Retailing In India - A Government Policy Perspective

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Retailing In India

A Government Policy Perspective

TABLE OF CONTENTS

. EXECUTIVE SUMMARY 5

2. INTRODUCTION 6

.1 EVOLUTION OF INDIAN RETAIL 7

.2 RETAIL FORMATS IN INDIA 8

.3 THE CHANGING INDIAN CONSUMER 10

.4 ANTICIPATED GROWTH IN THE RETAIL INDUSTRY 11

3. ISSUES IN INDIAN RETAILING 12

2.1 THE PROBLEM OF PRODUCTIVITY 12

2.2 OPERATIONAL PROBLEMS IN INDIAN RETAILING 12

2.3 POOR PRODUCTIVITY IN MODERN FORMATS 13

2.4 INDUSTRY DYNAMICS 16

2.5 EXTERNAL FACTORS AFFECTING PRODUCTIVITY 18

4. INDUSTRY STATUS TO RETAIL 24

3.1 PROBLEMS OF NOT BEING AN INDUSTRY 24

3.2 THE NEED FOR INDUSTRY STATUS 25

3.3 STAKEHOLDER BENEFIT ANALYSIS 26

5. FDI IN INDIA: AN ANALYSIS 30

4.1 GLOBAL TRENDS 30

4.2 INDIA'S SHARE 31

4.3 DIRECTION OF FDI INFLOW INTO INDIA 33

4.4 CAUSES AND REASONS FOR LOW FDI INFLOW INTO INDIA 35

4.5 FDI POLICY RECOMMENDATIONS 41

6. IMPACT OF FDI: THE GLOBAL EXPERIENCE 44

5.1 GLOBAL TRENDS 44

7. FDI IN RETAILING 51

6.1 INTERNATIONALIZATION: THE NEW RETAIL TREND 51

6.2 THE INDIAN RETAILING REGULATIONS 52

6.3 THE INDIAN ADVANTAGE 55

6.4 ENTRY ROUTES OF CURRENT FOREIGN RETAILERS 55

8. FDI IN RETAILING: THE DEBATE 57

7.1 FDI IN INDIAN RETAILING: WHY NOT? 57

7.2 FDI IN INDIAN RETAILING: WHY? 59

7.3 INCENTIVES FOR FDI IN RETAIL 62

7.4 REGULATING FDI IN RETAIL 63

7.5 WHAT SHOULD THE GOVERNMENT DO? 64

7.6 FDI IN RETAIL: AN IMPLEMENTATION FRAMEWORK 65

9. THE CHINESE EXAMPLE 66

8.1 CHINESE POLICY IN RETAILING 66

8.2 RETAIL FDI IMPACT IN CHINA 67

0. RECOMMENDATIONS 71

1. REFERENCES 74

. Executive Summary

This project is a critical analysis of the government policy in the Indian Retailing Sector. The report focuses on two primary issues: The granting of industry status to retail and the permission of FDI in Retailing. Apart from these the report also covers other areas of government policy that affect the growth and development of this industry. The report is focused towards the proposal of a set of policy recommendations to the Indian government that would facilitate the growth of the retailing industry and would also benefit the Indian economy as a whole. The report is based on extensive primary research, in the form of depth interviews with four categories of stakeholders: Retailers, Government Officials, Lobbyists and Real Estate Developers. The secondary research comprised of data collection and consolidation from various books, reports and consulting papers on related topics. The recommendations are developed in most cases on the basis of lessons learnt from policies and their impacts in other developing economies, especially China.

The first section of the report provides an introduction to the Indian scenario. It covers the status of the Indian retailing industry and tracks its growth over the years. We then discuss the various aspects of Indian Retailing that need improvement and analyze the inherent complexities involved in the Indian retail trade sector. Then we analyze the Indian FDI experience, and try to drive some conclusions from the experience we have had in other sectors. We then drive towards developing a comprehensive prescription for strengthening the Indian FDI policy framework.

The second section of the report begins with a summary of the findings of our study on the impact that FDI has had globally. Then we proceed ahead and critically analyze the issue of whether or not FDI should be permitted in retailing. The report highlights all the aspects of the debate. The debate is followed by detailed plan for introducing FDI in Retailing. This is followed by a case study on the Chinese experience and finally, the recommendations.

