Will the TPP bring down the price Canadians pay for milk?

Transcription

1 December 1, 2015 Will the TPP bring down the price Canadians pay for milk? Prepared By: Field Agent Canada

2 - Executive Summary Field Agent Canada conducted a cross-country price survey on fluid milk prices at 175 retailers in 19 markets from coast-to-coast between November 23 and November 28, For the second consecutive year, the survey uncovered some huge differences in the price Canadians are paying for one of the most basic grocery items - 2% Milk. There continues to be a huge disparity in milk prices in Canada with the most expensive market paying almost double what consumers are paying in the cheapest market. says Jeff Doucette, General Manager of Field Agent Canada. In addition, the average price per litre has gone up 3 cents in 2015 compared to our 2014 survey. Potentially consumers will get a bit of a break once international competition in the dairy sector opens up under the Trans Pacific Partnership (TPP) deal which was recently announced. hopes Doucette. Quite surprisingly the least expensive city to purchase milk in Canada is Sudbury, Ontario. Sudbury seems to have a very competitive retail marketplace at the moment and milk is a key traffic driver for retailers. Retailers want to have great milk prices because they make an impression on the rest of the store. said Doucette. Again in 2015, the most expensive city to purchase milk in Canada was St. John s, Newfoundland. Average milk prices have come down about 7% in St. John s vs. last year as the two major dairies have ramped up competition in this market. explained Doucette. The main issue in the Newfoundland market is that milk cannot be purchased in 4L packages, making this market unique in Canada. Shoppers do not have the option to buy bigger packages to save money at the checkout. Indeed, all four Atlantic provinces are paying high prices for 2% milk; with prices being 23-47% higher than the Canadian average. Prices in Charlottetown, PEI were just marginally cheaper than those in St. John s, NL. Surprisingly, both Quebec City and Laval which are in the relatively large Quebec market (and the home of the two largest dairy manufacturers - Agropur & Saputo) have prices that are 30% higher than the Canadian average. Where is the cheapest overall milk in Canada? If you shop at Costco in Windsor, London or Nepean, Ontario, you are in luck! These stores has the lowest price for a 4L of 2% milk at just $3.89 per unit. It appears that provincial supply management and inter-provincial trade barriers are causing consumers to pay more to subsidize the profits of small or inefficient producers, manufacturers and distributors. stated Doucette. There really seems to be some potential for a national milk strategy to make our industry more competitive and give consumers a break at the cash register. With the new Liberal government evaluating the Trans Pacific Partnership (TPP) deal that was announced during the Federal election, and the pending free trade deal with the European Union, we may be poised to finally see shift in the price of milk in the Canadian market. Countries like New Zealand and the Netherlands have developed their dairy industry to be driven by exports and Canadian consumers would likely benefit from the liberalisation of the dairy market in Canada. stated Doucette. The Canadian Dairy industry should work to tear down inter-provincial trade barriers and drive efficiencies through more efficient processing and distribution to reduce costs and provide a more competitive price on milk to all Canadians. Contact Us: Jeff Doucette, General Manager, Field Agent Canada jeff.doucette@fieldagentcanada.com

3

4 Contents i) Canadian Fluid Milk Report Highlights ii) Trans Pacific Partnership Overview iii) Supply Management Overview iv) Industry Consolidation & Competition v) Fluid Milk Price Survey

5 Price Survey - Cheapest Milk Across Canada The LEAST EXPENSIVE milk in Canada is at Costco locations in NEPEAN, LONDON & WINDSOR, ON with a 4L package of 2% Milk retailing for $3.89 ($0.97/L). This is the second year that WINDSOR can boast it has the cheapest milk in Canada, however prices are up from $0.91/L last year signalling a cooling off of the milk price war in the border city. The MOST EXPENSIVE milk in Canada is at a 7-Eleven outlet in TORONTO, ON with a 2L 2% Milk retailing for $5.19 ($2.60/L). This is the second year in a row that we found the most expensive milk price at this downtown location. The same package of 2L 2% Milk retails for $4.99 at a 7- Eleven outlet in Mississauga, ON. If you need milk in downtown Toronto it can be VERY expensive!

