Background
Summary of Council decision:
Three issues were investigated, one of which was Upheld and two were Not upheld.
Ad description
A website for Co-op, www.coop.co.uk, seen in August 2025, included a webpage for their Aldi price match scheme. Headline text in the banner at the top of the page stated “EVERYDAY ESSENTIALS, PRICE MATCHED TO ALDI” beside images of various groceries with a roundel and tick symbol with text that stated, “ALDI PRICE MATCH FOR MEMBERS”. Beneath were hyperlinked tabs “Milk, butter cheese and eggs, Food cupboard, Meat, fish and poultry, Fruit, veg and salad, Bakery and cakes, Household and pet” with images of the items and their prices for members and non-members with “See more” headings below.
Small text at the bottom of the page under the heading “Terms and conditions” stated “[...] Co-op Member Prices on selected products matched pro rata vs comparable products at Aldi GB […] For full list of price matched products, see here”. Text under the heading “FAQs” stated, “What is the Co-op Member Aldi Price Match? We have matched our Co-op Member Prices to Aldi prices on certain products. What prices do we match? We match the prices of certain Co-op products against comparable products available at Aldi."
Further small text stated, “Where can I buy Aldi Price Match Products? The products that we match prices on are available in our Co-op Group stores and online at coop.co.uk/aldipricematch. The particular products available will vary, depending on the range of products usually stocked in that store or online. The full list of products that we price match is available here”. The word “here” was hyperlinked and took consumers to a spreadsheet listing the matched products.
Issue
Aldi Stores Ltd t/a Aldi challenged whether:
- the claim “everyday essentials” was misleading, because it did not make clear which products were included in the price match scheme;
- all of the grocery items shown in the banner had been price-matched with Aldi because they understood that was not the case; and
- the basis of comparison was misleading because the price-match scheme did not compare the most appropriate products from Aldi.
Response
1. Co-operative Group Ltd t/a Co-op said they defined “Everyday Essentials” as the staple items that met core household needs and which had been identified as most frequently purchased by customers and contained in a higher-than-average number of customer baskets; essentially those that their customers and members bought the most. Co-op said a supplier conducted research over time on consumer purchasing behaviours to identify those products. For the Aldi Price Match (APM) campaign, they included products that were Co-op own brand, which would be easily comparable to Aldi’s own brand products and available in the majority of Co-op’s stores.
Co-op said they had run ad campaigns over the last few years in various media referring to “Everyday Essentials”. They therefore believed that customers and members were familiar with the term and would understand the types of products that were being referred to were those bought most frequently. It was for that reason the term was used in conjunction with the APM campaign. In their ads, where the medium and space allowed, they included additional terms and conditions that directed consumers to their APM landing webpage where consumers could see details of all Co-op products that were price matched to Aldi. The APM landing page included full T&Cs, FAQs and a link to the full list of products that were price matched to Aldi and the product they were matched to, which they believed aided understanding on how the price match operated. That list was updated weekly to show when prices had been checked and also incorporated any price changes.
Co-op said they believed that customers understood what they meant when they referred to “Everyday Essentials” and that the ads were sufficiently clear that only certain items were price matched to Aldi.
2. Co-op said that all the products featured in the banner at the top of the APM landing page were price matched to Aldi. If any of the featured products had been taken out of the APM campaign, then it would have been removed from the banner and from the webpage entirely. Co-op provided a breakdown of the prices that were applicable to the Co-op Chopped Tomatoes 400g, Co-op Lemon Washing-Up Liquid 450ml and Co-op Carrots 500g, products that Aldi believed were not included in the APM.
Co-op said its chopped tomatoes, washing-up liquid and 500g carrots were all accurately price matched to Aldi equivalents throughout the APM campaign, with tomato prices updated when Aldi lowered its own price. The 500g carrots were used because Co-op’s 1kg pack was not widely stocked enough to be included in the scheme. They considered the products featured in the banner to be core essential items that were widely available across their stores and constituted some of their top selling lines. Notwithstanding that, they did not expect consumers to rely on the banner as providing full details of all products that were price matched, because full details appeared directly under the banner on the APM landing page.
