Where are The Bread Police?

Since 2009, the Real Bread Campaign has pursued many complaints about labelling and marketing we believe to be misleading, untruthful or simply inaccurate. This is often a long, tedious process, with outcomes I believe aren’t always in the best interests of the people that consumer protection bodies are there to safeguard.

How it should work

If you have evidence of apparently dodgy practices by a food manufacturer or retailer, it falls within the remit of the trading standards (or, in some cases, environmental health) department of your local authority (LA).

Companies (such as supermarket chains and national brands) that trade across multiple LA areas can set up a Primary Authority (PA) partnership with one of them – typically where the head office is – for regulatory matters. If another LA receives a complaint they believe warrants investigation, they will usually contact the PA about how to proceed.

What’s going wrong?

One of the main challenges to swift and appropriate resolution of every trading standards case is insufficient (and continually falling) government funding and, therefore, staffing of trading standards services. Many LA trading standards departments, therefore, unsurprisingly focus their dwindling staff time on protecting people from the likes of smuggled fags, counterfeit vodka and fake Labubu dolls that might choke kiddies. Protection from being ripped off by companies’ misleading marketing of products that are freshly faked in loaf tanning salons, hardly wholegrain, artisan from an automated factory, or sourfaux, struggle to get a look in.

Published by civil society organization Unchecked UK, The UK’s Enforcement Gap 2020 reported that between 2009 and 2019, net spending on trading standards in England fell by 52% with the Food Standards Agency’s funding being cut by 51%. In June 2024, the Chartered Trading Standards Institute reported that people in the UK are ‘losing £54bn to rip-offs, rogue traders and unfair business practices’, and called for an extra £25m a year to bolster trading standards services. An August 2025 report by Which? highlighted a raft of concerns about variations between local authorities in funding, data collection, priorities and accountability in their trading standards services.

Some LAs no longer accept trading standards complaints direct from taxpayers, instead requiring us to jump the extra hurdle of contacting Citizens Advice to assess the case and decide if they’ll pass it on to the relevant LA.

(Not) getting fresh

In late 2024, we discovered that Defra had quietly 'archived' the government's ‘Criteria for the use of the terms fresh, pure, natural etc. in food labelling’, with no plan for updating or replacing this statutory guidance.

This was despite this guidance to preventing misuse of these descriptions being of ongoing value to food businesses, the trading standards service, the Advertising Standards Authority and other consumer protection bodies.

We continue to call for this guidance to be reinstated as an interim measure, pending a full review and overhaul.

Walking through syrup

As an example, we have been pursuing a complaint about Morrisons in-store 'bakery' marketing for more than a year. This has involved being passed back and forth between four local authorities. A very much abbreviated history is:

• 11 June 2024: We sent the complaint to Wakefield Council, which according to the BEIS website has the Primary Authority relationship with Morrisons for trading standards.
• 12 June 2024: Wakefield replied that it is not Morrisons' PA for trading standards, copying in the relevant officer at West Yorkshire Joint Services (WYJS).
• 31 July 2024: WYJS said we needed to send the complaint to our local authority, which is London Borough of Tower Hamlets (LBTH).
• 28 August 2024: LBTH advised us they had passed the case back to WYJS and we should liaise directly with them.
• 3 September 2024: WYJS contradicted this, advising we needed to contact LBTH. We emailed both local authorities, asking them to decide between them who will take responsibility.
• [We then spent almost seven months pursuing WYJS and LBTH for an update on the case.]
• 31 March 2025: We found new evidence in the case at a Morrisons store in Croydon and submitted it to WYJS.
• 8 April 2025: Despite this being an existing, national case, WYJS advised we needed to submit the evidence to Croydon Council.
• 15 April 2025: Croydon responded they had passed the evidence to WYJS.
• [We spent three months trying to get an update on the case from Croydon.]
• 16 July 2025: Croydon advised they would not be taking any further action.
• 18 July 2025: We asked WYJS for an update.
• 17 September 2025: We asked WYJS for an update.

