Loyalty Schemes and Member-only Price Promotions
Executive Summary
Many large retailers operate a loyalty scheme and are increasingly likely to offer member-only pricing promotions. Our analysis of pricing data for four large retailers, two supermarkets and two health and beauty retailers, finds they can have thousands of products on member-price promotions at any one time and that these products have prices that are on average at least 20% lower than the price for non-members. The frequency of these offers and the size of the price differences has brought scrutiny over the extent to which non-member prices are representative of typical selling prices and the eligibility criteria of the schemes.
During loyalty promotions, members are likely to use the non-member price as a reference price when making a purchasing decision. However, while the Consumer Protection Regulations apply, there is no regulatory guidance for traders on how a non-member price should be set. This is unlike other reference prices for which guidance does exist, and it creates uncertainty about what non-member prices should represent. In a survey of consumers, we found no clear understanding of what non-member prices represent. 29% told us they think these non-member prices are the same or lower than usual prices, but 55% said they believed these prices to be higher than the usual selling price, indicating a large degree of scepticism.
Using a sample of products that had member-only promotions on a snapshot day, we analysed daily price data to examine whether non-member prices are representative of usual selling prices. We found that the majority of non-member prices appear to be at or below a typical selling price. However, there were a minority of products at each retailer, ranging from 5% to 16%, for which the selling price had been lower than the non-member price for more than half the time in the previous six months. This is a sufficiently high proportion that a consumer cannot confidently assume a non-member price represents a usual selling price.
In some cases, lower historic prices may reflect the product being subject to recent cost inflation, and so we also examined the selling prices immediately before and after the member price promotion. We found that, for some retailers, the price available to all customers immediately before or after the loyalty promotion was often lower than the non-member price. This tended to be when there were successive promotions of different types, so that loyalty promotions directly follow ‘was/now’ promotions or vice versa. The setting of reference prices has particular challenges when different types of promotion are used in this way.
Overall, we believe the absence of guidance for retailers on how to use member-price promotions is problematic given the prevalence of such offers. We believe regulators should provide guidance on the determination of non-member prices in general and specifically the interaction between loyalty price promotions and offer discounts, and we welcome the Competition and Market Authority’s stated intention to do the latter.
Finally, the size of the discounts available to members increases the importance of scheme accessibility. Most retailers’ loyalty schemes have similar eligibility requirements but they may differ according to age restrictions, the need to provide an address and the ability to sign up offline. Which? believes that retailers should do as much as possible to ensure that customers are not unfairly excluded from schemes. For example, by lowering the age limit wherever possible and by ensuring it is possible to sign up to schemes in store and without an email address.
Introduction
Loyalty pricing schemes are a common feature of UK retail markets. In 2019, Tesco introduced member pricing to their stores by restricting some price promotions to their Clubcard members. Five years later, most of the largest UK supermarket retailers have a loyalty pricing scheme and they have been taken up by retailers in other sectors including health and beauty, DIY and fashion retailers.
These loyalty or member-price promotions are usually promoted with two prices, one for loyalty card members and another higher price for non-members, and the difference between these price points can be large. Previous Which? analysis of grocery prices has found the price of a basket of commonly bought groceries was 5.5% less for Tesco Clubcard members and 7.6% for Sainsbury’s Nectar members.
However, the magnitude of the price differences has brought scrutiny of the schemes with regard to customer eligibility and to what extent non-member prices are representative of typical selling prices. The latter matters because if customers with loyalty cards use non-member prices as a reference price and interpret them as genuine selling prices then they will influence purchasing behaviour. Reference prices have an anchoring effect, influencing how consumers perceive a product’s value. A larger difference between reference and discounted prices will increase the perceived gain from purchasing the product, and a larger perceived gain could also reduce a consumer’s willingness to search. If non-member prices are not typical selling prices then this may mislead customers.
In this report we investigate whether there may be harm from the use of non-member prices that are not genuine selling prices using a mixed methods approach. First, we conduct a survey of customers to explore their use of loyalty schemes and the assumptions they hold about non-member prices, in order to determine whether they use them as reference prices. Second, we analyse a large panel of price data for a sample of products with a loyalty price discount in order to understand the extent to which non-member prices represent usual selling prices. These samples were taken from two supermarket retailers and two health and beauty retailers. Our work complements that currently being undertaken by the Competition and Markets Authority (CMA) who are also examining loyalty pricing, albeit with an earlier dataset and for groceries only.
