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The Real Bread Campaign's complaint to the Advertising Standards Authority that Hovis advertising was misleading
One such issue is the promotion of industrial loaves in a way that we believe misdirects the consumer from the truth of the method of manufacture and/or what we see as the adulteration of the products with artificial additives and other non-food substances.
Below is documentation of a complaint we made to the Advertising Standards Authority about a TV and online advertisement for Hovis rolls. The advertisement began with a historic scene of a girl visiting a neighbourhood bakery; cut to a small batch of rolls being loaded into an oven by hand; transformed to a colour scene of rolls being removed from the oven by hand and finally cut to a present-day incarnation of the same girl at the same counter (shown to have become a small shop) being handed a plastic bag of industrially-produced Hovis rolls.
[Ironically, the website of Jones Dairy, the east London shop at which the advertisement was filmed, says it tries '...as much as possible to make small scale economics work to enable you as a customer to get as close to the point of production as possible. ']
What you can do
View Hovis advertisements online
16th December 2009
Advertising Standards Authority failing to protect consumers says the Real Bread Campaign
Today, the Advertising Standards Authority (ASA) rejected a complaint from the Real Bread Campaign that the Hovis ‘Rolls’ television advertisement had breached the TV Advertising Standards Code* by misleading consumers. The Campaign believes that in doing so, the ASA is guilty of a failure of duty to the public and now calls on consumers to take action.
The ruling comes despite a Hovis spokesperson recently having admitted: ‘…we were surprised at how may misconceptions we had. We believed our product was better than it actually was.’ The Campaign is urging people who feel that the decision is wrong to contact the ASA to demand that it reconsiders its ruling (case A09-102028), contact Hovis to insist it withdraws all advertising using the slogan.
Real Bread Campaign working party chair Iain Loe said:
‘We are shocked and saddened by this decision. How can Hovis still be “as good today as it’s always been” when 40% of the brand’s income now comes from additive laden white loaves? It seems to us that the ASA has chosen to ignore the facts and let Hovis mislead the public into thinking it still produces Real Bread by hand.’
In a four page letter to the ASA, the Campaign outlined the ways in which it felt the advert was misleading. These included:
Although Hovis dropped ‘Rolls’ from its website a few weeks ahead of the publication of the ASA ruling**, its predecessor ‘Go On, Lad’, which employs the same slogan and similar craft baker imagery (and that Hovis uses in school teaching packs) is still live.
The full complaint, the ASA response and how people can take action can be found at: www.sustainweb.org/realbread/hovis_advertising
The Real Bread Campaign is a not-for-profit initiative, co-ordinated by the UK charity Sustain: the alliance for better food and farming. Its aims are to encourage and support the increased production and consumption of Real Bread in Britain.
*The CAP (broadcast) TV Advertising Standards Code rule 5.1.1
**‘Rolls’ was removed sometime between 21st and 23rd November 2009. ‘Go on, Lad’ can still be viewed online at: http://www.hovisbakery.co.uk/our-ads/
Advertising Standards Authority
Mid City Place
71 High Holborn
11th August 2009
Dear Sir or Madam,
The Real Bread Campaign is a charitable organisation, the aims of which are to encourage and support the increased consumption and local production of Real Bread, which we define as being made using all natural ingredients and no artificial additives, improvers or processing aids. Other aspects of our work are to champion the improvement of all UK bread production and to address any issues that we see as running counter to our aims.
In the current ‘Rolls’ television advertisement for Hovis , a baker eases mini loaves into and out of a small oven by hand. With a smile and a not inconsiderable dose of artistic licence, the central character then purchases pre-packed Hovis rolls, clearly not the product of the bakery we have just seen. As with its September 2008 predecessor, ‘Go on Lad,’ ‘Rolls’ concludes with the slogan “as good today as it’s always been,” a direct, favourable, qualitative comparison between the Hovis of today and the Hovis of years past.
The Real Bread Campaign believes that in both its artisan baker narrative and concluding statement, ‘Rolls’ is misleading and therefore in breach of Section 5.1.1 of the TV Advertising Standards Code. The grounds on which we base this are myriad and so we shall focus on the following:
Today’s Hovis is not the same product as it’s always been and we contest that it is not as good.
