Association of Convenience Stores (ACS) Written evidence (FPO0050)


  1. ACS (the Association of Convenience Stores) welcomes the opportunity to respond to the House of Lords Select Committee on Food, Poverty, Healthy and the Environment’s call for evidence to inform their inquiry into food insecurity and sustainability. ACS is a trade association, representing over 33,500 convenience retailers across the UK. Members include the Co-Op, One Stop, Costcutter, Spar UK and thousands of independent retailers. For more information about ACS and the convenience sector, please see Annex A.


3) How accessible is healthy food? What factors or barriers affect people’s ability to consume a healthy diet? Do these factors affect populations living in rural and urban areas differently?


  1. Convenience retailers provide a range of grocery products and services to their local communities. 37% of convenience stores are located in rural areas, 37% trade in urban areas and 26% trade in suburban areas[1]. Convenience stores typically trade close to where people live and demand services. This means that convenience stores are often (38% of stores) located in isolated areas[2], neighbourhood parades (42% of stores)[3] rather than high streets and larger shopping parades (of which 21% of stores are located)[4].


  1. There is a significant variety of products offered in-store, with chilled foods one of the most popular categories in the convenience sector, representing 12.8% of total sales[5]. Fruit and vegetables represent 4.2% of sales in the convenience sector and canned and packaged grocery represents 7.2% of sales1. Convenience retailers continue to adapt the range of products sold in store to keep up with consumer demand and have been increasing and promoting healthier ranges in-store.


  1. ACS’ Voice of Local Shops survey in 2015 shows that 26% of independent convenience retailers sold more healthy food that it did five years ago[6]. In fact, 17% of independent convenience retailers responded in 2018 that they had increased promotions on a single product category – fruit and vegetables. Of the local shops that sell fruit and vegetables, all of them responded that they run promotions on these products. 17% of independent retailers saw their sales of fruit and vegetables increased compared to the previous year, and 18% had increased their range of fruit and vegetables in the last year[7].


  1. ACS commissioned polling in 2016 to understand to what extent consumers were impacted by food deserts. Only 5% of consumers responded that they were more than a 15-minute journey (using their usual mode of transport) from at lease one core local amenity[8]. When looking at region, 7% of consumers in London said they were not within 15 minutes of a local amenity, compared to 11% of consumers in the North East, 7% in Scotland, and 3% in the South East[9].


  1. Over half (52%) of consumers responded that they were within 15 minutes of healthy food from a convenience store. This was higher than 43% of consumers who said that they were within 15 minutes of healthy food from another outlet[10]. While we do not have a breakdown for rural, urban and suburban areas, there are not significant differences by region. 55% of consumers in London responded they were within 15 minutes of healthy food from a convenience store compared to 54% in Scotland, 53% in Wales and 51% in Yorkshire and Humberside[11].


4) What role can local authorities play in promoting healthy eating in their local populations, especially among children and young people, and those on lower incomes? How effectively are local authorities able to fulfil their responsibilities to improve the health of people living in their areas? Are you aware of any existing local authority or education initiatives that have been particularly successful (for example, schemes around holiday hunger, providing information on healthy eating, or supporting access to sport and exercise)?


  1. We believe that the government should consider how its proposed reforms to Healthy Start could promote its healthy eating agenda. Healthy Start is a government initiative which provides pregnant women and parents with young children, who are in receipt of qualifying benefits, Healthy Start vouchers. These vouchers can be used to purchase milk, fresh or frozen fruit and vegetables and infant formula milk from local shops which have signed up to the scheme.


  1. ACS is supportive of Healthy Start and has been encouraging more retailers to accept Healthy Start vouchers as currently only one third of independent retailers take advantage of the scheme. To raise awareness about Healthy Start and to encourage retailers to sign up, ACS developed an animation which explains what Healthy Start is and how retailers can benefit from accepting vouchers in their store[12]. We continue to encourage retailers to sign up to the scheme and will be responding to the government’s upcoming consultation on reforms to Healthy Start, as confirmed in Chapter 2 of the Childhood Obesity Strategy[13].



