Loyalty Pricing in Health and Beauty

Summary

• Boots and Superdrug both run extensive member pricing offers across thousands of products and large proportions of customers belong to their loyalty schemes. According to our survey 58% of Boots customers and 35% of Superdrug customers are members of their respective membership schemes.
• We found hundreds of promotions at Boots and Superdrug that might be considered problematic according to the Competition and Markets Authority’s (CMA) guidance for loyalty promotions in the groceries sector, which we expect to be relevant to retailers in other sectors. Promotions are most likely to be problematic when the non-member price is higher during a loyalty promotion than the price for all customers before and after.
• Potentially problematic patterns occurred where a product cycled through loyalty price promotions and ‘was/now’ price promotions for all customers.
• We also identified potentially misleading reference prices for own label products at Boots, where loyalty and all customer price promotions were layered on top of each other.

Introduction

Retailers have run loyalty schemes for many years, offering things like points-based rewards and personalised discount vouchers. A more recent practice is the use of member-only prices: where a separate, preferential price is listed for all members of a scheme. Tesco introduced its Clubcard prices in 2019, and other major supermarkets like Sainsbury's have followed suit. This trend has since expanded beyond the groceries sector, with other retailers now operating similar two-tier pricing schemes based on loyalty membership. In health and beauty, the major retailers Boots and Superdrug both use member-only pricing promotions. 

On the surface, this is a benefit for loyal customers (members) who have access to better prices. However, there are potential issues that can arise from membership pricing. Past Which? research has looked at who might be excluded from loyalty schemes, and therefore miss out on lower prices. It can also have implications for members themselves, if loyalty promotions are used and presented in such a way that misleads about how good a deal really is. 

Existing regulations are in place to protect consumers from misleading promotions, an example of which is the misuse of reference prices. Reference pricing refers to a price promotion where the current selling price of a product is compared favourably with a different, higher price, like a Recommended Retail Price (RRP) or a ‘was’ price. 

Loyalty prices introduce a new form of reference pricing: where the reference price is the non-member price. If non-member prices (the reference price in this scenario) are not usual selling prices then this may mislead members as to how good the saving really is. There is also a risk that non-members have to pay a higher price that has been inflated just to make the loyalty price more attractive. 

Our 2024 research on member pricing looked at these practices among a number of major retailers in the groceries and health and beauty sectors. We found that some products had a higher non-member price during a loyalty promotion period than before, and that this was particularly prevalent at Boots. Shortly afterwards, in its paper on loyalty pricing in the groceries sector, the CMA set out guidance on when loyalty promotions could mislead customers. The guidance states that loyalty promotions are most likely to be problematic when the non-member price is higher during the loyalty promotion than it is before and after.

This briefing follows on from our 2024 research but focuses on member pricing in two of the UK’s major health and beauty retailers: Boots and Superdrug. It explores the patterns of loyalty promotions alongside other promotions in more depth, highlighting where there are possibilities that customers could be misled. We use the CMA’s guidance as a basis for when promotions may be considered problematic, noting that while the guidance was explicitly for the groceries sector we expect it to be relevant to retailers in other sectors.

Section 1: Circumstances when a loyalty promotion could mislead shoppers

In its guidance on loyalty promotions in the groceries sector, the CMA set out when such promotions might mislead consumers. They identified that promotions are more likely to be problematic when the non-member price is higher than the all customer price for the product before the loyalty promotion. In other words, if the non-member price is increased at the start of the loyalty promotion it could mislead customers as to the magnitude of the savings. Promotions are most likely to be problematic when the non-member price is higher than the all customer price both before and after the promotion (see scenario 1 below). However, it may also be problematic if the non-member price is higher than the all customer price before the promotion but the same or lower than the all customer price after the promotion (scenarios 2 and 3 below).

