Journal of Trading Standards Winter 2026

✚ Trader licensing

Could a mandatory scheme help keep out the rogues?

✚ Apprenticeships

We hear from some of the profession’s new recruits

✚ DMCC Act

The landmark legislation being put into practice

✚ Neurodivergence

Harnessing the potential of thinking differently

Winter 2026 | www.tradingstandards.uk

SHADOW ECONOMY How organised crime infiltrated the UK’s high streets, doorsteps and supply chains

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Journal of Trading Standards WINTER 2026

Leader

Let’s hit the streets It is ironic that the role of Chair doesn’t involve much sitting down.

Since I had the privilege of formally taking on the job in October, I have been helping to get CTSI’s name out there, spreading the word about the important work done by our members up and down the UK. In November I was fortunate enough to be invited to the Lady Mayor’s Show in the City of London, where I took part in the David MacKenzie procession with colleagues. It was a bit of a step outside my comfort Chair, CTSI zone – I am usually far more comfortable cheering others on from the sidelines – but looking back at what turned out to be an inspiring day, I realise how important it is for CTSI and the wider Trading Standards profession to be visible at such events. They provide an opportunity for us to stand up and be counted, to find common ground with potential allies, to celebrate our “We must think creatively role in keeping the public safe, and to call for much-needed support and resources. and embrace the new We all know how desperately that support is needed.

As this issue’s cover story (see tools at our disposal” page 12) lays bare, organised criminals have gained a foothold in the UK’s cities, towns and villages in recent years, peddling illicit and dangerous goods, laundering money, and bolstering their capacity to pursue serious forms of criminality.

The Autumn Budget’s announcement of funding for 45 new Trading Standards Officers, on top of the previously announced funding for apprentices (see page 52) is, of course, welcome. But it is a drop in the ocean; as long as criminals, rogues and badly behaved businesses feel that no one is keeping tabs on them, we face the very real threat that swathes of harmful activities are effectively being decriminalised.

Alongside our partners in the police, national regulators, Environmental Health and a host of other agencies, Trading Standards is doing its best to fight back. In the face of such significant challenges and fast-paced change though, an adequate response will require more than just funding. We must think creatively and embrace the new tools at our disposal. The Digital Markets, Competition and Consumers (DMCC) Act, for example, gives us new civil enforcement options (see page 24), as does new animal welfare legislation (see page 56). Plans to reorganise local government could also create opportunities for us to amplify our effectiveness.

For that to work though, we must speak out. And, with its growing membership and sense of momentum, CTSI is in an ever stronger position to do that. But we need you, our members, to help us lobby for change. So please, get involved in your local branch, join us in our campaigns and, dare I say it, make a nuisance of yourselves. l

Winter 2026

Editor-in-Chief:

Kerry Nicol Editor:

Richard Young Designer:

Sam Millard Contributors:

Matt Allwright, Robert Grice, Pauline Lloyd Roberts, Kuldeep Maan, Jessica Merryfield, Andrew Passenger, Steph Young Writers:

Richard Young Editorial Board:

Damien Doherty, John Herriman, Tendy Lindsay, David MacKenzie, James Munro, Phil Owen, Giles Speid, Gareth Walters

Article suggestions and feedback should be sent to: editor@JournalofTradingStandards.co.uk

The Journal of Trading Standards magazine and website are produced on contract by Fourth Estate Creative Ltd. www.fourthestatecreative.com connect@fourthestatecreative.com Printed in the UK by Manson Group Distributed by Gold Key Media Published by the Chartered Trading Standards Institute, 1 Sylvan Court, Sylvan Way, Southfields Business Park, Basildon SS15 6TH. www.tradingstandards.uk 01268 582 200 © 2026, Chartered Trading Standards Institute. All rights reserved.

Views expressed by the authors are not necessarily the views of CTSI. Some of the images used in this publication were generated by AI.

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Journal of Trading Standards WINTER 2026

Contents NEWS, OPINION & FEATURES

COVER STORY

FEATURE

5 | Upfront

12

24

Little shops of horror Why Trading Standards has a central role in disrupting the organised criminal networks that have infiltrated the UK’s high streets, doorsteps and supply chains.

Theory into practice With parts of the landmark DMCC Act now in effect and more on the way, we hear from Lead Officers about how the legislation is making its mark in the ‘real world’.

FEATURE

FEATURE

26

30

Business unusual We hear from Slough, where financial pressures have required the Trading Standards team to get creative on issues including Sunday trading and giant snails.

Redressing the balance With rogue builders and organised criminals ruining lives and livelihoods, is it time for the introduction of a licensing scheme in the home improvement sector?

INTERVIEW

FEATURE

42

54

Sarah Adcock The DBT's Director of Consumer and Competition Policy explains why consumers are the foundation of a healthy economy.

Hero Awards Celebrating the individuals, teams and organisations that went the extra mile to protect the vulnerable in 2025.

News and views from Trading Standards, including the latest Lead Officer reports.

10 | Obituary: John Stapleton

The late broadcaster made a lasting contribution to consumer protection.

11 | Opinion: Matt Allwright Why John Stapleton's work to improve product safety is more important than ever.

20 | Opinion: Jessica Merryfield Looking ahead to CTSI's plans for new campaigns, events and initiatives in 2026.

22 | Gaining momentum

We hear from CTSI members ensuring equality is at the heart of the profession.

28 | Take the next step Exploring the benefits of CTSP status.

34 | Duty of care

Trading Standards' role in safeguarding the vulnerable victims of carer fraud.

36 | Back to College

The College of Fellows might have a new structure, but the good work continues.

38 | Guardians of principle From ancient Greece to modern-day scams.

40 | One step at a time Examining the dangers of unsafe ladders.

46 | Joined-up thinking

Sharing ideas on the Renters' Rights Act.

48 | Train of thought Harnessing the power of neurodivergence.

52 | Send in the reinforcements

Why apprentices are vital to the profession.

56 | CPPD: Animal Penalty Notices Get to grips with a new enforcement tool.

58 | Flower power Operation Tudor Rose makes its (hall)mark.

