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ASA Adjudication on Premier Foods Group Ltd

Premier Foods Group Ltd

Premier House
Centrium Business Park
Griffiths Way
St Albans


16 December 2009




Food and drink

Number of complaints:



Miles Calcraft Briginshaw Duffy (MCBD)

Complaint Ref:



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 its always been", was misleading because:

1.  they believed the modern Hovis loaf was made to a different recipe from the original and now included additives, sugar and vinegar;

2.  the commercial production of modern Hovis products involved the use of an unspecified improver and undeclared processing aids;

3.  Hovis now manufactured white bread, which was considerably lower in fibre than the original wheatgerm loaf;

4.  over recent years Hovis has centralised production and the direct socio-economic benefits gained previously by local communities in terms of employment and income had reduced;

5.  modern transportation methods and greater travelling distances of raw materials and finished products impacted more adversely on the environment than Hovis original produce; and

6.  Hovis original paper packaging had been replaced by plastic wrapping, which was derived from a non-renewable source and was not bio-degradable.



Premier Foods (PF) said the claim "As good today as its 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 individuals 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 Clearcasts view, viewers were unlikely to interpret the claim "As good today as its always been" in the context of Premier Foods 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 its 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, such as caramelised sugar and vinegar, which, they asserted, the original had not.  We noted, however, PFs 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 its always been" that Hovis produced exactly the same products as they originally had when that was not the case.  We noted PFs 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 individuals daily allowance, although we considered that viewers were unlikely to interpret the claim as an instruction to choose Hoviss 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 its 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 PFs claim for Hovis to be "as good today as its always been".  We also acknowledged PFs 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.

Adjudication of the ASA Council (Broadcast)

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