In broad terms, the primary recommendations of the report are that FDI should be permitted in Indian retailing in a phased manner, and the retailing sector should be granted industry status on a priority basis. Apart from these, the report also suggests several related reforms in areas like labor laws, real estate, bureaucracy, taxation and supply chain regulations.

2. Introduction

"Retailing in India could be as large as $450-500 billion and organized formats could account for a 20-25 per cent share of this."

CII-McKinsey Report "Retailing in India"

F

or the third year in a row, a retailing company has been declared as America's largest publicly traded company. The same retailing company also tops Fortune's list of top 500 Global companies. With annual sales at a whopping $220 billion, Wal-Mart symbolizes the immense potential inherent in the organized retailing industry. Retail, with worldwide sale of US$ 6.6 trillion, is the world's largest private industry.

In India too, the retail industry is large. Retail is the country's largest source of employment after agriculture, has the deepest penetration into rural India, and generates more than 10% of India's GDP. With close to 12 million retail outlets, India has the highest retail outlet density on the world. In spite of this, retail is also India's least evolved industries. In fact, it hasn't even been accorded the status of an industry.

Defining Retail Trade. The retail trade sector comprises establishments engaged in retailing merchandise, generally without transformation, and rendering services incidental to the sale of merchandise. The retailing process is the final step in the distribution of merchandise; retailers are, therefore, organized to sell merchandise in small quantities to the consumers and not for resale.

The Indian Story. For almost half a century, a paternalistic regime of control in India manifested itself in licensing laws that restricted the production of consumer goods and in regulations that limited the size of manufacturing plants. For a long time, the Indian consumer could by any car as long as it was an outdated Ambassador or a Fiat, any toothpaste as long as it was Colgate, any watch as long as it was from HMT, and any radio as long as Phillips produced it. The story is no longer the same.

The past decade has witnessed a tremendous revolution in the Indian Retail scenario. Market liberalization and an increasingly assertive consumer population is now sowing the seeds of a retail transformation that has started bringing in bigger Indian and multinational operators on to the scene. With the advent of these players, the Indian consumer is on his way to become what his counterparts in the more developed countries of the world have been for decades: The King of the market place.

.1 Evolution of Indian Retail

The concept of retailing in India dates back to ancient times when it was mainly in the form of weekly markets and the village fairs (Melas). Changing socio-economic patterns and consumption levels shifted the focus of retailing to mainly convenience stores (mom and pop stores) for daily needs with few prominent retailers on the high street in each city. While talking of Indian Retail, a special mention must be made of the role played by the PDS outlets, co-operatives and Khadi stores. The Indian government's PDS Outlet chain is amongst the largest retail chains in the world, but hardly does it find a mention anywhere in the Retailing literature.

Big commercial plazas with prominent nationwide and big city-based retailers were the next step. However, these complexes had nothing much to offer other than the all-important location. Shops offering wide variety of goods and services were merely clubbed together without any stress on providing any value-added services to customers. Shoppers had to cope up with lack of parking space, absence of toilets and improper maintenance observed in such places.

With the opening up of the economy in the early nineties, India saw the entry of the big international brands that opened their exclusive stores. Reebok, Nike, Lacoste, United Colors of Benetton were a few of the first retailers to set up their shops in India. This marked the beginning of the retail revolution in India.

Over the past decade, corporates, both Indian and Multinational, have started recognizing the immense potential that the Indian retail sector provides. But, due to government restrictions, most foreign players still haven't been able to enter the Indian market. Amongst the Indian corporates, there have been three categories of Indian businesses that have ventured into retailing as their business extension

a) Real Estate Developers

b) Corporate Houses

c) Manufacturers/Exporters

Due to scarcity of space and stringent provisions of rent control act, it was not possible for many players to start their operations from main markets or high street. This explains the natural progression of developers like Raheja's to kick start their retail venture Shopper's Stop, as they had understanding of real estate, one of the most critical component of the business.

Retail also presented an excellent opportunity for corporate houses like Tata, RPG, and ITC to profitably invest their excess funds as well as extend their business lines or brand reach. RPG's tie up with Dairy Farm International was the first Joint Venture in organized retailing in the country. It led to the establishment of specialty retail stores like Foodworld in grocery, Health and Glow in Pharmacy and Musicworld in music. The manufacturers and exporters also saw a potential for forward and horizontal integration of their respective business lines. This saw the emergence of the brands like Pantaloon, Provogue and Planet Fashion.