Survey Findings
A nationally representative survey was conducted online via Delta between 6th and 8th June 2024 with around 2,000 participants. The survey has two purposes. First, it explores customer use of loyalty schemes as publicly available data about this is incomplete. Second, we use it to understand what interpretation customers have of non-member prices.
Consumer use of loyalty schemes
Tesco has the highest reach with nearly three-quarters (74%) of our survey sample having a Clubcard, see Figure 1, which largely accords with Tesco estimating that 22 million households hold a Clubcard. Roughly half of respondents have a Sainsbury’s Nectar card and/or a Boots Advantage card, 50% and 47% respectively.
Figure 1: Scheme membership - Tesco has the highest reach
Source: online survey conducted by Delta with 1,970 participants weighted to be nationally representative. Question: Which, if any, of the following membership/loyalty cards do you currently have. Asked to participants who had shopped online or in-store in the last 6 months.
It is common for people to have memberships with multiple retailers, see Figure 2. The median consumer was a member of three of the eleven loyalty schemes we asked them about. More than 40% or people hold more than four memberships and only 1 in 20 individuals (5%) reported not being a member of any scheme we listed.
Figure 2: Most individuals hold multiple loyalty cards
Source: online survey conducted by Delta with 1,970 participants weighted to be nationally representative. Question: Which, if any, of the following membership/loyalty cards do you currently have. Asked participants who had shopped online or in-store in the last 6 months.
These memberships are well used, with a majority of consumers (55%) in our survey reporting having bought a product with a loyalty discount in the past six months. This is higher than any other promotion, such as ‘was/now’ offers, ‘reduced to clear’ or multibuys. Membership pricing has led to consumers shopping more often at the stores they are members of. More than a third (38%) of people reported shopping more often at retailers with whom they are members since membership pricing was introduced, see Figure 3.
Figure 3: More than a third of members have become more loyal since membership pricing started
Source: online survey conducted by Delta with 1,794 participants weighted to be nationally representative. Question: Since member-only prices have been introduced, do you think you shop more, same or less at the retailers you are a member of? Asked to participants with membership cards.
Overall, these findings show that loyalty schemes have become a fundamental feature of shopping at major retailers and that membership pricing has a competitive effect. However, if all retailers use membership pricing this competitive effect is likely to be reduced and non-members lose out by not being able to access discounts.
Consumer attitudes to member promotions
To understand whether non-member prices might influence the purchasing decisions of members, it is necessary to establish to what extent customers actually use these as a reference price. There are limits to the degree to which this can be measured using a survey. Even a customer sceptical of whether a non-member price is genuine may still find their transaction decision affected by its presence, and so this would be best understood using experimental methods. However, we expect attitudes to be usefully illustrative of how non-member prices are regarded.
We asked participants how much they trusted different types of promotions and found consumers generally trust member prices to offer them a good deal. Over two-thirds of people (69%) trusted member prices a great or fair amount, which is greater than other common promotions such as was/now pricing, see Figure 4.
Figure 4: Consumers are generally trusting that member prices offer a good deal
Source: online survey conducted by Delta with 1,970 participants in June 2024 weighted to be nationally representative. Question: To what extent do you trust that each of the following promotions offers a good deal? Asked participants who had shopped online or in-store in the last 6 months.
Unsurprisingly, those who don’t have any of the loyalty cards listed were less trusting that member prices offered a good deal. Only two-fifths (42%) of those without loyalty cards trusted member prices offered them a good deal versus 69% for those with a few cards (1-3) and 72% for those with over four loyalty cards.
Of course, trusting that an offer is a good deal overall does not imply that they believe the non-member prices to be representative of typical selling prices. We asked participants how they thought non-member prices generally compared to the usual selling prices at the same retailer. Just over half of respondents (55%) indicated they are sceptical of non-member prices, stating they believed these prices to be higher than the usual selling price, see Figure 5. However, a significant proportion, 29%, think these non-member prices are the same or lower than usual prices.
