ICSA calls on the government to recognize that retailers are partners, not adversaries.
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Independent convenience stores are among the most heavily regulated small businesses in Canada. We sell products governed by federal statute, provincial licensing regimes, and municipal bylaws all at once, and we accept that. Age-restricted products require serious rules, and our members have built their businesses around following them.
What we cannot accept is regulation made without evidence, without consultation, and without any apparent thought given to the consequences. Too often, rules written to address a legitimate public concern land squarely on the licensed retailers who were never the problem, while the actual problem moves somewhere the government cannot see it. The result is a predictable pattern: independents lose revenue, consumers lose access, and the unregulated market grows.
The clearest example is the August 2024 decision to ban legal nicotine pouches from our shelves. Using ministerial authority, the government restricted an approved smoking cessation product to sale from behind a pharmacy counter without the evidence, consultation, or scrutiny that a normal regulatory process would require.
No evidence was ever produced showing that convenience stores were the source of youth access. Our stores were already ID-checking every customer for these products. The government simultaneously trusted us to sell cigarettes, which are vastly more harmful, while deciding we could not be trusted with a product designed to help people quit them.
Two years later, the outcome is exactly what our industry predicted. Unauthorized pouches in fruit flavours and doses far above the legal limit are widely available from sellers who check nothing. Adults in rural communities with no nearby pharmacy lost access entirely.
The burden of compliance does not fall evenly. According to CFIB, Canadian businesses spent $51.5 billion and 735 million hours on regulatory compliance in 2024, and roughly 35% of that was red tape that could be eliminated without any loss to public health or safety.
The disparity by business size is stark. Firms with fewer than five employees spent $10,208 per employee on compliance. Firms with 100 or more employees spent $1,374. A national chain has a compliance department. An independent owner has themselves, usually after closing, usually unpaid.
This is why new rules that sound modest in a press release are not modest on the ground. A signage requirement, a new reporting form, a licensing renewal, a changed display rule: each one is absorbed easily by a corporate chain and painfully by an owner-operator working sixty hours a week behind their own counter.
Ontario's decision to allow beer, wine, cider and ready-to-drink cocktails in convenience stores is proof that the alternative is viable. Thousands of independent stores took on a new age-restricted category and handled it the way we have always handled age-restricted categories: with ID checks, trained staff, and full tax remittance.
There is an alternative path to endlessly layering new restrictions on hardworking local store owners. In this path, adults get convenient access to legal products, the sale happens in a channel that governments can see and tax, and public safety benefits from fewer contraband products and reduced revenue to criminal groups. A licensed retailer with a major investment at stake is a far more reliable partner than an anonymous website.
Require meaningful consultation with independent retailers before any regulation affecting our stores, and reserve ministerial orders for genuine emergencies.
Require that restrictions on legal products be supported by evidence that the restricted channel is actually the source of the harm.
Apply a small business lens to retail regulation, measuring the compliance cost per store before a rule is adopted, not after.
Harmonize federal, provincial, and municipal requirements wherever possible.
Return authorized nicotine replacement products to licensed convenience stores under strict age verification.
Recognize that licensed retail is the regulated, taxed, ID-checking channel that policy should be steering consumers toward.