The past 6-7 years have been especially exciting for the Indian retail industry. Sweeping changes have affected both the supply and the demand fronts of the market. On the demand front, customer spending has been on the rise and brand consciousness has also increased substantially. Consumers have started demanding a better shopping experience as global media exposes them to different lifestyles. Consumer research shows that households in metropolitan cities are gravitating towards supermarkets and other modern retail channels.

On the supply front, a number of organized retailers have entered the trade in the last 5 years. These include large Indian business groups such as the Tatas, RPG, the Rahejas and Piramal, as well as MNC brands in apparel, footwear and durables. The entry into retailing by MNC brands has driven the growth of specialty chains and upgraded the standards of existing multi-brand outlets. South India - most notably Chennai, and, to a lesser extent, Bangalore and Hyderabad - has emerged as a centre of organized retailing. In fact in Chennai, nearly 20 per cent of food sales now flow through supermarkets and an equal share of "durables" is sold through specialty chains such as Viveks. Until now, competition in the sector has been largely local with large global retailers such as Carrefour and Wal-Mart absent.

.2 Retail Formats in India

Retailing in India can be classified under two heads: Organized and unorganized retailers. Unorganized retail is the dominant mode of retailing in the country with organized retailing contributing to roughly around 2% of the whole market.

The unorganized retail formats are typically mom-and-pop stores, with very basic offerings, fixed process, zero usage of technology, and little or no ambience. These are highly competitive outlets, drawing on free land (unregistered kiosks or traditional property), unpaid/cheap labor (family members or village children paid below minimum wages) and zero taxes. Many of them also leverage the low or no cost of family labor to provide services like home delivery that would be uneconomic for any organized retailer.

Traditional formats such as rural counter stores, kiosks, street markets and vendors have low productivity potential because of their unorganized systems and processes. These formats have emerged largely due to the absence of alternative employment and typically require employees with very low skills. These formats can, and do, serve to absorb agricultural1 labor. They are, however, very important as they account for two -thirds of the sector's output. There are four main transition formats in India:

Rural counter stores: Indian retail is dominated by family-run counter (kirana) stores that stock a range of branded/unbranded items. Rural counter stores are multi-purpose stores that sell items of essential need, both food and non-food. These stores are often located in rural homes and serve to supplement the family's income from agriculture.

Kiosks: These small, pavement stalls stock a limited range of food and beverage items. Kiosks are convenient for impulse or emergency purchases, and are located in busy commercial and market areas.

Street markets: Held at fixed centers in urban and rural areas on a daily or weekly basis, street markets comprise multiple stalls (often more than 200) selling a wide range of food and non-food products. These markets compete on both variety and price, and also sell counterfeit goods and smuggled items. Street markets have traditionally acted as a place for social gathering. The bazaars in Poland and open-air wholesale markets in Russia are the foreign equivalents of this format.

Street vendors: These are mobile retailers, providing perishable food items (milk, eggs, vegetables and fruit) at the customer's doorstep. While their prices are higher than alternative retail channels, they compete on convenience.

Modern formats, such as supermarkets, department stores and specialty chains, have begun to crop up over the past few years. These formats have high productivity potential and are found in most developed and many developing economies.

Supermarkets/Hypermarkets: These are large (20,000 square feet plus) self-service stores selling a variety of products at discounted prices. The best practice chains in this format are Carrefour (France), Wal-Mart (US), Kroger (US), Tesco (UK) and Metro (Germany). Supermarkets tend to be located in key residential markets and malls, and offer competitive prices due to economies of scale in logistics and purchasing. This format is new to India and only three supermarket chains of note exist - Foodworld, Nilgiri's and Subhiksha. Indian supermarkets are smaller than those in other countries, with fewer cash registers and sizes that are at least a fifth of the global players' selling area (3,000-4,000 sq ft versus 20,000-25,000 sq ft).

Department stores: These large stores primarily retail non-food items such as apparel, footwear and household products. They stock multiple brands across product categories, though some of them focus on their own store label (e.g., Marks & Spencer's St. Michael). Department stores are found on high streets and as anchors of shopping malls. Several local department store chains have opened shop in India in the past 5 years (e.g., Shoppers Stop, Westside and Ebony).