It is reasonable to assume that the 29% of people who believe non-member prices are the same or lower than usual prices will use the non-member price as a reference price. If non-member prices are actually higher than usual selling prices then these people are at risk of being misled. This is likely to be the lower limit of the proportion of shoppers who use the non-member price as a reference price, since even customers sceptical of the non-member price may have regard for it when in the shopping environment. Further, the fact that so many customers are sceptical about them indicates a lack of trust and the need for greater transparency.
Figure 5: A majority of people think non-member prices are higher than usual selling prices
Source: online survey conducted by Delta with 1,970 participants weighted to be nationally representative. Question: Thinking of membership/loyalty cards and prices available at some retailers… Generally speaking, how do non-member prices tend to compare to the usual selling prices at the same retailer? Asked participants who had shopped in the last six months.
Pricing Analysis
The survey findings show that loyalty schemes are very well used by shoppers and generally trusted to deliver a good deal, but that consumers hold different attitudes as to whether non-member prices represent a typical selling price. To investigate exactly how non-member prices relate to usual selling prices, we analyse the pricing history of a sample of goods at supermarkets and health and beauty retailers with member pricing.
We took a snapshot of products available online with member pricing on a day in May 2024 for four supermarket retailers (Co-op, Morrisons, Tesco and Sainsbury’s) and two health and beauty retailers (Boots and Superdrug) [1]. The products with member pricing were identified through an independent price comparison company and spot checks were conducted manually in-house on the same day. For the health and beauty retailers, these were items from the health and beauty categories, while for supermarkets, the sample contains products from groceries, alcohol drinks, health and beauty and home care categories.
Table 1: Sample of products with membership pricing by retailer
Number of products with membership pricing | Exclusions: multi-buy offers etc. | |
---|---|---|
Tesco | 7,755 | 2,551 |
Sainsbury's | 4,824 | 4 |
Boots | 1,867 | 69 |
Superdrug | 1,729 | 831 |
Co-op | 212 | 4 |
Morrisons | 45 | 0 |
Note: These are products that had a dual price member and non-member price on 23rd May 2024 for the supermarkets and 8th May 2024 for Boots and Superdrug. We don’t include loyalty multi-buy discounts, products where the non-member is lower than the loyalty price or the same as the loyalty price and products with irregular last seen dates. Source: An independent price comparison company
Thousands of products at Tesco and Sainsbury’s were on a member price promotion on our snapshot day [2]. This is not surprising given that both retailers have replaced the majority of their promotions with loyalty discounts. Membership pricing started later at Boots and Superdrug but both have rapidly expanded their schemes; we found around 1,700 and 700 products with member pricing respectively on our snapshot day. Waitrose had no products with member prices on the day we collected the data, so is not included in our analysis. We did identify products at Co-op and Morrisons that had member pricing offers, but due to the small sample sizes we omit these retailers from the analysis presented in this report.
Using the same data source, we capture the non-member prices, which are the prices that consumers without a loyalty card would pay on the same snapshot day. We then match these prices to daily observations for this set of products over the preceding six months[3]. Additionally, we capture the price on the day after the membership-price promotion ended.
Before analysing the non-member prices, we provide a brief description of the data by exploring the strategies used by retailers for their membership pricing.
Analysis of retailer strategies
Splitting the sample by branded and own-label products shows clear differences in which products the retailers choose to include in membership offers, see Figure 6. Branded products dominate the sample for Tesco and Sainsbury’s, whereas a vast majority of Boots’ member price promotions are on own-label products. Additionally, more than a third of the Superdrug sample is also comprised of own-label products.
Figure 6: Loyalty products by retailer split by own-label and branded
Source: An independent price comparison company
Looking at the depth of discount, the median discount is generally higher for branded products, see Figure 7. Although notably for Boots, there is a distinct difference between the 10% median loyalty discount on own-label products versus a median loyalty discount of 31% on branded products. This is likely due to the Boots Best for Less campaign which offers 10% off for more than 1,000 own-label products[4].
