25 March 2026
Hayden
[FYI request #33882 email]
Kia ora Hayden
Official Information Act request 25.187
Thank you for your Official Information Act 1982 (the OIA) request on 27 February 2026
asking for:
1. “The most recent data held by the Commission on price-cost margins by
product category in the New Zealand grocery sector, including fresh
produce, bread, dairy, and meat.
2. Any analysis or assessment by the Commission of the role of community
food networks, food cooperatives, or local producer direct sales as
competitive alternatives to the grocery duopoly.
3. Any assessment of the extent to which regulatory barriers under the Food
Act 2014 and Animal Products Act 1999 contribute to barriers to entry in
the grocery sector — specifically, the cost of compliance for small-scale
local food producers.
4. The Commission's estimate of the total excess profits earned by the
major grocery retailers (Foodstuffs and Woolworths NZ) in the most
recent financial year for which data is available.
5. Any analysis of the potential consumer savings that could arise from a
shift of 5 to 10 percent of grocery spending toward local producer direct
sales and community food networks.
6. Any submissions or correspondence received by the Commission from
community food networks, food cooperatives, or local producer
organisations regarding barriers to competition in the grocery sector.
7. The Commission's 2022 market study found excess profits of
approximately $1 million per day. Community food networks such as the
Longwood Loop in Southland and Hauora Kai in Wellington consistently
deliver fresh produce at 30 to 40 percent below supermarket prices. I am
establishing whether the Commission has assessed the potential for
removing regulatory barriers to local food production as a competition
intervention.
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8. If this analysis does not exist, the question becomes: why not?”
Our Response
The Commerce Commission’s (the Commission’s) response to each of your requests is
set out below:
Request
Response
1 The most recent data
Our most recent (financial year 2024) published analysis
held by the Commission of price cost margins is included in our second annual
on price-cost margins by grocery report, available from page 65 here:
Link
product category
This is high-level analysis that only differentiates
between fresh and non-fresh departments.
The most recent (financial year 2023) published analysis
of product category level price-cost margins was
included our first annual grocery report, see page 49:
Link
We previously responded to an OIA request for the
analysis behind the statements in the first annual
grocery report on product category margins
: Link
The most recent (financial year 2025) unpublished price-
cost margin analysis is due to be included in our third
annual grocery report which we are aiming to publish on
our website at the end of May 2026. This analysis is high
level and only differentiates between fresh and non-
fresh departments, it does not split by product category.
This analysis is withheld under section 18(d) of the OIA
on the basis that the information will soon be publicly
available.
We have undertaken some financial year 2025 analysis
of product category level margins. This is withheld under
section 9(2)(b)(ii) of the OIA on the basis that its release
would be likely to unreasonably prejudice the
commercial position of the person who supplied the
information.
2 Any analysis or
The Commission has conducted analysis with regard to
assessment by the
competition in groceries generally, including in the
Commission of the role
Groceries Market Stud
y: Link and our annual grocery
of community food
reports:
Link
networks, food
cooperatives, or local
However, the Commission has not conducted analysis
specifically in relation to the role of community food
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producer direct sales as networks, food cooperatives, or local producer direct
competitive alternatives sales as competitive alternatives with regard to
groceries. As such this request is refused under section
18(g)(i) of the OIA on the basis that the Commission
does not hold the information, and we have no grounds
for believing that the information is held by another
department or organisation.
3 Any assessment of the
The Groceries Market Study considered compliance
extent to which
costs for smaller retailers. However, the Commission
regulatory barriers
has not carried out analysis on the extent to which the
under the Food Act 2014 Food Act 2014 and Animal Products Act 1999 contribute
and Animal Products Act to barriers to entry in the grocery sector, specifically, the
1999 contribute to
cost of compliance for small-scale local food producers.
barriers to entry in the
grocery sector —
As such this request is refused under section 18(g)(i) of
specifically, the cost of
the OIA on the basis that the Commission does not hold
compliance for small-
the information, and we have no grounds for believing
scale local food
that the information is held by another department or
producers.
organisation.