  1. ACS is supporter of Food Foundation’s Peas Please campaign which aims to bring together farmers, retailers, restaurants, caterers, processers, broadcasters and the government to increase the consumption of vegetables. ACS has sponsored industry fresh produce awards to promote best practice in selling more fruit and veg, as well as contributing to the development of a retailer toolkit to support more healthy produce being sold in stores[14].


  1. We have also worked with the Department of Health and Change4Life to increase the availability of fresh fruit and vegetables in convenience stores[15]. The programme aimed to increase sales of fruit and vegetables by improving range, merchandising, quality, and communication in stores as well as drive awareness of fruit and vegetables to consumers through signposting within stores using the Change4Life branding. As part of the programme, sales of fruit and vegetables were reported to have increased in stores that participated.


7) What impact do food outlets (including supermarkets, delivery services, or fast food outlets) have on the average UK diet? How important are factors such as advertising, packaging, or product placement in influencing consumer choice, particularly for those in lower income groups?


  1. Supermarkets dominate food purchases across all main product categories[16]. Only 3% of consumers use their local convenience store to purchase their main food shop compared to 94% of consumers who visit supermarkets to purchase their main food shop[17]. The majority of consumers in instead use convenience stores when they have run out of something (47%)[18]. This does not differ greatly by social grade, as set out in the table below.












Convenience Store





Location of main food and grocery shop in a typical week


  1. It is important that the government understands the role and context that convenience stores play in relation to people’s daily lives and shopping habits and whether changes to advertising, packaging or product placement will disproportionately impact smaller retailers as they do not dominate consumer purchases. We believe more evidence is needed to understand what impact advertising, packaging and product placement have on influencing consumer choice.


8) Do you have any comment to make on how the food industry might be encouraged to do more to support or promote healthy and sustainable diets? Is Government regulation an effective driver of change in this respect?


  1. We believe that the government should consider making a business case to retailers to provide healthier foods. We support Food Foundation’s recommendation to government to incentivise the shift to healthy eating through reduced business rates[19]. This could accelerate convenience retailers’ ability further to follow consumer trends by increasing and promoting healthier ranges in store.


11) How effective are any current measures operated or assisted by Government, local authorities, or others to minimise food waste? What further action is required to minimise food waste?


  1. Retailers are already being proactive and looking at reducing their food waste through various ways, including engaging with local and national charities and “reduced to clear” lines. ACS’ Voice of Local Shops survey of 1,210 independent retailers found that over a third (36%) of retailers do not produce food waste, 20% of retailers responded that they recycle using a separate food waste bin, 12% consume or give to staff, 10% reduce food waste through other initiatives, and 7% donate to a local cause[20]. There are also a number of voluntary initiatives which help to reduce food waste including Cortauld Commitment, WRAP and Love Food, Hate Waste which retailers engage with.


  1. The operation of stores plays a factor on how convenience retailers reduce food waste. A multiple convenience store (a chain of stores which are run from head office) may take a more coordinated approach to tackling food waste by involving all their stores. This could include engaging with national voluntary initiatives and charities, while symbol groups (usually organised by a wholesaler and are made up by independent businesses but collaborate in joint buying and marketing initiatives) may have a head office, they do not have the same control over the operation of individual stores.


  1. The approach to tackling food waste at both symbol group and independent retailer level will be decided locally by the individual store. This provides more flexibility as they can consider different options on how to reduce their food waste taking into account local circumstances and the practicalities of the store. For example, considering if there are local charities and food banks nearby that they could donate food waste to, or if that is not practical, then the retailer can decide to separate food waste for recycling.