Figure 7: The median loyalty discount is generally higher for branded goods
Source: An independent price comparison company. Sample sizes: Tesco branded 4,796, Tesco own-label 408, Sainsbury’s branded 4,299, Sainsbury’s own-label 521, Boots branded 232, Boots own-label 1,566, Superdrug branded 565, Superdrug own-label 333.
There are also differences between retailers with regards to the duration and frequency of offers. For each product in the snapshot sample, we calculate the proportion of the prior six months the product was on a member price promotion and find that the products tended to have spent more time on member promotion at Tesco than at Superdrug or Sainsbury’s, see Figure 8. At Boots, most own-label products were on offer with lower prices for members for more than half of our time period, which aligns with their Best for Less campaign.
Figure 8: The duration of loyalty promotions varies substantially within and across retailers
Source: An independent price comparison company. Products which are available less than half the time over the past six months have been removed from this analysis. Sample sizes: Tesco branded 4,267, Tesco own-label 337, Sainsbury’s branded 4,029, Sainsbury’s own-label 446, Boots branded 193, Boots own-label 1,562, Superdrug branded 456, Superdrug own-label 262.
We also find that there are often multiple membership price offers over the preceding six months for the same product in our snapshot sample. For example, a product at Sainsbury’s was, on average, subject to four membership promotions across the six months prior to our date of collection, each lasting an average of 16 days. At Tesco this was 3 promotions with an average of 23 days. However, at the health and beauty retailers we found that not only do membership price offers recur, these products are also placed on promotions available to all customers, such as ‘was/now’ offers[5]. These offers are sometimes used in conjunction with or alongside one another, while at other times the offers might follow continuously.
Assessment of non-member prices
Member prices are significantly discounted relative to non-member prices, however, it is unknown to what extent the non-member prices reflect typical selling prices. While the Consumer Protection Regulations apply and the Chartered Trading Standard Institute (CTSI) has published guidance on the use of other types of reference prices, there is currently no specific regulatory guidance for traders on the use of member pricing. This means that there is no definitive test as to whether a non-member price can be considered a usual selling price. Therefore, we conduct four different, indicative analyses in which we compare the non-member prices to other prices:
- The preceding six months of usual selling pricing history before the snapshot day, this includes past non-member prices, promotional prices which are not exclusive to loyalty card members, and non-promotional prices.
- The most recent price before the member promotion, this is the most recent selling price before the snapshot day when the product is not on loyalty promotion.
- The price immediately after the member promotion, this is the earliest selling price after the snapshot day when the product is not on loyalty promotion.
- Competitor prices on the same day. These prices include non-promotional prices and promotional prices which are not exclusive to loyalty card members.
The first of these analyses is analogous to the type of analysis that would be undertaken to assess ‘was’ reference prices in ‘was/now’ offers. For such offers, CTSI’s guidance notes it is necessary for a retailer to consider how long the product was at sale for the higher price and this period must be sufficiently long in relation to the offer period. In guidance specifically for the mattress sector, the CMA identifies this as the ‘price establishment period’. For membership offers, if a product is on sale for less time at (or above) the non-member price then it is less likely that this will represent a typical selling price. However, there are situations in which it might be reasonable for there to be only a short price establishment period, or even no such period at all. In particular, in times of high cost inflation it is possible that retailers may choose to pass on price rises to non-members first. For that reason we also present the three further analyses and table 2 sets out what we would expect to see in each of these if the non-member prices are typical selling prices.
Table 2: Means of assessing non-member prices
Comparator | Assessment of non-member prices |
---|---|
Pricing History | More likely to be considered typical selling prices if a greater proportion of previous prices have been at or above the non-member prices. |
Most recent pre-promotion prices | More likely to be considered typical selling prices if these are at or above the non-member price. |
First post-promotion prices | More likely to be considered typical selling prices if these are at or above the non-member price. |
Competitor prices | More likely to be considered typical selling prices if the difference between the non-member prices and competitor prices is similar to the difference between prices for products not on offer. |
1. The pricing history
To understand whether the non-member prices are representative of the usual selling prices, we compare the non-member prices on the snapshot day to the daily price over the preceding six months. From this, we identify the proportion of products for each retailer, shown in Figure 9, where the usual selling price was lower than the non-member price more than half the time.
