My claim is that the convenience of having milk at the front of the store would not be of sufficient value to overcome the higher price supermarkets would have to charge to cover the costs of putting the milk near the front.
Why is Milk in the Back of the Store?
Russ Roberts

Wouldn’t all of these arguments also apply to the items in the freezer aisle and in the sometimes refrigerated beer section? I can only speak to the grocery stores I have visited but all of them feature some kind of refrigeration that is also not on the back walls. They often feature confectioneries, sodas, and other luxury goods.
It seems like the ‘necessity vs luxury’ property is a much stronger predictor of where an item will be located rather than cost of storage or convenience due to more frequent need by the customer.

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