Figure 1: loyalty pricing patterns identified as most likely to be problematic by the CMA

Such pricing patterns seem most likely to occur when products cycle through different types of promotions: for example, a product might be on a price discount available to all customers for a period of time, and then move onto a member-only price promotion immediately afterwards, and vice-versa. 

Where this occurs, both the loyalty promotion and the regular price discounts before and/or after it have the potential to mislead customers: 

1. During a loyalty promotion, the non-member price could represent a misleading reference price for members if it is not a realistic usual selling price for the item.
2. During an all customer price discount, the ‘was’ price could represent a misleading reference price for loyalty customers. Advice from the Competition and Markets Authority (CMA), in the context of mattress sales, states that a product should have been available at the ‘was’ reference price for a sufficient period of time immediately before the promotions, and a sufficient number of sales should have been made at that reference price.

 The CMA advises that the best way for retailers using loyalty promotions to stay on the right side of the law is to avoid running consecutive price promotions and instead find alternative ways to lower prices [1]. 

However, the CMA notes that the proportion of shoppers belonging to the loyalty scheme will affect the likelihood of the average consumer being misled. If a retailer has a large proportion of customers using a loyalty card, so that members make up a majority of sales and rarely or never pay the higher price, the higher price is less likely to represent a genuine ‘usual’ selling price for the item. The CMA guidance highlights there is especially cause for concern where the proportion of scheme members is more than 50% of shoppers.

There is no single, recent and comparable publicly available figure of how many Boots and Superdrug shoppers are part of their loyalty schemes. They are both large schemes, with Boots itself claiming more than 17 million members and Superdrug nearly 16 million.  Further, Superdrug reported around 60% of its sales were through loyalty cards in 2023.

To get an up-to-date estimate comparable across the two retailers, we ran a short online poll with a nationally representative sample of consumers asking whether they typically use a loyalty card when shopping at these retailers [2]. We found that 58% of consumers who ever shop at Boots use an ‘Advantage Card’, rising to 70% among more regular shoppers (once a month or more). Membership was less common at Superdrug, with 35% of people who ever shop there saying they use a loyalty card. However, this did rise to 50% among those who shop there once a month or more. As well as shopping more frequently, we might also expect that loyalty scheme members would buy more than non-members and thus represent a larger proportion of retail sales. 

Section 2: Methodology

The data for this analysis comes from an independent price comparison company, which collects daily price and promotional data from major UK retailers including Boots and Superdrug. The pricing data gives us daily prices for products listed on the Boots and Superdrug websites, as well as the loyalty prices for the same products when applicable. It also provides data on the different promotions applying to products over a given time period. This allows us to identify loyalty promotional periods, and examine the prices available to all customers that are listed during, before and after loyalty promotions.  

We analysed pricing and promotional data for the 6-month period from March-August 2025, including in our sample all products that had been on loyalty promotion at any point over that 6 month period.

In this report we will refer to three types of pricing:

• The loyalty price - the price available to those with access to a loyalty membership during a loyalty price promotion.
• The non-member price - the price available to those who do not have access to a loyalty membership during a loyalty price promotion.
• The all customer price - the price available to all customers outside a loyalty promotion, since this will be the same for members and non-members. The all customer price might also be a price promotion, but one that is available to all customers.

Prices on days when products were out of stock have been excluded, since we only wanted to assess prices and promotions that were actually available for customers on a given day. However, we conducted a sensitivity analysis keeping the out of stock prices in the sample and found that it made very little difference to the proportion categorised as potentially problematic. 

Section 3: Use of loyalty promotions by Boots and Superdrug

Both Boots and Superdrug now operate extensive loyalty pricing promotions. As shown in Table 1, there were thousands of items on loyalty promotion at each of Boots and Superdrug between March to August 2025, and some of these items had multiple promotional periods during this time. In total, we observed more than 13,000 different loyalty promotions across both retailers.

A key difference in how these two retailers use loyalty promotions is that the majority (64%) of products that have been on loyalty promotion at Boots are own label products, whereas the majority at Superdrug are branded products (88%). 