3. Co-op said they sold some regional variants of products, so where those products were price matched to Aldi, regional variants were also matched to ensure that Co-op members had the same opportunity to buy price matched products in all regions.
Co-op said they conducted research on customer purchasing behaviours to make decisions about the products that they selected for their stores. The data was used to help them understand which products could be substituted for each other and allowed them to offer consumers a choice in store without stocking multiple products that met the same need, given that their stores were smaller than the larger grocers. The research analysed the baskets of Co-op members and whether the products bought by the same member were bought in the same basket, so would be complementary to each other, or were bought on different occasions, making them more substitutable. The data was usually analysed for a 52-week period of Co-op transactions. That analysis produced customer decision trees, so that they could ensure appropriate comparable products were matched to Aldi products where there was no identical match. Co-op provided copies of their customer decision trees for several categories.
Co-op provided the details of six different bread products which were included in the APM campaign. They believed that demonstrated products were matched to an identical Aldi product but highlighted an exception of the Co-op Wholemeal Farmhouse Loaf which was matched with an Aldi White Farmhouse Loaf. Co-op said that was because Aldi did not stock a Wholemeal Farmhouse Loaf. They wanted their members to be able to take advantage of the price match on both variants of a farmhouse loaf sold by Co-op, as they believed that was what their members would expect. They reiterated their view that a consumer looking to buy a Co-op Wholemeal Farmhouse Loaf would expect it to be price matched to an Aldi farmhouse loaf, as with the Co-op White Farmhouse Loaf, rather than to a wholemeal loaf. They believed that a farmhouse loaf was a different product to an ordinary sliced loaf, which was priced differently, and met a different customer need. They said that, to match the Co-op Wholemeal Farmhouse loaf to the Aldi Wholemeal Sliced Loaf because it also used wholemeal flour and was cheaper, did not take into account the product specification, use, or customer expectation, and was not the appropriate way to match a product. The Co-op standard wholemeal loaf, 800g was appropriately price matched to the Aldi wholemeal loaf 800g at 75p.
Co-op said it price matched its Fusilli Pasta Twists 500g, with Aldi’s Penne Pasta 500g and did not agree that it should instead have matched with Aldi’s Fusilli Pasta 1kg and then pro rata the price to achieve an appropriate match. They said products sold in larger volume were generally slightly cheaper than the smaller sized version. Therefore, they did not consider that comparing a Co-op 500g pack with an Aldi 1kg pack was the most appropriate product and their research suggested that a comparable customer need would not substitute a 500g pack against a 1kg pack. In the absence of Aldi stocking a 500g pack of fusilli pasta, the comparison of fusilli and penne in the same pack size was appropriate and served the same customer need. Co-op also disagreed that its tagliatelle pasta should be compared with Aldi’s egg tagliatelle, because that was part of their “Specially Selected” range and therefore a higher tier product, which was reflected in the higher price and would not be appropriate to match mixed tiered products for comparison. For the same reasons, it did not consider it appropriate to match Co-op linguine with Aldi’s “Specially Selected” linguine.
In relation to the products they had selected to match across their range of cookies, Co-op said where there was no identical flavour to compare to Aldi, they chose to match products which they believed fulfilled the same customer need and purpose, despite variance in individual ingredients, which they said was backed by their research.
Within the pet food category, Co-op said eight products were exact matches to Aldi products. For the remaining nine pet food products included in the APM, they matched to Aldi’s lowest-priced similar variants, taking into account nutritional equivalence, consumer flexibility on proteins in value tiers and typical supplier protein rotation.
Across the soft drinks included in the APM, Co-op said 13 products were exact or very close matches and five used the closest comparator, ensuring customer choice while meeting the same need and purpose.
