Competition Bureau Launches Investigation Into Minimum Advertised Pricing Policies in Grocery

On September 28, 2026, the Competition Bureau (Bureau) launched an investigation into the use of minimum advertised pricing (MAP) policies in the Canadian grocery sector and issued a public call for information seeking input from consumers, retailers, suppliers, distributors and manufacturers on how these policies impact grocery pricing. 

The announcement is the latest step in the Bureau’s examination of competition across Canada’s food supply chain, which was launched on June 16, 2026, with a final report and policy recommendations expected to be published in spring 2027. For more information on the Bureau’s examination, see our Blakes Bulletin: Competition Bureau Launches Examination on Competition in Canada’s Food Supply Chain.

Below is an overview of the competition law considerations associated with MAP policies and the focus of the Bureau’s investigation. 

MAP Policies – An Overview

MAP policies, which can be imposed by suppliers or negotiated between suppliers and retailers, set the lowest price at which a retailer may advertise a product. MAP policies do not regulate the actual price of the item but rather place a limitation on the price advertised in a retailer’s promotional materials. 

MAP policies are not prima facie prohibited under the Competition Act (Act); however, they may be subject to scrutiny under the price maintenance, abuse of dominance or anti-competitive agreement provisions of the Act, depending on the facts. 

In its call for information associated with the investigation, the Bureau has taken the position that the efficiency justifications associated with MAP policies, such as promoting inter-brand competition or preventing “free-riding” (i.e., a low-pricing retailer capturing sales from a higher-pricing retailer that offers high-quality customer service), should not apply in the grocery sector. 

The Bureau’s Concerns

According to the Bureau, MAP policies may restrict competition in the grocery sector and keep lower prices out of reach for consumers by:

• Making deals harder to find, as shoppers that cannot see lower advertised prices may be unable to compare prices before deciding where to shop
• Reducing price competition, as retailers may have less reason to discount a product, or may even decline to carry a product altogether, if they cannot use discounts to attract customers
• Creating barriers for discount and new grocers, as lower advertised prices can be an important way to attract customers and compete effectively
• Facilitating price alignment, as a common advertised-price floor may make it easier for grocers to mirror each other’s pricing, instead of competing

In connection with its investigation, the Bureau is seeking input from interested parties with information about MAP policies in the grocery sector. Among other things, the Bureau is seeking feedback on the following:

• How a MAP was introduced, communicated, monitored or enforced
• Whether the MAP limited discounts or affected prices, promotions or shopping decisions
• How the MAP affected retailers, suppliers, manufacturers or consumers
• Whether MAP policies in grocery should be restricted or prohibited

Key Takeaways

The Bureau’s investigation signals a significant development in its examination of the food supply chain. Businesses should consider the following: 

• Reviewing MAP policies and related supply or promotional terms, including how they are introduced, communicated, monitored and enforced
• Clearly documenting legitimate, pro-competitive rationales for MAP policies
• Whether to provide input to the Bureau’s examination, bearing in mind that the Bureau has indicated the information collected will be used to support potential enforcement

For more information, please do not hesitate to reach out to your usual Blakes contact or any member of the Blakes Competition, Antitrust & Foreign Investment group.