Figure 2: The proportion of loyalty promoted products that are own label versus branded

Boots has a major promotional campaign that gives loyalty customers 10% off Boots own brand products, which is where many of these own brand loyalty promotions come from. This 10% promotion appears to be available on an ongoing basis. Therefore, although Boots had slightly more individual products on loyalty promotion (3,441) compared to Superdrug (3,154) over the six months, Superdrug had many more distinct loyalty promotional periods, because products were more likely to cycle on and off loyalty promotion and thus have more than one loyalty promotional period each. Boots on the other hand had fewer distinct loyalty periods since many own label products were on a single loyalty promotion during the whole six month period. We identified 9,409 loyalty periods at Superdrug over the 6-month period, compared to 4,068 at Boots. Among the Boots promotions, there were 1,862 temporary loyalty promotions on branded products and 2,206 long term own label promotions. 

We know from our previous research that Superdrug’s use of loyalty promotions is broadly in line with the supermarkets in terms of their own label versus branded product split, and duration of the promotions, whereas Boots’ approach is atypical.

Section 4: Potentially problematic promotional patterns on loyalty products

We applied principles from the CMA guidance on supermarkets’ pricing practices to these Boots and Superdrug loyalty promotions, identifying where loyalty promotions might lead to customers being misled. Since Boots runs a large number of very long or permanent loyalty promotions on their own label products these do not move on and off loyalty promotion and need to be analysed differently to temporary deals. We therefore address temporary loyalty deals at Boots and Superdrug and permanent loyalty deals at Boots separately in this section, identifying where pricing patterns might be problematic for each.

Temporary loyalty deals

As already stated, we identified 1,862 temporary loyalty promotions in the Boots data and 9,409 temporary loyalty periods in the Superdrug data. However, many of these will have already been on loyalty promotion at the start of the 6-month period in March, and many others will have still been on loyalty promotion when the 6-month period ended in August, meaning we do not have before and after prices to assess for all promotional periods. For Boots 690 of the temporary deals had pricing data before and after the promotion. For Superdrug, 6,860 deals had pricing data before and after the loyalty promotion period [4].

The CMA looked at price changes at any point up to 35 days before and after the loyalty promotion. We applied the less stringent test of whether this happened just the day before and day after the promotion. We found 119 temporary loyalty deals at Boots and 257 at Superdrug that followed the pattern of having a lower all customer price immediately before and after a loyalty promotion, the pattern identified by the CMA as most likely to be problematic (scenario 1 in Figure 2). Although the absolute number of deals falling into this 'most likely to be problematic' category is larger at Superdrug, it is a smaller proportion of the total number of deals that could be analysed this way, at 4% compared to 17% for Boots. 

A further 479 deals at Superdrug and 54 at Boots had a lower all customer price before the promotion but the same or a higher price after, which the CMA also highlighted as potentially problematic (scenarios 2 and 3 in Figure 1).

Cases that fall into the potentially problematic patterns set out by figure 1 almost always occur because products cycle between price promotions for all customers and loyalty promotions. Whether these promotions do in fact mislead customers will depend on the facts of individual cases and it is impossible for us to determine whether or not any offers are actually misleading. For example, the volume of sales at each price point is one crucial factor and we have no data on this. Nevertheless, we have picked out some individual products that represent some of the ways that these potentially problematic promotions typically work. 

For example, an Avène moisturiser sold by Boots cycled through loyalty and all customer price promotions over the six-month period and was almost always on either a loyalty discount or an all customer price discount. A promotion like this has potential to mislead customers in two ways, which are illustrated by Figures 3 and 4 below. 