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Winter 2026

Journal of Trading Standards WINTER 2026

Upfront APPROVED CODE SCHEME

WORKFORCE CAPACITY

Minister backs Approved Codes SCOTSS sounds alarm Consumer Minister Kate Dearden MP has publicly backed the CTSI-administered Approved Code Scheme (ACS) at an event in Westminster, describing Approved Codes as “an important tool in supporting consumers and businesses to engage, innovate and drive growth”.

On 22 October Dearden joined CTSI Chief Executive John Herriman; Emma Cochrane, Acting Executive Director of Consumer Protection at the Competition & Markets Authority (CMA); and James South, Chief Executive of the Centre for Effective Dispute Resolution (CEDR) for the ‘Moments that Matter – A Lifetime of Protecting Consumers’ Interests’ event at Portcullis House.

The event, which was held in partnership with the All-Party Parliamentary Group (APPG) for Consumer Protection and featured a panel discussion on the benefits of Approved Codes,

Left to right: Kate Dearden MP, John Herriman, Martyn James, James South and Emma Cochrane at CTSI's Approved Codes event in October

was hosted by consumer protection journalist Martyn James.

It attracted representatives from some of the 40 ACS sponsors, who between them cover more than 45,000 UK businesses and protect more than £155bn in consumer spending.

MPs, peers and alternative dispute resolution (ADR) providers were also in attendance.

In her speech, Dearden said the Government would be

“discussing with CTSI and others how Codes can be further developed and better utilised, particularly in problematic sectors”.

Herriman said: “The ACS is a proven model that builds consumer confidence as well as helping responsible businesses to thrive.”

Read our interview with the Government's new Director of Consumer and Competition Policy on page 42.

DMCC ACT

CMA launches major pricing probe The Competition and Markets Authority (CMA) has announced a ‘major package of action’ designed to address online pricing practices, including drip pricing and pressure selling.

The investigation, which is the first of its kind since the introduction of the Digital Markets, Competition and Consumers (DMCC) Act 2024, will shine a spotlight on StubHub, viagogo, AA Driving School, BSM Driving School, Gold’s Gym, Wayfair, Appliances Winter 2026

Direct and Marks Electrical.

The CMA says it has ‘reason to suspect’ that the eight businesses ‘have infringed consumer law’. The regulator will also write to 100 businesses across 14 sectors outlining concerns about their use of additional fees and sales tactics.

If the CMA finds the law has been broken, it can order businesses to pay compensation to affected customers, as well as fining them up to 10% of their global turnover.

CMA Chief Executive Sarah Cardell said: “It’s crucial that people are able to shop online with confidence, knowing that the price they see is the price they’ll pay, and any sales are genuine.

“Whether you’re spending your hard-earned cash on concert tickets or driving lessons, joining a gym or buying furniture and appliances for your home, you deserve a fair deal.”

For more on the DMCC Act, see page 24.

The Society of Chief Officers of Trading Standards in Scotland (SCOTSS) has sounded the alarm about staffing levels, with its latest workforce survey revealing a drop in numbers below 250 for the first time. It also shows that 60% of staff are aged over 50.

SCOTSS Chair Alexandra Connell said: “Trading Standards services in Scotland are at their lowest ebb and our ability to do our job is significantly hampered by a lack of human resource.”

HALLMARKING

Gone for gold The winners of the 2025 Touchstone Award were invited to a special ceremony and training day at the London Assay Office on 18 November in recognition of their successes in enforcing the Hallmarking Act. The London Trading Standards (LTS) Officers were celebrated for Operation Stamping it Out, which removed more than £250,000 worth of non-compliant and illegal items from the market in the capital.

For more on hallmarking enforcement, see page 58.

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Journal of Trading Standards WINTER 2026

Upfront

VOICES FROM THE FRONT LINE

Trading Standards team CARMARTHENSHIRE COUNTY COUNCIL What has been your main area of focus over the past six months?

As with colleagues all over the UK, the influx of counterfeit Labubu dolls has taken up much of our time of late. We tried to get as much information out to the public as possible about the safety issues linked to these products and thankfully, the problem does now seem to be on the downturn.

Our attention has now returned to one of our main sources of work: multi-victim rogue traders, mostly in the garden maintenance and landscaping sector. Many of our recent cases cross borders, and we regularly take victim statements for colleagues in other local authorities in the region and vice-versa. We have a dedicated Financial Investigations Team that we work with closely who have achieved some great results with

“The age-old issue of consumers wanting to save money is usually a factor – but at what cost?”

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PoCA, as well as securing a custodial sentence in a recent case.

On the safety front, we continue to regularly test all sunbeds in Carmarthenshire as part of our proactive high-risk visit programme, as we think this is a sector that could slip back into old ways if not monitored.

Jenny Wiehahn Are there any emerging issues?

Even though one of our main focuses has always been rogue traders, the past few months have seen an increase in complaints in this area, and repeat offending does seem to have increased.

We are also seeing an increase in complaints stemming from traders that have been sourced via certain ‘trusted trader’ search platforms. We would query the standard and quality of background checks carried out on some of these traders as time and time again they feature in our investigations. The Buy With Confidence scheme however has proved to be invaluable.

What are the obstacles to tackling these issues?

The age-old issue of consumers wanting to save money is usually a factor – but at what cost?

Another obstacle is that victims are not always happy to provide a Section 9 statement, often because they have received a refund via their bank and are then less enthusiastic about helping bring the rogue trader to justice.

LEAD OFFICER FOR FOOD, ESSEX COUNTY COUNCIL What has been your main area of focus over the past six months?

We continue to receive a large amount of food allergen complaints as well as intelligence about poor allergen controls from Environmental Health.

Most of the complaints are from consumers who have told businesses about their allergies or that they have coeliac disease.

Either the businesses do not know enough about allergens, or do not take them seriously enough. This results in members of the public becoming ill after eating food contaminated with the allergen.

As part of a regional project, we are taking covert food samples at caterers, requesting that the food is free from allergens such as milk or egg and then getting it analysed. Out of the 39 samples taken in the past six months, there have been nine failures. We have one food allergen case in court and two more are due to go to our legal team.

