Chapter 3The impact of supermarket prices on consumers
3.1Cost of living pressures have been a focus of current public discussion. Thesepressures include increasing housing, energy and transport costs in the face of slow personal income rises, meaning people are unable to meet those increasing costs. Another key issue of concern for cost of living pressures has been increasing grocery prices.
3.2The community groups and individuals who provided evidence to the committee expressed their deep concerns and frustrations about the current high prices they must pay for food and groceries, and outlined how this impacts everyone's lives, and in particular those who are the most vulnerable, disadvantaged, or marginalised.
3.3The committee heard many accounts of how people struggle to afford healthy, nutritious, and culturally appropriate food, and how they are forced to resort to food relief services, 'dumpster‑diving', or shoplifting to meet their basic needs.
3.4People also explained to the committee how food insecurity affects their health, dignity and social cohesion, and how they feel powerless and voiceless in the face of the supermarket duopoly:
Australians rely heavily on supermarkets to supply them with food, groceries and essential items, making consumers vulnerable to their conduct. The current cost of living crisis has further highlighted this dependency and reignited concern about supermarket pricing.
3.5This chapter outlines the evidence received by the committee about how high supermarket pricing impacts Australians in their daily lives.
3.6The chapter further presents the evidence around opportunistic pricing and misleading price displays. It concludes with a discussion on the important role of unit pricing, and the Unit Pricing Code.
The increasing cost of living
3.7Evidence to the committee was clear about cost of living increases having a direct and detrimental effect on people's access to food, and their health and wellbeing in general.
3.8Dr Christina Zorbas of the Global Centre for Preventive Health and Nutrition at Deakin University (GLOBE) advised that 'food prices steadily rose after 2020, with increases between 2021 and 2023 being the greatest they've been in the last two decades' and that despite some known cost pressures from the Ukraine war, wheat prices and climate change, 'there's very little transparency in how this has affected supermarkets and how supermarkets set their prices across the board'.
3.9COTA Australia noted that even though inflation is now trending in the right direction, food and grocery prices remain high, with 3.7 million Australian households reportedly experiencing food insecurity in the last 12 months, many of those for the first time. COTA Australia further submitted that these people:
… identified food and grocery prices (followed by energy and housing) as the key reason why food insecure households struggled to afford food amongst other living expenses in the last 12 months.
3.10Fair Food WA, and WA Council of Social Service (WACOSS) pointed to a wide variety of available data showing the increasing effects of cost of living rises on Australians, with a focus on the lived experiences of people in WA:
The WACOSS Cost of Living Report (2023) found that many people, particularly those on minimum wage or government supports, are struggling to cover the increasing cost of essentials;
Australian Bureau of Statistics' 2023 June Quarter data revealed that food prices have risen 7.5 per cent on the previous year;
Foodbank Australia reported that in the past year, 3.7 million Australian households (36 per cent) experienced moderate to severe food insecurity, and the majority reported that cost of living expenses was the primary reason for food insecurity; and
WA's Financial Wellbeing Collective's Emergency Relief and Food Access Service received 3165 calls for assistance in October 2023, compared to 2275calls in the same month the previous year.
3.11WACOSS also stressed the increasing levels of 'working poor' who are turning to food relief organisations because, despite being employed, they are unable to keep up with rising costs of living.
3.12Ms Tania Hunt, Chief Executive Officer of the Youth Network of Tasmania, told the committee that organisation regularly hears from youth that they are not able to access nutritious fresh foods, with young people:
… forgoing supermarket groceries altogether because they're just too expensive, and they're relying on community sector organisations such as the Link Youth Health Service, their food pantry, headspace Hobart to access free food, and emergency food relief at places like Hobart City Mission.
3.13Ms Hunt went on to report that many young people are taking actions such as eating two-minute noodles, rationing food to pay for 'cost-of-living expenses such as rent, electricity and heating', eating only one meal per day and learning to cope with being hungry. Ms Hunt further reported that these issues are exacerbated for young people in rural and remote communities, where the price of supermarket groceries could be up to 50 per cent more expensive than in city stores.
3.14The Combined Pensioners and Superannuants Association of NSW (CPSA) noted that price increases had not just economic impacts, but also psychological impacts. The CPSA noted that 87 per cent of respondents to its survey on cost of living said they had experienced financial distress in the past six months.