Figure 9: Proportion of products for which the daily price is below the non-member price by length of time over the preceding six months
Source: An independent price comparison company. Products which are available less than half the time over the past six months have been removed from this analysis. Sample sizes: Tesco 4604, Sainsbury’s 4475, Boots 1755, Superdrug 718. Notes: The non-member price refers to the price a consumer without a loyalty card would pay on the snapshot day. The daily prices refer to the past prices over the preceding six months that a consumer without a loyalty card would have paid.
We find that the non-member price is most like the price offered over the previous six months at Sainsbury’s. Only for 5% of products has the price been lower than the non-member price for more than half the time. This increases to 10% for Boots and Tesco and 16% for Superdrug.
Of course, inflation may mean that prices are higher after six months and it may be that this is too long a time period over which to compare prices. We therefore also run a three month sensitivity check, see Figure 10. The proportion of products for which the non-member price looks to be above the typical selling price falls for all retailers, but it falls most for Superdrug so that it is now in line with Tesco and Boots.
Figure 10: Proportion of products for which the daily price is below the non-member price by length of time over the preceding three months
Source: An independent price comparison company. Products which are available less than half the time over the past three months have been removed from this analysis. Sample sizes: Tesco 4887, Sainsbury’s 4588, Boots 1741, Superdrug 715. Notes: The non-member price refers to the price a consumer without a loyalty card would pay on the snapshot day. The daily prices refer to the past prices over the preceding six months that a consumer without a loyalty card would have paid.
2. The price before the membership promotion
The next check we do is to see whether non-member prices are in line with the most recent pre-promotion selling price. The Chartered Trading Standards Institute advises that reference prices are less likely to be considered genuine when there have been intervening reference prices such as those highlighted in the CMA’s recent investigation into online mattresses.
For three of the four retailers we find few instances in which the most recent price is less than the non-member price, see Figure 11. However, about a third of products with member offers at Boots had a lower price immediately before the promotion started. This is because most of these products had back-to-back promotions, with the earlier promotion being available to all customers. Of these 526 products, 511 of these were on a non-member promotion immediately before the member-price promotion started. In contrast, only 21 of the 85 Superdrug products identified as having a lower pre-member promotion price, were on a non-member promotion directly before.
Figure 11: Non-member prices at Boots were most likely to be higher than the pre-promotion price
Source: An independent price comparison company. Products which are available less than half the time over the past six months have been removed from this analysis. Other products were removed as we could not find the earliest non-loyalty pre-promotion price. Sample sizes Tesco 4576, Sainsbury’s 4472, Boots 1524, Superdrug 717.
3. Post member promotion price
Comparing the non-member price with the first price offered after the members-only promotion had finished, there are no instances in which the post-promotion price was lower at Tesco or Sainsbury’s. However, the post member-promotion price was often lower at Boots. Of the 262 products for which we could check a post-promotion price, 201 had a save percentage and/or save amount promotion available to all customers directly after the loyalty promotion ended. We also identified 66 products at Superdrug where the price immediately after the member promotion is lower than the non-member price.
4. Competitor prices
The final comparison we make is how non-member prices compare to prices offered by competitors. We calculate the difference between the non-member prices to the price offered by competitor retailers for the same product on our snapshot day. Pairwise comparisons are conducted separately for each retailer and we include only branded products, as these will be identical across the retailers. For comparison, we use the results from the Which? cheapest supermarket basket as an indicator of general price differences between these retailers. These are based on the average price of a basket of 177 items in May 2024, the same month as our snapshot sample.
For both Tesco and Sainsbury’s, we can see that the median difference between its non-member prices and the prices offered by competitors is typically less than the difference found in the cheapest supermarket comparison, see Figures 12 and 13. For example, we find that Tesco’s non-member prices for the products on membership offer are 3% higher than the prices of these products at Asda, but that for the 177 products in Which?’s cheapest supermarket basket Tesco is 6% more expensive. The only exceptions are that the median difference between Tesco’s non-member prices and Saisbury’s and Waitrose are both zero, whereas Tesco is cheaper than both of these supermarkets for the cheapest supermarket basket. Overall, this comparison gives confidence that, on average, the non-member prices at Tesco and Sainsbury’s represent typical selling prices.
