At the end of February Consumers SA made a detailed submission to the Federal Government’s Review of the Retail Grocery Industry (Unit Pricing) Code of Conduct.
The submission was prepared by John Furbank, the Association’s Honorary Secretary.
John is a compliance consultant specialising in advising industry on compliance with consumer protection legislation and technical standards, Chair, ISO PC 297 Guidance on unit pricing and and Chair, Standards Australia Committee CS-116 Guidance on unit pricing.
Our submission points out that consumers have an enormous number of choices to make when deciding what to buy. These choices are influenced by a range of factors including taste, food preferences, health, social or environmental impact considerations, but also and especially, price. Price transparency is also one way of gaining consumer trust by making purchasing choices easier. Unit pricing assists consumers to get the best value for their money.
The market share of packaged food in Australia is high with supermarkets holding between 30,000 and 50,000 stock-keeping units. Together with the multitude of pack sizes for grocery items, the sheer volume of available products makes it difficult for consumers (particularly vulnerable consumers) to assess and compare their real price and value.
Unit pricing can assist consumers in forming an opinion as to which purchase to make by providing consumers with a base price with which to compare like items (e.g. different sizes and brands of pre-packed goods) and substitute or alternative items (e.g. frozen/canned/loose vegetables).
Our submission makes a number of recommendations designed to ensure compliance with the Code and to make it easier to use, including:
· increasing pro-active enforcement including using the new international standard ISO 21041:2018, Guidance on unit pricing to define prominence and legibility
· increasing consumer education by ACCC and retailers on how to use unit pricing effectively
· placing emphasis on font type and size, colour and contrast, white space, angled shelving for low and high shelves on shelf displays and on-line so that the unit price could be more easily read by consumers particularly the elderly and those with disabilities
· expanding the code to include pharmacies, hardware stores and grocery area of service stations
· providing the ACCC with the power to issue infringement notices for non-compliance.
Download a copy of the full submission here.