In 1887, Richard Smith and miller Thomas Fitton registered ‘Smith’s Patent Germ Flour,’ which in 1890 was renamed Hovis. For many years , tens of thousands of skilled craft bakers around the country combined this flour with just water, yeast and a small amount of salt. This dough was then left to prove naturally over a number of hours and baked to produce ‘the little brown loaf.’
Even though Premier still manufactures what they portray as the ‘little brown loaf,’ the wrapper of ‘Hovis Original Wheatgerm,’ actually names fourteen ingredients and additives . Studying the list and those across a selection of products that now help to comprise the Hovis brand, one finds the inventory to include sodium stearoyl-2-lactylate, mono- and diglycerides of fatty acids, mono and diacetyltartaric acid esters of glycerides of fatty acids, ascorbic acid, inulin, caramelised sugar, soya flour and vinegar .
Some of these extras are foodstuffs but ones unnecessary in bread production. Furthermore, could it be that the added caramel in Hovis Wholemeal is what helps to push its sugar levels up to 4.1g per 100g, that is to say the equivalent of just under a teaspoon of sugar in every two slices ? This is not only almost twice the levels in a typical wholemeal loaf 31 years ago but represents an increase in sugars of 3.2g per 800g loaf since The Times reported on the issue just two years ago. Such high sugar levels in what is a staple savoury foodstuff run counter to basic principles of healthy eating.
What place does vinegar have in bread making? Now that most Hovis is produced by Premier using industrial ‘no time’ techniques, one function of vinegar is to help make up for the shortfall in the flavour development that used to have time to occur when independent bakeries made Hovis by the traditional ‘overnight sponge’ or even ‘bulk fermentation’ methods. If Hovis was as good as it’s always been, would it need to have its flavour enhanced in this way?
Conversely, others of these additives, including mono and diacetyltartaric acid esters of glycerides of fatty acids (aka Diacetyl Tartaric (Acid) Ester of Monoglyceride or DATEM), are not foodstuffs. On 21st March 1997, the 106th meeting of the European Commission’s Scientific Committee on Food declared that '...the use of DATEM in foods for infants and young children in good health is not acceptable.' Although this opinion was later revised, how sound can the ‘as good…’ claim be when such a concern has been raised about substances used in the manufacture of the product to which it pertains?
In addition to these extra ingredients and additives, several recipes given by Premier for the commercial production of Hovis loaves by other bakers list an unspecified ‘improver’ and the centralised manufacture of some Hovis products could involve the use of undeclared processing aids. Whilst these substances are perfectly legal and (currently) deemed to be safe, a survey carried out earlier this year by AGR Food & Drink Market Research on behalf of the Real Bread Campaign and the Real Food Festival indicated that over 93% of people believe that such a lack of transparency in product labelling is unacceptable. These factors of production and disclosure clearly are not what most people think of as ‘good’.
Another consideration is that products sold under the Hovis brand now include white bread. White bread is considerably lower in fibre than wholemeal and even brown breads. As noted in Our Daily Bread, a joint report by The Federation of Bakers and the Flour Advisory Bureau, “a low fibre intake is associated with constipation and some gut diseases such as diverticulitis and an increased risk of bowel cancer.” The recommended daily intake of fibre for an adult of 18 grams can be found in eight and a half slices of Hovis Original Wheatgerm. In order to get this amount from Hovis Soft White, one would need to eat 18 slices, which would also involve the consumption of 16 grams of fat, 25 grams of sugars and over 7 grams of salt , more than the Food Standards Agency’s recommended maximum adult intake of the latter for a whole day. Furthermore, a study reported in the American Journal of Clinical Nutrition found that regular consumption of foods with a high glycaemic index, such as most white breads, is associated with a higher risk of a range of chronic diseases.
Clearly, in these respects, Hovis Soft White is not as good as the original wheatgerm loaf and as white bread now accounts for approximately 40% of Hovis sales , it can be said that the brand as a whole is not as good as it was before white bread entered the portfolio in 1991.