3.15Ms Gaye Matthews encapsulated the frustrations expressed by many people:
I, and many other Aussies, are just outraged at the obvious price gouging going on by the big companies. Companies that claim they need to implement the prices increases to stay inline with inflation, yet are all posting billion dollar profits. Billion dollar profits for them while the ordinary, everyday Aussie has to decide between medicine and food, rent and power bill. Assistance being sought at charities is at an all time high, people that have jobs and never needed assistance, are now joining the queue just so they can make ends meet.
3.16Ms Louise Adams, appearing as a private individual, spoke about the new working poor who are 'struggling make ends meet', with this impacting mental health, social connections and a person's ability to engage in education and employment. Ms Adams told the committee:
It means that people are literally going without. I see it all the time at work through child safety. We've got parents who simply can't afford to provide for their children, and they're being seen as not meeting their responsibilities. This is not an individual problem; this is a social problem.
3.17Mr Danny Carney of Grassroots Action Network Tasmania (GRANT) spoke about how the issue is critical to so many people:
This is about whether people eat food. This is about whether kids eat good food that helps them grow so their brains develop and they can do well at school. It's really serious stuff. It is getting much worse. I think we all know that. I think the really damning thing that makes us all really angry is that the supermarkets are making more and more money as it gets harder and harder for the rest of us.
Lack of choice
3.18The inquiry heard that the market concentration of the two supermarket giants meant that people were unable to exercise choice or seek other options to address the increasing costs of groceries. Mr Geordan Nicholson noted that due to the market concentration of Coles and Woolworths:
… the regular argument of "vote with your money" or "go shop elsewhere" cannot work, as many items are only stocked by these two companies, and these companies have overrun small, local grocers, meaning that many places have no access to any other store.[11]
3.19Similarly, the CPSA noted that the supermarket sector is too concentrated to 'provide any downward pressure on prices, especially in rural and regional areas where a single supermarket may have an effective monopoly on the sale of food and groceries in that community'. It went on to state that this means customers are forced to accept prices rises, without the freedom to choose different products or '"vote with their dollar" if they feel that prices are unreasonable'.
3.20GetUp submitted the results of a survey they conducted regarding supermarkets, where members 'spoke about the need for more competition in the grocery sector and a crackdown on price gouging'. One person noted:
Whenever I go to the supermarket I take a list. I notice that most people now shop this way looking at their phones then up at the shelves. Even though the items I buy at one of the supermarkets aren't luxuries, my grocery bill has almost doubled. Please restore an equitable balance in our supermarkets where price gouging isn't the norm.
3.21Mr Carney of GRANT noted that grocery costs are far higher in regional communities. Speaking to the situation in Tasmania, Mr Carney observed that:
… the thing that makes it particularly expensive here is that we simply have no choice of where to shop. It's the two big supermarkets or nothing, basically. Unless we bust up the power that they have and bring in more competition, we're stuck paying what they offer.
3.22Mr Carney spoke about how the issue of the supermarkets' duopoly and lack of choice was now entering the broader public discussion and suggested that:
… part of that is from the solidarity that's being built across classes and across demographics; everyone is realising that we're in this situation where most of us can only get food from two supermarkets, and we're completely powerless about what we can do about it.
3.23Fair Food WA and WACOSS highlighted 'the precarity of our food system for people living in regional and remote areas' and noted that people living in remote communities experienced far higher food prices across the country, where 'residents of remote communities pay, on average, 39 per cent more for supermarket supplies than those in capital cities'. It further submitted that:
Living in rural area the price of food items has skyrocketed, prices go up daily. We can't often afford the basics. Every fortnight there are major trade‑offs. Even if we need both we must decide, is it eggs or cheese? Nextdecision, the quantity? No kidding it's now serious family business.
Unaffordable necessities
3.24The committee heard from diverse witnesses and submitters that many people can no longer afford to buy basic food and grocery staples, including toilet paper, underwear and back-to-school items.
3.25The Consumer Action Law Centre advised the inquiry that 'it is increasingly common to hear from single parents who state they aren't eating themselves, tomake sure their kids are'.
3.26GRANT told the committee:
Members of our community who were nurses have reached out to us and said they're studying full time, they're working as nurses, and they're also having to go to the bins to get food, because that is just the most economically and environmentally friendly way they're able to source these essential items.
3.27COTA Australia advised that in their January 2024 survey, '90% of respondents indicated food and grocery price increases were affecting their fortnightly shop and financial planning with 66% saying this was impacting adversely on their psychological and emotional health'. Further, '80% of respondents said they have had to make major lifestyle changes to better manage the increased cost of food and groceries. For some respondents this has been an unwelcomed new experience'.