First, the reference price (i.e. the non-member price) for loyalty customers during a loyalty promotion may not be genuine. During the loyalty promotion period from 8th May - 2nd July, members were offered a 25% discount from the listed reference price of £22, see Figure 3. However, there was a price discount available to all customers immediately before and after the loyalty promotion. The evidence set out in section 1 suggests that most sales at Boots are likely made using an ‘Advantage Card’ (loyalty) card. So it is likely only a minority of sales were made at £22, particularly for loyalty customers who would have paid a maximum of £17.60 over the course of these three promotions. This means that £22 may not be a genuine reference price for Boots members, but as noted above, a number of factors can be relevant to this determination.

Figure 3: This Avène moisturiser is an example of where loyalty customers could be misled by the reference price used for a loyalty promotion

Second, the reference price (i.e. the ‘was’ price) for loyalty customers during an all customer price promotion may not be a realistic usual selling price. As shown in Figure 4, the Avène moisturiser is £16.50 on an all customer price discount from 3rd July - 27th August. The reference price given during the all customer price promotion is “was £22”. Non-members would indeed have paid £22 before the discount, but it may be a misleading reference price for members because the item was available to them for £16.50 on loyalty discount immediately before the all customer price discount.

Figure 4: This Avène moisturiser is an example of where loyalty customers could be misled by the reference price used during an all customer price promotion

Although we only show two promotional periods in Figure 4, there was another all customer price discount before the loyalty discount, and another loyalty discount prior to that all customer price discount. Specifically, during our six month period of analysis the product was sold as follows [5]:

1. 1st March - 12th March: “£22 - Save 20% with your Advantage Card” 
2. 13th March - 7th May: “Was £22.00 Now £17.60 Save £4.40”
3. 8th May - 2nd July: “£22 - Save 25% with your Advantage Card” 
4. 3rd July - 27th August: “Was £22.00 Now £16.50 Save £5.50” 
5. 28th August - 30th August: £22, but with a multibuy offer

This means that a loyalty scheme member would have almost never paid the full £22 in this six-month period.

We observed similar patterns for products at Superdrug. The Oral-B Pro 1 Pink Electric Toothbrush with travel case cycled between all customer and member only price discounts during the six-months. There were three loyalty discounts where the non-member price was £69.99. Between these, the toothbrush was always on an all customer price discount at £34.99 or £31.50 with a £69.99 ‘was’ price. However, members would have never needed to pay more than £34.99 over the entire six month period, meaning that £69.99 could be a misleading reference price for loyalty customers [6]. 

The promotional text presented to customers for this product were as follows:

• During the three loyalty promotional periods the product is listed at £69.99 with a “Member Price £34.99” loyalty price advertised.
• During the all customer price discounts, a strikethrough ‘was’ price is listed as £69.99 with a discounted price of either £31.50 or £34.99.

Permanent own label promotions at Boots

As already outlined, Boots own label loyalty promotions work fundamentally differently to branded ones. Boots runs an ongoing 10% off Boots own label products for Advantage Card holders [7]. This means that we cannot assess Boots own label products in the same way (identifying all customer prices before and after loyalty promotion) since they do not come off loyalty promotion. 

These products are often placed on additional all customer price promotions though, and we are concerned that these also risk misleading loyalty customers [8]. Taking the Boots Antiseptic Cream as an example (see Figure 4), an ongoing 10% discount is available to Advantage Card holders across the six months, giving them access to a price of £2.12:

“Save 10 percent on selected Boots Brand with your Advantage Card”

At various intervals, an all customer price discount is also available, which for loyalty customers can be applied in combination with the 10% loyalty discount.

Figure 5: Boots own label products like this antiseptic cream risk misleading customers by using the non-member price as a reference price

The most a loyalty scheme member would have paid over the six-month period was £2.12, and only non-members would have paid the maximum price of £2.35. But when the antiseptic is on an all customer price discount (which for loyalty customers can be applied in combination with the 10% loyalty discount), it uses the non-member price as a reference price (“Was £2.35 Now £1.88 Save £0.47”). 