Trading Standards teams across the four nations have been tackling issues including fake Labubus, allergen awareness, used cars and holiday parks

Are there any emerging issues?

We have many food importers and manufacturers in Essex, which means that imported food is always a concern. This can involve American sweets, drinks and snacks which contain prohibited additives. We have been conducting visits to retailers and importers of these items as part of another regional project.

Another concern is the import and sale of ‘Dubai style’ chocolate products. These do not always declare allergens such as wheat. We are also finding that as they contain pistachios, they can be contaminated with high levels of B1 and total aflatoxins, which are dangerous to consume.

Even though they are not yet banned for under-16s, we are getting an increasing number of complaints about highly caffeinated drinks being sold to children.

We have heard that students are buying these drinks on their way to school and are then unable to concentrate on lessons.

What are the obstacles to tackling these issues?

We have limited food officer resource and a very large county to cover but are fortunate to have a number of apprentices, three of whom qualified in food this summer. All the food officers in our authority are multidisciplinary, with food being only part of their work.

Winter 2026

Journal of Trading Standards WINTER 2026

Cara McParland AREA INSPECTOR, NORTHERN IRELAND TRADING STANDARDS SERVICE What has been your main area of focus over the past six months?

Alongside my day-to-day work of overseeing complaints and investigations within my own team, I have been assisting in the coordination of a service-wide project looking at used car traders across Northern Ireland.

Each year we receive a substantial number of complaints about unfair trading practices by used car traders. Following a review of complaint data, we identified a number of areas of concern around traders’ practices that were likely to breach consumer protection legislation.

We’re currently engaging with the most complained-about car traders by meeting with them to talk through our concerns, advising on areas where improvements can be made and offering training on the relevant legislation. So far we’ve had a positive response from the trade. Some have requested to maintain regular communication with us to ensure improved compliance.

Are there any emerging issues?

Northern Ireland is facing a significant housing crisis, with a large social housing waiting list, a

Winter 2026

shortage of new homes and rising private rental costs. My team and I lead on complaints and enquiries in relation to estate and letting agents, and we regularly receive requests for advice and assistance on estate agency matters, tenancy agreement terms, tenancy fees and other matters that arise before, during and at the end of a tenancy.

While we have no remit under the relevant housing legislation in Northern Ireland, we know how to identify clear breaches of consumer protection legislation in relation to the estate and lettings sectors, and act accordingly.

We also continue to see the devastating effect that scams and rogue traders can have on consumers – especially the most vulnerable in our society.

We have dedicated Officers who work tirelessly with victims and our partner organisations to provide support, seek redress and bring the perpetrators to court.

What are the obstacles to tackling these issues?

In terms of the property sector, having strong, clear and mandatory guidance and/or standards to hold property agents accountable would help massively when advising consumers and agents on their rights and obligations respectively. The Government recently consulted on home buying and selling reform, so I hope to see robust and even revolutionary changes in the sector over the coming years. In the meantime, we will continue to advise and support legitimate businesses on how they can comply with consumer protection legislation, and hold those who don’t to account.

“Issues regarding underage sales of vapes and tobacco products remain a significant concern”

Glenys Brown TRADING STANDARDS OFFICER, HIGHLAND COUNCIL What has been your main area of focus over the past six months?

My work has concentrated on several initiatives, the first being vape compliance. Tackling non-compliant vapes and preparing for the single-use vape ban created challenges around enforcement, disposal and consumer awareness. Ongoing issues regarding underage sales of vapes and tobacco products remain a significant concern, requiring test purchasing and retailer engagement.

Another key project has been on holiday homes, an emerging issue since the Covid pandemic.

Expansion and development in this area has resulted in consumers entering contracts without any prior legal advice. Prices of lodges/caravans for holiday use can range from £75k-£180k, so they are a very costly purchase. Issues relate to unfair contract terms, unclear utility charges and site service obligations in holiday parks and lodge sites.

The SCOTSS Fair Trading Group’s Bulk Fuel Project is another ongoing initiative to analyse the impact of poorly drafted consumer contracts in the bulk fuel sector, particularly those with unfair terms and excessive charges.

Last but not least, the creation of the Highland Trusted Trader Scheme has meant that we have proactively contacted businesses and provided guidance on consumer protection legislation as part of the member recruitment process. Application numbers continue to grow.

Are there any emerging issues?

There has been an increase in illegal vape products in shops and persistent underage sales occurrences. We continue to issue Fixed Penalty Notices of £200 for each breach relating to underage sales and other breaches under the Tobacco and Primary Medical Services (Scotland) Act 2010.

We have also seen an increase in complaints relating to green energy and heating solutions, with particular concern regarding misleading claims and aggressive marketing around renewable energy installations.

What are the obstacles to tackling these issues?

Civil law issues and new legislation require specialist expertise. We continue to collaborate with CTSI Lead Officers and make use of Business Companion resources. We also continue to work with specialist groups within SCOTSS. However, more staff and targeted training is required to keep up with specialist knowledge and build resilience into the profession.

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Journal of Trading Standards WINTER 2026

Reporting in Animal Health & Welfare

Activities: Representing CTSI on the National Animal Health and Welfare Panel and the National Animal Welfare Companion and Exotics Group.

Notes: Areas of focus include the Animal Welfare (Import of Dogs, Cats and Ferrets) Bill. There are concerns about the unintended consequences of the legislation, including welfare being compromised if animals are smuggled into the UK without ID. This will pose a bio-security risk and concerns have been raised with Defra. Exotic notifiable disease also remains a concern.

Digital, AI & Emerging Markets

Activities: Delivered talks to the NTS Regional Intelligence Analysts and to various regional CTSI branches and Conference.

Notes: The increased use of AI for companionship and therapeutic purposes raises concerns about user vulnerability. Publicity has increased around the risk of large language model (LLM)-generated psychosis, alongside reports of some LLM models encouraging illegal or unethical behaviours. AI is also being used to finetune fraudulent sales pitches and to identify vulnerable consumers.

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Civil Law

Activities: Participating in the CTSI Policy Committee and the Consumer Protection Partnership (CPP) Working Group for Park Homes.

