The shift from voluntary to mandatory felt incremental on paper. In practice, it handed suppliers something they hadn’t held in years — a document with genuine enforcement weight sitting behind every trading conversation.
Australia’s Food and Grocery Code of Conduct has been reshaped materially in recent periods, and the latest round of changes — including new supplier disclosure requirements applied to Coles, Woolworths, and Aldi — signals that the Australian Competition and Consumer Commission (ACCC) is no longer content to observe the power imbalance between major retailers and their supplier base. It is moving to correct it.
What the Grocery Code Actually Requires Now
The grocery code governs how Australia’s largest supermarket retailers must treat the suppliers they buy from. For years, the code operated as a voluntary framework — retailers could sign up, but the absence of mandatory participation blunted its practical reach.
Making the code mandatory changed that calculus entirely. Coles, Woolworths, and Aldi are now bound by its provisions in ways that carry real compliance risk, not just reputational pressure. Suppliers who previously absorbed unfavourable trading adjustments quietly now have a documented framework to push back against.
The code covers a range of conduct areas: how retailers communicate changes to trading terms, how disputes must be managed, what notice periods apply to de-listing decisions, and what protections exist around retrospective charges. Each of these areas represents a historical flashpoint between large-format retailers and their supplier networks.
ACCC’s Disclosure Rules Targeting Coles, Woolworths, and Aldi
The ACCC’s decision to change supplier disclosure requirements for the major three retailers sits within this broader enforcement posture. The regulator has been increasingly direct about scrutinising the grocery sector, including its well-publicised probes into pricing conduct and its unusual decision to publicly disclose an investigation into fuel retailers given its “significance” — a signal of intent that extends across the retail and FMCG space.
Disclosure requirements matter because opacity is where supplier disadvantage is manufactured. When trading terms, rebate structures, and category management decisions are obscured, smaller suppliers have no basis to benchmark whether what they’re being offered is fair or just standard industry practice.
Greater transparency in how retailers document and communicate their commercial decisions doesn’t just protect individual suppliers. It creates an information environment where the ACCC can actually audit conduct against the code’s requirements.
| Code Area | Previous Position | Current Position | Who It Affects Most |
|---|---|---|---|
| Retailer participation | Voluntary sign-up | Mandatory for major retailers | Coles, Woolworths, Aldi |
| Supplier disclosure | Limited formal obligation | Enhanced ACCC-directed requirements | All grocery suppliers |
| Dispute resolution | Internal retailer processes | Structured mediation pathway | Mid-tier and small suppliers |
| De-listing notice | Inconsistent application | Minimum notice periods codified | Branded and private label suppliers |
| Retrospective charges | Disputed, often absorbed | Code prohibitions apply | Fresh produce and perishables suppliers |
What the Code Still Cannot Do
I want to be clear about the limitations here, because professional readers deserve a grounded assessment rather than a regulatory press release dressed up as analysis.
The grocery code does not equalise commercial power. Coles and Woolworths collectively control the majority of Australia’s packaged grocery volume, and that structural reality persists regardless of what the code prescribes. A supplier reliant on one of the major chains for 60 per cent of revenue is not negotiating from a position of strength, full stop.
The code also relies substantially on suppliers being willing to use it. Raising a formal dispute against a retailer who controls your route to market is not a decision made lightly. For many smaller manufacturers, the risk of relationship damage outweighs the protection the code theoretically provides. Enforcement culture will need time to mature before those suppliers engage the framework with confidence.
Who Stands to Gain and When
Mid-tier branded suppliers and category specialists in perishables stand to benefit most in the near term — particularly those with documented grievances around retrospective charges and de-listing conduct. The disclosure changes also create a clearer baseline for new suppliers entering range reviews with the major retailers, reducing the information asymmetry that has historically favoured the buying side of the table.
A Regulatory Posture That Is Only Getting Sharper
The grocery code changes don’t exist in isolation. The ACCC has become demonstrably more active across the retail sector — from its pricing inquiries into Coles and Woolworths to its public disclosure of the fuel retailer probe. The regulator is signalling that concentrated retail markets will receive concentrated scrutiny.
For FMCG brand managers and supply chain professionals, the practical implication is this: the rules of engagement with major retailers are shifting from informal power norms toward documented, enforceable obligations. Teams that understand the code’s provisions — and build commercial strategies that account for them — will be better positioned in range reviews, contract negotiations, and dispute situations than those treating it as a compliance checkbox.
If you work in supplier relationships, category management, or commercial strategy, now is the time to review how your trading terms and dispute processes align with the code’s current requirements. The framework exists — using it effectively is the work that remains.