CFA has made a submission to the federal government on its draft new Grocery Unit Pricing Industry Code of Conduct.
The submission disagrees strongly with the conclusions of the review of the current Code and with the proposed new Code’s provisions (which are identical to those of the current Code).
It also argues that implementation of the proposed new Code in its present form will be a great waste of a long overdue opportunity for consumers and the economy (including retailers) to gain even more benefits from grocery, and other relevant, retailers providing effective unit pricing.
It requests that the provisions of a new Code be substantially different to those in the current Code and should address CFA’s 15 recommendations for improvements designed to:
- Make unit prices much easier for consumers to notice, read, and use.
- Require more grocery retailers to provide unit prices.
- Require some non-grocery retailers to provide unit prices.
The submission also says that:
- Surveys have shown clearly that consumers want better and more unit pricing.
- Many submissions to the review called for changes to the Code to improve its effectiveness and scope for grocery products and grocery retailers, and to increase the benefits available from unit pricing by requiring provision of unit pricing for products sold by some non-grocery retailers.
- The review has given excessive weight to possible (but often unquantified) negative implications for industry of changing the current legislation and insufficient account has taken of the benefits for consumers, retailers, and the economy (including increased competition between retailers and between producers).
- There has been insufficient recognition:
- Of the very large amounts consumers spend annually on grocery (estimated at around $100 billion) and other relevant products.
- That a very high proportion of the population spend large amounts of scarce time buying grocery products (and others to which the provision of unit pricing is highly relevant).
- Of the very high value of the benefits relative to industry costs likely from even very small changes in consumer purchasing behaviours and time savings if the amount and quality of unit pricing provided by retailers were increased.
- Of the increasing awareness by regulators and others that the quality and consistency of provision greatly affects consumer awareness and use of written consumer information.
- The proposed new Code does not address the requirements of consumers with specific needs, including those with disability, and the provisions of discrimination legislation.
The following CFA members also made submissions and supported CFA’s submission:
- CHOICE and Queensland Consumers Association (jointly)
- Financial Counselling Australia
- Consumer Policy Research Centre
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