Canada’s new grocery code has reached its first public checkpoint with a telling imbalance: the industry is registering, responding to surveys, and publicly backing fair-dealing rules, but only a small number of participants have formally raised issues through the system built to surface problems.
The Office of the Grocery Sector Code of Conduct released its Spring Report on June 16, giving the first public look at how the Canada Grocery Code is operating after full implementation on January 1, 2026.
The OGSCC received 9 issue submissions through its confidential Issue Centre during the first five months of 2026. Since the Issue Centre opened in July 2025, total submissions reached 14, with 10 involving supplier concerns about retailers, 3 involving retailer concerns about suppliers, and 1 involving a supply-chain party outside the Code’s coverage.
That gap between broad adoption and low reporting is now the main strategic question for the Code.
Information and contract power
The first issues reported to the OGSCC cluster around commercial control points rather than consumer-facing prices.
The most common concerns involved unilateral changes to commercial arrangements and inadequate notice for contractual changes. The report says these issues often related to pricing, promotional arrangements, negotiation processes, notice, and agreement practices.
A second recurring group involved administrative fees and deductions, including disputed deductions, substantiation for charges, and non-compliance fees. Other submissions raised communication and good-faith negotiation concerns.
But the most concrete early finding came from the OGSCC’s first sector-wide information-gathering exercise. The office launched a Request for Information on March 2, kept it open until March 31, and collected anonymous responses from members. It received 62 responses, equal to 37% participation across membership classes.
Among respondents, 82% said they had encountered click-to-accept mechanisms. Another 73% said they had encountered unilateral amendment clauses either frequently or occasionally.
The report says respondents saw digital acceptance tools and standardized amendment processes as potentially useful in high-volume commercial environments.
The issue is the surrounding process. Respondents raised concerns about whether proposed changes were explained clearly, whether notice periods gave businesses enough time to assess the changes, whether counterparties had a real opportunity to review and discuss them, and whether terms could be declined without commercial consequences.
The OGSCC responded by publishing guidance on May 6 covering click-to-accept practices and unilateral amendments. The move effectively made digital contracting the Code’s first major compliance education target.
Confidence on the Code
The OGSCC is not presenting the low number of formal issue submissions as a failure. It says the Issue Centre is still new, and that low volume in the initial implementation phase was not unexpected.
Still, the report identifies hesitation as one of the most significant early implementation themes.
Some members remain reluctant to raise Code-related issues with commercial counterparts. Others are hesitant to report concerns directly to the OGSCC, even through confidential channels. The reason most often cited is commercial risk: possible retribution, damaged relationships, or negative business consequences if their identity becomes known.
In May, the OGSCC added a fully anonymous reporting option to the Issue Centre to address that concern. The tradeoff is obvious: anonymity may increase participation, but it can limit the office’s ability to follow up, verify details, or push a specific matter toward resolution.
The office is also trying to correct a misconception about what the Issue Centre is for. The report says some members view it as an individual complaint-response process. The OGSCC instead describes it as a broader intelligence-gathering and compliance-support tool used to spot recurring concerns, guide education, and identify systemic issues.
After strong initial registration in 2025, growth has slowed to roughly one or two new member registrations per week. The OGSCC says that may mean many early adopters and larger organizations have already joined, leaving smaller, regional, or less aware participants to be reached through targeted outreach.
As of May 31, membership included 14 primary producers, 91 small and medium manufacturers, 36 large manufacturers, 17 non-affiliated wholesalers and distributors, 35 independent retailers, and 7 large retailers.
The report says participation by small and medium manufacturers and independent retailers has grown in 2026, but those groups remain underrepresented relative to their place in the broader grocery ecosystem. Primary producers are also flagged as a recruitment focus.
Regionally, participation is concentrated in Ontario and Quebec, with meaningful representation in British Columbia and Alberta. Atlantic Canada and the territories remain more limited.
The report lands as Ottawa is again under pressure over grocery affordability and market concentration. Reuters reported that Prime Minister Mark Carney announced more than $1 billion to support food-sector competition and security, including food terminals and hubs aimed at helping independent grocers buy more directly from farmers and processors.
Five companies reportedly control 75% of Canada’s grocery market and that Canada’s food inflation rate was 3.8% in April, among the highest in the G7.
The OGSCC says it will continue focusing on education, outreach, member recruitment, and compliance support for the rest of 2026.
Later this summer, the newly appointed Code Advisory Group is expected to begin the mandatory annual review of both the Canada Grocery Code and the Dispute Resolution Management Process.
That may be the real first-year metric. In a concentrated grocery market, the Code’s power will not come from registration alone. It will come from whether the companies most exposed to deductions, unilateral changes, and quiet pressure believe the process is safer than silence.
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