The Economics of Electronic Shelf Labels: How Dynamic Pricing Is Reshaping U.S. Grocery

How electronic shelf labels and pricing technology are reshaping U.S. grocery, why the fear of surge pricing outruns the evidence, and what it all means for the value of grocery real estate.

In June 2024, Walmart told investors it would put digital price labels on the shelves of 2,300 of its U.S. stores. Within days the announcement had been recast in the press as the arrival of “surge pricing” at the supermarket, the grocery equivalent of paying more for a rideshare in the rain. By the end of that year the company had extended the contract to cover its entire U.S. fleet, a deal its vendor valued at roughly $1.027 billion, with full deployment expected by the end of 2026. (1, 2)

The reaction was loud, bipartisan, and largely beside the point. The technology Walmart and its peers are installing is real, the money behind it is real, and the regulatory backlash is real. But the thing most people are afraid of, a shelf price that jumps while you reach for the can, is not what is actually happening in American grocery aisles. What is happening is quieter, more interesting, and far more consequential for anyone who finances, builds, or values the real estate these stores occupy.

This is a report about that gap between perception and practice. It is also, in the end, a report about real estate, because the same thin margins that push grocers toward pricing technology are the margins that decide whether a grocery anchor pays its rent for the next fifteen years. We will move from the technology to the economics that drive it, through the evidence on what these systems actually do, into the store-by-store reality of who is deploying them, and finally to what all of it means for the value of grocery-anchored real estate and the lenders who finance it.

A Technology America Is Late To

Electronic shelf labels, or ESLs, are the small e-paper tags that replace the printed paper price stickers on a store shelf. They are not new. European grocers have been installing them for two decades, driven by higher labor costs, stricter pricing-transparency rules, and sustainability mandates. Estimates put European supermarket adoption near 80 percent. The comparable figure for the United States is somewhere between 5 and 10 percent. (3)

That gap is the single most important fact in the story, and it is why the American rollout feels so sudden. The United States is not inventing shelf-edge pricing technology; it is catching up to it, all at once, led by its largest retailer. The global market for these systems was estimated at about $2.09 billion in 2025 and is projected to reach roughly $7.3 billion by 2033, a compound annual growth rate near 17 percent, with North America the fastest-moving region. Estimates vary widely across research firms, but every one of them points the same direction. (4)

The vendor landscape is consolidating around two Western leaders, France’s VusionGroup, formerly SES-imagotag, and Sweden’s Pricer, with fast-rising Chinese challengers such as Hanshow and Taiwan’s E Ink supplying the displays underneath. VusionGroup crossed one billion euros in revenue in 2024 and counts Walmart, Hy-Vee, and The Fresh Market among its U.S. clients; Pricer has delivered more than 350 million labels across 28,000 stores worldwide. (1, 5)

The economics that finally moved American grocers are straightforward. A label costs roughly $5 to $15. Outfitting a large store runs into the low hundreds of thousands of dollars, with payback periods that vendors and integrators put at twelve to twenty-four months, driven mostly by labor savings. These figures come largely from vendors and the firms that install the systems, so they deserve a degree of caution. But the underlying labor math is hard to dispute: the average supermarket carries more than 30,000 items and changes thousands of paper tags a week by hand. A Walmart associate in Texas described a price change that used to take two days of manual work and now takes minutes. (1, 6)

Why Pennies Decide Everything

To understand why grocers are willing to spend this money, you have to understand how little of every dollar they keep. The U.S. food-retail industry runs on a net profit margin of about 1.7 percent. As the Food Industry Association put it in its 2025 report:

Our industry, long accustomed to operating on narrow margins, is once again feeling economically squeezed, with food retail profit margins settling at 1.7%, while food product suppliers reported a net income of 7.7%.  — FMI, The Food Retailing Industry Speaks 2025

That contrast, 1.7 percent for the retailer against 7.7 percent for the supplier, tells you where the pricing power in the food chain actually sits, and why the grocer in the middle has so little room to absorb a mistake. (7)

Set that 1.7 percent against what the same stores lose to shrink and spoilage and the picture sharpens. McKinsey found that shrink consumes 2 to 3 percent of a typical grocer’s revenue, rising to between 5 and 15 percent in ready-to-eat and ready-to-heat categories. In plain terms, what grocers throw away or lose often exceeds the entire profit they keep. A single point of margin recovered from the dumpster is worth more to a supermarket than a large increase in sales. (8)