Focussing on the principal of the now numerous ingredients in Hovis loaves, several studies have reported that the micronutrient levels in bread making wheat have been in steady decline . Whilst this factor is by no means unique to Hovis and current high-yielding varieties are arguably important to the growing worldwide demand for food, the use of contemporary wheat strains by Hovis means that the micronutrient profile of their loaves is not as good as it used to be.
It is interesting to note that in the iconic 1973 ‘Boy on the Bike’ campaign the slogan was: “as good for you as it’s always been.” Could it be that Premier Foods decided that saying Hovis is as good for you, as it’s always been was a claim too far? Given that Hovis products returned to being free from artificial preservatives and flavourings (though not free from sodium stearoyl-2-lactylate, mono- and diglycerides of fatty acids, mono and diacetyltartaric acid esters of glycerides of fatty acids) in 2003 and in 2005 began a (FSA target induced) reduction of salt , perhaps ‘not quite as bad in a couple of respects as it was until quite recently,’ would be more appropriate?
Produced in remote plants and purchased from supermarkets, it is very hard to see how the majority of today’s loaves of Hovis could be considered to be as good in socio-economic terms as their locally-baked predecessors.
A 1931 advertisement boasted that Hovis was ‘supplied by 20,000 bakers.’ Today, the Hovis division of Premier Foods has just 12 industrial baking plants , though the website of The Federation of Bakers is a little behind Premier’s schedule of closures and lists 13. Even if every medium-sized and small, craft bakery in Britain also produced Hovis loaves, the number of bakeries supplying Hovis would not even reach a quarter of the 1931 figure.
When the Real Bread Campaign contacted customer services at Premier Foods to establish how many independent bakeries also baked Hovis loaves, they were only able to say that that Rank Hovis (the company’s flour milling and distribution operation) has ‘more than 200’ customers, not all of which are bread bakers. As for individuals, the whole of Premier Foods, of which Hovis is but one division, has fewer than 16,000 employees in total and figures from the National Association of Master Bakers in 2007 put the total number of bakers at around just 10,800.
Whilst the factors behind the decimation of the independent local bakery sector are complex and not solely attributable to one company, a factsheet published by The Federation of Bakers, of which Premier Foods is a member, acknowledges that competition from plant bakers (such as Hovis) has played a role and the fact that the production of Hovis no longer accounts for as many jobs as it once did surely is irrefutable.
The loss cannot just be seen in terms of numbers employed in the production of Hovis but also in skills. Like the bakers before them, those who continue to work in the craft sector and the one portrayed by ‘Rolls,’ the bakers making Hovis in 1931 were highly trained craftsmen. They learned and developed not only manual talents but also the ability to judge the many variables involved with bread making in order to maintain the highest standards of the finished product. We believe that the depiction of the craft baker in ‘Rolls’ is misleading as today, the production of most Hovis loaves is controlled by computer at the expense of employees learning those traditional craft skills. Whilst we do not denigrate the skills or people involved in industrial bread manufacture, we feel that the job satisfaction amongst Hovis producers taken in general cannot be as good as it’s always been.
The centralisation of production also has had a huge negative impact on the contribution that the sale of Hovis loaves could make to local economies. Money spent with locally owned businesses is worth many times more to a local economy than purchasing from a company based outside the area. A study by the New Economics Foundation in Northumberland found that, of every £1 spent with local businesses, an average of 76% was re-invested locally, giving a total local spend of £1.76. By contrast, for every £1 spent with suppliers based outside the area, only 36p was returned . With most loaves now being produced by Premier Foods, rather than by local independent bakers, can Hovis’ current contribution to local economies be said to be as good as it’s always been? We think not.
This is not to mention the incalculable loss suffered by communities in which there is no longer a bakery from which to buy a loaf of Hovis, therein enter into conversation with other members of the community who work there and catch up on gossip with friends and other locals during the short walk, bike or bus ride there and back. Again, the factors behind the slow, continuing death of the British high street are complex and not down to just the business practices of one company but the channels through which most Hovis is now sold do not make as good a contribution to the social fabric of local communities as local independent bakeries.
According to company literature, Hovis flour was originally delivered by horse and cart , a fine example of sustainable transport with a low-carbon footprint. Today most of the transportation involved in the Hovis chain from grain to consumer is powered by fossil-fuel consuming, carbon dioxide emitting trucks and lorries.
