FAQ
Find answers to the most common questions about the Canada Grocery Code. Understand how the Code works, its benefits, and how it impacts your business.
Implementation
When does the Canada Grocery Code come into effect?
The Code of Conduct document, which was agreed to in principle by many of the largest grocery retailers and suppliers in 2024, contains a reference date of June 1, 2025 by which members are expected to be in compliance with the Code. That date was based on the assumption that the Office of the Grocery Sector Code of Conduct (OGSCC) would be established in 2024 and that a broad membership base would be in place by then.
In reality, the Office was only established in March 2025, and the necessary infrastructure to support membership, such as administrative systems, dispute processes, and registration tools, is still being finalized. For that reason, the Code is being rolled out in phases, with the period from June 1 to December 31, 2025 serving as a transition period. During this time, the sector is expected to prepare for full compliance and the OGSCC will support stakeholders through education and outreach. Formal operations, including enforcement, dispute resolution and membership dues, will begin on January 1, 2026.
What is expected of businesses during the transition period (June 1 – December 31, 2025)?
During this period, companies are encouraged to:
• Begin adjusting internal practices to align with the Code;
• Join the Office of the Grocery Sector Code of Conduct (OGSCC) and access its educational resources;
• Use the guidance materials and FAQs as they become available;
• Resolve any issues directly with their business partners wherever possible;
• Report challenges or trends to the Office through the member portal.
This preparatory period is intended to build awareness, allow for internal alignment, and identify early implementation issues before full operation begins
Will the Code be enforced during the transition period?
No. Between June 1 and December 31, 2025, the Code will not be actively enforced through formal dispute resolution or public notices of non-compliance.
However, the Office of the Grocery Sector Code of Conduct (OGSCC) may still receive and review issues raised by stakeholders, provide guidance, and work to clarify the Code’s application. This phase is focused on education, alignment, and voluntary preparation.
In some cases, the OGSCC may also follow up directly with businesses to discuss concerns that have been raised through the sector. These follow-ups will be conducted in a spirit of education and collaboration to help ensure all parties understand and prepare to meet the expectations of the Code by January 1, 2026.
What happens on January 1, 2026?
As of January 1, 2026, the Code will be considered fully operational, meaning:
• The Dispute Resolution Management Process (DRMP) will be available, allowing members who are unable to resolve issues bilaterally to submit formal complaints
• All parts of the Code will be expected to be fully implemented by members;
• The Office will begin collecting annual membership dues.”
What should businesses do if they have a dispute or concern before January 1, 2026?
Companies in the grocery sector are always encouraged to resolve issues with each other. If the issue cannot be resolved, a company can submit issue reports to the Office of the Grocery Sector Code of Conduct (OGSCC) during the transition period. While formal dispute resolution processes won’t be implemented until January 1, 2026, the Office will track recurring themes, and identify areas where clarification may be needed once the Code is fully in force.
Is membership in the Office of the Grocery Sector Code of Conduct (OGSCC) required to be covered by the Code?
Yes. Only businesses and associations eligible for membership under the Code (i.e., grocery retailers, suppliers, wholesalers, and primary producers) and who are members in good standing of the OGSCC will be officially covered by the Code. This includes access to the dispute resolution process and protection under the Code’s provisions.
How will the Code be monitored and updated?
The Office of the Grocery Sector Code of Conduct (OGSCC) will monitor the implementation of the Code, track recurring issues, and gather data during the transition. An annual report will be issued starting in 2026, highlighting areas which could include sector trends, systemic challenges, and proposed improvements. These reports may include anonymized case summaries and recommendations for continuous improvement.
How can I stay informed or participate?
• Join the OGSCC
• Subscribe to our monthly newsletter
• Follow us on LinkedIn
• Use the member portal to share feedback
• Contact us at info@canadacode.org with questions
Membership
What will the annual membership dues be for joining the Office of the Grocery Sector Code of Conduct?
The dues structure is as follows:
| Sales Tranche | Annual Membership Dues |
| More than $1 billion | $30,000 |
| More than $500 million up to $1 billion | $20,000 |
| More than $200 million up to $500 million | $7,500 |
| More than $50 million up to $200 million | $3,000 |
| More than $10 million up to $50 million | $500 |
| More than $50,000 to $10 million | $250 |
| Less than $50,000 | $50 |
Sales are defined as ‘annual sales of grocery products in Canada’
Role of the Adjudicator
What is the role of the Adjudicator at the OGSCC?
The Adjudicator provides independent leadership and oversight in support of the Canada Grocery Code. The role includes interpreting the Code, engaging with industry stakeholders, and ensuring that the Code is implemented in a consistent and neutral manner.
Is the Adjudicator part of the industry?
No. The Adjudicator operates independently from grocery retailers, suppliers, and other sector participants. This independence is essential to ensure impartiality in Code-related guidance and dispute oversight.
Does the Adjudicator have enforcement or investigative powers?
No. The Adjudicator does not investigate individual reports or enforce decisions. The focus is on education, interpretation of the Code, and support for the dispute resolution process (once launched in January 2026). However, the Adjudicator may choose to follow up on matters that appear systemic or broadly relevant to the sector.
How does the Adjudicator contribute to Code guidance?
The Adjudicator plays a central role in identifying areas where additional clarity is needed and contributes to the development of FAQs, case studies, and other guidance materials. Reports submitted through the OGSCC’s online portal and direct input from members help shape this work.
Will the Adjudicator be involved in the formal dispute resolution process?
Yes. Once the formal Dispute Resolution Mechanism becomes operational on January 1, 2026, the Adjudicator will oversee its function and help ensure that disputes are managed fairly, efficiently, and in alignment with the principles of the Code. While the specific details of the process are still under development, it is anticipated that the Adjudicator will serve as a final decision-maker in applicable cases and will have the authority to issue public reports on rulings. These reports will support transparency and contribute to broader compliance with the Code. Further guidance on the Adjudicator’s role and the dispute resolution process will be provided as development continues
What makes this role unique?
This is the first role of its kind in Canada’s grocery sector. The Adjudicator is expected to balance neutrality and transparency with a deep understanding of the sector’s dynamics. The aim is to foster trust, accountability, and fairness in how the Code is interpreted and applied.
Can the Adjudicator make public reports?
Yes. The Adjudicator has the authority to issue public reports that identify systemic issues, highlight trends, and flag implementation challenges. These reports are a key tool for promoting transparency, encouraging compliance, and maintaining sector-wide accountability. In some cases, individual businesses may be named, depending on the circumstances. However, any information provided to the OGSCC in confidence will continue to be treated as confidential.
Will public reports name individual businesses?
They may, depending on the circumstances. For example, if a matter proceeds through the formal dispute resolution process and results in a decision or outcome that is relevant to broader sector compliance, the business involved could be named. However, any information provided to the OGSCC in confidence, such as reports submitted through the member portal, will be kept confidential and will never be disclosed in a way that identifies the source.
How do public reports support compliance if the Code is voluntary?
While the Code is not legally binding, public reporting helps ensure that participants are held to account through transparency. Reports from the Adjudicator can:
• Highlight concerns or patterns of non-alignment
• Recognize best practices and positive examples
• Increase reputational pressure to align with the Code
• Inform ongoing education, FAQs, and policy refinement”