The losses are not spread evenly. They concentrate in the perimeter departments, the fresh food that defines a modern supermarket and produces nearly half its sales. Industry shrink data has historically shown deli at 8.7 percent, bakery at 8.5 percent, seafood at 7.6 percent, and meat at 5.7 percent, against just 1.2 percent for shelf-stable dry grocery. Produce is routinely cited as the single largest contributor to food waste. (9)

Put those facts together, thin margins and perishable waste concentrated in fresh, and the real use case for shelf-edge pricing technology comes into focus. It is not about charging more when demand spikes. It is about marking down a tray of salmon or a rack of bread before it is thrown out, at the right moment and the right discount, without sending an employee around with a label gun three times a day. There is one more lever worth naming here: private label. Store brands carry gross margins twenty to thirty points above national brands and now account for roughly a quarter of units sold, with their deepest penetration precisely in the high-margin, high-shrink perishable departments. The margin story and the markdown story are the same story. (9)

The Myth, and What the Data Actually Says

The fear is intuitive. If a price can change with a keystroke, surely it will change against the shopper, climbing on a hot day or when the shelf is busy. Lawmakers have leaned into the analogy, comparing digital tags to rideshare surge pricing, and consumer sentiment has hardened accordingly. In one survey, 68 percent of consumers said they feel taken advantage of when brands use dynamic pricing; in another, the same share called it a form of price gouging, up from the year before. (10, 11)

The trouble is that the intuition does not survive contact with the evidence. Three economists, Ioannis Stamatopoulos of the University of Texas at Austin, Robert Sanders of UC San Diego, and Robert Bray of Northwestern, examined more than 180 million product-level observations across 114 stores in four states, comparing pricing behavior before and after those stores installed electronic shelf labels. They found that short-lived, unexplained price increases, the statistical fingerprint of surge pricing, affected about 0.0050 percent of products before the labels went in, and that the rate moved by six ten-thousandths of a percentage point afterward, a change indistinguishable from zero. (12)

Stamatopoulos put it plainly: targeting digital shelf labels as a source of price gouging “has no basis in reality.” The study is still a working paper rather than a peer-reviewed publication, a caveat worth keeping in mind, but it is by a wide margin the most rigorous look at the question to date. (12)

The reasoning is commercial as much as empirical. A grocer does not make money on a single can; it makes money on the whole basket and on a shopper’s loyalty over years. As Stamatopoulos noted, surging the price of an item to exploit a momentary rush is the fastest way to lose that shopper to the store across the street, which is “the last thing grocers want.” Unlike a hotel room or an airline seat, a can of beans is not a perishable, fixed unit of capacity; the economics that make surge pricing work in travel simply do not transfer to the grocery aisle. (12)

How markdown optimization actually works

What the technology genuinely enables is the opposite of surge: systematic markdown. The discipline behind it is decades old and well developed in the operations-research literature. The foundational model, published by Guillermo Gallego and Garrett van Ryzin in 1994, showed how to set an optimal declining price path for a fixed stock of goods sold over a finite horizon. The fashion retailer Zara later turned that theory into practice, and a controlled field experiment across its Belgian and Irish stores raised clearance revenue by roughly 6 percent. (13)

A markdown engine is, at heart, three things working together: a demand forecast for each item by store and time of day, an estimate of how sensitive shoppers are to price in that category, and an optimizer that sets a price path to clear the stock before it expires while giving up as little margin as possible. That last constraint, the expiry clock, is what makes grocery harder and more valuable than fashion. A sweater that does not sell this season can be stored; a rotisserie chicken cannot.

The payoff is measurable. The most rigorous grocery study on the subject, by Robert Sanders in Marketing Science, modeled dynamic pricing of a perishable category and found it reduced waste by about 21 percent while raising the chain’s gross margin by 3 percent and even nudging consumer surplus up slightly. Sanders also pointed to the white space: fewer than a quarter of U.S. grocers offer any kind of dynamic pricing at all, even as hotels and airlines have discounted unsold capacity for decades. Independent peer-reviewed work has likewise found that the margin gains from shelf labels run well beyond simple labor savings, concentrated in exactly the low-shelf-life categories where waste lives. (14)

Why grocers move staples so rarely also has a technical answer that cuts against the gouging narrative. Recent research finds the binding constraint on in-store price changes is not the cost of changing a tag but information: grocers often lack reliable, real-time, item-level data on how much stock is on the shelf and when it expires. The labels remove the cost of changing the price. They do not, by themselves, create a reason to raise it. (14)