With regards to comparing milk originating from different regions, Co-op defended comparing its regional (Irish, Scottish and Welsh) one-pint semi-skimmed variants to Aldi’s national (British) line on the basis that the underlying product was identical and that including regional variants ensured their members in all regions could purchase a standard or regional variant.
Co-op said their ad included relevant terms and conditions and a link to a landing page where they specifically said they had price matched comparable products. The product list provided the full list of the Co-op products alongside the products to which they were price matched at Aldi; this they believed was the same approach taken by other retailers.
Assessment
1. Not upheld
The ad featured the claim “Everyday Essentials price matched to Aldi” at the top of a webpage that displayed product-category tabs which included, “Milk, butter, cheese and eggs”, “Food cupboard” “Meat, fish and poultry”. The banner showed images of tinned tomatoes, carrots, milk, grapes, a loaf of bread, washing-up liquid, eggs and yoghurt. Further down the page, additional products were shown within their respective categories.
The ASA considered that the average consumer would understand the claim to mean that Co-op had price matched with Aldi groceries and products that consumers used every day, or bought most often, such as the examples featured in the banner and shown in the images.
We considered that consumers would understand the claim to refer to selected essential lines rather than to Co-op’s entire range, and that the term “everyday essentials” distinguished those items from luxury, one-off or occasional purchases.
While individual shopping habits varied, we considered that most consumers would be able to identify certain staple products or categories of items as being bought regularly, whilst also accepting that items they personally regarded as an “everyday essential” might not necessarily be included due to differences in shopping habits and personal preferences.
We nonetheless considered given that the banner sat directly above the tabbed product categories at the top of the webpage, together with the item-by-item listings and images, readers were unlikely to rely solely on the term “everyday essentials” or banner imagery to identify the scope of included items. The “see more” links provided also made it easy for consumers to identify the full range of products included in the APM as well as the links to the full list provided at the bottom of the webpage.
We therefore concluded that the ad made sufficiently clear which items were included in the price-match scheme and that the claim “everyday essentials” was unlikely to mislead on that basis.
On that point we investigated the ad under CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), and 3.7 (Substantiation), but did not find it to be in breach.
2. Not upheld
We understood that Aldi believed that the chopped tomatoes, washing-up liquid and carrots included in the banner at the top of the ad had not been included in the APM and, therefore, should not have been featured.
Co-op provided pricing history of the three products for both parties covering the start of the price match scheme in March 2025 until the start of October 2025. We assessed the evidence up to and including 20 August 2025, the time at which the ad was seen.
The price of the tomatoes changed once, and the prices of the lemon washing-up liquid and carrots three times during the period covered by the pricing history, on each occasion after Aldi changed its prices.
We understood that the carrots featured in the ad were the 500g pack size. However, Aldi’s concerns were raised against Co-op’s 1kg sized pack of carrots. We understood the larger 1kg pack was not included in the APM because it was only sold in a limited number of Co-op stores, whereas the 500g pack was sold by both retailers in a large number of stores. The data provided showed that at each price change, Co-op matched the price of the 500g pack of carrots to Aldi’s. We were therefore satisfied that the carrots pictured in the banner were included in the price match scheme.
Aldi’s assertion that the Co-op Chopped Tomatoes were not included in the price match scheme was based on the price of their “Everyday Essentials” Chopped Tomatoes being cheaper than the Co-op tinned tomatoes in the ad. However, we understood that the Aldi “Everyday Essentials” range was their value range and therefore considered it would not be appropriate for price matching against the selected Co-op product.
Co-op’s Lemon Washing-Up Liquid 450ml was sold for 59p and price matched with Aldi’s 500ml product priced at 65p. Aldi said that pro-rated for volume, their product cost 58.5p, rather than 59p, per 450ml. We understood that Co-op rounded up for prices of 0.5–0.9p and their evidence showed that they had price matched to Aldi rounding up to the nearest penny to 59p. Because the smallest unit of currency in circulation was one penny and retail prices were expressed in full pence only, we therefore accepted the pro-rated price of the Co-op Lemon Washing-Up Liquid was 59p, in line with standard rounding.