Notes: Key areas of focus include the Digital Markets, Competition and Consumers (DMCC) Act (see page 24); the Consumer Credit Act (CCA) 1974 consultation; and work on park homes work with the Department for Business and Trade (DBT) and the Competition and Markets Authority (CMA).

It is important to ensure that the rights and remedies set out in legislation can actually be enforced.

Doorstep Crime, Scams & Consumer Vulnerability

Activities: Participated in the NTS Doorstep Crime Working Group, the Scams Team Research Innovation and Collaboration Taskforce, and the Coercive Control Taskforce.

Notes: Key areas of focus include the continued need for a licensing scheme for the home improvement sector (see page 32). There is a genuine concern about the decriminalisation of doorstep crime in practice, despite it forming a ‘high priority’ area almost universally at national, regional and local levels.

CTSI's Lead Officers produce reports every six months on their areas of specialism, looking at current and upcoming threats and challenges, as well as recent activities and initiatives with which they have been involved.

Consumer & Product Safety

Activities: Participating in the Royal Society for the Prevention of Accidents (RoSPA), Electrical Safety First product safety committee, and the Office for Product Safety & Standards (OPSS) National Product Safety Group, and the BSI Designated Standards Committee.

Notes: The Product Regulation and Metrology Act awaits secondary legislation to address potential gaps in consumer protection. It is anticipated that updates on new legislation resulting from the Act will be a topic of discussion at Conference 2026.

e-Commerce

Activities: Providing continuing guidance and training on the Digital Markets, Competition and Consumers (DMCC) Act, the unfair commercial practices and civil enforcement aspects of which are now in force (see pages 5 and 24).

Notes: The DMCC Act's new provisions on subscription contracts will have widespread impact, and we await the details following the DBT consultation. The ADR provisions of the DMCC Act have had less focus and apply less widely, but are crucial for ADR operators and potentially for CTSI.

Consumer Advice, Education, Fraud, Scams & Consumer Vulnerability

Cosmetics & Beauty

Education & Training

Energy, Green Heating & Net Zero

Activities: Engagement in the Consumer Credit Act (CCA) reform consultation; media appearances to highlight risks and promote consumer rights; and input into the Fraud Strategy Review to ensure Trading Standards is central to multi-agency consumer protection hubs.

Notes: There is increasing consumer detriment linked to green finance scams and unregulated credit products. There is rising demand for practical vulnerability training across sectors.

Activities: Participated in the CTSI Qualifications Panel, the Legal Metrology Working Group, and the CTSI Northeast Branch Executive.

Notes: The main development in this period was CTSI Council’s decision on the recommendations to improve the delivery of the Legal Metrology qualification. Following the Extraordinary Council Meeting, a secondary proposal was agreed for the Qualifications Panel to review the Legal Metrology portfolio. A working group is being formed, with representatives from each region.

Activities: Participated in the Cosmetics Stakeholders Group, National Product Safety Group, and the Office for Product Safety & Standards (OPSS) Working Group on Aesthetics.

Notes: The Department of Health and Social Care (DHSC) has announced plans to regulate high-risk aesthetic procedures and treatments. There are ongoing weaknesses in the GB Cosmetics Portal (SCPN), including fraudulent or misleading product notifications. Challenges from unsafe products sold online and imported through unconventional supply chains persist.

Activities: Participated in the Consumer Protection Partnership (CPP) on Net Zero and the Microgeneration Certification Scheme (MCS) Panel.

Notes: The new MCS Scheme is formally recognised by ISO 17067, the Financial Protection Standard, and Centralised Complaint Management.

There are concerns that some consumers who have installed energy-efficient products in their homes have seen their energy bills rise dramatically because the wrong products were installed, or were fitted incorrectly.

Winter 2026

Journal of Trading Standards WINTER 2026

Fair Trading & Pricing

Food Standards & Nutrition

Hallmarking

Activities: Participated in the Pricing Experts Group and the Second Hand Car Working Group.

Notes: A key area of focus has been the Digital Markets, Competition and Consumers (DMCC) Act (see page 24). Training has been rolled out to Officers and businesses, including sessions at CTSI Conference. These were well attended and generated significant discussion, reflecting the scale of interest in this new legislation.

A plenary session also took place on dynamic pricing, another issue addressed under the DMCC Act.

A large proportion of recent work has centred on CMA consultations.

The Lead Officers have also contributed to wider regulatory discussions including the review of Package Travel (led by the Holiday & Travel Law Lead Officer), the Department for Business and Trade's (DBT) review of Park Homes legislation, and collaboration with the Property & Lettings portfolio to assess the impact of the DMCC Act on property sales. Looking ahead, Government work on secondary ticketing and planned amendments to the Price Marking Order will demand attention.

Legal Metrology

Motor Trade

Petroleum & Explosives

Property & Lettings

Activities: Represented CTSI on the National Legal Metrology Group and WELMEC Working Group 5. Lead Officers have also worked on a report to Council on the rejected twotier legal metrology qualification.

Notes: Although the Product Regulation and Metrology (PRaM) Act received Royal Assent in July, no legal metrology regulations have been made or discussed as of this point. There is the potential for further legal metrology regulations to be introduced as part of the Act. Winter 2026

Activities: Represented CTSI on the Primary Authority Car Sales Group; the Vehicle Safe Trading Advisory Group; the Motor Ombudsman multi-agency group on Japanese imports; the NTS Car Sales Group; and the Regional Vehicle Sales Group.

Notes: The main developments are the expansion of the electric vehicle (EV) market and its infrastructure. Other issues include 'ghost' number plates (see page 12) and second-hand vehicle sales being a major cause of detriment, as highlighted by the most recent Consumer Detriment Report.

Activities: Participated in the Food Standards Agency (FSA) project on edible oils; National Food Standards and Information Focus Group; Business Expert Group; Knowledge Hub Food Group; the National Codex Consultative Group; and the Exports Working Group.

Notes: Non-compliant products continue to enter the UK. This has extended to imports from countries such as Dubai and Japan.