3.28COTA Australia concluded that:
Weekly 'Specials' need to be aimed at food, hygiene products and baby care not seventeen different brands of vitamin supplements as Woolworths has recently done. Feeding a family with nourishing affordable food is an absolute priority.
Aging Australians
3.29National Seniors Australia submitted that for older people, groceries were the second most important cost of living concern behind insurance. But for older people whose income was the Age Pension only, groceries were the highest cost of living concern.
3.30Respondents to a cost of living survey noted that older people were unable to take similar actions to those of younger people to save on grocery items, saying:
Some of us don't have the privilege of chasing bargains! We go to the nearest supermarket and pay whatever the cost is because we are physically weaker, and the number of visits has reduced to once a fortnight or monthly. We are not going back to pick up a bargain. This is what is happening in our lives.
…
Most older Australians believe supermarkets – including Coles and Woolworths – are entitled to make a profit as are their shareholders. However, they are equally clear that profit should not be achieved at the expense of primary producers, consumers and/or the natural environment.
3.31COTA Australia noted that for all income brackets 'the proportion which is needed to finance the regular supermarket shop is growing exponentially' and this means that for 'increasing numbers of older people, the ongoing rise in prices means a constant re-evaluation of the household shopping budget to determine what is affordable and, what (although needed) could be considered as discretionary purchases'.
3.32CPSA noted that many older Australians are:
… cutting out meat, cheese and in some cases, fruits and vegetables from their diets, or skipping meals altogether in order to keep prices down. One respondent told us: "I rarely buy meat and if I buy vegetables I get frozen", while another respondent said that "I have had to live on just the basics cutting out fruits, vegetables and meat". This appeared to be a common occurrence among our respondents. Another stated that: "We have had to reduce our fortnightly spend and concentrate on specials that are mainly junk food. Our diet has changed in keeping with what we can afford. We now have one or two meals per day instead of three. We cannot afford to buy red meat."
Food insecurity
3.33Many individuals and organisations pointed to the increasing levels of food insecurity for individuals. The issue of food insecurity at the national or regional level, caused by reduced levels of farming and production is discussed further in Chapter Four.
3.34GLOBE pointed to the increased burden of food insecurity felt by Aboriginal and Torres Strait Islander peoples, telling the committee that 'depending on location, 22 to 32 per cent of our communities experience some form of food insecurity' but for Aboriginal and Torres Strait Islander people this could be 'as high as 59.6 per cent'.
3.35Dieticians Australia advised that food insecurity 'rarely happens in isolation but rather in co-occurrence with economic, health and housing insecurity and other hardships'. It further noted that food insecurity was 'associated with all forms of malnutrition including overweight/obesity, and chronic diseases such as type2 diabetes, heart disease and mental illness' and more broadly, it can impact on 'quality of life, social and emotional well-being, and productivity'.
3.36Fair Food WA and WACOSS noted that 11 different government departments contribute to national food policy, each one focused on different aspects of the food system. Its submission pointed to the success of the Supermarket taskforce established during the COVID-19 pandemic, which 'demonstrated the value of a collaborative approach to issues impacting the food system' and became a:
… mechanism for supporting industry cooperation with the aims of stabilising consumer confidence, maintaining equitable access to food, and minimising the negative impacts of the pandemic on the supermarket industry and consumers.
3.37Fair Food WA and WACOSS recommended 'the establishment of a single agency to coordinate food system policy in Australia' which:
… would be responsible for overseeing the integration of a national food system framework that achieves positive outcomes for producers, suppliers, retailers and consumers and can explore issues such as supermarket pricing within the context of the National food system.
Supermarket pricing and access to healthy food
3.38The committee heard from individuals and organisations that with increasing grocery prices, many people were now unable to afford healthy foods, leading to negative health outcomes. As Healthy Food Systems Australia noted:
Healthy food and good nutrition are major determinants of health. The right to adequate food is a basic human right. Price, affordability, availability and accessibility of healthy, nutritious food is fundamental to food security.
3.39Ms Aimen Jafri, Chair of the Multicultural Council of Tasmania, informed the committee that one in four families struggle to afford food, which impacts their food security. Families then eat cheaper junk food, impacting their health and causing financial stress.
3.40Ms Jafri continued that multicultural, international students were struggling to manage, especially those without full-time jobs, and finding it challenging to 'bring food to the table'. Ms Jafri also noted there was a lack of access to culturally-appropriate food, saying:
… there is a big issue that we have to go to these supermarkets, spend hundreds of dollars there to get regular food, and then we have to go to these specialised cultural markets to get our other food. It just adds to the cost.