6 Least Expensive / Most Expensive Least Expensive Milk Costco - Windsor, London & Nepean, ON 4L - $3.89 Cost Per Litre = $0.97 Most Expensive Milk 7-Eleven - Toronto, ON 2L - $5.19 Cost Per Litre = $2.60

7 Price Survey - Cheapest Overall City To Purchase Milk The LEAST EXPENSIVE city to buy milk in Canada is SUDBURY, ON with an average cost of $3.97 ($0.99/L) on 4L packages of 2% milk. The MOST EXPENSIVE city to buy milk in Canada is ST JOHN S, NL with an average cost per litre of $3.63 ($1.82/L) on 2L packages of 2% milk (no 4L packages available). The average cost per litre in ST JOHN S, NL is almost DOUBLE the average cost per litre in SUDBURY, ON.

8 Average Price by Market Survey 2015 Average Current Price 2% Milk - 4L Size Average Price Per Litre Index v. National Rank Average Current Price 2% Milk - 2L Size Average Price Per Litre National Average $4.90 $ $3.74 $ Index v. National Rank St. John s, NL NA NA NA NA $3.63 $ Halifax, NS $6.04 $ $3.48 $ Moncton, NB $6.44 $ $3.37 $ Charlottetown, PE $7.20 $ $3.61 $ Quebec City, QC $6.32 $ $3.52 $ Laval, QC $6.40 $ $3.49 $ Ottawa / Nepean, ON $4.10 $ $3.82 $ Mississauga, ON $4.13 $ $3.93 $ Scarborough, ON $4.14 $ $3.77 $ Toronto, ON $4.31 $ $4.10 $ London, ON $4.13 $ $4.06 $ Windsor, ON $4.21 $ $3.93 $ Sudbury, ON $3.97 $ $3.81 $ Winnipeg, MB $4.84 $ $3.54 $ Regina, SK $4.89 $ $3.68 $ Calgary, AB $4.82 $ $3.76 $ Kelowna, BC $4.98 $ $3.78 $ Burnaby / Coquitlam, BC $4.87 $ $3.66 $ Victoria, BC $4.82 $ $3.84 $

9 Average Price by Market Survey 2014 Average Current Price 2% Milk - 4L Size Average Price Per Litre Index v. National Rank Average Current Price 2% Milk - 2L Size Average Price Per Litre National Average $4.80 $ $3.74 $ Index v. National Rank St. John s, NL NA NA NA NA $3.92 $ Halifax, NS $ $3.80 $ Moncton, NB $6.44 $ $3.32 $ Charlottetown, PE $7.24 $ $3.62 $ Quebec City, QC NA NA NA NA NA NA NA NA Laval, QC $6.28 $ $3.46 $ Ottawa / Nepean, ON $4.28 $ $4.00 $ Mississauga, ON $4.12 $ $3.86 $ Scarborough, ON $3.92 $ $3.70 $ Toronto, ON $4.44 $ $4.14 $ London, ON $4.12 $ $3.90 $ Windsor, ON $4.40 $ $3.88 $ Sudbury, ON $4.00 $ $3.96 $ Winnipeg, MB $4.80 $ $3.46 $ Regina, SK $4.72 $ $3.86 $ Calgary, AB NA NA NA NA NA NA NA NA Kelowna, BC $4.88 $ $3.66 $ Burnaby / Coquitlam, BC $4.92 $ $3.52 $ Victoria, BC NA NA NA NA NA NA NA NA

10 Trans Pacific Partnership Overview During the recent Federal election Canada agreed in principle to the Trans Pacific Partnership (TPP) deal which includes provisions to open up 3.25% to other signing countries such as the U.S., New Zealand and Australia. While this is not a significant amount of volume it may work as a wake-up call to Canadian milk producers and processors to work to tear down the inter-provincial trade barriers and resulting inefficiencies in processing to provide Canadians with more affordable milk right across the country. Under the TPP, the controversial Supply Management programs in place in each province will still stand but they will need to make adjustments for the new imported volume. Canada will also make available part of the $450 million processor modernisation fund to the dairy industry. Consumers should demand that companies that access the fund do so to create larger more efficient processing facilities designed to supply a wider trans-provincial market. Th dairy industry will also be able to draw on a $2.4 billion income support program to recover losses due to the new imports being allowed into the market. Under the TPP, Canadian produced milk will still be required to be hormone free while imports will not be required to meet these standards. This will likely be the best marketing point of attack against imports, although Health Canada has not found any health issue in consuming milk that contain growth hormones.