There is increasing evidence of organised crime groups moving into the sale of non-compliant food and drink (see page 12).

Activities: Participated in the Association for Petroleum and Explosives Administration Fireworks Enforcement Liaison Group; delivery training on enforcement; and updated Business Companion guidance on fireworks licensing, storage and sale.

Notes: Emerging issues include evidence of increasing illegal activity in the fireworks sector. There are growing reports of unlicensed individuals importing fireworks, storing them in unsafe conditions, and selling them via social media marketplaces.

Activities: Since the last report, there has been much more activity on hallmarking and associated criminal activity within the jewellery sector. Most queries come from CTSI members intent on starting enforcement activity.

Notes: Market surveillance shows that up to 30% of online sales of jewellery are dishonest. Many online traders, even those with impeccable reputations, do not comply with the Hallmarking Act since they do not display a statutory jeweller's notice when a customer moves to check out. (For more on hallmarking, see page 58.)

Activities: Participated in the Home Buying and Selling Group and Council.

Now that the Renters' Rights Act is in effect, we are contributing to training (see page 46).

Notes: The introduction of the Renters' Rights Act brings in wholesale changes to how the lettings industry operates, including the introduction of a number of new offences which it will be the duty of Trading Standards to enforce. As the law covers housing, Environmental Health and Trading Standards, it will be interesting to see how they all work together.

Holiday & Travel Law

Activities: Participated in ABTA's Code of Conduct Committee and the Air Transport Insolvency Protection Advisory Committee run by the Department for Transport (DFT).

Notes: The Department for Business and Trade (DBT) is considering removing UK package holidays from the Package Travel and Linked Travel Arrangement Regulations (PTRs) and using credit card protection and travel insurance as possible alternatives. Outcomes of the DBT's consultations on the PTRs will be available in early 2026.

Vaping & Tobacco

Activities: Participated in the Vaping Expert Panel; the Smokefree Action Coalition; the National Illicit Tobacco Partnership Group; and the Cross Government Regulatory Group on Vaping.

Notes: CTSI Lead Officers were instrumental in obtaining funding for more than 90 new apprentices in England (see page 52).

Colleagues in other nations should be supported to make the case for similar funding. The Tobacco and Vapes Bill will likely introduce huge changes, as well as powers for Government to bring forward more regulations in future. |9

Obituary

By Richard Young

Obituary: John Stapleton The journalist and broadcaster was a stalwart ally of consumers and the Trading Standards profession John Stapleton, who died on 21 September 2025 after a battle with Parkinson’s disease, was a longstanding friend and supporter of Trading Standards. Along with his late wife and fellow journalist Lynn Faulds Wood, Stapleton served as a tireless ambassador and campaigner for consumers, bringing issues such as product safety, scams and unfair business practices to the attention of a wide audience.

Born in Oldham in 1946, where he was educated at Hulme Grammar School and St John’s College of Further Education in Manchester, Stapleton cut his teeth as a reporter on local newspapers in the 1960s before heading to Fleet Street and the national press. In 1970 he got his first break in television, working as a researcher on This Is Your Life. There followed a series of jobs in front of the camera, including as a reporter and then presenter on the BBC’s current affairs show Nationwide, where he covered topics including local government corruption and protection rackets.

Stapleton met Faulds Wood in 1971 when she was working in a bar in Richmond before beginning her own career in television. The couple married in 1977.

Stapleton became a household name throughout the 1970s and 80s. Alongside Faulds Wood he presented consumer affairs show Watchdog between 1986 and 1993, working to highlight rip-offs, expose rogue traders and sound the alarm on dangerous products.

It was during the Watchdog years that the duo’s relationship with TSI (as CTSI

10 |

was known before achieving chartered status in 2015) began. According to the Institute’s former Chief Executive, Ron Gainsford OBE, “John and Lynn came as a package; they were both so prevalent in their support for us. John often would be seen at Conference and events like the Young Consumer of the Year competition, and we came to rely upon them.

“They were always enthusiastic, both very nice people, and they both had a zest and a zeal about them that was quite contagious. In my years as Chief Executive it was wonderful to have Lynn and John around, whether together or separately, because you knew that they were passionate about the subject of consumer protection and treating people fairly. They both had such an appetite not only to help us, but to get our messages across in the media. That helped us immensely.”

Going the extra mile Stapleton and Faulds Wood were both prepared to step up when it counted, Gainsford reflects. “I can remember one particular year when we had our Conference in Brighton, and they both had other engagements straight afterwards,” he says. “Lynn had to get to Europe and John was flying up to Scotland, but typically they both agreed to help us out on the day. I looked at the time and said to Lynn, ‘If you’re going to get to Gatwick Airport I think the only thing that’s going to get you there is on two wheels’. To my surprise, she agreed, so

John Stapleton, 1946-2025

we hired a motorcycle courier who arrived at the hotel with a spare crash helmet and leathers, and away she sped. John also had to get to Gatwick, but he went by more conventional means – we got him a car.

“Neither of them needed to do that – they could have so easily said, ‘No, we’ve got these other engagements’. But typically, neither of them did. I’ve never forgotten it, because on the one hand it was great fun, and on the other it showed how much they were prepared to do for us.”

While Faulds Wood was a visible presence in consumer protection campaigns, particularly in the area of product safety, Stapleton’s work behind the scenes was equally indispensable, Gainsford says. “They were absolutely instrumental in the work we were doing on a variety of fronts. I can remember talking to John when we were pushing for the abolition of the doorstep selling of energy, and he was immensely helpful in ensuring that campaign was successful. He wasn’t up front on it – but in the background he was always very helpful. And we did succeed in putting a stop to the outrageous practice of elderly people being pressurised into signing up to energy contracts that they didn’t understand.”