Elasticity is the last piece. Demand for most grocery staples is inelastic: a peer-reviewed review puts the own-price elasticity of eggs at 0.27 and of food at home overall at 0.59, both well below the threshold where a price increase would pay for itself in a competitive market. Milk, eggs, and bananas are “known-value items” that shoppers use to judge whether a store is cheap, which makes them the worst possible candidates for a price hike and the best candidates to keep sharp. The items genuinely worth discounting are the perishables nearing their sell-by date, which are relatively price-sensitive at the margin and otherwise headed for total loss. The economics point in one direction, and it is down. (15)

The risks that are real

None of this means the public’s concern is baseless; it means the concern is aimed at the wrong target. The genuine risk is not demand-based markdowns on the shelf but personalized pricing, where the price is tailored to the individual shopper using their data, and the closely related danger of pricing algorithms quietly learning to coordinate across competitors. The cautionary precedent here is not in grocery at all. It is the litigation over algorithmic rent-setting software in multifamily housing, where the U.S. Department of Justice and more than a dozen states alleged that landlords sharing data through a common algorithm amounted to price coordination. That is the pattern regulators fear, and it is categorically different from a supermarket marking down its own bread. (16)

The distinction matters far beyond the pricing debate, because the health of the grocer at the center of a shopping center is what holds the whole asset together. When an anchor weakens, the damage spreads to every inline tenant, a dynamic playing out across the country in our 2026 store closure tracker.

A Framework: The MMCG Dynamic Pricing Readiness Index

Not every grocery format is equally exposed to this shift. A hard-discount chain with 1,500 mostly private-label items faces a different calculus than a supercenter carrying 120,000. To make that comparison concrete, we built the MMCG Dynamic Pricing Readiness Index, which scores six store formats on the factors that actually drive adoption and benefit, rather than on the anxieties that drive headlines.

The Index weights six inputs. Gross margin thinness and perishable mix carry the most weight, 25 percent each, because they are the two factors the academic literature most strongly supports as drivers of dynamic-pricing benefit. ESL and technology readiness accounts for 20 percent; SKU count and the pricing-labor burden it creates, 15 percent; competitive density and price-image sensitivity, 10 percent; and balance-sheet capacity to fund deployment, the remaining 5 percent. Every input traces to sourced data from the analysis above, and a short methodology note accompanies the published Index so that any reader can see how a score was built. (7, 9)

The pattern the Index surfaces is that the formats most ready for shelf-edge pricing are not the ones the surge-pricing narrative fears most. Conventional supermarkets and supercenters, with their deep perishable assortments and heavy pricing-labor burden, score highest on markdown opportunity. Hard discounters, with few items and razor-simple assortments, have less to gain from the labels as a pricing tool and more from the labor savings. Warehouse clubs, which turn inventory fast and carry few SKUs, sit lower still. The point of the framework is to move the conversation from fear to fit: which formats benefit, why, and what that means for the operators behind them and the real estate that houses them.

On the Ground: Who Is Actually Doing This

Abstractions only go so far. The clearest way to see what dynamic pricing means in American grocery is to look at the handful of retailers driving the story, because their choices, and their stumbles, define the real boundaries of the practice.

Walmart: the inflection point

Walmart is the reason this is a national story rather than a trade-press footnote. Its rollout runs on VusionGroup hardware, began with a single supercenter in Grapevine, Texas, and scaled to a 2,300-store announcement in June 2024 before expanding to the full U.S. fleet by the end of that year. The company has been emphatic about what the labels are not for. Greg Cathey, a senior Walmart executive, told investors the technology would not be used to change prices hour to hour, and the company has said that prices are the same for every shopper in a given store regardless of time of day or demand. (1, 17)

That message was tested in early 2026, when Walmart was granted two pricing-related patents and the coverage again reached for the words “dynamic pricing.” Walmart told the Financial Times the patents were unrelated to it, one being specific to e-commerce markdowns and the other a decision-support tool for merchant teams rather than an automated price-changer. The episode is a useful reminder that the gap between what a retailer patents, what it deploys, and what the public fears can be very wide. (18)

Kroger: where the controversy lives

If Walmart supplies the scale, Kroger supplies the controversy. The chain has used digital displays since 2018 under a system it calls EDGE, and in August 2024 it drew a pointed letter from Senators Elizabeth Warren and Bob Casey, who warned that the technology, paired with data and cameras, could let the company “determine how much price hiking each of us can tolerate.” (19)

Kroger’s response was unequivocal:

Kroger does not and has never engaged in ‘surge pricing.’ Any test of electronic shelf tags is designed to lower prices for more customers where it matters most.  — The Kroger Co.

