Sustain / Real Bread Campaign / About / Marketing and labelling

Artisan baker = packet mix user?

May 2016

The Advertising Standards Authority (ASA) has declined to take action following a complaint by the Real Bread Campaign about advertising claiming that ‘artisan bread’ can be made using a corner-cutting packet mix in lieu of time, skills and specialist knowledge.

The advertisement also promises ‘sour dough’ [sic] with just 60 minutes’ fermentation, despite itself noting that genuine sourdough normally requires a ‘bulk fermentation period of up to 24 hours.’

The ASA made its decision on the grounds that professional bakers ‘will be aware of what Artisan means’ and that shoppers merely expect ‘artisan-style bread’. As a result, the ASA said it believed it unlikely that either group would be misled.

The Campaign believes this to be misleading and that the ASA’s decision not to take action is at very least a disservice to shoppers and genuine artisan bakers. The Campaign believes this yet again highlights the need for an Honest Crust Act that will, amongst other things, include legal definitions for artisan bread and sourdough.

The Campaign is currently consulting its supporters and friends on the next steps to take on the issue of loaf labelling and marketing regulations.

The following is the correspondence between the Campaign and the ASA in complaint case ref. A16-335004

The Real Bread Campaign’s original complaint
The ASA’s response
The Real Bread Campaign’s follow on complaint
The ASA’s second response
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The Real Bread Campaign’s original complaint

Artisan bread is not a trend, a look, or achievable by an unskilled baker simply by using proving baskets, rather than loaf tins. By definition, artisan bread can only be made by an artisan baker.
The OED defines an artisan as ‘a worker in a skilled trade, especially one that involves making things by hand.’

The advertiser claims that this product ‘gives bakers the opportunity to enter this lucrative market without the need to invest in specialist staff.’ The marketing brochure notes that it means there will be ‘no learning needed on pH and acidity.’

We believe this to be misleading as training and employing ‘specialist staff’ with specific knowledge and skills, ie an artisan baker, is the fundamental requirement for a bakery to be able to claim to make artisan bread, and that this would be the average consumer’s understanding of the term.

As defined by OED, artisan food is ‘made in a traditional or non-mechanized way using high-quality ingredients.’

Clearly a ‘clean label improver’ is not a traditional ingredient and we believe not something that a genuine artisan baker would need or want to use, or the average consumer would expect to have been used in a loaf marketed as ‘artisan’.

Furthermore, as the advertisement itself notes, the traditional way that the types of bread this product claims to help bakers to imitate ‘can require a fermentation period of up to 60 hours.’ Conversely loaves made using the product in question ‘only need a bulk fermentation period of 60 minutes.’

As the brochure points out, the longer the dough ferments ‘the better quality the product and customers are prepared to pay a premium for this.’ Are they not at the same time encouraging bakers to reduce the time (and so not achieve that better quality), yet call the resulting loaves ‘artisan bread’ and still charge customers a premium price?

While the desire for ‘an excellent profit margin’ is understandable, the only ‘easy way’ to artisan bread is employing an artisan baker.

The ASA’s response

We have considered your comments about the use of the term “artisan” by British Bakels Ltd and we have concluded that we will not be perusing this matter further.

As you may know, our role as an organisation is to assess the content of ads and consider whether they are likely to breach the UK Codes of Advertising on the basis suggested. We may consider there is likely to be a breach of Code if, for example, we deem the ad likely to materially mislead the majority of consumers, or cause serious or widespread offence or harm. If this is the case, we can take action in the form of ensuring the problematic ad is amended or withdrawn.

In this instance the ad appeared in space specifically targeted to those in the industry; the British Baker Magazine newsletter and on the Bakels website. This is a significantly different context than if it was to appear to the general public as those in the industry will have more knowledge about bread and much less likely to be mislead [sic]. Consumers would likely interpret the claim “artisan” in this context as meaning that the end-product will be artisan-style bread, and therefore, are unlikely to be misled.

Our overall role at the ASA is to weigh up the potential consumer detriment which could be brought on by the advertising material which you have presented us with. On this occasion, for the above reasons, we propose no further action under the Code.

The Real Bread Campaign’s follow on complaint

We believe that the intention of the advertisement is very clear – to lead non-artisan bakery owners, or at very least the end consumers (ie shoppers) to believe that loaves made using this product are ‘artisan bread’ and therefore warrant a premium price. Nowhere does the advertiser state or suggest that the loaves could be marketed merely as ‘artisan style’.

Whilst we’re confident that genuine artisan bakers would not be misled by this advertisement, it isn’t targeted towards them. It is designed to attract business owners who do not employ genuine artisan bakers but who would like to be able to charge a premium for their products anyway. As such, the level of knowledge about artisan baking amongst such business owners may well be little enough to leave them open to being misled.

Isn’t the alternative - that the intended consumers of the product (the business owners) won’t be misled – only possible if it is accepted they are going into this situation knowingly? If so, then isn’t the ASA giving the tacit signal that it is acceptable for additive suppliers and industrial bakers to effectively collude in marketing to the final consumer, ie shoppers as ‘artisan bread’ loaves made by industrial means not employed by genuine artisan bakers?

In either case, we urge the investigation team to please reconsider its initial decision and to investigate this case fully.

The ASA’s second response

We still maintain that this ad is targeted towards those in the industry and we consider that those individuals will be aware of what Artisan means, as they are likely to appreciate whether they employ Artisan bakers, or not, and that the product is producing mere artisan styled bread. The ad is therefore unlikely to mislead its target audience given that they will have this knowledge. Furthermore, I appreciate your concern for end consumers of these products, but I must point out that we cannot comment on the business practice of bakeries which chose to market this bread as Artisan. We can only comment on the use of the term if it was used in further marketing that falls within our remit. However, as we are only assessing the specific ad to which you provided, we maintain that no further action is required on the issue raised.

Take action!

If you see advertising you believe to be misleading, you can submit a complaint to the Advertising Standards Authority.
If you see a product on sale that you believe is not what it says it is, or otherwise is in bread of consumer protection law, you can submit a complaint to your local authority’s trading standards department.

In either case, please let the Real Bread Campaign know how you get on.

To support the Real Bread Campaign’s work calling for an Honest Crust Act, please join us today!