11 Supply Management Overview Canada incorporates a dairy supply-management system that sets production limits on Canadian farmers and sets the supply of dairy available to Canadian consumers. As a result, dairy prices are set to match planned production and this helps protect dairy farmers. These dairy supply-management practices in Canada have been criticized as being too restrictive on supply leading to higher prices for consumers. Provincial marketing boards set the price for fluid milk or drinking milk supplied to grocery stores. This type of milk garners the highest price in the marketplace. Provincial boards set limits on the production of fluid milk within each province. This enables supply to equal demand and prices are set according to this formula. The Canadian Diary Commission, also known as the CDC (chair of the Canadian Milk Supply Management Committee or CMSMC) also intervenes in buying or selling certain dairy commodities at desired support prices in order to maintain a chosen level of milk production. The support prices then help set industrial milk prices.

12 Supply Management Overview The provinces have been freely trading industrial milk, but the CDC sets an overall country-wide limit on the amount of industrial milk that may be produced. The CMSMC allots milk between the provinces according to demand. Industrial milk is sold to processors, which turn the milk into fluid milk, ice cream, yogurt and other milk products. Processors then sell the various dairy products to grocery stores at minimum wholesale prices and customers are charged minimum milk prices marked up by expenses and margins. Total allowable milk production is divvied up to farmers holding quotas that enable milk production and the amount of quotas rises and falls depending on desired output. Provincial marketing boards are in charge of overseeing the fulfilment of production quotas. The federal government helps support the whole supplymanagement process by retaining import tariffs in order to prevent lower priced dairy products entering the Canadian marketplace.

13 Industry Consolidation & Competition The dairy Canadian marketplace has undergone a series of consolidation attempts in recent years. Agropur is one of the major players in the Canadian dairy industry and the largest dairy cooperative in Canada. It was founded in 1938 and is headquartered in Longueuil, Quebec. Currently it has sales of more than $3.8 billion along with 3,554 dairy producer owners and 6,500 employees. The company processes more than 3.4 billion litres of milk per year from its 32 plants across North America. Some of Agropur s brands include: Lucerne, Natrel, Fine cheeses, Sealtest, Ultima Foods, Island Farms, Logo, Quebon, Olympic, Cook's, Anco, Oka, Farmer s Dairy, Central Dairies, Grand Cheddar and Allegro. In 2014, Agropur purchased Sobeys dairy manufacturing facilities in Western Canada to supply dairy to Sobeys, Safeway and IGA stores in Western Canada. The $356 million deal will see Agropur adopt Lucerne trademarks. Agropur also purchased Northumberland Dairy Cooperative in The purchase included the Miramichi plant in New Brunswick along with a total operations purchase of $67 million in annual sales.

14 Industry Consolidation & Competition In 2013, Agropur purchased Cook s Dairy, which gave the company a stronger position in Nova Scotia and output of 2.7 million litres of fluid milk. Agropur s board of directors also merged with the Board of Directors of Farmers Co-operative Dairy Limited. In 2014, the other major Canadian player Saputo, acquired the fluid milk assets of Scotsburn Co-operative Services Limited based in Atlantic Canada for $61 million. Saputo is one of the top ten dairy processors in the world, the largest in Canada and the third largest in Argentina. The company s products are sold in more than 40 countries and some popular brands include Saputo, Alexis de Portneuf, Armstrong, Baxter, Dairyland, Dragone, DuVillage 1860, Friendship, Frigo Cheese Heads, Great Midwest, King s Choice, Kingsey, La Paulina, Milk2Go, Neilson, Nutrilait, Ricrem, Salemville, Scotsburn, Stella and Treasure Cave. In 2008, Saputo acquired Neilson Dairy, the dairy division of Weston Foods (Canada) Inc. Neilson produced a variety of dairy products including fluid milk, butter, yogurt, juices, drink and others primarily in Ontario.