Figure 12: Tesco Competitor Comparison
Source: An independent price comparison company, checked on 23rd May 2024. The competitor prices include non-promotional prices and promotional prices where the promotion is not exclusive for members. Sample sizes: Asda 2834, Morrisons 2476, Sainsburys 1747, Waitrose 1645. Cheapest Supermarket basket sample size 177 items in May 2024.
Figure 13: Sainsbury's Competitor Comparison
Source: An independent price comparison company, checked on 23rd May 2024. The competitor prices include non-promotional prices and promotional prices where the promotion is not exclusive for members. Sample sizes: Asda 2745, Morrisons 2543, Tesco 1647, Waitrose 2046. Cheapest Supermarket basket sample size 177 items in May 2024.
This analysis is more difficult for the health and beauty retailers. We have no equivalent of the cheapest supermarket analysis for these retailers to give context to the price differences, and too few branded products are on member offers at Boots for a pairwise comparison with any retailer other than Superdrug. For the 109 matching products between Boots and Superdrug the median price difference was 0% [6]. The non-member prices at Superdrug are higher than those at the supermarkets. The median price difference ranges from 5% with Tesco to 25% with Asda, but we are not able to say whether these differences are typical for all products [7].
Discussion
Member pricing has become a fundamental feature of grocery and other retail markets. The average consumer is a member of at least three loyalty schemes and some retailers have thousands of products with member-only pricing at any one time, with the discount for members being on average in excess of 20%. We have found that customers value member price promotions, despite a majority claiming to be sceptical about the non-member prices and therefore doubtful that the discounts offer savings as great as the difference between the member and non-member prices.
Our research is important for two policy and legal issues relevant for loyalty schemes with member pricing. First, it addresses the questions of whether loyalty scheme members do and should use the non-member price as a reference price and, second, the size of the membership benefits raises the issue of access to loyalty schemes.
Considering the first of these, it seems clear that large numbers of customers do use the non-member price as a reference price. 29% of customers told us they believe non-member prices are the same or lower than usual selling prices. We expect this will represent a lower limit of who uses the non-member price as even customers who are sceptical of non-member prices are likely, at least some of the time, to regard the difference between the member and non-member price as a genuine saving.
Given this, it is important to establish whether non-member prices are representative of typical selling prices. The absence of specific regulatory guidance for traders on the use of member pricing means there is no clear understanding of how a non-member price should be set to be an appropriate reference price. We therefore applied a range of indicative analyses to the non-member prices of four large retailers.
Overall, the majority of non-member prices appear to be at or below a typical selling price, and we do not find evidence that customers are being systematically misled by member price promotions. In this our findings accord with the provisional findings of the CMA.
However, we did find that for each retailer there were a minority of products, ranging from 5% to 16%, for which the price has been lower than the non-member price for more than half the time in the previous six months. This is a sufficiently high proportion that a consumer ought not assume a non-member price represents a typical previous selling price.
In some cases the product has been subject to recent cost inflation and so we also examined the selling prices immediately before and after the member price promotion. In doing so, a particular issue that emerges from our analysis (and the CMA’s) is that some retailers use successive promotions of different types, so that loyalty promotions directly follow ‘was/now’ promotions or vice versa. We found that it was common for Boots to do this, and that when promotions followed one another the price immediately before or after the member price promotion was often lower than the non-member price quoted during the promotion. The CMA has indicated that it will publish guidance for retailers when offering was/now promotions in close proximity to a loyalty price promotion and we believe there are a number of important factors that retailers will need to consider.
In cases when a ‘was/now’ offer immediately follows a member-price promotion, and the ‘was’ price is not the member price, then we believe the following factors will be important for determining whether the ‘was’ reference price represents a genuine selling price:
- The duration of time for which the product was sold at the 'was' price.
This represents the price establishment period and it will be the sum of days for which the ‘was’ price was offered as the non-member price during the loyalty offer and as the price immediately before the loyalty offer began.
A longer price establishment period will make it more likely the ‘was’ reference price can be considered genuine. While we expect that price establishment periods may be shorter for fast-moving consumer goods than, say, home furnishings, it must still be proportional to the duration of the offer period.