Specialty chains: These retail outlets focus on a particular brand or product category, usually non-food items, and are located on high streets and in shopping malls. While most specialty chains compete on service, a segment called "category killers" offers price as an advantage (Toys 'R' Us is a good example of a category killer). Examples of specialty chains include Gap, Levi's and Benetton. This format has seen the highest levels of adoption in India, with several chains establishing a strong presence, typically through franchising, e.g., Lacoste and Benetton.

Urban counter stores: These small family-run stores dominate food and non-food retailing and are found in both residential and commercial markets in towns and cities. The food stores stock a wide range of branded and unbranded food items. They typically have a loyal clientele bound to them by personal relationships and the convenience of credit and home delivery. Non-food counter stores typically stock multiple local brands. Even though urban counter stores have existed for decades, we have included them in the category of modern formats given that they have more organized systems and processes (than kiosks) and provide stable employment.

.3 The Changing Indian Consumer

There is distinct evidence to suggest that the Indian Consumer, irrespective of her socio-economic origin, is on a self-appeasement mission. Greed is good and she wants more of the best that life has to offer. As she traverses this path, we find that she defines fulfillment "materialistically and emotionally" no different from her more monied counterpart. SEC-based classifications notwithstanding, the Indian Consumer is out to seek pleasure and lifestyle. 177 million households in India are at various stages of defining their "self" from the "common". The asset acquisition rate of the average Indian consumer has been on the rise ever since India opened its markets in 1991, and is expected to grow at an even greater rate.

Also, the Indian consumer is more discerning and demanding than ever, especially due to the increased levels of exposure to international lifestyles and better levels of education. Shopping is increasingly becoming a family experience, showing a clear shift from the need-based shopping trends of the pre-liberalization India. Also, a whole segment of post-liberalization children, constituted by a whopping 100 million 17-21 year olds is coming of age, and the segment is spending like never before.

One noticeable trend in this regard has been the rise in the spending capacity of the Indian middle class. The Euromonitor retail survey estimates that there has been close to a 20.9% growth in the real disposable income of the Indian Middle Class in the four-year period of 1999-2003. Complementing this growth in income is the rise in the middle and high-income population itself. This demographic segment, which is widely believed to be a main driver of the global retailing industry, has been rapidly growing at a pace of 10% per annum over the past decade.

Also of significant importance is the rise in the affordability of the Indian consumer. The Indian consumer's affordability has been facilitated by a host of other related factors like falling interest rates and easier availability of consumer credit. Also, the increasingly competitive nature of the Indian market in categories like FMCG and consumer durables has increased consumer spending, by ensuring availability of a greater variety and quality of products at never-before price points.

This change in consumer spending patterns has turned out to be a major driver of the rapid retail revolution that we have been witnessing over the past few years.

.4 Anticipated Growth in The Retail Industry

The retailing phenomenon that is currently sweeping across the country is here to stay. Retailing is not a standalone industry, and hence, the growth in this sector is closely linked to a host of other macro and micro economic as well as cultural factors.

Growth in Indian Retailing is likely to rest on the following key determinants:

a) Government Policy

b) Infrastructure development

c) GDP growth

d) The employment scenario

e) Changes in the retailing supply chain

The CII-McKinsey report "Retailing in India: The Emerging Revolution", makes a conservative estimate that the retailing industry is likely to grow to around $350 billion by 2010 and that organized retail would account for 10-15% of this market. This estimate is based on the fact that incomes and consumer demand are likely to grow at a faster pace as the economy performs well, lifestyles continue to change and better product and shopping options would become available. On the regulations front also, it is likely that several important changes will take place, e.g. foreign investment will be permitted into the sector bringing in global competitors, other regulatory constraints impacting the sector will be relaxed, etc. This transition is likely to be gradual.

Currently, the Indian retail sector is worth roughly $292 Billion, and roughly 2% of this is classified as organized retail. Of the 12 million stores in India almost 95% are less than 500 sq. ft in area. The retailing sector in India is expected to grow at roughly 8.3% during the next 5 years, with organized retailing growing at rates anywhere between 24 to 49%.

3. Issues in Indian Retailing

"Supply chain wastage in India, in fruits and vegetables alone, is estimated at RS 50,000 crore, that is the amount of fruits and vegetables which is wasted, (it falls off the truck, goes bad because of unhygienic conditions etc.). If we fix that, we can actually distribute, free fruits and vegetables to every person in this country."

