What's in a name?. Copyright: Roberts Bakery (fair use)
The Real Bread Campaign questions loaf label legality.
What's in a name?. Copyright: Roberts Bakery (fair use)
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.’
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:
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 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:
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.’
Despite this unequivocal, zero-tolerance approach, the Regulation contains two key loopholes that the Real Bread Campaign challenges:
*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?
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:
Resolution of other complaints was left in limbo, while a number of trading standards officers awaited Defra’s long-promised guidance.
...will appear here
Real Bread Campaign: Finding and sharing ways to make bread better for us, our communities and planet.
Sustain
The Green House
244-254 Cambridge Heath Road
London E2 9DA
020 3559 6777
sustain@sustainweb.org
Sustain advocates food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the working and living environment, promote equity and enrich society and culture.
© Sustain 2025
Registered charity (no. 1018643)
Data privacy & cookies
Icons by Icons8