We were therefore satisfied that the three products were included in the APM and that the evidence provided demonstrated that Co-op had matched its prices to Aldi throughout the period assessed.
On that point we investigated the ad under CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), and 3.7 (Substantiation), but did not find it to be in breach.
3. Upheld
The CAP Code stated that ads that included a comparison with an identifiable competitor must not mislead, or be likely to mislead, the consumer about either the advertised product or the competing product. It also stated that they should make the basis of any comparison clear.
The headline claim stated, “Everyday Essentials price matched to Aldi”. Small text at the bottom of the ad stated, “We match the prices of certain Co-op products against comparable products available at Aldi”, together with links to the full list of products included in the APM. We considered that given its position at the bottom of the webpage, and the small font, that text was likely to be overlooked by some consumers, and they would therefore expect the main claim to mean that prices were being matched against the same products sold by both stores. We further considered it was likely to be overlooked by consumers because there was no indication within the ad that there were qualifications to the headline claim “Everyday Essentials Price Matched to Aldi”.
We considered that consumers who had read the small text would understand that on the occasion the same product was not sold by Aldi, Co-op would price match against the nearest comparable individual product. Notwithstanding that, we considered that the term “comparable product” was ambiguous and could reasonably be understood by consumers in different ways, based on their individual shopping behaviours and preferences. We noted that there was no further information in the ad which defined “comparable product” or explained how comparable products at Aldi were selected as matches by Co-op. We therefore considered that, even for consumers who had read the small text, the absence of further qualifying information meant it would not be clear to them what degree of comparability was intended, or how closely products had to match to be “comparable” for the purposes of the price match scheme.
The small text also included a link to a verification list which stated the Aldi products selected for comparison against the Co-op products in the price match scheme. Again, the link was not clearly connected to the initial price match claim which appeared at the top of the page. Because of that, and because the link was located at the bottom of the homepage, we similarly considered it would likely be overlooked by many consumers. We also considered its placement on the homepage, rather than being accessible within each product page, meant it was unlikely that consumers would refer to the list to check a product’s match as necessary. We therefore considered the list was unlikely to aid a consumer’s understanding of the term "comparable product”.
We understood that Aldi believed Co-op had not selected the most appropriate products for comparison in the price match scheme. Aldi provided a list of 45 items which they said identified all the products they believed were not appropriate for comparison.
We assessed those, alongside the rationale Co-op provided explaining why they had selected specific products for comparison.
Firstly, we noted there were products included in the price match scheme that were an exact match both in terms of the product’s variant and size. For example, we were provided with examples such as Co-op’s Seeded Loaf, Tiger Bloomer, White Toastie Loaf and Wholemeal Loaf which were exact matches to the Aldi products. We were also provided with other examples across different product categories, such as, Co-op’s Sparkling Lemonade and its diet variants which were similarly matched with Aldi’s equivalent products.
We understood that certain products had been matched to similar alternatives where no identical product was sold at Aldi. Such examples included Co-op’s Linguini Pasta with Aldi’s Cucina Spaghetti, Co-op’s Summer Fruits Flavoured Still Spring Water with Aldi’s Apple & Blackcurrant Flavoured Still Water and Co-op Meaty Chunks in Jelly with Turkey with Aldi’s Earls Meaty Chunks with Chicken in Jelly. We considered that consumers who overlooked the small text at the bottom of the ad would understand the claim to mean that exact products were being matched and would therefore not expect alternative products to be compared with one another. However, we also considered that, because the ad did not include information explaining how Aldi’s comparable products were selected, we considered that even those consumers who had read the small text would not understand the basis on which those matches had been made. In the absence of clarifying information, and given individual differences in shopping behaviour and preferences, we considered whether those products that were seen as comparable would vary by consumer. To include information about the basis of the comparison was, therefore, important for consumers.
