Supplemental Nutrition Assistance Program (SNAP)

Last Updated: January 23, 2019

The Issue

Convenience stores provide essential access to nutrition for low income Americans who live in rural or urban environments. Out of the 154,535 convenience stores in the United States, more than 119,000 participate in the Supplemental Nutrition Assistance Program (SNAP)—representing approximately 45% of all retail outlets authorized to accept SNAP benefits. Convenience stores are often the only establishments easily accessible by walk-in or public transportation, or the only food retail locations open for business with extended or 24-hour service.

In 2014, a comprehensive Farm Bill was passed and signed into law that imposes some additional obligations on SNAP retailers. Subsequently, the U.S. Department of Agriculture’s Food and Nutrition Service (FNS), the agency that oversees SNAP, finalized a rule in December 2016, which enacted some of the 2014 Farm Bill’s provisions and other requirements for retailers.

Retail Impact

To participate in SNAP, convenience stores must meet so-called “depth of stock” requirements that specify the amount and types of foods they must have available on their shelves for customers. The 2014 Farm Bill expanded these requirements. Subsequently, FNS finalized a rule enacting the depth of stock provisions and additional provisions.

Under the Final Rule, to participate in SNAP, convenience stores must:

  • Stock 7 varieties of foods in each of the 4 staple food categories: (1) meat, poultry, or fish, (2) bread or cereals, (3) vegetables or fruits, and (4) dairy, and at least 1 perishable food item in 3 of the categories.
  • They must have three units of every variety, 84 total items, on shelf

NACS Position

It is critical that Congress and the Trump Administration understand the important role convenience stores have regarding SNAP. Convenience stores represent 45% of all retail outlets authorized to accept SNAP benefits—they are intensely local businesses that serve as a gathering place and source of community pride and offer an ever-growing range of products and services.

Many financially challenged Americans rely on convenience stores to redeem their SNAP benefits, especially in both urban and rural areas where they do not have access to traditional grocery stores or because they shop during hours when larger format food stores may be closed. The local convenience store is often their only outlet to redeem this benefit.

Meeting the new requirements can be difficult for convenience stores for several reasons:

  • FNS has defined what counts as “variety” in a very complicated way where a retailer can only count one item per species (i.e. if you stock sliced ham and bacon, only one can count as pork). The agency is expected to propose a new definition of “variety” in the coming months.
  • On average, convenience stores get food deliveries 1-2 times a week, which can make stocking certain foods, particularly perishable foods, difficult.
  • The average convenience store is approximately 2,800 square feet—almost 16 times smaller than the average supermarket. This means that convenience stores have limited space in which to display and store products, particularly perishable products that must be refrigerated or frozen.

For an overview of the final rule, please click here. For a more in depth compliance guide for NACS members, please visit the Government Relations Resource page.