A separate concern, that Kroger might pair the labels with facial recognition to tailor prices, drew its own congressional letter. Kroger said its shelf-label tests did not include facial recognition, Microsoft said its facial-recognition technology was not part of the current system, and Kroger told one outlet it had ended an earlier facial-recognition pilot. The facial-recognition scenario remains, as of this writing, an alleged capability rather than a documented practice. But the episode shows how quickly the conversation moves from markdowns to surveillance, and why the distinction between the two matters so much. (19, 16)

Schnucks and Hy-Vee: the regional operators

The most concrete operational evidence comes from regional chains. Schnucks, a roughly 115-store grocer in the Midwest, has layered shelf labels onto a fleet of shelf-scanning robots and connected them to order-picking software, so that an out-of-stock item can flip its own tag and a picker can be guided to the exact shelf. Its technology executive described the manual tag-hanging the labels replaced with admirable candor: the team, he said, “realized how much it sucked.” Hy-Vee, deploying across more than 230 stores, uses the labels for intra-day markdowns on perishables and flashing lights to speed up order picking. (20)

Instacart: the cautionary tale

The sharpest warning of the cycle came not from a grocer but from a platform. In December 2025, an investigation by Consumer Reports and the Groundwork Collaborative reported that Instacart’s pricing tests could show different shoppers different prices for the same item from the same store at the same time, with variations the authors projected could cost a household of four around $1,200 a year. Within days, and amid a federal inquiry, Instacart ended retailer price testing on its platform, while disputing that the practice amounted to surveillance or demand-based pricing. (21)

The Instacart episode draws the real line in bright ink. It involved an online platform able to personalize at the individual level, which is precisely the practice the evidence does not find in physical stores, and the market and regulatory response was swift. It is the clearest signal yet of where the boundary sits: between marking down the shelf for everyone, and quietly pricing the person.

The Real Estate Underneath

This is where the story leaves the aisle and enters the rent roll. Grocery-anchored retail is, by a wide margin, the most sought-after slice of American retail real estate. CBRE’s 2026 investor survey found that 85 percent of retail investors favored grocery-anchored centers, the most preferred format by a wide margin, and national cap rates for the type compressed to roughly 6.7 percent at the close of 2025. Vacancy sits near 3.5 percent, the lowest of any retail subtype. (22, 23)

The reason is the anchor. A grocer pulls the same household through the parking lot two or three times a week, traffic that sustains every inline tenant in the center, from the dry cleaner to the nail salon. That dependence is written directly into leases through co-tenancy clauses, which let smaller tenants cut their rent or walk away if the anchor goes dark. When a grocer fails, the damage does not stay contained to one box; it cascades across the center as relief clauses trigger. The grocer’s viability, therefore, is the central question in valuing the whole asset.

And grocer viability is exactly what pricing dynamics touch. The connection runs in two links, each independently supported, even if the full chain is our own synthesis. First, thin margins make operating efficiency decisive, which is why a rating agency such as Moody’s ties a grocer’s credit rating directly to its operating performance and leverage. Second, credit quality drives lease durability and cap rates: identical centers trade at higher prices behind stronger-credit anchors, because the income stream is more certain. Pricing technology improves the first link by lifting margins and cutting waste. To the extent it does so durably, it strengthens the operating fundamentals that lenders and investors already price into grocery-anchored real estate. No rating agency has yet connected the full chain from shelf label to cap rate; that synthesis is ours. But each link rests on established ground. (14, 24)

There is a second real-estate signal worth watching, and it has nothing to do with technology. It is about which grocers are winning. Foot-traffic data has split the market into two tracks. Value formats and premium-fresh formats are pulling shoppers in, while conventional supermarkets are squeezed in the middle. In 2025, same-store visits rose 10.4 percent at Trader Joe’s and 9.8 percent at Whole Foods, against essentially flat traffic, up 0.3 percent, at Kroger. (25)

For anyone valuing a grocery-anchored center, the lesson is that the banner now matters as much as the box. The right grocer is a durable, defensive anchor; the wrong one is a co-tenancy problem waiting to happen. The discount and premium-fresh operators gaining share are also, not coincidentally, among the most aggressive at taking over boxes left dark by weaker conventional chains, which is reshaping which centers hold their value. The same trade-area data and debt-coverage discipline used to answer that question in a feasibility study are the tools that reveal which grocers are gaining and which are slipping.

