Most coverage of the Canada Grocery Code treats it as a single milestone: the Code launched, the major grocers joined, and the file was finished. For suppliers, trade associations representing food and consumer product companies, and the government relations teams advising them, that framing misses the details that matter in practice. Those details include which companies are formal members of the Office of the Grocery Sector Code of Conduct (OGSCC), whether both sides of a commercial relationship can use the dispute process, and what the Office’s guidance since launch says about applying particular provisions. Gnowit’s legislative and regulatory monitoring platform is built to follow that level of detail, and this is a breakdown of where the Code actually stands.
Where the Code Came From
The Code didn’t begin with legislation. It began in 2020, when food producers, processors and independent grocers raised concerns about retailer fees and commercial practices. In November of that year, federal, provincial and territorial agriculture ministers set up a working process to examine the issue. In July 2021, ministers called on industry to lead a collaborative effort to develop provisions and guidelines aimed at greater transparency, predictability and fair dealing. Years of negotiation among grocers, suppliers, wholesalers and primary producers followed, and the OGSCC was established to govern the result.
The Code is voluntary and industry-led. It is not federal or provincial legislation. It sets out principles around fair dealing, reciprocal trust and informed business decisions, backed by a governance structure and an independent dispute resolution process rather than statutory penalties. That distinction matters for anyone tracking it. This isn’t a bill moving through Parliament or a provincial legislature. It’s an industry governance body issuing its own rules, membership requirements and guidance on its own schedule.
Fully Operational as of January 1, 2026
The Code became fully implemented on January 1, 2026, the same day the Dispute Resolution Management Process (DRMP) became operational. The five major national grocery retailers had formally registered by then: Costco Wholesale Canada, Empire Company, Loblaw, Metro and Walmart Canada. At launch they joined more than 150 other OGSCC members.
Membership is the detail that changes what a commercial relationship looks like. The Code applies only to OGSCC members in good standing, and a retailer that hasn’t joined isn’t covered by its provisions or its dispute process, however the industry talks about the Code in general terms. Tracking who is actually a member, and not just who has publicly signalled an intention to join, gives you an accurate picture of your commercial exposure instead of a headline version of it.
What the Code Covers, and What It Leaves Out
The Code covers food categories such as bakery, deli, meat and seafood, produce, centre-store grocery, frozen and dairy products. It also reaches selected non-food categories, including household products, paper products and pet food. Pharmaceutical and over-the-counter products are excluded. If a participating retailer operates pharmacies, the Code applies only to grocery products sold through them that already fall within its defined product scope. Scoping details like this rarely appear in general coverage, but they matter to any supplier selling across more than one retail channel.
How the Dispute Process Works
The formal DRMP is available only when both parties were OGSCC members at the time of the incident. A company that joins after a dispute arises doesn’t get retroactive access.
Before applying, parties must exhaust the internal dispute and escalation steps in their agreement. If the agreement doesn’t set out a process, the matter goes first to the designated representative and then to senior management. An application generally has to be submitted within six months of the alleged breach, or within one month after internal resolution efforts fail, whichever is later.
Mediation is optional, confidential and non-binding. If it is skipped or doesn’t resolve the matter, the dispute can move to adjudication. An adjudication decision isn’t legally binding, but a finding of breach results in a public Notice of Non-Compliance naming the member and the provision involved.
The Guidance Few People Are Watching
Since full implementation, the OGSCC has published guidance clarifying how members are expected to understand and apply particular provisions. In May 2026, it released guidance on unilateral amendments permitted by agreement, addressing section 1.4 of the Code. Its guidance on click-to-accept practices and agreement formation, which deals with standardized digital processes used to form or amend agreements, was updated in July.
The Office also released its first public report on June 16, 2026, covering January 1 through May 31. It recorded nine submissions through its confidential Issue Centre. The recurring concerns were unilateral changes to commercial arrangements, notice periods, disputed deductions, administrative fees and good-faith negotiations.
This is the easiest part of the file to miss. A launch is a single event, while guidance, membership updates and periodic reports keep coming, and they get buried under general grocery news if nobody is watching the Office’s own publications. The Sources page shows the kinds of government and agency publications Gnowit follows.
A Short Checklist Before You Assume Your Monitoring Has This Covered
- Are you tracking which retailers and suppliers are actually OGSCC members, not just which ones have publicly committed to the Code?
- Do you have automated legislative alerts set up to catch guidance as it’s published, instead of finding out about a clarification after a dispute has surfaced?
- Does your monitoring treat the Grocery Code as its own topic, or does it get lumped into a general agri-food or retail category?
- Are you watching the Office’s periodic reports for recurring commercial concerns, implementation trends and areas likely to receive more guidance?
Talk to Gnowit About Your Specific Files
The fastest way to know whether your current monitoring covers the Grocery Code is to see it configured against the topics your organization is responsible for, not a generic overview. Book a short conversation with our team to walk through your setup.
Book a 30-minute conversation with Shahzad Khan
Frequently Asked Questions
Does Gnowit track updates from the Office of the Grocery Sector Code of Conduct specifically, or only broader grocery industry news?
Gnowit follows OGSCC publications, including guidance documents and periodic reports, alongside federal, provincial and Gazette sources in one platform, so Code-specific developments don’t get buried under general industry coverage.
Can I set alerts just for Grocery Code developments?
Yes. Alerts follow the topics and keywords your team selects, so you can follow Grocery Code activity on its own instead of the whole industry, and choose who on your team receives each one.
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