M&S on a (non-UPF) roll?
Real Bread Campaign coordinator Chris Young considers the retailer’s ‘only five ingredients’ claim.
At face value, M&S making rolls with ‘only 5 ingredients’ appears to be a positive step, giving more people the chance to choose additive-free food. If the product is indeed free from all additives and not an ultra-processed food (UPF), it’s a clear signal that it is possible to manufacture Real Bread at scale, in a way that meets the needs of the supermarket distribution and retail system.
Clean product or just clean label?
M&S has not listed any additives on the ingredients panel of the product. This is great news, neatly disproving the ‘using additives is the only way we can give people what they want’ type claims I’ve heard from industrial dough fabricators over the past 16 years. Here’s an additive-free product that’s apparently soft and fluffy (full disclosure – I haven’t tried one), with a shelf-life of several days.
Is the product truly ‘clean label’, though? By this I mean: is it manufactured without the use of any so-called ‘processing aids’? This is a way of categorising an additive that allows a manufacturer to choose to leave it off the label. To be clear, while the law permits a manufacturer not to declare a ‘processing aid’ it does not prevent them from doing so. (The law doesn’t require companies to make marketing claims, either, yet they all seem more than willing and able to do so prominently and in abundance.)
I also wonder: now that M&S has demonstrated that additives are unnecessary, when will the company remove them all from every other product in its own-brand bread and bakery ranges?
How many ingredients?
While the Real Bread Campaign welcomes M&S launching an additive-free (pending an answer to the ‘processing aids’ question) product, we have concerns about the company’s information provision and marketing of it. The ingredients listed on the M&S website are:
- Wheatflour
- Water
- Wildfarmed wheatflour
- Rye flour
- Dried fermented wheatflour
- Wheat gluten
- Salt
- Yeast
- Vitamin D Yeast
- Wholemeal wheatflour
- Wheatflakes
By my count that’s 11 entries on the ingredients list - 15 if you include the four so-called 'fortificants' that were added by law to the non-wholemeal wheat flour.
Even if you gave M&S the benefit of the doubt by counting the three instances of refined wheat flour as a single ingredient, and doing the same for wholemeal wheat flour plus wheat flakes; and pretended the two types of yeast were just one; the product still would have seven ingredients. Why has M&S chosen to overclaim (or is that underclaim?) by saying it's made from ‘only 5 ingredients’? Doesn’t this breach consumer protection legislation? To my mind, it is disingenuous at the very least.
Assuming this product is made without any undeclared ‘processing aids’, surely ‘this is Real Bread’ is USP enough, setting it apart from perhaps around 90% or more of what is sold as ‘bread’ in the UK. Why not put the actual ingredients list on the front, sign up to The Real Bread Loaf Mark scheme and be done with it?
QUID pro (sour)dough
On the front of pack, M&S claims the product is made with ‘51g sourdough culture’, presumably to benefit from the marketing value of that term. The ingredients list, however, makes no reference to sourdough culture, let alone give the quantitative ingredient declaration (QUID) required due to it being emphasised on the pack front.
Does the front of pack claim relate to the dried fermented flour on the ingredients list? If so, can M&S confirm that this contains live / active yeasts and lactic acid bacteria, as the term ‘culture’ denotes and implies, rather than an inactive powder thrown in for a bit of flavour and tang? I also wonder why M&S has used different terms on the front and back of pack, which has left me guessing and is sure to confuse the average shopper.
Brand name on an ingredients list
The ingredients panel of this product lists ‘Wildfarmed wheatflour’. Why? The selling point of this product is that it has fewer components than many other rolls available in supermarkets, hence M&S choosing to bundle ingredients together for the front of pack count. So why has the company chosen to then declare the refined wheat flour from one supplier separately on the ingredients panel from the rest of the refined wheat flour from other (unnamed) suppliers, unnecessarily adding an entry to the list? Is it so M&S can attempt to profit from the marketing value of using ‘regenerative farming’ claims?
More importantly, Article 18.2. of Regulation (EU) No 1169/2011 on the provision of food information to consumers requires: 'Ingredients shall be designated by their specific name, where applicable, in accordance with the rules laid down in Article 17…'
Article 17.1 states: 'The name of the food shall be its legal name....' with Article 17.4 adding: 'The name of the food shall not be replaced with a name protected as intellectual property, brand name or fancy name.'
The specific name of this ingredient is wheat flour. ‘Wildfarmed wheatflour’ is a brand name, protected as intellectual property.
Watch this space
Again, we welcome M&S doing something positive that, hopefully, will encourage the company and others to get real by kicking all additives out of all of their bread type products. At the same time, we have concerns that retailer is being a bit too enthusiastic in the way that it’s marketing the move.
If all or any of this has got you scratching your head as well, please watch this space* as I’ve asked M&S these questions and will be reporting back as and when I receive answers.
*by which I mean sign up to our free enewsletter list (or, better still, join us as a Campaign supporter) at our website.
See also
Updates
10 April 2025: A member of the M&S customer care team replied: 'My colleague has raised your questions with the appropriate team and as soon as I have a response, I will be in contact. Unfortunately, this can take up to six weeks. Thank you for your patience in this matter.'
9 April 2025: We asked M&S when we can expect answers to our questions.
3 April 2025: M&S responded: 'Thank you for your interest in our 'Only 5 Ingredient' rolls. We appreciate your inquiry and have forwarded your email and information to our senior buyer, who oversees these pre-packed goods. They will be in touch with you shortly to discuss your request in more detail.'
Published Thursday 3 April 2025
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