Raghu Pillai, CEO, RPG-Retail

Indian retailing has come a long way from the scarcity driven days of the past. Availability of products is no longer a major issue in India. The Indian retailing system may be grossly inefficient when compared to global benchmarks, but it should be noted here that we have a system in place that ensures that products reach every nook and corner of this country. Considering the geographic and cultural diversity and complexity of India that is no mean achievement. But yet, it is now time for India to move onto the next phase of evolution. And for that we have to analyze what exactly is the problem with Indian retailing.

2.1 The Problem of Productivity

The McKinsey retail study reports that the Indian Retail Productivity is at around 6% of the benchmark US retail productivity. While most Indian retailers and industry experts disagree with this figure, the fact remains that Indian Retailing is grossly unproductive especially when compared with international productivity standards. There are a host of strategic, operational and external factors affecting the Indian retail productivity. And retailing productivity is a very important factor in determining the economy-wide productivity of a country. For example, retail trade constituted nearly one-fourth of the extra-ordinary productivity jump experienced by the USA towards the end of the last millennium.

Productivity is a key factor in retailing also because of the fact that retailing productivity is a key indicator of the health of the entire supply chain. A productive retailing industry is indicative of a strong and efficient supply chain backing it. On the contrary, a poor productivity performance, as is the case with India, indicates operational inefficiencies in all the related backend industries, and is an issue of grave concern.

2.2 Operational Problems in Indian Retailing

A large productivity gap exists in retail - 95 per cent in the case of food retailing and 91 per cent for non-food retail. This is driven by two factors - a format mix that is heavily skewed towards transition formats, and poor operational performance (productivity) of modern formats.

Unfavorable format mix

Modern retail formats such as supermarkets, department stores and specialty chains account for only 2 per cent of retail output. This leads to lower overall/sector productivity, as counter stores are much less productive.

Supermarkets and specialty chains are more productive than counter stores for two reasons - they leverage their volumes to drive costs down and possess superior skills. The larger volumes or scale of modern retailers make it possible for them to bargain for lower unit costs not only while procuring, but also while distributing and marketing. In addition, supermarkets and specialty stores possess strong skills supported by technology in the front end (i.e., merchandising and marketing) as well as in the back end (i.e., managing the supply chain and inventory).

A key reason why supermarkets have not grown share rapidly, especially in food retail, is the underdeveloped nature of upstream industries. The relatively higher price proposition of supermarkets versus counter stores will be a key determinant of the sector's evolution. Currently, supermarkets are not able to capture the benefits of larger scale due to a fragmented supply chain and a sub-scale processing sector. They are also penalized by the current operating environment, which favors counter stores (e.g., tax and labor laws). Consequently, prices in Indian supermarkets are slightly higher than those of counter stores - a quick survey in Chennai indicated that supermarkets were 2-3 per cent more expensive for a set of branded FMCG products than some of the popular discount based kirana/wholesale stores- while in other countries, supermarkets are about 10 per cent cheaper than counter stores. As large food retailers in India begin passing on the benefits of better purchasing to customers in the form of lower prices, they will be able to capture share more rapidly.

2.3 Poor productivity in modern formats

Supermarkets in India experience a productivity penalty due to:

) The fragmented and inefficient supply chain that raises the cost of procurement;

2) The need to maintain competitive price levels vis-à-vis cheaper counter stores.

This leads to a lower level of value add when compared with firms such as Wal-Mart, which source directly from processors. The supply chain for food in India (for both branded and unbranded goods) has two to three more intermediaries on an average, compared with similar chains in more developed markets. This is because of market regulations (constraints on food grain movement across states, inability to purchase directly from farmers, etc.) that slow down the growth of large processors and the fragmented nature of retail.

The following are some of the specific problems associated with a modern format retail store in India.

. Organization of functions and tasks (OFT): Most Indian retailers can double their productivity by improving the organization of tasks and rationalizing the workforce. The average retailer in India has many more employees than an US retailer due to the limited use of multi-tasking and part-time help to meet peak hour needs as well as non-standard layouts that reduce efficiency. In contrast, India's best practice supermarket ensures that its sales personnel play multi-faceted roles and undergo in-house training prior to joining. A quarter of the sales staff works only part time, putting in 4-6 hours a day during peak shopping hours. This supermarket also has a scientifically designed layout that they try to adhere across their chains. Consequently, this chain has a much better performance than its other competitors.