3.41The Public Health Association of Australia spoke plainly about the effects of supermarket duopolies on prices, and the flow-on effects of this on public health:
Vulnerable Australians are already at an increased risk of adverse health outcomes; when supermarkets raise food prices, they contribute to the widening of existing health disparities, both directly (by influencing what and how much people buy and consume) and indirectly (by reducing the available budget for other living costs).
3.42The Public Health Association of Australia cited research from the Institute for Health Transformation, Deakin University, which showed the impact of 'specials' pricing on food choices by consumers. The research found that:
… in the two major Australian supermarkets, unhealthy foods are discounted twice as often and with a larger discount compared to healthier foods and beverages, and that sugary drinks make up approximately two thirds of all price-promoted beverages in any given week. As many Australian make shopping decisions based on items on that are on special, this increases the amount of food and drink items that are higher in sugar being purchased than would otherwise occur.
3.43Dieticians Australia likewise pointed to the research indicating that 'unhealthy foods and beverages are discounted more often than healthier alternatives, with larger discounts', influencing consumers' choices on dietary intake.
3.44The Food for Health Alliance similarly advised that supermarket pricing influences the foods that people buy and therefore impacts diets and health and wellbeing. The alliance argued that supermarkets often use price promotions and marketing to encourage consumers to purchase unhealthy food and drinks, which will 'have a significant impact on population diets and health over the long-term'. The alliance pointed to the National Obesity Strategy which recommends 'the restriction of temporary price reductions and promotions as an example action to reduce exposure to unhealthy food marketing'.
Food wastage
3.45The evidence is clear that many people can no longer afford to buy basic food and grocery staples. Despite this, when the demand does not meet the supply, it is well known that supermarkets throw out large volumes of food and grocery items.
3.46GRANT noted that it sometimes found items in the bins that supermarkets had thrown out that were not even close to the used-by date, and that these items had not been diverted to the local food charities the supermarkets had a relationship with.
3.47GRANT observed Tasmanian supermarkets discarding large amounts of perfectly good food into the rubbish, leading Ms Amelia Cromb to suggest that either food donation programs were failing in a large way, or supermarkets were choosing to not put the required resources into maintaining those donation programs. MsCromb went on to state 'I think with the profit they've made over the past year they have the human and financial resources to put into blowing up and expanding their efforts on that food relief front, but they're not for whatever reason'.
3.48Ms Amy Booth concurred, observing that food donation programs were about corporate responsibility, and supermarkets were not making an effort to donate useable items to charity or find other ways of passing on items they wish to discard.
3.49GRANT noted that if supermarkets were in a position to put so many items into the bin, it lends support to the argument that their business models are very profit-driven.
3.50Ms Irene Di Lauro submitted that there is 'hypocrisy' in the current food and grocery system, where it 'creates so much waste and has contributed to creating a charitable sector that begs for that food to be given to people who cannot afford it at the current inaccessible rate'.
3.51GRANT representatives noted that other nations have regulations for supermarkets food wastage and noted 'it would be amazing to see things like that implemented here'. It further recommended greater transparency on the statistics of what supermarkets discard:
We don't know the statistics. I'm sure they have stats on tonnage that's going through their waste, but we don't know exactly how much in every store is being thrown out. They probably have donation statistics. I think if people found out exactly how much by tonnage or whatnot was actually going in the bin and seeing those items, then there would be a lot more transparency. That data is really important, because that's something we can't get. We just have firsthand experience multiple times a week of seeing what we see.
3.52Coles discussed this wastage, advising that 'with things that you would find in a bin, it's not always completely obvious as to why it was put there' and further advised 'we would just caution anyone not to eat food out of a Coles bin, because there's probably a good reason why it's there'.
3.53Both Coles and Woolworths pointed to their food donation programs as a means to address food waste while providing groceries to vulnerable Australians. For example, Coles submitted that it had:
… supplied the equivalent of 40.1 million meals of unsold, edible food to food rescue organisations such as SecondBite and Foodbank who support well over a thousand charities throughout local communities to feed individuals and families suffering food insecurity.
3.54Coles further addressed the issue, stating some food could not be donated, due to expiry or damage:
If the product is still edible and within its use-by date, we will donate it, for example, to one of our charity partners, SecondBite or Foodbank. If, for example, the use-by date has expired or the product is damaged—for example, it might be cheese that has been left on a shelf outside of the refrigerator, so it hasn't been kept at the required temperature—we would then put it into an organic waste bin, and it would then be offered, for example, to farmers. Anything that we can do to minimise waste and further support our charity partners, such as SecondBite and Foodbank, we would be pleased to do.