- The proportion of customers who are members.
The greater the proportion of sales that have taken place at the member price the less reasonable it is to consider the period of the member-only offer as part of the establishment period.
If a large proportion of a retailer’s customers are members, such that most sales are made at the member price, then it would be inappropriate to ever use the non-member price as part of the price establishment period. And since the ‘was’ price should refer to the price immediately prior to the promotion starting then if the non-member price cannot be used as part of the price establishment period then a ‘was/now’ offer should not immediately follow a loyalty offer.
We do not seek to define what ‘a large proportion’ will be. It will certainly be no more than 50% of customers, since in this case only a minority of customers will have faced the non-member price. However, it could be that the proportion is considerably lower than 50% because members are likely to purchase more than non-members, i.e. be more regular customers with larger spends, and therefore be responsible for a disproportionately high share of sales.
- The duration of the loyalty offer.
Longer loyalty offer periods make it less likely a ‘was’ reference price can be considered genuine. Long loyalty offers mean the part of the price establishment period that applied for all customers is less recent, which weakens the perception of the ‘was’ price as being a genuine selling price. Further, it means that the proportion of sales at the reference price is likely to be relatively lower.
When a member-price offer immediately follows a ‘was/now’ offer then the issue is whether the non-member price can be considered to be a genuine reference price for members looking to purchase at the discounted price. In general, there is no clear requirement to have a price establishment period for a non-member price and, in fact, there are circumstances in which there might reasonably be no price establishment period. For example, in an inflationary environment a retailer may prioritise holding down prices for members, and the non-member price might be higher than the price previously available to all customers. In such cases an assessment of whether the non-member price is genuine would need to be made by considering the price immediately after the promotion and competitor prices.
However, we believe it will be difficult to argue that because of inflation there should be no price establishment period if the retailer has offered a temporary sale to all customers immediately prior to the member-price offer. For that reason, we believe retailers should avoid member-price offers that directly follow ‘was/now’ offers.
Overall, we believe the absence of guidance for retailers on how to use member-price promotions is problematic given the prevalence of such offers. We believe regulators should provide guidance on the determination of non-member prices in general and specifically the interaction between loyalty price promotions and offer discounts, and we welcome the CMA’s stated intention to do the latter.
Turning to the issue of access to loyalty schemes, the size of the discount available to members means that any customers who would like to join a loyalty scheme, but who are unable to do so are likely to pay a considerable premium. Most retailer’s loyalty schemes have similar eligibility requirements, but they may differ according to age restrictions, the need to provide an address and the ability to sign up offline, see Annex 2. The consequence of this is that younger customers, people without a fixed address, and those who are digitally excluded may find it more difficult to become members of loyalty schemes and could be forced to pay higher prices. Which? believes that retailers should do as much as possible to ensure that customers are not unfairly excluded from schemes. For example, by lowering the age limit wherever possible and by ensuring it is possible to sign up to schemes in store and without an email address.
Annex 1: Supermarket and health and beauty retailer loyalty schemes
Some loyalty schemes have been around for decades, this includes the Tesco clubcard scheme that launched in 1995. The scheme has many benefits including earning points for future purchases both at Tesco and other linked retailers, personalised coupons and loyalty pricing. The member price discounts known as Clubcard Prices began in May 2019, and restricted some price discounts to Clubcard members. They have since expanded the scheme to more products, and there are over 8,000 Clubcard offers available weekly in 2024. In 2022, we found that the majority of promotions were now restricted to those with a Clubcard.
Clubcard pricing has proven successful for Tesco, the number of households with a Clubcard has continued to grow to 22m last year and the vast majority of sales, 82%, are conducted with a clubcard in the UK. Other supermarkets have followed suit with their own loyalty pricing schemes. The Nectar card scheme started in 2002 with a few major retailers including Sainsburys, but it was only in April 2023 when Sainsbury’s introduced Nectar Prices starting with around 300 items. Also in April 2023, Co-op launched member prices in-store, however these were only available online earlier this year in late March 2024. Morrisons introduced some products with member pricing in mid-2023, at the time of our analysis in May 2024 this was a small proportion of products. However, in late August Morrisons announced they would be expanding the scheme to over 2,000 products.