Faulds Wood passed away in April 2020 following a stroke – like her husband, she left the world a safer, fairer place for consumers. It is a legacy that is now being continued by the couple’s son Nick, a presenter on the BBC’s Scam Interceptors. l

Winter 2026

OPINION

Matt Allwright Journalist and presenter of the BBC’s Watchdog and Rogue Traders

A legacy worth fighting for John Stapleton spent his career calling out unfair and shoddy business practices. Although he is no longer with us, his work is more relevant than ever

The way we buy things now has created an accountability gap

Winter 2026

There was sad news in September. We said goodbye to John Stapleton (see obituary, opposite). With his late wife, Lynn Faulds Wood, John set the standard and expectation for almost everything I have done on television in the last 30 years. They are both personal heroes. As you can imagine, the funeral ceremony was full of those wanting to celebrate John and also taking the opportunity to remember Lynn, who died during Covid. Their son Nick continues their brilliant work.

Nowhere was their effect more keenly felt than in product safety. Lynn campaigned for many years to make sure that the things we buy don’t do us harm, helping to establish the Office For Product Safety and Standards (OPSS), and complaining when it didn’t do its work well enough.

I know that Lynn was often frustrated by the lack of progress since the 1990s, when she and John transformed our homes from accidents waiting to happen into safe spaces. Insulated oven doors, moulded plugs on appliances, breathing holes in pen lids; all born from their belief that manufacturers and importers won’t keep us safe out of the goodness of their hearts. They have to be encouraged, goaded, shamed and, when necessary, legislated into doing so.

And yet it feels that, in many ways, we have gone backwards since the 1990s. The way we buy things now has created an accountability gap which means that progress towards a home we can lock up and leave in confidence, around which our kids can toddle

anxiety-free, has been reversed. The way that online buying platforms have replaced shops has allowed online retailers to offload legal responsibility onto the end provider, in all likelihood a drop-shipping outfit thousands of miles away which prioritises low-cost manufacturing over UK consumer law.

The result has made my inbox party like it’s 1979 with exploding batteries, underage knife sales, fake cosmetics, electrical non-compliance and enough general shoddiness for series after series of ’80s consumer TV. The terms and conditions make it clear that whatever the problem was, the platform is merely acting as a middle-man. You can have your money back, but that’s it. To paraphrase; if we’re a broker, it don’t need fixing.

It’s unrealistic to imagine we’ll ever go back to buying things exclusively from shops. The apparent availability, convenience and competitiveness of online shopping makes that kind of face-to-face accountability feel Jurassic. It makes sense therefore, that the new Product Regulation and Metrology (PRaM) Act has a specific focus on the missing link: making online sellers responsible for whatever they sell, however they frame themselves.

Let’s hope it’s enforceable. After all, any transaction should come down to the same premise; if you take my money, you are responsible for what I get. That’s a principle with which I’m fairly sure Lynn and John would have agreed. l

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By Richard Young

Little shops of

HORROR

Organised criminal networks have infiltrated the UK’s high streets, operating chains of interconnected businesses that conceal dark and disturbing secrets.

We take a look at the scale of the problem, and explain why Trading Standards is at the heart of the solution Surrey Trading Standards take part in Operation Machinize

It all started with a rogue trader. In 2023 Rochdale Trading Standards were called in to help an elderly woman who had lost a substantial amount of money to a builder.

She happened to live next to a main road equipped with an automatic number plate recognition (ANPR) camera, so the team gained access to the footage in an attempt to discover the trader’s identity. But while his van was clearly visible on the monitor, the number plate itself was a grey blur.

“We were like, ‘How is this possible?’,” says Rochdale Trading Standards’ Dennis Chalmers, one of the investigating Officers. “A couple of weeks later we were doing an operation with the DVLA [Driver and Vehicle Licensing Agency] and we spoke to them about it. That’s when they told us about ghost plates.”

Ghost plates are illegally manufactured number plates that look normal to the human eye but use a reflective coating or lettering that prevents ANPR cameras from reading them.

According to Darren Hughen, also a Rochdale Trading Standards Officer, “We started looking into how many traders in Rochdale are supplying these plates.

When we discovered the amount, we nearly fell off our chairs. There were 600 suppliers of registration plates in

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Rochdale alone. We realised there was something seriously wrong here.”

Chalmers and Hughen immediately recognised the implications of the widespread manufacture, sale and use of ghost plates. Because the devices create a blind spot for enforcement, they can be used to conceal all kinds of organised criminal activity, enabling goods and people to move around the country – and beyond – with no traceability.

“We thought, from a Trading Standards perspective, ‘What’s this got to do with us?’ And then we saw that ghost plates are linked to rogue trading, counterfeit goods... it was just endless,” Hughen says.

“Illicit cigarettes are being stored in the street in vehicles equipped with ghost places. It means stuff coming from ports can’t be traced. There are vehicles coming in from overseas, and the ANPR is not reading them.”

The realisation sparked a pioneering campaign to exorcise ghost plates from the UK’s roads, which has taken Chalmers and Hughen from Rochdale to all parts of the country, and has won national attention, plaudits and allies in parliament (see boxout, right). Their work also highlights the intertwined nature of modern organised crime,

demonstrating how ‘polycriminality’ has become its defining feature.

Organised crime touches on the entire breadth of Trading Standards work, from illicit tobacco and rogue trading offences, to money-laundering and illegal money lending; from fraud and scams, food safety and animal welfare, to product safety and counterfeiting. But it doesn’t stop there. There is also evidence that many of the organised crime networks that Trading Standards teams come into contact with, both on and off the high street, are connected with the illegal drugs trade, people trafficking, firearms offences, child sexual exploitation and even terrorism.

Because they are embedded in their communities, local authority Trading Standards teams have a unique insight into the dangers of organised crime. Indeed, in the most recent CTSI member survey, its presence on the high street was cited as the number-one threat to the profession.

In this article we’ll hear about the experiences of frontline Trading Standards Officers, gather insights from experts in related fields and, perhaps most importantly, hear some suggestions about how society can get to grips with a growing and serious threat.

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Journal of Trading Standards

Left to right: Dennis Chalmers, Paul Waugh MP and Darren Hughen hold up a sample of a ghost plate

Operation Ghost

Cambridgeshire Police on an Operation Machinize raid

Right under our noses You don’t have to work in Trading Standards to be aware that the UK’s high streets have changed significantly over the past few years. As many mainstream retailers have struggled to stay afloat, decamping to out-of-town retail parks where rents and business rates tend to be cheaper, or shifting their focus to the online space to keep up with changing consumer habits, opportunist criminals have identified that there is a vacuum waiting to be filled.

