Submission: ComCom on Supermarkets

Read our submission that was presented orally to the Commerce Commission on 27 September 2021 at Submission on the Commerce Commission Draft Report on Competition in the Retail Grocery Sector.

We advocated for how 4,000 plus dairies, convenience stores and service stations could play in offering consumers cheaper groceries as our sector has 17.34% market share (worth $3.4bn)

We opposed ‘facilitation’ for what would be a foreign supermarket entrant, or worse, a state-owned one, with financial and/or market privilege not available to existing taxpayer retailers

We explained that planning privilege for supermarkets runs counter to the Zero Carbon Act, with central cities being denied cars but car intensive supermarkets are promoted. We estimate over half a billion kilometres of supermarket car journies take place each year

We asked the Commission to examine how vertical and horizontal integration has given the supermarket duopoly genuine market dominance across non-grocery markets

We recommended that the Commission should structurally separate wholesaling/distribution centre operations away from market-dominating retailers to create a truly competitive retail environment where wholesale/distribution centres compete for suppliers and retail shelf space

We recommended tobacco products are removed from the analysis, as they are a highly regulated outlier that would have skewed its analysis of alcohol. Asked for reform of the 2012/2013 sale of liquor act and regulations that slashed regulated outlets only to worsen alcohol harms.