Summary of Council decision:

Two issues were investigated, one of which was Not upheld. The other was informally resolved after the advertiser agreed to amend their advertising.

Ad description

Two ads for Warburtons bread, seen in February 2021:

a. A post on Warburtons' Instagram page featured headline text stating "100% WHOLEMEAL NO ADDED SUGAR” and a pack shot of the product. Further text in the post stated “Try the true taste of wholemeal”.

b. Another post on Warburtons' Instagram page featured headline text stating "GUESS WHAT'S HIDING IN OTHER LOAVES?" alongside an image of a tablespoon of sugar. The post also featured a pack shot of the product. Further text in the post stated "We think the truest tasting wholemeal is the tastiest. So unlike in some others, you'll find no added sugar in our loaf, just 100% wholemeal."


The Real Bread Campaign challenged whether the claim "100% WHOLEMEAL" in ad (a) and the claim "So unlike in some others, you'll find … just 100% wholemeal" in ad (b) were misleading, because all wholemeal loaves were required by law to contain 100% wholemeal flour.


Warburtons Ltd explained that the primary purpose of the campaign was to highlight the fact that their wholemeal loaf did not contain any added sugars. They did not believe the claim “100% wholemeal” to be an implied comparison to any identifiable competitors.

The ads (when taken as a whole) did not seek to draw a comparison with other products in relation to “100% wholemeal”. They did not imply that Warburtons included or excluded an ingredient which others did not in relation to wholemeal flour, but rather used it to highlight that they had not added sugar (an ingredient which others did add). Warburtons’ use of “100% wholemeal” was a simple description of the nature of the product and therefore not misleading. The term had not been used in a comparative manner with any identifiable competitor.

Warburtons believed there was no suggestion in the ads (whether implied or explicit) that another product was not 100% wholemeal. In ad (b) the use of “no added sugar … just 100% wholemeal” was intended to make clear that other manufacturers used sugar additives in addition to 100% wholemeal flour. The words were combined with an image of a spoon with sugar which added to that impression. That was not dissimilar to ad (a) which stated “100% wholemeal no added sugar”. The comparison was therefore that sugar had been added to other products in addition to the 100% wholemeal flour, not that any other product was not 100% wholemeal flour. To view “100% wholemeal” as a distinct claim would deprive the ads of their core purpose, which was to emphasise that the product was simply 100% wholemeal and that no sugar had been added.

They provided some examples of competitor products which did contain added sugar.

They pointed out that the use of the claim “100% wholemeal” was not unique to their product and provided examples of other loaves using that description. They believed those examples showed that the term was being used as a method of description and not as a point of comparison.

They also pointed out that they had not received any complaints or queries about the ads from consumers, direct competitors or retail customers.


Not upheld

The ASA considered that the emphasis of the ads was on the fact that the product did not contain added sugar. In ad (a), “no added sugar” was featured in the headline in large lettering as well as on the image of the product, and in ad (b) the headline text “Guess what’s hiding in other wholemeal loaves?” was accompanied by a visual of a tablespoon of sugar and “no added sugar” also featured in the image of the product. We also noted that both of the ads referred to ‘taste’ – in ad (a), where it stated “Try the true taste of wholemeal” and in ad (b) where it stated “We think the truest tasting wholemeal is the tastiest …”.

We understood that the complainant believed consumers were likely to view the claims as meaning Warburton’s loaf contained flour that was 100% wholemeal and that, by highlighting that fact, there was an implication that other wholemeal loaves might not contain flour that was 100% wholemeal. We considered consumers were unlikely to interpret the claims in that way because of how they were presented in the context of the ads, where the focus was on the product containing no added sugar.

We considered consumers were also unlikely to interpret “100% wholemeal” to mean that because there was no added sugar, the loaf only contained wholemeal flour and no other ingredients. We considered consumers were unlikely to take such a literal view and would understand that loaves were likely to contain other key ingredients in addition to flour, such as salt and water.

We considered that, in the context in which the claims were made, with the emphasis being on ‘no added sugar’ and taste, consumers were likely to interpret the claims “100% wholemeal” in ad (a) and “So unlike in some others, you'll find no added sugar in our loaf, just 100% wholemeal” in ad (b) to mean their product had a less adulterated or purer taste compared to loaves with added sugar which created a sweetness that might mask some of the wholemeal taste.

For those reasons, we concluded that the claims were not misleading.

We investigated ads (a) and (b) under CAP Code (Edition 12) rules  3.1 3.1 Marketing communications must not materially mislead or be likely to do so.    3.3 3.3 Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, the  medium and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means.
 (Misleading advertising) and  3.33 3.33 Marketing communications that include 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.  (Comparisons with identifiable competitors), but did not find them in breach.


No further action necessary.

CAP Code (Edition 12)

3.1     3.3     3.33    

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