The 1990 World Cup-winning captain believes that the German striker will have to bide his time as he looks to return to the starting line-up after pre-season surgery
Mario Mandzukic and Claudio Pizarro have scored 17 goals between them already this campaign, and Matthaus thinks that the Germany striker may have to play the waiting game as he continues his recovery from ankle surgery he had in the summer.
"He must take a back seat because the injury has him thrown back and others have taken advantage," he told Alendzeitung.
"Gomez is not a new player who has nothing to prove. [Jupp] Heynckes has done well psychologically. But Gomez will not come back and play. He will have to wait to get one or two short appearances.
"Last season he would have been straight back into the starting team but not this season. That is the strength Bayern now have."
Gomez scored 41 goals last season as the German side reached the Champions League final, but Matthaus has insisted that no one can rest on their laurels at the Allianz Arena due to the strength in depth the club now possesses.
"At Bayern there is a trend; everyone is replaceable and they must be good enough to play in the starting 11.
"That is the secret of success. No one can rest, just like last year. Mario had a great three years at Bayern with a superb goal average - but the other strikers have that now too. There will be no free ride for Mario Gomez."
The former Germany captain admitted that he would not know which of the club's three strikers he would pick if they were all fit as they all bring different skills to the table.
"We know he [Gomez] scores goals, but he has to face competition. Last year the competition was Nils Pedersen. And now? All three have a nose for goal and are forwards on a similar level, but of different types.
"Gomez the penalty area striker, Mandzukic rather a combination player who works hard for the team, and Pizarro's qualities you have all seen after so many years.
"If all three are fit, I would not say that one is stronger than the other. The coach may want to vary it to surprise the opposition."