National Food Waste Strategy
3.55The National Food Waste Strategywas finalised in November2017. It notes that food waster costs the Australian economy around $20 billion per year and has a goal to halve food waste by 2030.
3.56Waste in Australia includes:
Up to 25 per cent of all vegetables produced don't leave the farm—31percent of carrots don't leave the farm, equating to a cost of $60million.
The total cost of agricultural food losses to farmers is $2.84 billion.
2.2 million tonnes of food is wasted from the commercial and industrial sectors, resulting in significant waste disposal charges and lost product costs to business.
3.57The strategy notes a number of areas where avoidable food waste occurs and could be reduced, including in areas relevant to this inquiry:
Primary production: a fall in market prices making it unprofitable to harvest, inability to meet contracted produce specifications, such as quality or size.
Processing and manufacturing: excessive trimming of vegetables for processed foods, changes in production due to consumer demand.
Retail: poor stock management, including over-ordering, produce no longer meets quality standards, last minute order changes that can leave suppliers with excess product, limited access to facilities to recycle or repurpose food waste.
Opportunistic pricing
3.58It was put to the committee that the market concentration of supermarkets could result in companies using their power to engage in opportunistic pricing, resulting in consumers paying unnecessarily higher prices. The committee was provided with extensive examples of such opportunistic pricing, some of which are detailed below.
3.59The CPSA noted its concerns with the two major supermarket chains and suggested they had used the 'twin spectres of inflation and rising supply chain costs as opportunities for profiteering'. The CPSA continued:
Put simply, we argue that Coles and Woolworths have become drivers of inflation, increasing their profits during a time of hardship for most Australians. This has left their customers, especially vulnerable people, far worse off.
3.60The CPSA pointed to a recent study showing that 'firms with market power are likely to raise prices if they believe their competitors will do the same'—referred to as 'seller's inflation'. The CPSA further cited The Australian Institute which found:
… historically high profits have accounted for a disproportionate share of the initial rise of economy-wide prices in Australia (and many other countries) since the pandemic. This confirms that Australian corporations had power to drive up their prices much more than their costs – and this, by definition, constitutes inflation.
3.61Mr Luke Curran submitted to the committee about the supermarkets' practice of consumer price index (CPI) grocery price updates, suggesting that Coles was updating its prices in line with any recent CPI increases:
This is Coles' practice of increasing the price of almost every product on the shelves by the latest CPI price increase.
Casual staff on the lowest wages and with no reasonable prospect of a pay increase were required to start early, and often finish late that day, to increase almost every price within the store.
Coles even had the brazenness to call this generalised price increase the "CPI ticket update".
Such a practice meant that a firm with significant market power, a near‑duopoly with a price-setting ability, was increasing its prices simply because it could. This process has zero regard to the actual input costs of the firm.
Arguably, such a practice might be justifiable by a small firm with no cost‑setting or price-setting power. But it is completely unacceptable for a large duopolistic firm to simply increase across the board prices without regard to actual input costs. It is both a failure of the market and a failure of competition law to moderate this behaviour.
3.62Mr Darryn Wiley also provided examples of opportunistic pricing, following the storms which hit the Gold Coast area. Mr Wiley said that in areas where several dairy farms and milk processing plants were located 'the price of UHT Milk suddenly shot up from $1.30/litre to $1.60/litre' and when Cyclone Yasi wiped out 75 per cent of Queensland banana farms, banana prices went up from $2.50/kg to $10.00/kg, including stock that was already delivered and paid for.
3.63Per Capita submitted an example of misleading advertising which also suggest opportunistic pricing is occurring:
Take for example the story of Newcastle resident Rachel King, told by Guardian Australia journalist Johnathan Barret in June last year. King began tracking the price of a coffee product she regularly bought from Woolworths. In the 18 months from the end of 2021 the product could normally be bought for about $14 as part of the store's prices dropped promotion. However, at the beginning of 2023 'the price went from $14 to $22 and then discounted to $15, with the latter advertised as a cost saving, even though it was above the price charged just weeks earlier'.
3.64CHOICE agreed that opportunistic pricing occurs, submitting that:
The major supermarkets employ a number of potentially misleading or deceptive pricing strategies. Discount and 'special' claims made by supermarkets are often confusing and difficult for consumers to verify, making it incredibly hard for people to know if they're getting a genuine discount or value for money.
