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November 25, 2025 - Yesterday, the Energy
Marketers of America (EMA) voiced significant concerns regarding a
proposed U.S. Department of Agriculture (USDA) Food and Nutrition
Service (FNS) rule that would dramatically increase staple food
stocking requirements for retailers authorized to accept
Supplemental Nutrition Assistance Program (SNAP) benefits.
EMA acknowledged the agency’s goal of improving access to
nutritious foods for the more than 41 million SNAP participants
but warned that the proposed changes fail to account for the
unique operational and economic realities of small-format
convenience stores—many of which are co-located with retail fuel
stations and serve as critical food access points, especially in
rural and underserved communities.
“While we strongly
support efforts to enhance the nutritional quality of foods
available to SNAP beneficiaries, program integrity must be
balanced against the practical constraints facing small business
retailers,” EMA stated. “These stores are not supermarkets. They
operate on thin margins, limited square footage, and customer
demand driven largely by convenience rather than meal
preparation.”
The rule would raise the minimum number of
stocking varieties from three to seven in each of the four staple
food categories (fruits/vegetables, dairy, grains, and protein),
while imposing narrow definitions of what constitutes a “variety.”
EMA argues this combination creates insurmountable compliance
hurdles for small stores.
EMA emphasized the interconnected
nature of the convenience-store and retail-fuel business model.
Any substantial reduction in in-store revenue—particularly from
SNAP redemptions, which can represent 10–20% of sales at some
locations—directly threatens fuel operations. Cash-flow
disruptions at the retail level cascade upstream to fuel
wholesalers through slower payments and heightened credit risk.“
If small stores are forced to exit the SNAP program because
compliance is economically unfeasible, the result will be less
food access for low-income Americans in the very communities the
rule intends to help,” EMA warned.
EMA urged FNS to adopt a
more flexible framework that considers store size, geographic
location, and demonstrated customer purchasing patterns.
Click here to read the comments.
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