They have realised that cash-intensive businesses like mini-marts, barbershops, nail salons and vape shops provide an ideal opportunity to gain a foothold in local communities, enabling them to launder money, exploit the vulnerable, and accumulate huge sums of money by selling illicit goods, all in plain sight.

And while the shops themselves are an all-too visible indication of the size of the problem, they are backed up by a hidden infrastructure of storage lockers, vehicles and upstairs rooms used to store illicit products and house illegal workers.

As Ricci Dolan, a police officer at the South East Regional Organised Crime Unit (SEROCU) puts it, “Our eyes have been opened to what is happening on the high street because if Marks &

Winter 2026

Spencer, Starbucks and Costa can no longer afford to pay the business rates at these premises, then there is the obvious question: how can shop X, Y or Z?” The ROCU network was created in 2010 to bridge a gap in how local- and national-level crime is tackled. According to Dolan, the nine ROCUs “deal with organised crime groups and priority individuals at the top level. As crime has changed, forces and funding streams have had to change too. While ROCUs target the highest harm threats, there is much more of an understanding holistically that organised crime isn’t just firearms and drugs; it is organised immigration crime, modern slavery, child sexual exploitation, and all of the pool that sits within.

“My team works to disrupt the networks and the individuals, but also to assist our partners by providing them with policing powers when required. We also think holistically when we’re tackling our own threats by bringing those partners on board to support us.”

Organised crime is big business.

As crime has According to the changed, forces National Crime and funding Agency (NCA), at streams have had least £12bn of to change too

Operation Ghost grew out of efforts by Dennis Chalmers and Darren Hughen, two Trading Standards Officers at Rochdale Council, to bring wider attention to illegal ‘ghost’ number plates on the UK’s roads.

Recent reports highlight that around one in 15 number plates may be illegible to ANPR cameras, with one enforcement exercise in London finding that 40% of taxi and private hire vehicles had illegal plate modifications. Wolverhampton Council has also discovered widespread use of ghost plates by local taxi firms.

Under the current law, being caught with an illegal number plate typically results in a £100 fine – equivalent to a minor speeding ticket. The proposed crackdown, which is supported by the British Numberplate Manufacturers’ Association (BNMA), as well as Paul Waugh, MP for Rochdale, and Sarah Coombes, MP for West Bromwich, calls for the fine to increase to £1,000, and for violators to receive six penalty points on their driving licence.

Coombes, who has brought the issue to the attention the All Party Parliamentary Group (APPG) for Road Safety, said: “The sale of illegal number plates is not a victimless issue – it enables criminal behaviour, undermines road safety, and erodes public trust. The websites and platforms selling these plates must also take responsibility. I fully support the action being taken by the CTSI and Trading Standards authorities around the country, whose efforts are essential if we are going to end the number plate Wild West.”

The Rochdale Trading Standards team were recognised for their work with a CTSI Hero Award in 2024 and again in 2025.

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Cover story

By Richard Young

criminal cash is generated in the UK each year, much of it either being funnelled out of the country or used to fund further criminality. The size of the threat has called for a proportionately large response, as well as the recognition that a siloed approach, with different agencies chipping away at different parts of the problem in different areas, simply doesn’t work.

Joining forces In 2025 the NCA coordinated Operation Machinize, a two-phase, UK-wide, multiagency initiative to ‘target the criminal exploitation of high street businesses’.

Alongside the NCA, the campaign involved the National Police Chiefs’ Council (NPCC), every UK police force and ROCU, Home Office Immigration Enforcement, HM Revenue & Customs, Companies House and, of course, Trading Standards.

During Operation Machinize’s first phase, which ran for three weeks in March and April, 380 premises were visited and bank accounts holding assets of more than £1m were frozen. Some 84 warrants were executed and 35 arrests were made, with 97 potential victims of modern slavery being safeguarded. Officers also seized more than £40,000 in cash, 200,000 cigarettes, 7,000 packs of tobacco and more than 8,000 illegal vapes.

Phase 2 of Operation Machinize, which ran throughout October, yielded even more substantial results. The operation saw 2,734 premises across the UK being visited and raided; 924 individuals arrested; more than £10.7m of suspected criminal proceeds being seized; and more than £2.7m worth of illicit goods being destroyed. According to Rachael Herbert, Director of the National Economic Crime Centre at the NCA, “Depriving criminals of their source of income has a real impact, limiting the amount of funds they can reinvest in further offending and deterring them from taking spaces on our high street that could be used by legitimate businesses.”

Security Minister Dan Jarvis MP said in a statement: “Criminals are using these dodgy shops as fronts for serious organised crime, money laundering and illegal working, risking the future of the

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(Above left) Bundles of illicit tobacco were found in a van in Rochdale; (above right) illicit shisha tobacco was also found

British high street. We have intensified our joint efforts with law enforcement to dismantle criminal networks and relentlessly pursue those who use dirty money for personal gain.”

Planting the seed As the old adage goes, you have to spend money to make money. It is obvious that for the organised crime groups, infiltrating the UK’s high streets can’t have come cheap. So where did they get the cash that enabled them to set up shop in the first place?

According to Phil Lewis, Director General of the Anti-Counterfeiting Group (ACG), criminals have exploited the complexity of globalisation, ‘piggybacking’ established, legitimate systems to accrue vast wealth. “Counterfeiting has become a ‘seed funder’ for other, darker forms of criminality,” he says. “Organised criminal groups are motivated by profit, power, and political influence.

They exploit It is a shadow legitimate business economy, running structures, in parallel to everyday economic legitimate systems

systems, supply chains, logistics, banking, property and finance so that they can move goods and profits very quickly.

“Some of the money involved is quite staggering,” he adds. “It is a shadow economy, running in parallel to legitimate systems.”

Lewis believes that one of the main catalysts for criminals’ expanding presence in ‘legitimate’ markets is a discrepancy in the level of deterrence.