2. Merchandising and marketing: Poor merchandising and marketing skills and absence of private labels among Indian retail players have led to lower sales per store. Stores in India lack the skills to better align stocking patterns and promotions to consumer needs. Merchandising and marketing issues in Indian retailing pose problems at several levels and can be broadly categorized into the following categories

. Skills: Indian organized retailing industry does not focus on systematically understanding the purchasing patterns of consumers to determine the products to stock and the targeted promotions to undertake. The same applies to factors such as store layouts and ambience. A couple of players have begun to address this issue by defining clear strategies for pricing as well as building customer traffic and loyalty. For instance, a Chennai-based supermarket chain offers a price discount of 8-9 per cent on an average and seeks to keep its regular customers informed of good buys through fortnightly newsletters.

2. Poor Competitive Scenario: Indian retailers have not faced the sort of competitive pressure that would force them to raise their standards. In other countries, to survive competition from supermarkets, counter stores have opted to focus on product or service niches. For instance, in France, gourmet cheese stores and farm-fresh vegetable stores thrive in the vicinity of supermarkets. In New York, Korean grocery stores stay open all 24 hours to provide added convenience to customers. In India, we see early signs in Chennai, where competition from supermarkets is the highest (17 per cent of sales) and larger counter stores have begun stocking imported or non-food items to differentiate their merchandise from supermarkets.

3. Private label/product mix: A second aspect of merchandising and marketing is the share of revenues from private labels. Supermarket chains in the US enjoy a larger share of sales from private/store labels that earn them higher margins. This factor, plus a product and sales mix skewed towards higher value items, earns them 3-4 per cent higher margins. Building a strong private label should be a key priority for supermarkets in India. Groceries, fresh fruit and vegetables and ready-to-eat items are the focus segments for this, and a couple of players are planning to set up kitchens to cater to this demand.

4. Scale: Retailers in India currently have a low scale of operations both in terms of number of stores and size per store, and this leads to a productivity penalty. The larger supermarket chains in India have 30-40 stores compared to the 1,000-store average observed in the US. Supermarkets in the US are also much larger than their counterparts in India. Higher scale makes it possible for retailers to use fixed labor (such as purchasing, marketing and administration) more expediently as well as use their bargaining power to buy cheaper and rationalize logistics upstream.

5. Supplier relations: Sourcing from multiple sub-scale suppliers is a key issue for supermarkets in India. Stores can increase productivity by buying more strategically and benefit from the simplification of the supply chain brought about by the entry of large retailers and food processors. Buying in bulk and availing of cash discounts can help improve margins.

6. Lack of strategic purchasing: Large food retailers in India can lower costs by rationalizing the vendor base, and undertaking strategic collaborations with processors and FMCG companies. Indian organized retail players procure from a large number of vendors, across regions. For instance, the best practice player has 1,600-1,700 vendors - over 400 per region. As a consequence, a retailer needs a large sourcing and quality control team, which raises the costs of procurement. Focusing on fewer national suppliers wherever possible can reduce the sourcing complexity, which will also help meet the cost/quality needs. McDonald's in India is a good example of best practice in supply chain management. The company works with one carefully selected vendor per item, sets quality and cost targets and helps the vendor upgrade operations systematically.

Supermarkets can also lower costs or increase value add by entering into strategic deals with upstream players. These initiatives include collaborating with food processors in purchasing as well as manufacturing private label goods, and engineering strategic relationships with branded goods companies aimed at increasing sales and reducing distribution costs (benefit shared by both parties). This is already beginning to happen. For instance, a supermarket chain purchases wheat along with an atta company to lower costs, and has succeeded in entering marketing/ promotional deals with several branded goods players.
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7. Limited adoption of best practices by upstream players: Food processors in India are typically small and unorganized. The business systems of these processors as well as of the large FMCG companies are not configured to meet the needs of large retailers. This imposes a penalty on retailers, adding costs and forcing them to engage in additional non-core activities. For instance, most local processors as well as some national and multinational food manufacturers do not bar code their products. As this is essential for supermarkets, which use scanning equipment for billing, it becomes necessary for the retailers to ...

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