Does Food and Grocery Code of Conduct (now mandatory) apply to retail trade businesses?
A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.
Short answer: Only if
Only if you are a large grocery retailer or supply one. Being in this industry makes the obligation worth checking (Industry: Retail trade), but the trigger is a fact the industry alone does not settle.
The obligation in brief
Food and Grocery Code of Conduct (now mandatory). Food and Grocery Code of Conduct mandatory from April 2025 (was voluntary). Applies to Coles, Woolworths, Aldi, Metcash (above turnover thresholds).
Trigger: Mandatory commencement April 2025.
Why retail trade get a different answer
Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 32 of those industries the answer for "Food and Grocery Code of Conduct (now mandatory)" is no. Retail trade is one of the 3 where the answer is different: only if.
The deciding fact for retail trade businesses: Industry: Retail trade; applies only if you are a large grocery retailer or supply one.
About the industry: Retailers covered by the General Retail Industry Award and ACL product safety.
Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires a trigger outside this questionnaire).
Answer by business structure and size
Each cell is the engine's outcome for a business in retail trade with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.
| Structure | No employees | 1–5 employees | 6–19 employees | 20–99 employees | 100–499 employees | 500+ employees |
|---|---|---|---|---|---|---|
| Sole trader | Check | Check | Check | Check | Check | Check |
| Partnership | Check | Check | Check | Check | Check | Check |
| Trust | Check | Check | Check | Check | Check | Check |
| Pty Ltd company | Check | Check | Check | Check | Check | Check |
| Public company | Check | Check | Check | Check | Check | Check |
| Not-for-profit (unregistered) | Check | Check | Check | Check | Check | Check |
| Registered charity | Check | Check | Check | Check | Check | Check |
| Super fund | Check | Check | Check | Check | Check | Check |
| Foreign company | Check | Check | Check | Check | Check | Check |
What the obligation requires
- When due
- Continuous.
- Evidence to keep
- Code-compliant supplier agreements; dispute resolution records; ACCC + Code Reviewer engagement.
- Maximum penalty
- Civil penalties up to ~$10M for serious code breaches
- Regulator
- ACCC
- Jurisdiction
- Commonwealth (national)
Other obligations where retail trade differ from the norm
- Franchising Code of Conduct (mandatory industry code): Only if
- Button + coin battery safety standard (mandatory): Only if
- Comply with Heavy Vehicle Chain of Responsibility (CoR): Only if
- Comply with mandatory product safety standards + bans (ACL): Yes
- Register security interests on the PPSR: Only if
- Comply with Plain English Allergen Labelling (PEAL): Only if
- All 16 answers for retail trade
Other industries with a non-default answer
Questions
- Does Food and Grocery Code of Conduct (now mandatory) apply to retail trade businesses?
- Only if you are a large grocery retailer or supply one. Being in this industry makes the obligation worth checking (Industry: Retail trade), but the trigger is a fact the industry alone does not settle.
- Is the answer the same for every industry?
- No. For 32 of the 35 industries Rules Mate maps, the answer is no. Retail trade is one of 3 industries with a different answer.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.