15 St. John s, NL Circle K NA NA $3.65 $1.82 Costco NA NA $3.37 $1.69 Dominion NA NA $4.17 $2.09 Needs NA NA $3.70 $1.85 Shoppers Drug Mart NA NA $3.49 $1.75 Sobeys NA NA $3.69 $1.85 Walmart NA NA $3.37 $1.69 $1.69 $1.82 $2.09

16 Halifax, NS Circle K $5.99 $3.25 $1.62 Costco $5.19 $1.30 NA NA Needs $8.49 $2.12 $3.65 $1.82 Shoppers Drug Mart $5.59 $1.40 $3.19 $1.60 $1.30 $1.51 $2.12 Sobeys $5.69 $1.42 $3.69 $1.85 Superstore $5.69 $1.42 $3.69 $1.85 Walmart $5.67 $1.42 $3.39 $1.70 $1.60 $1.74 $1.85

17 Charlottetown, PE Circle K NA NA $3.60 $1.80 Needs NA NA $3.50 $1.75 Shoppers Drug Mart $7.08 $1.77 $3.49 $1.75 $1.77 $1.80 $1.82 Sobeys $7.18 $1.80 $3.69 $1.85 Superstore $7.27 $1.82 $3.69 $1.85 Walmart $7.27 $1.82 $3.67 $1.84 $1.75 $1.80 $1.85

18 Moncton, NB Circle K $7.25 $1.81 $3.40 $1.70 Costco $6.22 $1.56 $3.31 $1.66 Needs NA NA $3.50 $1.75 $1.56 $1.61 $1.81 Shoppers Drug Mart $6.39 $1.60 $3.31 $1.66 Sobeys $6.25 $1.56 $3.39 $1.70 Superstore $6.25 $1.56 $3.39 $1.70 Walmart $6.25 $1.56 $3.33 $1.67 $1.66 $1.69 $1.75

19 Quebec City, QC Boni Soir $6.21 $1.55 $3.54 $1.77 Costco $6.21 $1.55 $3.39 $1.70 Couche-Tard $6.99 $1.75 $3.75 $1.87 $1.55 $1.58 $1.75 IGA Extra $6.21 $1.55 $3.54 $1.77 Maxi $6.21 $1.55 $3.54 $1.77 Pharmaprix $6.21 $1.55 $3.24 $1.62 Provigo $6.45 $1.61 $3.54 $1.77 Super C $6.21 $1.55 $3.54 $1.77 Walmart $6.21 $1.55 $3.54 $1.77 $1.76 $1.87 $1.62

20 Laval, QC Boni Soir $6.81 $1.70 $3.54 $1.77 Costco $6.21 $1.55 $3.39 $1.70 Couche-Tard $6.75 $1.69 $3.54 $1.77 $1.55 $1.60 $1.74 IGA Extra $6.21 $1.55 $3.54 $1.77 Loblaws $6.21 $1.55 $3.54 $1.77 Metro $6.21 $1.55 $3.54 $1.77 Pharmaprix $6.21 $1.55 $3.24 $1.62 Provigo $6.21 $1.55 $3.54 $1.77 Super C $6.21 $1.55 $3.54 $1.77 Walmart $6.97 $1.74 $3.47 $1.74 $1.62 $1.74 $1.77

21 Ottawa / Nepean, ON Costco $3.89 $0.97 $3.95 $1.98 Food Basics $3.97 $0.99 $3.79 $1.90 FreshCo $3.97 $0.99 $3.69 $1.85 Independent $3.97 $0.99 $3.99 $2.00 $0.97 $1.03 $1.37 Loblaws $3.97 $0.99 $3.99 $2.00 Mac's $5.49 $1.37 NA NA Metro $3.99 $1.00 $3.79 $1.90 Shoppers Drug Mart $3.97 $0.99 $3.89 $1.95 Sobeys $3.97 $0.99 $3.47 $1.74 Superstore $3.97 $0.99 $3.79 $1.90 Walmart $3.97 $0.99 $3.87 $1.94 $1.91 $2.00 $1.74

22 Mississauga, ON 7-Eleven $5.89 $1.47 $4.99 $2.50 Costco $3.95 $0.99 NA NA Food Basics $3.97 $0.99 $3.79 $1.90 FreshCo $3.97 $0.99 $3.69 $1.85 $0.99 $1.03 $1.47 Loblaws $3.97 $0.99 $3.99 $2.00 Mac's $3.99 $1.00 NA NA Metro $3.99 $1.00 $4.19 $2.10 No Frills $3.97 $0.99 $3.77 $1.89 Shoppers Drug Mart $3.97 $0.99 NA NA Sobeys $3.97 $0.99 $3.47 $1.74 Superstore $3.97 $0.99 $3.87 $1.94 Walmart $3.97 $0.99 $3.58 $1.79 $2.50 $1.96 $1.74

