Real Bread Campaign

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An honest crust?

We don't like artificial additives, including so-called processing aids. Real Bread is made without them.

What we like perhaps even less is loaf manufacturers using substances in the making of their products without even mentioning them.

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The situation

We believe that people have the right to make as fully-informed choices as possible about the food they eat. There are three key points of law that hinder people in Britain in obtaining full information about the loaves they buy:

  1. Bakers and retailers are not required to provide customers with full lists of ingredients and any additives they use in making unwrapped loaves - e.g. those from supermarket in-store bakeries.
  2. The use of so-called processing aids can go completely undeclared, even on the ingredient and additive lists of wrapped loaves.
  3. There are no legal definitions for terms commonly used in loaf marketing, including 'fresh' (or 'freshly baked'), 'sourdough', 'wholegrain', 'artisan' and 'craft.'

The problems

Not all loaves are created equal.

Though some of the differences between and industrial loaf and Real Bread are obvious, the loopholes in legislation around unwrapped loaves (such as those sold by supermarket in-store bakeries) means that shoppers may be led to make like-for-like comparisons.

One or more of the following could apply to a supermarket in-store bakery (or should that be 'loaf shop'?) loaf:

  • Made using a number of processing aids and other artificial additives.
  • Baked at sometime in the past at an industrial unit a long diesel-consuming way down a motorway from your local employment opportunities.
  • Rebaked in the supermarket's 'loaf tanning salon', thereby requiring around twice as much energy as an equivalent once-baked loaf, and staling faster than a genuinely fresh loaf.
  • Produced from start to finish by a machine (such as the Genesis) not by a skilled baker employed from within anyone's local community.

But without the supermarket being required to say so, a shopper would be forgiven for making a like-for-like comparison with a loaf of Real Bread from a local independent bakery, which creates skilled jobs for local people making genuinely freshly baked bread without the use of artificial additives.

Britain says: ‘hidden loaf additives are unacceptable’

A survey by the Real Bread Campaign of 1300 people around the UK in October 2011 found that:

  • more than 71% of us believe it’s unacceptable that food additives known as ‘processing aids’ don’t have to appear on an ingredients list for any loaf
  • more than 70% of us believe it’s unacceptable that an ingredient/additives list doesn’t have to be displayed at all for unwrapped loaves

The Real Bread Campaign's demands

We call for an 'Honest Crust Act' that will require:

  1. All bakers and retailers to provide full lists of ingredients (and any processing aids or other artificial additives used) for all loaves on their wrappers. In the case of unwrapped loaves, this information may be provided using shelf labelling.
  2. A legal requirement to declare all additives in flour: currently the four 'token nutrients' added to most UK milled bread flour do not have to be shown on the label and extra powdered dried gluten could be creeping in unannounced, too.
  3. Meaningful, legal definitions for the terms 'fresh' and 'freshly baked' when used in the marketing of loaves - not to be used for 'bake-off' products.
  4. Meaningful, legal definitions for the words (and related terms) 'sourdough', 'artisan', 'wholegrain' and 'craft.'
  5. Section six of the Bread and Flour Regulations 1998 to be tightened and fully enforced to ensure the likes of dried gluten and soya flour do not make their way into loaves sold as wholemeal.
  6. A ban on below-cost selling (other than to reduce the discarding of short-date items) of loaves by multiple retailers, a practice we believe leads to an artificial misperception of the baseline price of this 'Known Value Item'.

In the meantime, we call upon all bakers and retailers voluntarily to provide full information about their loaves, stop marketing to bake-off loaves as fresh, and ensure that the terms 'sourdough', 'artisan' and 'craft' are used appropriately.

Following the French example

On this issue let’s take inspiration from France, which on 13 September 1993 issued Décret n°93-1074 - which could easily be called The Real Bread Act.

This decree (law) states that bread may be marketed/sold as pain de tradition française, pain traditionnel français, pain traditionnel de France, or under similar names only if it is made:

  • without any artificial additives
  • from a mixture of only wheat bread flour, drinkable water and cooking salt
  • bakers' yeast (Saccharomyces cerevisiae) and leaven (as defined below), or one of the two

Permitted optional extras (maximum in relation to flour weight) are 2% bean meal; 0.5% soybean meal; 0.3% malted wheat flour.

The decree also:

  • prohibits the dough or bread from being frozen at any point in the process
  • states that loaves can only be sold/marketed as pain maison (or similar) if it is fully kneaded, shaped and baked (i.e. no bake-off loaves) in the place at which it is sold to the final consumer. The term can also be used when the bread is sold to final consumers elsewhere only if it is sold by the baker who did the kneading, shaping and baking
  • limits the use of the term 'sourdough' to bread with a maximum pH of 4.3 and an acetic acid content of at least 900 parts per million
  • defines the composition of 'leaven'

Food Information for Consumers Regulation

October 2011

The process for the passing of a new EU regulation on food labelling is in its final stages. Once passed, EU member states (including the UK) will have to amend existing laws or pass new ones to bring them into line with the new regulation.

You can read the text of the proposed regulation as agreed by the European Parliament here, and more about the proposals here.