The Regulatory Weather

The policy environment around all of this changed sharply across 2025 and 2026, and it is the part of the story most likely to affect store-level economics directly. The activity falls into three layers: federal study and legislation, a fast-moving patchwork of state law, and an organized labor campaign that has given the others momentum.

At the federal level, the Federal Trade Commission opened a study of “surveillance pricing” in 2024, ordering documents from intermediaries including Mastercard, Accenture, and McKinsey, and released initial staff findings in January 2025 before the change in administration shifted the agency’s posture from active study toward case-by-case enforcement. Bills to ban shelf labels in large grocery stores and to prohibit surveillance-based pricing have been introduced in Congress, though they remain in committee. (26, 27)

The states have moved faster. New York’s Algorithmic Pricing Disclosure Act took effect in November 2025, requiring a disclosure when a price is set by an algorithm using personal data, and it survived a First Amendment challenge from the National Retail Federation when a federal judge found the mandated language “plainly factual.” Maryland went further still, becoming in April 2026 the first state to restrict surveillance pricing specifically in the food sector, with a law that reaches food retailers in stores above 15,000 square feet, though consumer advocates criticized its loopholes. By one tally, more than 40 bills across two dozen states were introduced in a single year. (28, 29)

Driving much of this is organized labor. The United Food and Commercial Workers, which represents some 1.2 million members including more than 800,000 grocery workers, launched an “Affordable Groceries and Good Jobs” campaign in February 2026 and has pushed model legislation in a dozen states that would require paper shelf pricing in any store above 10,000 square feet. Industry groups have pushed back, arguing the labels are a communication tool rather than a pricing weapon and that existing law already bars gouging and discrimination. (30)

For a feasibility analysis, the store-size thresholds buried in these bills are the detail that matters most. The lines being drawn, commonly at 10,000 or 15,000 square feet, run directly through the supercenter and large-format world, which is precisely where the real estate value and the deployment cost concentrate. A pricing-technology investment that pencils out today could face a compliance retrofit, or an outright ban, depending on the state and the square footage. The disciplined move is to price that regulatory risk into the format and site decision now, not after the law lands.

What It Means

Strip away the noise and the picture is coherent. American grocers are adopting shelf-edge pricing technology because their margins are too thin to keep losing fresh food to the trash, not because they intend to surge the price of eggs. The best available evidence says the surge is not happening, and the commercial logic says it would be self-defeating if it did. What the technology genuinely does, cut waste, lift margins, and free up labor, makes grocers modestly healthier, and healthier grocers are more durable anchors for the real estate that depends on them.

The risks worth taking seriously are narrower than the headlines: personalized pricing built on individual data, algorithmic coordination across competitors, and a regulatory patchwork that increasingly targets the exact store formats that dominate grocery real estate. Those belong in any serious analysis of a grocery or grocery-anchored deal. The fear of a shelf price jumping while you shop does not, because it is not happening.

At MMCG, that is the work: translating how a business actually earns its margin into whether the real estate it occupies will hold its value and service its debt. Dynamic pricing is one more variable in that translation, and like most variables in this industry, it rewards the people who read the data instead of the headlines.

May 29, 2026 by Michal Mohelsky, J.D.,

About MMCG

MMCG is a national feasibility study firm, We prepare independent feasibility studies and market analyses for lenders and investors across more than thirty asset classes, including grocery and grocery-anchored retail. Learn more at mmcginvest.com.

Reach out to discuss how our methodology supports your lending or development decision.

Michal Mohelsky, J.D. | Principal | mmcginvest.com 

Contact: michal@mmcginvest.com

Phone: (628) 225-1125

Disclaimer: This report is provided for informational purposes only and does not constitute investment advice. Data presented herein is derived from proprietary MMCG databases and third-party sources believed to be reliable; however, MMCG Invest makes no representation as to the accuracy or completeness of such information. Figures from third-party industry databases have been independently verified and, where appropriate, adjusted to reflect MMCG's proprietary analytical methodology. Past performance is not indicative of future results.

Sources

Figures are attributed to their original publishers and dates. Where market-size or adoption estimates differ across research firms, the report cites the most widely referenced source and notes the variance in the text.

(1)  VusionGroup, contract and deployment disclosures, and Path to Purchase Institute coverage of the Walmart digital shelf label rollout, 2024.

(2)  CNBC, “Walmart digital price tags will be in every US store by end of 2026,” March 21, 2026.

(3)  RELEX Solutions / Associated Press, June 2025 (U.S. vs. European ESL penetration estimate, ~5–10% vs. ~80%); ABI Research installed-base estimates, 2024.