23 Scarborough, ON Costco $3.95 $0.99 NA NA Food Basics $3.97 $0.99 $3.79 $1.90 FreshCo $3.97 $0.99 $3.69 $1.85 Mac's $4.99 $1.25 $3.49 $1.75 $0.99 $1.03 $1.25 Metro $4.49 $1.12 $4.19 $2.10 No Frills $3.97 $0.99 $3.69 $1.85 Shoppers Drug Mart $3.97 $0.99 $3.89 $1.95 Superstore $3.97 $0.99 $3.87 $1.94 Walmart $3.97 $0.99 $3.58 $1.79 $2.10 $1.75 $1.89

24 Toronto, ON 7-Eleven $5.89 $1.47 $5.19 $2.60 Food Basics $3.97 $0.99 $3.79 $1.90 FreshCo $3.97 $0.99 $3.69 $1.85 Hasty Market $3.99 $1.00 $4.99 $2.50 $0.99 $1.08 $1.47 Loblaws $3.97 $0.99 $3.99 $2.00 Mac's $3.99 $1.00 $3.50 $1.75 Metro $4.69 $1.17 $4.19 $2.10 No Frills $3.97 $0.99 $3.69 $1.85 Shoppers Drug Mart $3.97 $0.99 $3.89 $1.95 Sobeys $4.69 $1.17 $4.09 $2.05 $2.60 $2.05 $1.75

25 London, ON 7-Eleven $5.79 $1.45 $4.99 $2.50 Costco $3.89 $0.97 NA NA Food Basics $3.97 $0.99 $3.79 $1.90 FreshCo $3.97 $0.99 $3.69 $1.85 $0.97 $1.03 $1.45 Loblaws $3.97 $0.99 $4.29 $2.15 Mac's $3.99 $1.00 $4.99 $2.50 Metro $3.99 $1.00 $3.79 $1.90 No Frills $3.97 $0.99 $3.69 $1.85 Shoppers Drug Mart $3.97 $0.99 $3.89 $1.95 Sobeys $3.97 $0.99 $4.17 $2.09 Superstore NA NA $3.79 $1.90 Walmart $3.97 $0.99 $3.58 $1.79 $2.50 $2.03 $1.79

26 Windsor, ON 7-Eleven $5.89 $1.47 $4.99 $2.50 Costco $3.89 $0.97 NA NA Food Basics $3.97 $0.99 $3.79 $1.90 FreshCo $3.97 $0.99 $3.69 $1.85 $0.97 $1.05 $1.47 Mac's $3.99 $1.00 NA NA Metro $3.99 $1.00 $3.79 $1.90 No Frills $4.97 $1.24 NA NA Shoppers Drug Mart $3.97 $0.99 $3.89 $1.95 Sobeys $3.97 $0.99 $3.47 $1.74 Superstore $3.97 $0.99 $3.87 $1.94 Walmart $3.97 $0.99 $3.87 $1.94 Zehrs $3.97 $0.99 $3.99 $2.00 $2.50 $1.96 $1.74

27 Sudbury, ON Costco $3.95 $0.99 NA NA Food Basics $3.97 $0.99 $3.79 $1.90 Metro $3.99 $1.00 $3.79 $1.90 Shoppers Drug Mart $3.97 $0.99 $3.89 $1.95 $0.99 $0.99 $1.00 Superstore $3.97 $0.99 $3.69 $1.85 Walmart $3.97 $0.99 $3.87 $1.94 $1.85 $1.90 $1.95

28 Winnipeg, MB 7-Eleven $5.99 $3.99 $2.00 Co-op $4.99 $1.25 $2.99 Costco $4.45 $1.11 NA NA Mac's $5.49 $1.37 $4.49 $1.11 $1.21 Safeway $4.59 $1.15 $3.19 $1.60 Shoppers Drug Mart $4.59 $1.15 $3.79 $1.90 Sobeys $4.59 $1.15 $2.99 Superstore $4.45 $1.11 $3.37 $1.69 Walmart $4.45 $1.11 $3.47 $1.74 $1.77

