The Association of Convenience Stores (ACS) has published its response to the provisional findings of the Competition Commission’s investigation into the UK supermarket sector.

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The ACS said it had provided the Commission with “further evidence to prove that we are witnessing a sustained decline in the number of convenience stores in the UK”.


The trade group said it had based its submission on confidential sources made up of suppliers, wholesalers and market analysts.


The ACS also re-iterated concerns over the way the Competition Commission had “neglected to properly evaluate the impact of below-cost selling on groceries and related products including fuel”, and the importance of buying price differentials to supermarket buying power and competition.


It also outlined the competition problems caused by the entry of major multiples into the convenience store sector itself.

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“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,” said ACS chief executive James Lowman. “The latest data used by the Commission, from the Office of National Statistics, is as unreliable as the Experian-Goad database the Commission has erroneously given credence to up until this point.”


Lowman suggested that the Commission should be looking at why some convenience 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,” he said. 


The ACS has a further third formal hearing with the Competition Commission on 12 December.