MOH annual return process hampers industry’s ability to respond

In principle, VIANZ supports the government’s gathering of sales information from industry. But we believe that the regulatory requirement, as currently drafted, is onerous and resource-intensive, and is hampering industry’s ability to respond in a timely fashion.

The annual returns form requires industry to report on numerous product lines and variants, accommodate frequent changes due to new regulations, and provide extensive detail for each product. Additionally, businesses must submit a separate return for each individual entity or store.

It is also our view the data sought by the government results in an inflated valuation of the market. By recording both the sales from manufacturers and distributors, as well as the sales from retailers, the same products are being counted twice. Furthermore, tracking the Recommended Retail Price (RRP) doesn't reflect the actual sale price of the products. As a result, these factors significantly overestimate the true size of the market.

If the purpose of the annual return data is to provide the government with detailed data to help regulate and monitor the industry, then accuracy is critical.

To increase compliance MOH needs to remove unnecessary complexity. VIANZ recommends simplifying the process to capture the total sales of each individual retail store and distributor or manufacturer. This will give government a more accurate picture of the size of the market across the key channels and removes the risks of market inflation as detailed above.