The greater the distances over which raw materials and finished food products are transported domestically, the greater the environmental damage that will be done. In the past, grain would have been transported to the nearest of numerous Rank Hovis mills. Each high street bakery would then source its flour from the closest of these mills. Today, with just 8 Rank Hovis mills and 12 Hovis bakeries in operation nationwide, the average distance travelled by Hovis grain and flour within Britain and therefore negative environmental impact in this respect is likely to be greater than it once was.
Moving on to the finished loaves, independent bakeries once sold their Hovis directly to local customers. Now around 2 million loaves of Hovis are transported by the aforementioned vehicles, not direct to the point of retail sale but via centralised distribution centres, an extra, environmentally damaging link in the chain. From these centres Hovis then makes 9000 daily deliveries to retail outlets. As further illustration of the scale of the petrol guzzling involved, Hovis’ Dagenham bread delivery distribution centre, the largest in Europe, sees an average of 80 articulated lorries arriving and 120 trucks leaving every day.
Many consumers then make a long round trip by car to purchase their Hovis from an out-of-town supermarket. Whilst Premier Foods is not directly responsible for the whole of this chain of events, this sequence of how much Hovis now finds its way from bakery to the kitchen table is environmentally not as good as the previous, more sustainable model of local, in-community production.
By the 1930’s, Hovis was supplying two million paper bags to bakers every week. Premier Foods now dispatches around two million loaves a day into the world in plastic wrappers. These packing films are produced from mineral oil, which unlike wood pulp, is a non-renewable resource. Also unlike paper, the films used are not bio-degradable. Whilst Premier could argue that the limited facility for re-cycling of polyethylene is the fault of local waste management providers, Premier chooses to use it, meaning that in environmental terms, even Hovis packaging is not as good as it was.
Returning to the now extensive inventory of ingredients and additives used in the manufacture of Hovis products, one finds listed ‘vegetable fat.’ According to an article in The Independent earlier this year, entitled “The guilty secrets of palm oil: Are you unwittingly contributing to the devastation of the rain forests?” the three leading manufactured loaf brands, Warburtons, Hovis and Kingsmill, use palm oil. According to the article, “wildlife-rich forests of Indonesia and Malaysia are being chain-sawed to make way for palm-oil plantations” and “When the rainforests disappear almost all of the wildlife – including the orangutans, tigers, sun bears, bearded pigs and other endangered species – and indigenous people go.” An article in the September 2008 issue of the Premier Foods publication, Premier Life, says that the company is “…at the forefront of sourcing sustainable third party certified palm oil as it becomes available" and that Premier Foods has "...a target to source 100 percent sustainable palm oil by 2011.." Whilst this piece does not confirm that Hovis products contain palm oil from unsustainable sources, can we take these lines as an assurance that they are yet free of it? The Real Bread Campaign does not.
Given the depletion in nutrient levels and increase in sugars in some lines; introduction of white loaves into the brand; adulteration of the products with non-food substances; move to a centralised production system that not only deprives local communities of opportunities for skilled employment and decreases the likelihood of local reinvestment of funds but also requires the product to be transported over greater distances to retail outlet and then on to the customer; the use of less sustainable packaging and allegations of the use of palm oil from unsustainable sources, we ask that the ASA rules that both the advertisement ‘Rolls’ and Premier Foods’ claim that Hovis “is as good as it has always been” are misleading.
I can confirm that no legal action in connection with this subject is underway or will be initiated by either the Real Bread Campaign or Sustain. Additionally, I confirm that the Real Bread Campaign agrees to be named as the complainant.
Project Officer, Real Bread Campaign
Case number: A09-102028/JG
Sector: Food and drink
Agency: Miles Calcraft Briginshaw Duffy (MCBD)
Premier Foods Group Ltd
Centrium Business Park
Number of complaints : 1
A TV ad, for Hovis, opened with a sepia-tinted Victorian scene in which a young girl wandered along a busy cobbled street and into a bakery where individual loaves were being loaded into an oven on a wooden palette. The voice-over stated "At Hovis, we've always taken pride in baking bread for everyone. That's why we've taken your favourite bread and created a new range of rolls. They're available in seven varieties including seed sensations, granary and mini loaves". The scene then transformed into a present day view as the young girl, having bought bread, left the shop. The voice-over continued "Hovis. As good today as it's always been".