We also understood that, because Aldi did not sell a ginger ale or bitter lemon product, Co-op’s Low Calorie Bitter Lemon, Low Calorie Ginger Ale and Soda Water were each matched to Aldi’s Vive Low Calorie Indian Tonic Water. We considered that, although those products were all soft drink mixers, they were distinct in flavour and intended use. We further noted that, in the data provided by Co-op to demonstrate customer purchasing behaviours, the low-calorie and regular versions of the drinks were shown as complementary to each other, but ginger ale and bitter lemon were shown as being distinct from tonic water. Again, we considered that the consumers who understood the claim to involve exact product matches would not expect the bitter lemon, ginger ale or soda water to be compared with tonic water. We further considered that even those consumers who were aware that comparable products were being matched would not consider those drinks as the nearest comparable product to tonic water given that they differed in flavour and typical use. We therefore considered the nature of the product being matched was material information which should have been included clearly and prominently.
We further understood that, in some cases, products were compared with a less similar alternative despite a nearer match being sold by Aldi. For example, Co-op matched their Wholemeal Farmhouse Loaf with an Aldi White Farmhouse Loaf. Co-op said that Aldi did not sell a Wholemeal Farmhouse Loaf, and they believed that the bread being a “farmhouse” style was the more significant feature than the loaf being wholemeal. We considered that wholemeal and white loaves differed in legally recognised composition and had different nutrition and taste profiles. Because of that, we considered consumers would actively choose between wholemeal or white flour for different reasons, such as health or personal preferences. We considered that shoppers would likely view the flour type as a primary product characteristic, and that loaf style, such as farmhouse, standard or toastie, would be a secondary consideration. We therefore considered that the majority of consumers would not view a white loaf as the nearest comparable product to a wholemeal loaf and that, because Aldi sold a wholemeal loaf, the Aldi Farmhouse White Loaf was not an appropriate match.
Co-op matched their Fusilli Pasta Twists 500g with Aldi’s Cucina Penne Pasta 500g. Co-op explained that was because Aldi only sold fusilli pasta in a 1kg sized pack. While we acknowledged Co-op’s point that a cross-size comparison (500g vs 1kg) was not an exact match, we did not consider that penne pasta was the nearest comparable product when fusilli was sold by Aldi.
We noted that the qualification stated that prices would be matched pro-rata and that Co-op had pro-rated the price match of the washing-up liquid and had chosen to exclude the 1kg pack size of carrots from the APM because it was only sold in limited stores. We therefore considered that Co-op could have applied the same approach in respect of the pasta matches, and that in not doing so they were inconsistent in how products were selected and price matched in the APM. We also noted their view that a comparable consumer’s need would not be met by substituting a 500g pack with a 1kg pack. However, we considered that, because dried pasta was non-perishable, consumers would be more likely to substitute it with a larger pack size, unlike perishable items such as carrots.
We considered that consumers would understand the prices to be matched against the same products sold by both stores, or, for those who had read the small text at the bottom of the ad, that on the occasion the same product was not sold, the nearest comparable individual product would be selected for comparison. However, because Aldi’s nearest comparable individual product had not always been selected by Co-op for inclusion in the price match, and because no sufficiently prominent information was provided or adequately signposted to explain how products were deemed “comparable”, and to verify the claim, we concluded that the basis of the comparison had not been made clear and that the ad was therefore misleading.
On that point the ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 3.7 (Substantiation), 3.9 (Qualifications) 3.32, 3.34 and 3.38 (Comparisons with identifiable competitors).
Action
The ad must not appear again in the form complained of. We told Co-operative Group Ltd t/a Co-op that where identical products were not available in their price match scheme to ensure that their selection of comparable products did not mislead. We also told them to ensure that the basis of comparison was made clear to consumers and that they provided sufficiently prominent information to enable consumers to verify comparisons with identifiable competitors, or signposted consumers to such information.
CAP Code (Edition 12)
3.1 3.3 3.7 3.9 3.32 3.34 3.38
