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Real Bread Campaign wholemeal proposal to be adopted

Legal description amongst UK regulatory changes.

Wholemeal flour definition plus 'fortification' exemptions. Credit: Chris Young / CC-BY-SA-4.0

Wholemeal flour definition plus 'fortification' exemptions. Credit: Chris Young / CC-BY-SA-4.0

On 17 January 2024, Defra and DoHSC published a response to the results of the public consultation on proposed amendments to The Bread and Flour Regulations 1998 and The Bread and Flour (Northern Ireland) Regulations 1998, which ran from 1 September to 23 November 2022.

Wholemeal means wholemeal

While the existing Regulations only permit use of the word wholemeal to name and advertise a product if all of the wheat flour used is wholemeal, there is no legal definition of that word. Though not included in the limited scope of the consultation, the Real Bread Campaign had proposed that one is needed.

The consultation response confirms adoption of this: ‘To maintain consumer protection so that consumers can be assured wholemeal flour is authentic, we will be introducing a legal description that means wholemeal flour must consist of the whole product from the milling and grinding of cleaned cereal.’

Real Bread Campaign coordinator Chris Young said:

‘We’re glad that the government listened to us on this point. We welcome this small step towards clearing up the confusion surrounding use of the words wholemeal and wholegrain.’

Complaints by the Real Bread Campaign about companies using the word wholemeal to name and advertise products made using white flour are currently being investigated by trading standards officers at a number of local authorities.


Two new exemptions from the requirement to add so-called fortificants to non-wholemeal wheat flour, which the Real Bread Campaign supported in its submission to the consultation, are:

  • Flour milled from wheat other than Triticum aestivum, such as spelt, emmer, durum, einkorn and khorasan.
  • Flour from mills that produce 500 tonnes or less per year.

Chris Young said:

‘We welcome these changes, which at least offer the choice of additive-free food to a few more people, as well as giving a USP to the farmers, millers and bakers who will produce these flours and make Real Bread from it. It’s frustrating that people who enjoy food made using white and brown wheat flour, which is the vast majority of us in the UK, don’t have that choice.’

Mass medication of the nation

Other changes proposed in the consultation that are now due to be enacted in 2024 include:

  • Increasing the minimum level of calcium carbonate, iron and niacin in non-wholemeal flour to 15% of the nutrient reference value per 100g of flour.
  • Non-wholemeal wheat flour will be required to contain 250 micrograms of folic acid (added in the form of pteroylmonoglutamic acid) per 100 grams of non-wholemeal wheat flour.

The Real Bread Campaign’s position on these issues remains unchanged.

Manufacturers will have 24 months from enactment to comply with the new requirements.

Honest Crust Act

The Real Bread Campaign maintains that this was a missed opportunity to fully review and overhaul outdated regulations related to bread and flour, and continues to lobby for updated and improved composition, labelling and marketing standards.

Please note that this is an initial reaction, based on a first reading of the consultation response.


24 January 2024: Defra replied: 'We are currently preparing to notify the WTO of the draft legislative changes in the coming weeks. The notification process involves a comment period for WTO members, following this we anticipate laying the amending legislation in the summer.'

18 January 2024: We emailed Defra: 'It is good to see that the government has agreed to adopt our proposal of introducing a legal definition of wholemeal flour. We also welcome the new exemptions from 'fortification' requirements for flour milled from wheats other than T. aestivum, and flour milled by mills producing less than 500 tonnes p/a.

What is the timescale of when this year the new Regulations (including the new wholemeal definition), and accompanying guidance, will be published?

Despite the clarity of Regulation 6, trading standards officers at a number of local authorities are still declining to take action against companies using the word wholemeal to name and advertise products containing non-wholemeal flour until they receive the guidance from Defra.'

Published Wednesday 17 January 2024

Real Bread Campaign: The Real Bread Campaign finds and shares ways to make bread better for us, better for our communities and better for the planet. Whether your interest is local food, community-focussed small enterprises, honest labelling, therapeutic baking, or simply tasty toast, everyone is invited to become a Campaign supporter.

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