Her comments were made on BBC Radio 4's Today programme where she was discussing the impact of alcohol-fuelled anti-social behaviour.
ACS chief executive James Lowman said her comments would cause deep offence to the thousands of responsible retailers who worked on the front line of preventing underage drinking.
The association has also sent a strongly worded letter expressing its concerns to the home secretary.
"The convenience store sector has worked hard for a number of years to prevent young people buying alcohol illegally," said Lowman. "There is no evidence that off licences are more likely to sell alcohol to underage drinkers than any other part of the trade, neither is it true that the problem of underage drinking will be solved by sanctions against retailers alone."
Lowman added that the government was "far less advanced" than it should be in developing measures to deter young people from wanting to obtain alcohol illegally, prosecuting those adults who sanction and supply them and cracking down on the multi-million pound black market in alcohol.
"All these elements have to be addressed effectively if we are to make real long-term changes to underage drinking behaviour," he said.