This week, the National Party proposed that, if re-elected, it would pursue structural separation of the supermarkets (as reported in the NBR, One News, and the New Zealand Herald). This was interesting timing. My ECONS102 class has just covered firms with market power and monopolies, and one of the regulatory options available to government is structural separation. If this news had broken a week earlier, this would have made a great example for an assessment question. Instead, I'll have to console myself with a blog post.
In short, the proposed structural separation is nonsensical. Foodstuffs is currently comprised of two cooperatives - Foodstuffs North Island, and Foodstuffs South Island. The two cooperatives run three brands of supermarkets: Pak'n'Save, New World, and Four Square. The National Party is proposing to separate the business into two, with Pak'n'Save as one business and New World and Four Square as another.
There are several elements of the proposal that are plain dumb. The first problem with the proposal is that it would require a substantial reorganisation of the two existing geographically-based cooperatives into two nationwide businesses. This proposed reorganisation is somewhat ironic, given that the Commerce Commission declined a Foodstuffs merger into a nationwide business in 2024. Both of the two new supermarket chains would then have to create their own warehousing, logistics, and other backend systems, separate from the other new chain. And the two pre-existing warehousing and logistics (and other systems), which are geographically separated at present, would need to be split up in order to do this. In its own house, the government is busy trying to reduce back-office functions to increase efficiency. And yet, it seems quite happy to generate inefficiency in a private sector business?
Moreover, the cost-benefit analysis that Sense Partners completed for the Ministry of Business, Innovation and Employment demonstrates how sensitive the case is to assumptions about supply-chain costs. The preferred analysis assumes supply-chain costs rise by one percent, generating an estimated net benefit of $2.9 billion over 20 years. However, if supply-chain costs rise by two percent, the estimated benefit falls to around $920 million, and if supply-chain costs rise by more than two percent, the costs outweigh the benefits. That doesn't leave much margin for the proposal to go wrong before society is worse off overall.
The second problem is that this proposal leaves the other major player in the supermarket sector, Woolworths, structurally unchanged. While the proposal would reorganise Foodstuffs into two separate nationwide supermarket groups, Woolworths would be free to continue its current operations, which also includes three brands: Woolworths, FreshChoice, and SuperValue. Admittedly, the two businesses are not structured in exactly the same way. Woolworths operates its Woolworths supermarkets directly, while FreshChoice and SuperValue are locally owned stores franchised through a Woolworths subsidiary. So, there may be good reasons why the same form of structural separation would not be appropriate for Woolworths. But the obvious question then is, if structural separation is the answer to weak competition in the supermarket sector, why is restructuring only one of the two big market players the right approach?
The third problem is that this proposal ignores another, arguably more obvious, form of structural separation that could be enacted, which could be applied symmetrically to both of the large supermarket players. This is to structurally separate wholesale and distribution from supermarket retail. Currently, both Foodstuffs cooperatives and Woolworths benefit from substantial economies of scale in purchasing, wholesale, and distribution. Those economies of scale may themselves create a barrier to entry, because a new supermarket chain that cannot obtain groceries on similarly competitive terms faces higher costs and will struggle to compete effectively.
Structurally separating wholesale and distribution from retail could potentially address that problem by allowing existing and new retailers to access the scale economies of the established distribution networks on fair and non-discriminatory terms, without having to build their own nationwide wholesale and distribution systems. This isn't a new idea (for example, see here and here). Wholesale ownership separation was explicitly considered in a government-commissioned study in 2022, although that analysis raised significant concerns about whether an independent wholesaler would remain viable after structural separation. Despite those concerns, this remains an alternative worth considering, and the Labour Party announced a policy along these lines earlier today. Its proposal would require Foodstuffs and Woolworths to run their wholesale businesses independently from their retail businesses, although it would not require the wholesale businesses to be separately owned.
As I note in my ECONS102 class, structural separation can be an effective way of regulating a monopoly. Typically, it is used with natural monopolies, where increasing competition across the entirety of a sector is not straightforward. For example, in New Zealand we structurally separated the telecommunications backbone (now run by Chorus) from the retail. We also separated electricity lines businesses from generation and retail, although generation and retail were allowed to remain integrated in the so-called 'gentailers'.
Now, supermarket retail itself isn't obviously a natural monopoly, but wholesale and distribution may contain some of the characteristics that we associate with natural monopolies, including high fixed costs and large economies of scale. Regardless, it is clear that to date government's various measures have been largely ineffective in increasing competition in the supermarket sector. So, structural separation may be more effective than what has been tried so far. However, what is being proposed by the National Party is only one possible form of structural separation. The more important question is where in the supply chain separation would do the most to reduce barriers to entry while preserving the economies of scale that keep costs down.
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