Who’s responsible?

To get definitive information on which of these three LAs is officially responsible for handling the case, and the system in place to ensure that LA did so, we contacted National Trading Standards (a subsidiary company of the Chartered Trading Standards Institute), Defra and the Food Standards Agency. In summary, their responses were:

• Defra: On 19 September, Defra replied to our 24 July (!) email, saying that LAs are responsible, rather than the FSA. Oddly, the resonse didn't mention Defra.
• The Food Standards Agency: ‘The FSA will not routinely have involvement in assessing individual activities by LAs, such as specific complaint investigations.’
• National Trading Standards: ‘Unfortunately this is not a matter that we would be able to help you with as NTS is not an enforcement or advice body.’

All three bodies advised that someone unhappy with how a trading standards department has handled a case can escalate it through that local authority’s complaints procedure. If unsatisfied with the result of a review, the complainant can next take the case to the Local Government Ombudsman.

None of this answers the question of which LA is responsible in this case, so do we need to escalate it through the complaints procedures of all three?

What now?

I understand that most (and probably every) LA trading standards department is underfunded, therefore understaffed and overstretched. I also appreciate that they have to prioritise cases where direct causal links to potential physical harm or financial loss are clear. There remains, however, the need to protect people (and business owners) from the effects of inaccurate, untruthful and / or misleading information and marketing remains.

Who does that leave to be The Bread Police? Me? Earlier this year, lack of funds forced Sustain to cut staff (i.e. my) time on the Real Bread Campaign by 25%. How much of my three days a week can I and should I justify spending on pursuing individual cases, when I know each is likely to be a protracted battle lasting months or over a year?

How should this sit alongside our Honest Crust Act lobbying and within the rest of our work championing Real Bread and people who make it, while challenging obstacles to their rise, towards a future in which everyone has a realistic chance to choose Real Bread?

Here are ways that you can help ensure that Sustain can keep running the Real Bread Campaign into 2026 and beyond.

See also

Ongoing cases also include:

• Non-wholemeal flour in 'wholemeal' products: Includes complaints dating to 2018. Partly resolved – awaiting response from LBTH, which in turn is waiting on a response from Defra.
• Waitrose 'in-store bakery' marketing: complaint submitted to LBTH on 3 March 2025
• Sainsbury's ‘in-store bakery’ marketing: partly resolved – 'freshly made' and 'freshly baked' claims still being used in some stores. 
• Co-op 'in-store bakery' marketing: complaint submitted to Manchester City Council on 7 February 2024.
• Asda ‘in-store bakery’ marketing: complaint submitted to West Yorkshire Joint Services on 3 July 2024.
• Tesco ‘in-store bakery’ marketing: complaint submitted to Hertfordshire County Council on 28 May 2024
• Lidl ‘in-store bakery’ marketing: complaint submitted to London Borough of Bexley on 20 September 2023. Partly resolved.
• M&S 'in-store bakery' marketing: complaint submitted to Birmingham City Council on 25 June 2024.
• M&S 'heritage' wheat claim: complaint submitted to Birmingham City Council on 29 April 2025
• M&S 'Only X ingredients' claims: complaint submitted to Birmingham City Council on 19 May 2025 and the ASA on 24 June 2025.
• M&S marketing modern variety rye flour as an 'ancient wheat variety': Complaint submitted on 23 May 2025 to M&S, which passed it on to Birmingham City Council. 
• Kingsmill USDA-based health claim: complaint submitted to the ASA and LBTH on 24 April 2025. Trading standards case remains unresolved. 
• Costco sourfaux: complaint submitted to Aberdeenshire County Council by a Campaign supporter on 18 December 2023

…and we’re still deciding whether to saddle up to submit complaints about companies choosing not to name the added preservative propionic acid on ingredients lists.