29 Regina, SK 7-Eleven $6.39 $1.60 $4.39 $2.20 Co-op $5.09 $1.27 $3.59 $1.80 Costco $4.45 $1.11 NA NA Extra Foods $4.68 $1.17 $3.35 $1.68 $1.11 $1.22 $1.60 Mac's $5.49 $1.37 $4.49 Safeway $4.59 $1.15 $3.39 $1.70 Shoppers Drug Mart $4.59 $1.15 $3.79 $1.90 Sobeys $4.59 $1.15 $3.39 $1.70 Superstore $4.54 $1.14 $3.37 $1.69 Walmart $4.45 $1.11 $3.37 $1.69 $1.68 $1.84

30 Calgary, AB 7-Eleven $5.99 $4.59 $2.30 Co-op $4.99 $1.25 $3.39 $1.70 Costco $4.45 $1.11 NA NA Mac's $5.49 $1.37 $4.49 $1.11 $1.20 No Frills $4.50 $1.13 $3.25 $1.63 Safeway $4.54 $1.14 $3.59 $1.80 Shoppers Drug Mart $4.49 $1.12 $3.89 $1.95 Superstore $4.45 $1.11 $3.37 $1.69 Walmart $4.46 $1.12 $3.47 $1.74 $2.30 $1.88 $1.63

31 Kelowna, BC 7-Eleven $6.39 $1.60 $4.09 $2.05 Costco $4.45 $1.11 NA NA Extra Foods $4.69 $1.17 $3.39 $1.70 Mac's $5.49 $1.37 $4.49 $1.11 $1.25 $1.60 Safeway $4.89 $1.22 $3.49 $1.75 Save On Foods $4.89 $1.22 $3.65 $1.83 Shoppers Drug Mart $4.59 $1.15 $3.99 $2.00 Superstore $4.47 $1.12 $3.37 $1.69 $1.89 $1.69

32 Burnaby / Coquitlam, BC 7-Eleven $5.99 $3.99 $2.00 Costco $4.45 $1.11 NA NA Extra Foods $4.69 $1.17 $3.39 $1.70 IGA Marketplace $5.79 $1.45 $3.79 $1.90 $1.11 $1.22 Mac's $5.49 $1.37 $4.49 No Frills $4.46 $1.12 $3.37 $1.69 Safeway $4.69 $1.17 $3.39 $1.70 Save On Foods $4.69 $1.17 $3.39 $1.70 Shoppers Drug Mart $4.49 $1.12 $3.79 $1.90 Superstore $4.45 $1.11 $3.37 $1.69 Thrifty Foods $4.79 $1.20 $3.69 $1.85 Walmart $4.45 $1.11 $3.57 $1.79 $1.69 $1.83

33 Victoria, BC 7-Eleven $5.99 $4.39 $2.20 Costco $4.45 $1.11 NA NA Mac's NA NA $4.49 Save On Foods $4.79 $1.20 $3.59 $1.80 $1.11 $1.20 Shoppers Drug Mart $4.79 $1.20 $3.99 $2.00 Superstore $4.45 $1.11 $3.37 $1.69 Thrifty Foods $4.79 $1.20 $3.69 $1.85 Walmart $4.45 $1.11 $3.37 $1.69 $1.92 $1.69

34 - Methodology Price audits were conducted using Field Agent Canada s panel of over 45,000 smartphone users who have downloaded our free app and conduct audits, mystery shops and shopper surveys from Coast-to-Coast. Data was collected in 175 stores from November 23rd to November 28th in 19 markets across Canada with at least one market in each of the ten provinces. We measured retail prices on 2% milk products which represent the largest segment of Canadian Fluid Milk sales. Agents collected the regular price point and any promotional price points available for 2% Milk including both 2L and 4L sizes, and carton, jug and bagged formats. The CURRENT PRICE reflected in this report is the retail shelf price including any current promotions. When a multi-buy promotion is in place the cost per unit is the promotion price divided by the number of required units purchased. When prices have a limit (i.e. $4.99, over 2 units pay $5.99) the lower price per unit is assumed. Prices recorded were the prices shown on shelf tags, on-pack price stickers or store signage. Where prices were not available the current price was sourced through the store clerk and recorded. When multiple offerings of 2% milk were present, the lowest priced 2% Milk in both the 2L and 4L segments was recorded. Prices are for base milk products. Value added products such as fine-filtered, organic or lactose free varieties were excluded.