This is a complex example since the permanent loyalty discounts mean that there are multiple promotions, which are sometimes concurrent. The CMA guidance contains separate examples of both concurrent and consecutive promotions, but not combined as in this example. However, the guidance is clear that the reference price needs to be the genuine ‘usual’ price for the product [9]. Factors relevant to determining this include the volume of sales made by those with and without an Advantage card, and whether it is clear that members get a permanent 10% discount on this product as this will affect whether they consider the ‘was’ price to be a reference price.

We are concerned that in this case the ‘was’ price could be a misleading reference price because our survey indicates that most customers are members of the loyalty scheme and would never have had to pay the £2.35 over these six months, meaning it may not represent a ‘usual’ selling price for the average consumer. Further, while we have no empirical evidence on the knowledge of members about the duration of offers, we are concerned that the presentation of the offer, see Annex A item 5, could do more to make it clear that the member discount is permanent. For example, no ‘was’ price for members is presented and there is no clear indication that the 10 per cent discount is permanent.  

This issue could apply to a large number of was/now promotions as the vast majority (85%) of the 2,206 own-label Boots products on loyalty promotion in our data were also on a price discount at some point over the six months we analysed.

Conclusion

Member-only pricing is an established feature of the health and beauty sector, but our analysis shows that its use at Boots and Superdrug can create a risk of misleading consumers. 

Across both retailers we identified hundreds of cases where products cycled between loyalty promotions and regular price discounts available to all customers in ways that could obscure the true value of the saving, matching patterns highlighted as potentially problematic in the CMA’s guidance. In fact, we applied a less stringent test than the CMA by looking only immediately before and after the promotion, whereas the CMA looked at any price changes up to 35 days before and after the promotion. 

We further found that Boots’ use of long-running promotions on own label products may be problematic when all customer price discounts are layered on top of loyalty promotions. This is because non-member prices may act as ‘inflated’ reference prices for members. 

These issues matter because large proportions of shoppers at both retailers use loyalty cards, meaning many customers are unlikely ever to pay the higher non-member price used as the basis for savings claims. This raises questions about whether these reference prices genuinely reflect realistic ‘usual’ selling prices and whether consumers are receiving accurate information about the deals on offer.

It should be noted that the CMA guidance states that such pricing patterns may not mean consumers are misled in all instances, and examples must be considered individually on their own facts. However, the findings suggest that loyalty pricing in health and beauty warrants closer scrutiny and as member pricing becomes more widespread beyond groceries, it will become increasingly important for regulators and retailers to ensure promotional practices remain transparent, fair, and in line with consumer protection principles.

Annexes

Footnotes 

[1] CMA (2024) - Loyalty pricing in the groceries sector (Page 85), accessed at https://assets.publishing.service.gov.uk/media/6749f2a7ebabe47136b3a2c0/_____Findings_report___2.pdf  ↑

[2] Yonder, on behalf of Which?, ran this online poll with a nationally representative sample of 2,079 consumers on 10th-11th November 2025. ↑

[3] Note: products will very likely have been on multiple different promotions at different points in the six month period, hence there being far more promotional periods than products ↑

[4] Before and after prices for loyalty price may have been missing because the product was out of stock, or because the loyalty promotion started and continued into the six month period or went on after the six month period, and so we could not identify a before or after price in our dataset. ↑

[5] See Annex A, items 1 and 2 for images of how these discounts are presented ↑ 

[6] See Annex A, items 3 and 4 for images of how these discounts are presented ↑

[7] Note: this applies to products branded as Boots own label. There are some Boots manufactured products that are not branded as Boots, for example ‘Soap & Glory’. These products are not subject to the ongoing 10% loyalty discount. ↑

[8] See Annex A, item 5 for an example of a Boots own brand product with loyalty and price discount promotions running simultaneously. ↑

[9] Paragraphs 6.47-6.54 and CMA (2024) - Loyalty pricing in the groceries sector, accessed at https://assets.publishing.service.gov.uk/media/6749f2a7ebabe47136b3a2c0/_____Findings_report___2.pdf ↑