  1. We believe retailers should determine how they tackle food waste based on local circumstances, and the needs of the store. As such, we do not think this is an area that should be regulated by national legislation. Tackling food waste does not work as a one size fits all approach. Convenience stores will face different challenges than supermarkets when it comes to food waste. For example, due to the low volume of food waste that convenience stores produce compared to supermarkets, there can be less interest from charitable causes to engage or pick up food waste from stores. Charities do not have the confidence of supply from convenience stores, as they may not receive food on a daily basis which is a suitable volume.


12) A Public Health England report has concluded that “considerable and largely unprecedented” dietary shifts are required to meet Government guidance on healthy diets. What policy approaches (for example, fiscal or regulatory measures, voluntary guidelines, or attempts to change individual or population behaviour through information and education) would most effectively enable this? What role could public procurement play in improving dietary behaviours?


  1. Convenience retailers have an important role to play in promoting healthy eating and ensuring that healthy products are available for customers and the industry wants to align with the Department of Health and Social Care’s ambitions to reduce childhood obesity. However, we have particular concerns that their proposed restrictions on the location of products high in fat, salt or sugar will place onerous operational burdens on smaller retailers. ACS responded to the government’s consultation on ‘Restricting Promotions of Products High in Fat, Sugar and Salt by Location and by Price’ which contains more detail about our concerns and how the proposals will disproportionately impact small shops[21].


  1. Moreover, government should not introduce restrictions on the promotions of products high in fat, sugar and salt by location and by price without evidence to suggest that they will be effective in promoting public health. University of Stirling’s report, ‘Identifying and Understanding the Factors that can Transform the Retail Environment to Enable Healthier Purchasing by Consumers’ suggests that while studies have been published on measures in the retail environment to reduce obesity, these have focused on individual elements in short time periods such as “better information provision around healthy products alone and on the price of such products” [22] and therefore “there is limited published academic research on the direct alterations to the food retail environment aimed at changing consumer decision-making.” 


13) Has sufficient research been conducted to provide a robust analysis of the links between poverty, food insecurity, health inequalities and the sustainability of food production? How well is existing research on the impact of existing food policy used to inform decision making?


  1. We believe there is a need for further research to be conducted in order to understand the links between poverty, food insecurity, health inequalities and the sustainability of food production. Policy being developed by government must be based on robust evidence.


For more information on ACS’ submission, please contact Julie Byers, ACS Public Affairs Manager by emailing or calling 01252 515001.



12 September 2019


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[1] ACS Local Shop Report 2019

[2] ACS Local Shop Report 2019 – Isolated store meaning no other retail/service business close by

[3] ACS Local Shop Report 2019 – small parade meaning up to five retail/service businesses close by

[4] ACS Local Shop Report 2019 – Larger parade defined as up to 10 retail/services close by and main high street defined as more than 10 retail/service businesses close by

[5] ACS Local Shop Report 2019 (refers to sales value not volume of sales)

[6] ACS Voice of Local Shops Survey November 2015

[7] ACS Voice of Local Shops Survey August 2018

[8] Including cash machine, fuel, bill payment services, parcel collection facilities and access to healthy food

[9] Populus Consumer Polling 2016 (of 2,000 UK consumers)

[10] Populus Consumer Polling 2016 (of 2,000 UK consumers)

[11] Populus Consumer Polling 2016 (of 2,000 UK consumers)

[12] ACS Advice: Healthy Start

[13] Department of Health and Social Care: Childhood obesity: a plan for action chapter 2 (page 27)

[14] Peas Please Retailer Toolkit

[15] Department of Health: Change4Life Convenience Stores Evaluation Report

[16] Populus Consumer Polling 2016

[17] Populus Consumer Polling 2016

[18] Populus Consumer Polling 2016

[19] Food Foundation: The Broken Plate

[20] ACS Voice of Local Shops Survey August 2016

[21] ACS Submission: Restricting Promotions of Products High in Fat, Sugar and Salt by

Location and by Price

[22] University of Stirling - Identifying and Understanding the Factors that can Transform the Retail Environment to Enable Healthier Purchasing by Consumers