There is a sustained decline in the number of convenience stores in the UK, the Association of Convenience Stores (ACS) has said this week in its official response to the Competition Commission’s (CC) provisional findings report, which was published at the start of last month.
The new evidence has been provided by confidential sources made up of wholesalers, suppliers and market analysts.
The ACS’s submission has also reiterated its concerns over the way the CC has failed to properly evaluate the impact of below-cost selling on groceries and related products; reiterated the importance of buying price differentials to supermarket buying power and competition; outlined the competition problems caused by the entry of major multiples into the convenience store sector; and re-emphasised the waterbed effect theory and considered weaknesses in the CC’s analysis of it.
ACS chief executive James Lowman said: “It is a great shame that, several months after we explained clearly why the commission’s analysis of store numbers in our sector was flawed, we are once again rehearsing these arguments. The latest data used by the commission, from the Office of National Statistics, is as unreliable as the Experian-Goad database the commission has given enormous credence to up until this point.
“We have presented new data from suppliers, wholesalers and independent market analysts to show the decline in our sector, and we believe the commission will listen to this new evidence and come to a more realistic view on store numbers in its final report.
“What the commission should really be doing is looking at why these stores are closing down and what impact that has on competition. We contend that some of the pricing activity of the major multiples is predatory, and that the loss of independent stores leads to a decline in choice and particularly harms less mobile consumers,” Lowman added.
ACS is to hold its third formal hearing with the commission on December 12.
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