Everything in this display was manufactured elsewhere at some time in the past. Credit: Chris Young / www.realbreadcampaign.org CC-BY-NC-SA-4.0
Co-op case highlights consumer protection needs
Two-year trading standards investigation reveals room for improvement
After chasing an update for almost two years, the Real Bread Campaign has been advised that its 2024 trading standards complaint about Co-op’s in-store loaf tanning salon marketing has been closed.
The complaint was that The Co-op used the claim ‘freshly baked today’ to market products that were manufactured elsewhere, including some fabricated outside the UK.
On 7 September 2026, the Campaign received an email from a team leader in the ‘public protection and integrated enforcement division’ of the London Borough of Tower Hamlets (LBTH). It asserted that ‘the terminology in question is used more widely across the food industry’ but there is an ‘absence of evidence of consumer detriment’ and ‘complaints trends’. LBTH concluded: ‘as far as a legal breach is concerned, I am of the opinion that there is not enough evidence to warrant further investigation so this matter will also be closed on our end.’
Real Bread Campaign supporter Chris Young reacted: ‘is this opinion simply “all supermarkets do this, which is okay because nobody complains”? Are we in a situation where a corporation can market baked products in any way they see fit and nobody is going to stop them?’
He went on to say: ‘This case is further evidence of the need for our proposed Honest Crust Act of improved composition, labelling and marketing standards. It also demonstrates a need for the government to adequately fund and empower consumer protection services.’
Young concluded: ‘In the meantime, we believe the safest bet for people who want honest loaves, rather than marketing lies, is making their own bread or buying it from a Real Bread bakery.’
The conclusion
The Campaign submitted its complaint in February 2024 to Manchester City Council, which has the Primary Authority (PA) relationship for with Co-op for trading standards. After Manchester last responded in November 2024, in June 2026, we asked LBTH to liaise with the PA and update us on progress that has been made on this case. This led to the September 2026 email from LBTH:
The PA provided the Co-Op with details of the concerns raised by yourselves at the time but did not identify grounds to require changes to the way they described the products. I am told you were provided with a detailed response setting out the basis for that decision.
Whilst you did not appear to agree with the conclusions reached, the PA indicated that the concern raised are heavily dependent on differing interpretations of the FSA guidance, consumer perception, and the application of food labelling legislation, rather than clear-cut breaches of prescriptive legal requirements. The FSA guidance was produced to assist with interpretation of the legislation rather than introducing standalone legal requirements.
No enforcing authority has referred concerns to them relating to consumer complaints about the 'freshly prepared' claim nor have any concerns been referred to them identified during routine enforcement visits. They are aware that guidance was issued to one retailer by their PA, however, they are not aware of any wider regulatory consensus requiring changes across the sector.
Their view remains that any regulatory intervention should be proportionate, consistent and evidence based. The terminology in question is used more widely across the food industry and, in the absence of evidence of consumer detriment, complaints trends or a clear legal breach, they did not consider it appropriate to recommend formal action against the Co-Op. This approach is, in their view, consistent with the principles underpinning the Regulators' Code.Other than advising the Co-Op that consideration could be given to providing a clearer indication of when the product was prepared (e.g. "freshly prepared daily"), no further action was proposed and the matter was considered concluded.
Based on the above feedback, I am satisfied that the matter was dealt with and I agree with the PA interpretation of the FSA guidance and food labelling legislation. As far as a legal breach is concerned, I am of the opinion that there is not enough evidence to warrant further investigation so this matter will also be closed on our end.
Thank you for bringing this matter to our attention.
See also
Real Bread Campaign: Finding and sharing ways to make bread better for us, our communities and planet.
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