4 The Commission's
The Groceries Market Study assessed excess
estimate of the total
profitability of the major grocery retailers to 2019. Our
excess profits earned by first annual grocery report updated this analysis to cover
the major grocery
the period to 2023. See our first annual grocery report,
retailers (Foodstuffs and available from page 50 here:
Link
Woolworths NZ) in the
most recent financial
This is the most recent estimate available for excess
year for which data is
profitability. Our analysis of profitability focuses on
available
ongoing trends rather than a firm’s performance in any
given year. As such we only look at this type of excess
profitability analysis occasionally over time.
5 Any analysis of the
This request is refused under section 18(g)(i) of the OIA
potential consumer
on the basis that the Commission does not hold the
savings that could arise
information, and we have no grounds for believing that
from a shift of 5 to 10
the information is held by another department or
percent of grocery
organisation.
spending toward local
producer direct sales
and community food
networks.
6 Any submissions or
We have received the following public submission that is
correspondence
in scope of this request:
received by the
• Kiwi Co-op (Nelson) on the Groceries Market
Commission from
Stud
y: Link
community food
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networks, food
Please see our website for a full list of public
cooperatives, or local
submissions regarding barriers to competition in the
producer organisations
grocery sector with regard to:
regarding barriers to
• the Groceries Market St
udy: Link
competition in the
• the Review of the Grocery Supply C
ode: Link
grocery sector.
• the Groceries Wholesale Supply Inquir
y: Link
• the Consumer Complaints Disclosure Standard:
Link
At the time of publication, some information within
these submissions was redacted in line with the
principles of section 9(2) of the OIA. We have not
reassessed these redactions at this time.
Regarding non-public submissions or correspondence:
• On 6 December 2023 we received an enquiry from
a representative of a community food network,
food cooperative, or local producer organisation.
This correspondence is withheld in full under
section 9(2)(b)(ii) of the OIA on the basis that its
release would be likely to unreasonably prejudice
the commercial position of the person who
supplied the information.
• On 6 September 2024 we received an enquiry
[ENC0002101] from a representative of a
community food network, food cooperative, or
local producer organisation. This
correspondence is withheld in full under section
9(2)(b)(ii) of the OIA on the basis that its release
would be likely to unreasonably prejudice the
commercial position of the person who supplied
the information.
• On 9 July 2025 we received a submission to our
Wholesale Supply Inquiry from a representative of
a community food network, food cooperative, or
local producer organisation. This submission is
withheld in full under section 9(2)(b)(ii) of the OIA
on the basis that its release would be likely to
unreasonably prejudice the commercial position
of the person who supplied the information.
7 The Commission's 2022 The Commission has conducted analysis with regard to
market study found
regulatory barriers to competition generally, including in
excess profits of
the Groceries Market St
udy: Link
approximately $1 million
per day. Community
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food networks such as
However, the Commission has not conducted analysis
the Longwood Loop in
specifically in relation to removing regulatory barriers to
Southland and Hauora
local food production as a competition intervention with
Kai in Wellington
regard to groceries.
consistently deliver
fresh produce at 30 to
As such this request is refused under section 18(g)(i) of
40 percent below
the OIA on the basis that the Commission does not hold
supermarket prices. I
the information, and we have no grounds for believing
am establishing whether that the information is held by another department or
the Commission has
organisation.
assessed the potential
for removing regulatory
barriers to local food
production as a
competition
intervention.
8 If this analysis does not
Please see response to 7 above.
exist, the question
becomes: why not?
In making these decisions to withhold certain information under section 9 of the OIA,
we have determined that the public interest does not outweigh the need to withhold the
information at this time.
Further information
We hope this response has been helpful.
If you have any questions about this response, please do not hesitate to contact us at
[Commerce Commission request email]. If you are not happy with our response, you have the right to complain to the
Ombudsman. Information about how to do this is available at
www.ombudsman.parliament.nz.
Finally, confirming the Commission may publish this response on its website as part of
our proactive release process. Any personal information will be redacted prior to
publication.
Ngā mihi nui
OIA Coordinator | OIA & Information
5772265-2
