Real Bread Campaign secures encouragement from Defra but no commitment.
After more than eleven weeks and three follow up emails, on 7 November 2023 the Real Bread Campaign received a response to the email it sent on 17 August to Thérèse Coffey and Mark Spencer, respectively the Secretary of State and Minister of State at Defra.
Having once again rejected the Campaign’s long-standing call for a legal definition of the word sourdough and regulation of its use, Mr. Spencer turned to the Campaign's proposals for defining and regulating use of the words wholegrain and wholemeal. He wrote: “while there are no immediate plans to adopt a definition of wholegrain into law, work to consider a definition for wholegrain has been added as part of the Scientific Advisory Committee on Nutrition future work programme.”
The public consultation on proposals to amend The Bread and Flour Regulations 1998 ended on 23 November 2022, with the Government originally committing to publish its response within 12 weeks – ie by mid-February 2023. Responding to the Campaign’s latest request for a revised ETA more meaningful than the previous ‘later this summer’, Mr. Spencer wrote: “We are unable to provide an exact date of publication,” adding a vague aspiration “to publish as soon as possible.”
On 8 November 2023, Campaign coordinator Chris Young sent the following reply, seeking answers to outstanding points of the Campaign’s Honest Crust Act proposals.
Dear Mark and Thérèse,
Thank you for your response dated 7 November to my email of 17 August.
Wholegrain and wholemeal
Thank you for listening to the Real Bread Campaign’s assertion that the word wholegrain needs defining, and for confirming that work to consider doing so has been added to the Scientific Advisory Committee on Nutrition’s future work programme. When will this project start?
It is also encouraging that you write: ‘we hope to provide clarification [on use of the word wholemeal] in guidance which will accompany the planned legislative amendments to The Bread and Flour Regulations 1998 next year’. When next year will the amended Regulations and accompanying guidance be published?
In the meantime, trading standards officers at LB Enfield (who are investigating our complaint about Warburtons using the word wholemeal to name/market a product made using non-wholemeal flour) forwarded to us a communication from Defra. Confirming our long-standing assertion, Defra stated that The Bread and Flour Regulations: “prohibit the use of the term wholemeal in the naming of advertising of these products.”
Enfield has advised Warburtons accordingly, while Sainsbury’s has relabelled its half-and-half product on the advice of Oxfordshire CC. When we last checked, however, trading standards officers at Primary Authorities investigating similar cases involving Aldi, Asda, The Co-operative, Hovis, Jacksons, Marks & Spencer and Waitrose products were unaware of the information sent to Enfield.
Has Defra since sent the communication to the trading standards departments of all other local authorities and to the CTSI? If not, when will you in order to give them (and manufacturers/retailers) some clarity while awaiting fuller guidance?
Full ingredient listing
Why will you not introduce legislation that requires retailers to display at point-of-sale the full ingredient lists of all food sold unwrapped, for whatever reasons people need or want this important information? What are the ‘practical reasons’ that you claim prevent retailers from displaying these important details alongside the mandatory information they are clearly able to display already, including product name, allergen information and (for ‘non-standard’ loaves) weight?
Are they the same reasons as those behind repeated rejections of the full ingredient labelling of PPDS products that we and others spent years calling for? If so, the fact that those supposed barriers vanished almost overnight at the tipping point of Natasha Ednan-Laperouse’s tragic death, proves they were not insurmountable. If the reasons to which you allude are different, what are they?
Returning to a related question: why will you not introduce legislation that requires all manufacturers and retailers to state on ingredients lists any and all so-called processing aids that have been used, alongside all other additives? What reason do you have for wanting to continue blocking this honesty and transparency?
Other marketing claims
We are pleased to learn that Defra is planning to review guidance on the use of marketing terms such as fresh, pure and natural. Although, as you note, the current version outlines relevant legislation and general advice, it also provides specific best practice advice on the use of more than a dozen particular terms.
Will the review process enable us (and others) to submit terms for consideration of inclusion and when exactly will the public consultation be? I don’t doubt that Defra has much on its plate but, after 15 years of our Honest Crust Act proposals being deferred and rejected, surely this staple of the UK’s diet (not to mention the people who make and eat it) must be nearing the front of the priority list by now.
13 November 2023: We sent this reply to the email we received on 8 November:
"The Real Bread Campaign has nothing to hide and publishes correspondence and other information we believe is in the public interest, unless agreed otherwise.
Defra is well aware of the Real Bread Campaign’s interest and involvement in discussions of wholemeal and wholegrain labelling and marketing. It is, therefore, unfortunate that nobody there thought (or someone actively chose not) to forward a copy of that communication to us six months ago, prior to which a non-disclosure request could have been made and discussed.
I look forward to answers to the outstanding questions from the email that I sent to the Minister and Secretary of State earlier on 8 November, in which I CCd you."
8 November 2023: After sending the email above, we received the following from a member of Defra's Food Compositional Standards team:
"The text [that the Real Bread Campaign] published was not intended as a public communication but an email response to points raised with us directly by the correspondent. We would not expect an individual response to end up in the public domain. I’m sure your aware that any public facing Defra statement would always go through our Communications Department.
The correspondence you published is from 6 months ago, and since then we have been considering the issue further including within trading standards forums. As [my colleague] explained in his email having discussed this further, we think a satisfactory way forward might be to produce some further guidance on 50:50 breads. We will also need to discuss our approach with our devolved colleagues before we look to circulate anything on this more widely to interested parties for consideration. We want to ensure the final guidance captures the intent of Regulation 6 but does not have any adverse impact on consumer choice while still ensuring accurate consumer information.
Our current focus is on publishing the government response which we hope will be very shortly.
In relation to the Honest Crust proposals as mentioned before these cover cross-cutting areas, hence, the arguments have been shared to a wider group of officials. Since the proposals cut across different areas, they aren’t necessarily considered alongside each other. Rather any proposals are considered on their merits by the relevant policy leads."
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Published 8 Nov 2023
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