Similar to Tesco, the Boots advantage scheme has been around since the 1990s allowing members to earn points which could be used to discount future purchases. However, member pricing through the loyalty scheme only started a couple of years ago, launching in-store first in January 2022 followed by an online launch in April 2022. According to the press release, consumers said they wanted more immediate benefits through their advantage card. Also similar to Tesco, many consumers would have been automatically enrolled as a member on the new pricing scheme.
In September 2023, Boots expanded their member pricing to include over 1,000 own-label products with 10% constant discount for Advantage card members. Unlike the supermarket retailers, there are still many products on promotion which are not exclusive to members. The other major health and beauty high street retailer, Superdrug also has their own loyalty price scheme which launched loyalty price discounts for health and beauty members in August 2022.
Annex 2: Eligibility criteria for loyalty schemes
Table A2: Loyalty card restrictions
Retailer | Age restrictions | Location restrictions | Digital restrictions | Terms and Conditions |
---|---|---|---|---|
Tesco Clubcard | Must be over 18 | Must have a UK address | No - there is a completely non-digital scheme | https://www.tesco.com/groceries/en-GB/zone/clubcard-terms-and-conditions |
Sainsbury's Nectar | Must be over 18 (except where they are an additional collector on the Nectar account of a parent or guardian). | Must have a UK address | No - physical cards are available in store although it asks for an email address to register them, if a customer contacts the Nectar helpline they can be registered without one. | https://www.nectar.com/about/privacy-and-legal/collector-rules |
Asda | Must be over 18 | NA | Yes - must have an email address and online access for sign up. They must have downloaded app to a mobile device or sign up at Asda.com | https://www.asda.com/rewards/terms |
Morrisons | Must be over 16 | Must be a UK resident | No - there is a completely non-digital scheme | https://www.morrisons.com/more/terms-and-conditions/ |
Waitrose | Must be aged 18 or over. Waitrose & Partners may refuse an application for any reason. | All members of the scheme must be residents of England, Scotland, Wales or the Channel Islands. | Yes - customers need to have an email address and access to the internet to sign up to MyWaitrose membership - but this can be done either on a mobile device or computer. Although consumers require an email address to sign up, they don’t need to have access to a mobile to get the savings. | https://www.waitrose.com/corporate_information_home/corporate_information/legal_notices/my_waitrose_terms_and_conditions.html |
Lidl | Must be 18 years old or over. | NA | Yes - you must download the app. A mobile number and email address is required. | https://www.lidl.co.uk/c/lidl-plus-terms-of-use/s10025414 |
M&S | Must be 18 years old or over. | Must be a UK resident. | No - terms and conditions say email address needed, but when asked they told us their loyalty scheme is open to all and physical cards are available on request. | https://www.marksandspencer.com/c/help-and-support/loyalty-and-rewards#intid=footernav_sparks-faqs |
Footnotes
[1] The loyalty promotions and associated prices are based on the retailers online websites, without a user logging in for inputting a geographic location. Other than Coop where it is based on a single postcode in the Leeds area.
[2] For supermarkets, the snapshot day is 23rd May with 6 months of preceding data from 23rd November 2023 to 22nd May 2024. For health and beauty retailers, the snapshot day is 8th May 2024 with 6 months of preceding data from 8th November 2023 to 7th May 2024. We stopped data collection on the 20th June 2024, so we do not have a ‘day-after-promotion’ price for any product for which the member offer lasted beyond this.
[3] This price data includes past non-member prices, promotional prices which are not exclusive to loyalty card members, and non-promotional prices.
[5] This was especially common at Boots, where we found 1,653 products that had both a members-only and regular promotion over the previous six months. At Superdrug this was 500.
[6] Source: An independent price comparison company, checked on 8th May 2024. The competitor prices include non-promotional prices and promotional prices where the promotion is not exclusive for members. Sample sizes: Superdrug 109.
[7] Source: An independent price comparison company, checked on 8th May 2024. The competitor prices include non-promotional prices and promotional prices where the promotion is not exclusive for members. Sample sizes: Boots 256, Asda 190, Morrisons 147, Sainsbury’s 158 and Tesco 105.