The Real Bread Campaign challenged whether the ad, and particularly the claim “As good today as it’s always been”, was misleading because:
Premier Foods (PF) said the claim “As good today as it’s always been” had appeared in Hovis advertising in one form or another since the early 1900s. They said the claim had recently featured in another very successful TV ad, which they understood had been seen by approximately 93% of the UK viewing population without complaint. PF said Hovis always sought to produce good quality bread: initially that was via a single type of bread, Hovis Original Wheatgerm, but as tastes changed they launched other breads including white, wholemeal and seeded loaves. They said they were proud of the quality of their produce and argued that it was as good as it had always been. PF explained that eating habits had changed significantly over the 100 years or so that the Hovis name had been in existence and part of this change was reflected in the ad: it depicted progress through the ‘timeline’ portrayed and was intended to convey the message that Hovis’ brand values continued to be upheld throughout the changes.
1. PF explained that, historically, there had never been a unique recipe or process for Hovis, because originally the Wheatgerm loaf was sold as a flour and the individual bakers adjusted the recipe to suit their process. They said the flour used for Hovis Original Wheatgerm products continued to contain wheatgerm at a level governed by the Bread and Flour Regulations. They said, by their nature, other products in the Hovis range required different recipes, for example, it was not possible to make wholemeal bread from wheatgerm flour.
PF said, while the original wheatgerm loaf was still in production, it had been adapted to meet modern day customers’ shopping and eating habits, for example, it was sliced for convenience and had an improved shelf life. They said the use of additives was always considered carefully, although some were statutory requirements, and the minimum amounts possible were used to give the best possible product throughout its shelf life as consumers demanded.
Clearcast explained that they had sought substantiation for the claim following its appearance in an earlier ad. They said on that occasion they found that the Hovis Wholemeal loaf had the same recipe that it had when first produced, although with less salt. The Wheatgerm loaf, which was the original loaf traceable back to 1886, was still in production although it was now available as a sliced loaf. Essentially, they were satisfied that Hovis was making the same bread as it always had. Clearcast said the substantiation documents they received during the clearance process for this ad stated that Hovis’ newer bread recipes followed their previously held nutritional standards.
2. PF confirmed that there was no undeclared improver in Hovis bread. They explained that certain processing aids were used in baking Hovis bread, but stressed that the ingredient declarations on all Hovis bread followed current Legislative requirements with regard to ingredients and additives, including processing aids. They said, under legislation, processing aids did not need to be declared.
Clearcast said they were unaware of any unspecified improver or processing aids.
3. PF said the focus of this ad was Hovis wholemeal products as demonstrated by the loaf baking in the oven, the large plate of Hovis Wholemeal mini loaves and the girl purchasing and putting a pack of wholemeal rolls into her bag. They acknowledged, however, that the ad ended with a shot of five of the seven varieties of roll being launched: Seed Sensation, Best of Both, Soft White, Wholemeal and Granary. In response to the complaint, they explained that white bread was a good source of complex carbohydrates and was low in fat and sugar. They pointed out that the Food Standards Agency (FSA) guidance was that starchy foods, of which white bread was one, should make up one third of an individual’s overall diet. They said the FSA ‘Eatwell’ plate showed several types of bread, including white and seeded varieties and, in addition, Hovis produced a wide range of wholemeal and seeded loaves and rolls, many of which had more fibre than their Original Wheatgerm loaf.
Clearcast said they were assured that the newer bread types were made to the same nutritional standards as the original loaf. They had not sought to substantiate the amount of fibre in each type.
4. PF said they had 7,000 employees across 13 bakery sites in the UK and were, therefore, actively involved in several communities. They said their produce, which sold at approximately £1.20 per loaf, was available across the whole country and provided a healthy, nutritious and affordable food for all socio-economic groups.
