relationship. We detail the technical treatment in our dedicated guide to back-margin and rebate accounting.

In our large-retail files, the most common error is not ignorance of SRP+: every manager knows it. It is the absence of an automatic control at the checkout. A promotional price falls below the floor with no alert, and the gap only surfaces afterwards, sometimes during the annual review.

One case recurs regularly. A neighbourhood chain we support had launched a back-to-school operation on branded products, combining a till discount and a loyalty bonus. Taken separately, the two discounts seemed reasonable. Combined, they placed several references both below SRP+ and beyond the 34 % cap. No one at the store had done the addition, because the checkout software did not do it either. The matter was corrected before any audit, but it illustrates the real risk: not bad faith, but the lack of a technical safeguard.

Our recommendation has two parts. First, a checkout configuration that blocks or flags any sale below SRP+ and any promotion stacking beyond the caps. Second, a systematic archive of supplier agreements justifying the exceptions, linked to shrinkage and margin management in large retail. A chartered accountant specialised in large retail secures both regulatory compliance and the back-margin accounting that follows. For groups with several outlets, the topic connects to multi-store holding structuring, where pricing and re-invoicing consistency becomes central.

• SRP+ is calculated on the effective purchase price, net of all immediately deductible discounts, not on the gross catalogue tariff. A wrong starting point distorts the whole floor.
• The 34 % cap combines immediate and deferred advantages: watch operations that stack till discounts and loyalty points.
• Exceptions are not presumed: without a dated written document, a sale below SRP+ remains irregular.
• The shift to back margins must be traced in account 609, or gross margin is distorted and a VAT gap appears.
• The 2028 horizon is not a programmed end: the scheme has already been renewed several times and may be again.