3.65Mr Abdel Badoura provided a detailed submission discussing grocery price tactics and noted:
In summary, both Coles and Woolworths are running risk-free businesses propped up by suppliers who are paying for the majority of their expenses, underpinned by the Australian public who is being overcharged at every step. They have gotten away with this for years due to the lack of competition in the market and market power abuse. As a result, you see higher recommended prices versus other countries on the same products from large multinationals. This hurts Australian households.
Misleading price displays
3.66Under laws and regulations enforced by the Australian Competition and Consumer Commission (ACCC), businesses cannot display incorrect pricing or pricing that could create a false impression.
3.67CHOICE outlined the ways in which it contended that supermarkets were 'potentially confusing, misleading or deceiving consumers through a number of pricing and promotional strategies' including, but not limited to:
False pricing claims: for example where a supermarket advertised the price of a product was 'locked' until a certain date but raised the price of the product before the end of the promotional period.
Was/now pricing claims: where supermarkets choose comparative prices from points in time that were long ago, giving a false impression of recent price reductions or where supermarkets use natural seasonal variations in pricing to make was/now discount claims.
Specials and discounts without contextual information: where the price tag does not contain the previous price or the amount of the discount, which may lead consumers to believe that products are more discounted, or better value, than they actually are.
Tags designed to look like a discount offer: when it is the regular price and a person could be easily misled into thinking the product is on sale.
Other promotional claims: such as 'everyday', 'everyday low price', 'low price', 'fresh special'. People may be misled into thinking an item is of good value or discounted, when in fact it may be the price it has always been.
3.68CHOICE recommended that the government 'introduce a mandatory information standard for supermarkets that ensures their pricing is clear and consistent with consumer expectations'. CHOICE outlined its reasons for this recommendation, noting there needs to be 'increased price transparency around supermarket pricing to ensure that people are able to effectively assess the variety of ways supermarkets communicate specials and discounts'. CHOICE recommended that:
Supermarkets should publish historical pricing data on all products in stock so that consumers are able to compare and verify pricing claims. Empowering consumers with this information will mean they are able to make stronger purchasing decisions and not be lured into misleading specials and discounts.
Price tags offering specials and discounts should be consistent with consumer expectations and follow a mandatory information standard that outlines what qualifies as a discount and how it should be communicated.
A new mandatory information standard should mandate how the price of an item is displayed. The standard should:
Require clear prices to be displayed on all products sold by supermarkets online and in-store.
Standardise and rationalise discount and promotional terms, including preventing supermarkets from using terms, designs or colours that indicate a discount is being offered when the product is not discounted.
Require supermarkets to publish the most recent previous price of the product, with the date, and clearly state the amount the product has been discounted in dollars and as a percentage.
Unit pricing
3.69Unit pricing is a fundamental strategy in maintaining competition in grocery pricing. Unit pricing details the cost of a product using standard units of measurement, thereby helping consumers to compare prices and find the best value for money.
3.70Unit pricing is enforced by the Unit Pricing Code (UPC), which is a mandatory industry code that outlines the rules regarding where, how, and for what products unit prices are displayed. Most common grocery items must display unit pricing, including:
Bread
Butter
Eggs
Flour
Fresh fruit and vegetables
Fresh milk
Meat
Rice
Sugar
Other packaged food.
3.71Physical businesses that use more than 1000 square metres of floor space to sell groceries must follow the UPC, and physical businesses that use less than 1000square metres of floor space to sell groceries can choose to follow the UPC.
3.72The Queensland Consumers Association argued that the UPC needs increased monitoring and enforcement 'because consumer usage of grocery unit pricing is sub optimal due mainly to many unit prices not being easy enough for many consumers to notice, read, understand and use both instore and online'. The association noted that prices were often in small, non-bold print, used inconsistent units of measure or there were simply no unit prices for all items.
3.73National Seniors Australia submitted that 'supermarkets do not always provide unit pricing in ways that are easily legible and understandable, especially for older people with vision impairment'.
3.74The Consumers Federation of Australia also recommended the ACCC be resourced to 'prioritise the monitoring and enforcement of retail compliance with' the UPC.
3.75The ACCC itself recommended government action on the UPC, suggesting:
… the Government could consider the benefits of including more prescriptive requirements to improve the legibility and prominence of unit prices in the next review. Such a change could be pro‑consumer by improving consumers' access to unit pricing.