5. PF said Hovis continued to supply from a wide range of bakeries across the country direct to local shops and supermarkets and, therefore, tried to keep any impact on the environment to a minimum. They said they also used a large percentage of UK grown wheat in their products: in the 1880s, when Hovis was launched, the majority of wheat was imported from as far away as Canada or Australia.
6. PF explained that properly sealed packaging had to be adopted as part of ensuring food safety. In addition, plastic wrapping meant that the bread dried out less quickly and could be used over a longer period of time, thus reducing waste. They said the weight of the packaging was very low in comparison with most other food categories.
Clearcast believed points 4, 5 and 6 were not relevant to their clearance of the ad. They said they would only investigate the socio-economic impact of a company if it was alluded to in their advertising. In Clearcast’s view, viewers were unlikely to interpret the claim “As good today as it’s always been” in the context of Premier Food’s impact on the local community or environment as a result of packaging or transportation methods.
1. Not upheld
The ASA considered that viewers were likely to interpret the claim “Hovis. As good today as it’s always been” in the context of this ad, which also claimed “At Hovis, we've always taken pride in baking bread for everyone. That's why we've taken your favourite bread and created a new range of rolls” to mean that Hovis continued to meet the needs of their customers (by introducing new products, made to the same brand standards and values, to suit differing tastes or requirements), just as it had since it began producing bread.
We noted the complainants’ concern that the current product contained additives, sugar and vinegar, which, they asserted, the original had not. We noted, however, PF’s explanation that there had not been a unique recipe for the original Hovis loaf and considered, furthermore, that viewers would understand that the exact ingredients of contemporary Hovis products might differ from those used in a product from 1886; we noted the claim stated “as good today…”, but not, for example, “the same recipe today …”.
We also noted the original Hovis bread was a wheatgerm-based loaf, whereas the ad referred to a “new range of rolls”. We considered that viewers were unlikely to infer from the ad, as a whole and in context, that Hovis products were manufactured in exactly the same way as they always had been or that the ingredients of the products within the ad were the same as the original Hovis Wheatgerm loaf. We concluded that they were unlikely to be misled by the claim in this respect.
2. Not upheld
We understood that all of the ingredients incorporated into Hovis products were listed on the packaging as required by labelling legislation. We considered that the claim was unlikely to mislead on these grounds.
3. Not upheld
We acknowledged that the contemporary Hovis brand incorporated several bread types, whereas originally only one variety, the Hovis Wheatgerm loaf, had been produced.
We considered, however, that viewers were unlikely to infer from the claim “Hovis. As good today as it’s always been” that Hovis produced exactly the same products as they originally had when that was not the case. We noted PF’s comments that FSA guidelines pointed to the inclusion of a starchy food such as bread, in any form, at a quantity of one-third of an individual’s daily allowance, although we considered that viewers were unlikely to interpret the claim as an instruction to choose Hovis’s white bread over other varieties when considering their daily nutrition. We further noted the original Hovis Wheatgerm loaf still contributed to the Hovis brand and that other breads within the brand had a higher fibre content than the original loaf.
We concluded that the addition of white bread to the brand range did not impact on the claim “As good today as it’s always been” in this context and viewers were unlikely to be misled on those grounds.
4., 5. & 6. Not upheld
We noted the Real Bread Campaign were concerned about wide-reaching socio-economic and environmental issues arising from modernisation and the expansion of Premier Foods particularly in the context of PF’s claim for Hovis to be “as good today as it’s always been”. We also acknowledged PF’s comments in relation to minimisation of any environmental impact during the manufacture of their products and the potential benefit to local communities as a direct result of bread production, sales and consumption. We considered, however, that viewers of the ad were likely to interpret the claim only in the context of the addition of new product varieties to the Hovis brand but not as a comment on the evolution of Hovis as a business model or the business practices of Premier Foods in general. We concluded, therefore, that the claim was unlikely to mislead on those grounds.
On all points, we investigated the ad under CAP (Broadcast) TV Advertising Standards Code rule 5.1.1 (Misleading advertising) but did not find it in breach.
No further action required.
If you agree with the Real Bread Campaign and feel that any Hovis advertisement and/or the slogan 'as good today as it's always been' is misleading, you can: