What’s ‘wholemeal’ hiding?

In light of new guidance from Defra, the Real Bread Campaign has launched an investigation into brands using the word ‘wholemeal’ to name products containing non-wholemeal flour.

Most notable of the Campaign’s findings was a product manufactured by Roberts, in which half of the flour was white.

Regulation 6 of The Bread and Flour Regulations demands that: 'There shall not be used in the labelling or advertising of bread, as part of the name of the bread, whether or not qualified by other words - the word "wholemeal" unless all the flour used as an ingredient in the preparation of the bread is wholemeal.'

Real Bread Campaign coordinator Chris Young said: ‘The Regulations are clear that if any non-wholemeal wheat flour is used, the word wholemeal must not appear in the product name. Highlighting the presence of other flour does not grant an exemption, nor do the Regulations include a minimum-quantity threshold.’

Not all wholemeal

In April 2025, the Campaign looked at products manufactured by / for the UK’s 10 biggest supermarket chains and other large industrial dough fabricators. The Campaign found the following brands using the word ‘wholemeal’ in the name of one or more products in which non-wholemeal wheat was used as an ingredient:

• Asda
• The Co-op
• Hovis
• Iceland
• Jacksons
• M&S
• Morrisons
• Roberts
• Tesco
• Waitrose

Product list download

On 30 April 2025, the Campaign wrote to the companies, asking them to advise whether they will be removing either the word wholemeal from the names of non-compliant products or all non-wholemeal flour from their formulations.

The Campaign also wrote to Aldi and Lidl for ingredients lists, which both companies choose not to publish on their websites.

The law

The recently-published, official guidance to The Bread and Flour Regulations includes confirmation that Regulation 6 means: ‘When labelling or advertising bread, the word ‘wholemeal’ is only allowed in the name of the bread when all of the flour used as an ingredient is wholemeal.’

The term ‘wholemeal flour’ (or ‘wholemeal wheat flour’) must, however, appear on the ingredients list.

The Regulations do not provide any exemption for the word ‘wholemeal’ to be used to name a product on the basis of:

• The amount of non-wholemeal flour being ‘small’ or ‘minimal’.
• Any perception that the word’s use is ‘not misleading’, for example a product that is clearly labelled as being 50% white.
• The point at which flour is used. The Co-op once argued a product was exempt because it was dusted with flour after baking.

Young said: ‘I had to laugh at Co-op’s attempt at justification. The white flour was on the ingredients list and yet the company claimed it wasn’t an ingredient but a “dressing”. It was the only time in more than 15 years I’d heard of flour being added flour after baking, as if it was icing sugar. It would also be a concern if Co-op was admitting to serving raw, unbaked flour for its customers to eat, against official guidance from the Food Standards Agency.’ 

Exceptions

Despite this unequivocal, zero-tolerance approach, the Regulation contains two key loopholes that the Real Bread Campaign challenges:

• It only applies to wheat flour. Any amount of refined / non-wholemeal products from other grains, legumes, tubers etc. can be used, because the Regulations do not consider them to be flour, so they fall outside the ‘all the flour’ requirement.*
• It does not apply to other products of wheat. A manufacturer can dilute the wholesomeness of wholemeal flour by the addition of any quantity of highly-refined gluten power, wheat starch etc.

*which begs the questions: if soya flour isn’t flour, then what the heck is it and why is it legal to name it 'soya flour' on an ingredients list?

History

The Campaign has previously challenged the use of the word ‘wholemeal’ in the names and marketing of products manufactured using non-wholemeal flour. Resulting changes have included:

• Aldi: removed wholemeal’ from ‘Both in One’ pack front. (by April 2025)
• Iceland: discontinued ‘White and Wholemeal’. (January 2023)
• Sainsbury's: renamed ‘wholemeal tortilla wraps’ (July 2023), removed wholemeal’ from ‘Both in One’ pack front. (October 2023) 
• Warburtons: renamed ‘Half White Half Wholemeal’ as ‘Half & Half’ (by January 2024)

Resolution of other complaints was left in limbo, while a number of trading standards officers awaited Defra’s long-promised guidance.

See also

• Wholemeal bread
• Loaf-tanning salon lies?
• Supermarket loaves: why the massive markup?
• Is Kingsmill’s whole grain claim legit?

Updates

13 May 2025: Hovis responded by claiming they had not received our complaint, so we re-sent it.

10 May 2025: Waitrose replied: 'I have passed over your request for more information over to our back office team. When I receive feedback I will be in contact with you.'

9 May 2025: We followed up with all 10 companies, asking for an answer to the question we asked on 30 April.

6 May 2025: Asda replied: 'We are aware of the new guidance and are already underway with ensuring that all of our products remain correctly labelled.'

We asked Asda to advise the company's timescale for completing this review and making necessary changes.

2 May 2025: Waitrose replied 'We want to bring you the highest quality products and the best possible service, so we welcome and value feedback from our customers. I'm very grateful to you for your comments and have discussed them with the management team and relevant department(s) here at head office, who will consider them at their next review.'

We asked when that review would be and when we can expect an answer to our question.

1 May 2025: Iceland replied: 'I am sorry for the inconvenience caused and would like to thank you for bringing this to our attention. I cannot imagine how stressful this must have been when noticing that the term whole meal is on our The Daily Bakery products and that your research shows that this does not contain the ingredients of the whole meal. I have forwarded this to the relevant department to have it reviewed.'