In September, Chris Young of the Campaign sent DEFRA the following email:

Having had chance to read through [the proposed regulation], I have a few questions to which I've been unable to find answers.

What is the EU's definition of 'technological function'? e.g with regard to bread, are any of the following considered to be 'technological functions in the end product'?

  • Prolonging the crumb softness of the finished loaf
  • Increased loaf volume
  • Finer crumb structure
  • Improved crispiness and colour

My belief is that the first definitely is, but I'm not sure about the others.

Am I correct in my reading that the new regulations would make the labelling of the following mandatory:

  • The presence in flour and baked goods of added powdered gluten
  • The presence in flour of added nutrients, including the four (calcium carbonate, iron, thiamin, nicotinic acid/nicotinamide) required by Bread and Flour Regulations 1998 
  • If dough or a part-bake loaf has been frozen before baking for sale - a process that reduces the shelf life
  • The origin of the grain from which flour is milled if different from the country of milling - e.g if flour labelled as British was milled in England but from Canadian wheat
  • The country in which flour is milled, if different from the country in which a product is baked - e.g. if a loaf labelled as French was made from flour milled in France but baked in England, or vice versa  

Closely related to the frozen bake-off question, is regarding a loaf has been part-baked, chilled (but not frozen) and then rebaked. After all, this process does have a negative impact on the shelf life of the loaf, uses twice as much energy as a once-baked loaf, and replaces the potential for a local skilled employment opportunity, with setting an oven timer. We would consider marketing this as 'freshly baked' or simply 'fresh', or failure to indicate that it has been baked twice to be misleading - would DEFRA agree?

On 6 October 2011, we received the following response from DEFRA's Food Policy Unit:

You highlight some useful points and I expect some of these will need further discussion to identify consensus as the new requirements are applied to labels. I have tried to address your questions below.

What is the EU's definition of 'technological function'?

There is no specific definition as far as we are aware of technological function for use in the context of the defrosted provisions. We anticipate the this aspect of the dossier will need some further work to establish consensus on the process that are understood to be captured, bearing in mind the need to balance the burden to businesses and consumers needs. The discussions in the negotiations focused on a limited range of circumstances e.g. meat that is frozen to be sliced and further thought will be needed to identify how this applies to specific food types. This may need input from a range of organisations to achieve a common understanding.

The presence in flour and baked goods of added powdered gluten will need to be labelled

It is likely that powered gluten would need to be labelled unless any specific exemptions apply. Any substance derived from one of the allergens e.g. cereals containing gluten would require labelling.

The presence in flour of added nutrients, including the four (calcium carbonate, iron, thiamin, nicotinic acid/nicotinamide) required by Bread and Flour Regulations 1998 will need to be labelled

It is correct that the nutrients required under the bread and flour regulations will need to be labelled once the transition period for the FIR ends in 3 years time. This reflects that there is less ability for Member States to have national rules as the European requirements are now a regulation. Given the impact on business we have investigated if there is an alternative solution and unfortunately a solution could not be found. 

If dough or a part-bake loaf has been frozen before baking for sale - a process that reduces the shelf life  would need to be labelled.

How the resulting product is sold is important in answering this question. Some products produced this way will be sold non prepacked or prepacked for direct sale in which case the defrosted provisions would not apply. If prepacked, whether not providing the information is considered misleading is dependent on the overall presentation of the product. It is likely that information may be required where consumers as a result of the labelling and manner in which the bread was sold would otherwise think the bread was freshly made on site. This is something to be considered as part of enforcement practice on the FIR.

The origin of the grain from which flour is milled if different from the country of milling - e.g if flour labelled as British was milled in England but from Canadian wheat would need to be labelled

The Commission are charged with developing implementing rules on the Country of Origin provision. As such we would not want to prejudge the result of those discussions as this may influence how information is presented on the label.

The country in which flour is milled, if different from the country in which a product is baked - e.g. if a loaf labelled as French was made from flour milled in France but baked in England, or vice versa would need to be labelled

Again, the Commission are charged with developing implementing rules on the Country of Origin provision. As such we would not want to prejudge the result of those discussions as this may influence how information is presented on the label.

We would consider marketing this as 'freshly baked' or simply 'fresh', or failure to indicate that it has been baked twice to be misleading - would DEFRA agree?

The term fresh in the context of bread is not defined. The Government has produced based practice advice on the criteria for using marketing terms such as fresh. In this it is suggested:

Fresh bread:

46. Terms such as “freshly baked”, “baked in store” and “oven fresh” may mislead consumers into believing that they are being offered products that have been freshly produced on site from basic raw materials. Some stores sell bread made from part-baked products that have been packed in an inert atmosphere or frozen off-site then “baked off” at in-store bakeries. Use of terms like “freshly baked”, “baked in store” and “oven fresh” on these products could potentially infringe the general legal provisions referred to in paragraph 14 above.

Point 14 refers to whether the information is misleading. Ultimately it is for enforcement authorities and the courts to decide if labels are misleading. We will be revisiting this guidance in light of the new provisions in the FIR on misleading labelling.