(4)  Grand View Research, Electronic Shelf Label Market Size & Trends, 2025 ($2.09B in 2025 to $7.32B by 2033, 17.4% CAGR). Estimates vary across research firms.

(5)  VusionGroup, 2024 Annual Results and Q3 2025 sales disclosures; Pricer AB, Year-End Report 2024.

(6)  TRUNO and integrator deployment-cost benchmarks; Walmart corporate news, associate accounts of pricing-task time savings, 2024–2026.

(7)  FMI – The Food Industry Association, The Food Retailing Industry Speaks 2025 (food retail net margin 1.7%), July 15, 2025.

(8)  McKinsey & Company, “Beating the shrink on grocery shelves,” September 2020.

(9)  FMI, The Food Retailing Industry Speaks (department-level shrink rates); private-label penetration data, Numerator/Circana, 2024.

(10)  Gartner, consumer dynamic-pricing survey, released December 16, 2024 (68% feel taken advantage of).

(11)  CivicScience, consumer pricing survey, March 2024 (68% view dynamic pricing as price gouging).

(12)  Stamatopoulos, I., Sanders, R. E., & Bray, R., “Electronic Shelf Labels Have Not Led to Surge Pricing in US Grocery Retail, Despite Regulator Concerns,” SSRN working paper, May 27, 2025; UC San Diego Rady School news release, July 22, 2025.

(13)  Gallego, G., & van Ryzin, G., “Optimal Dynamic Pricing of Inventories with Stochastic Demand over Finite Horizons,” Management Science, 1994; Caro, F., & Gallien, J., “Clearance Pricing Optimization for a Fast-Fashion Retailer,” Operations Research, 2012.

(14)  Sanders, R. E., “Dynamic Pricing and Organic Waste Bans: A Study of Grocery Retailers’ Incentives to Reduce Food Waste,” Marketing Science, Vol. 43, No. 2, 2024 (waste −21%, gross margin +3%); Stamatopoulos, Bassamboo & Moreno, Management Science, 2021; Chehrazi, Sanders & Stamatopoulos, Marketing Science, 2025.

(15)  Andreyeva, T., Long, M. W., & Brownell, K. D., “The Impact of Food Prices on Consumption,” American Journal of Public Health, 2010.

(16)  U.S. Department of Justice and state attorneys general, antitrust action regarding algorithmic rent-setting software (RealPage), 2024–2025.

(17)  Walmart corporate news and shareholder remarks on digital shelf labels, June 2024 and March 2026.

(18)  Financial Times reporting on Walmart pricing patents, March 2026 (via PYMNTS and other outlets).

(19)  Senators Elizabeth Warren and Bob Casey, letter to The Kroger Co., August 5, 2024; Kroger and Microsoft public statements, 2024.

(20)  Schnucks and Hy-Vee deployment coverage, Grocery Dive and Supermarket News, 2024–2025 (vendor- and company-sourced operational figures).

(21)  Consumer Reports and Groundwork Collaborative, “Same Cart, Different Price” investigation, December 2025; Instacart program changes, December 2025.

(22)  CBRE, 2026 North American Investor Intentions Survey (85% of retail investors favor grocery-anchored centers) and U.S. Cap Rate Survey H2 2025.

(23)  JLL, Grocery Tracker 2026 (national grocery-anchored cap rate ~6.7%; vacancy ~3.5%), February 2026.

(24)  Moody’s Ratings, Kroger credit commentary (rating tied to operating performance and leverage); CRE valuation literature on credit-tenant quality and cap rates.

(25)  Placer.ai / JLL, 2025 same-store grocery foot-traffic data (Trader Joe’s +10.4%, Whole Foods +9.8%, Kroger +0.3%).

(26)  U.S. Federal Trade Commission, surveillance-pricing 6(b) study and staff findings, January 2025.

(27)  Federal “Stop Price Gouging in Grocery Stores Act” (H.R. 4966) and related bills, 119th Congress, 2025–2026.

(28)  New York Algorithmic Pricing Disclosure Act, effective November 10, 2025; NRF v. James, S.D.N.Y., dismissed October 8, 2025.

(29)  Maryland Protection from Predatory Pricing Act, signed April 28, 2026, effective October 1, 2026; state-bill tally via Covington/Consumer Reports trackers.

(30)  United Food and Commercial Workers, “Affordable Groceries and Good Jobs” campaign and model legislation, February 2026; National Retail Federation and FMI public positions.