“The penalties for dealing in illegal drugs, weapons or people trafficking are high, but for counterfeiting, they’re much lower,” he points out.

“Counterfeiting is part of a transnational organised crime wave,” Lewis adds, citing a 2021 study by the Organization for Economic Co-operation and Development (OECD) and the European Union Intellectual Property Office (EUIPO) which puts the value of the international trade in counterfeits at $467bn. “It is part of a global fraud ecosystem that has built up. In terms of how it endangers the UK, first of all, it undermines our normal business platforms. It attacks the big brands, but it also attacks smaller brands, and it

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Journal of Trading Standards

don’t expect to – they’ll pay a little bit less than they would in a cash-and-carry shop. That creates these entrepreneurial opportunities for individuals to enter spaces which they previously couldn’t because they needed connections.

“Organised crime is now more diffuse and horizontal than ever,” Gantz adds.

“When we talk about the increasing sophistication of organised crime, it has just as much to do with gangs or groups becoming more sophisticated as it does with groups working together in a very sophisticated fashion. It’s an overall ecosystem of criminality that’s far more agile than the responses to it.”

A well-stocked cash register in one of the shops visited by Rochdale Trading Standards

undercuts genuine product prices. That creates an unbalanced playing field for business. With that comes the loss of jobs and impact on the wider economy.

“In terms of consumer threats, it leads to dangerous products. The criminals are now much more sophisticated and have more resources. But there are certain things that they still can’t manufacture properly, and those are the things that become the danger. Domestic everyday goods like hygiene and cleaning products, medicines, auto components, fast moving consumer goods, toys and fashion are all under pressure.

“With football shirts, for instance, they will use whatever they can to sustain colour, and generally that means adding toxins. Cheap stabilisers – including animal urine – are used in counterfeit perfumes. We’ve seen electrical goods like e-bikes which catch fire when you plug them in; everything is pretty much under attack by these guys. It’s become far more dangerous to consumers than they would ever believe.”

Dangerous counterfeit goods can trickle into legitimate businesses as well, with companies buying them in good faith

Winter 2026

and unwittingly putting their customers at risk. Lewis highlights the emergence of counterfeit auto components as an example: “A small garage might have no intent to deceive people, but will look for parts at the cheapest price. Very often they use one of the big online platforms to source them, and the criminals know how to infiltrate these.”

Democracy in action Elijah Gantz, Research Fellow at the Royal United Services Institute (RUSI), also believes that organised crime is thriving by embracing a ‘hybridised model’ that combines legitimate business structures with illegal practices. “Particularly in the online domain, organised crime is more democratised than it ever has been,” he says. “If, for example, you were to steal a particular item based on pure opportunity, as a single individual, you could go on any kind of online marketplace It’s an overall and sell it, and ecosystem of nobody’s going to criminality that’s ask you for papers far more agile than because they the responses to it

Smokes and mirrors As Operation Machinize illustrates, the connections between the sale and supply of illicit tobacco and organised crime run deep. Trading Standards teams across the country have worked tirelessly for years to tackle the problem, seizing tonnes of illicit cigarettes and tobacco and, more recently, vapes. According to the most recent Association of Chief Trading Standards Officers (ACTSO) ‘Impacts and Outcomes’ report, Trading Standards teams in England and Wales seized 23.5 million illicit cigarettes and 7.2 tonnes of illicit hand-rolling tobacco in 2024-25, with a combined street value of £16.4m.

No one understands the dangers of illicit tobacco better than Andy Wright, Principal Trading Standards Officer at Lincolnshire County Council. In 2012, Lincolnshire resident June Buffham died in a house fire caused by an illicit cigarette that failed to self-extinguish. The tragedy prompted Buffham’s daughter, Julie Grant, to work with Lincolnshire Trading Standards on Operation June, a campaign to raise public awareness and tackle sales of illicit tobacco in the county. “We’ve given it a high priority; this isn’t the only instance we’ve had,” says Wright. “We’ve had reports from the Coroner’s Court and a lot of the time, the Fire Service is putting house fires down to illegal cigarettes that didn’t self-extinguish.”

Like many other Trading Standards teams, Wright and his colleagues hit

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Cover story

By Richard Young

the streets, seizing illicit cigarettes, prosecuting the businesses selling them, and slapping them with closure orders.

But, also like many others, Wright quickly came to realise that no sooner had one shop been closed, than another would spring up in its place. “It’s a little bit like a game of whack-a-mole; high streets in Lincolnshire are probably no different from anywhere else in the country,” he says.

“There are lots of vacant retail premises everywhere. You stop it at one shop and they move a little bit down the road.

“I quite quickly realised that often the people who appear on the tenancy contract tend to be stooges who have been served up on a plate specifically for us to prosecute, whilst the person that’s really behind the business takes a back seat and doesn’t put their name on any piece of documentation anywhere.

“If you were in charge of an organised crime group, you’d keep your name as far away from the paperwork as you possibly could, wouldn’t you? And that’s what they do. They’re not stupid – that’s why it’s called ‘organised’ crime. Just because somebody’s name is on the tenancy agreement, you’re not dealing with some sort of Moriarty-type character – you’re actually just nicking a bloke who’s got nothing. He’s come to the country probably about six months ago and somebody’s offered him £100 a month to put his name on the tenancy.”

Follow the money To really make an impact on the criminal networks, Wright believes it is important to trace the money as far as possible up the chain – and this can often be done through the shops’ card payment machines. “A few years ago, a lot of these retailers used to be strictly cash-only businesses,” he says.

“You never saw a card payment machine in any of them. But over the past five or six years, we’ve been quite proactive with the police. We don’t have powers of seizure for cash, but they do. If we’re in a shop and there’s a lot of cash there – and when they’re selling illegal cigarettes, there does tend to be quite a lot of cash – the police will seize it and hand it over to us for processing as proceeds of crime.

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“The organised crime groups have caught on to that Just because and have realised somebody’s name cash isn’t the way is on the tenancy to go. So they’ve agreement, you’re started using card not dealing with payment machines. some sort of By looking at the Moriarty-type machine, even character without a password, you can usually find out who’s provided it, the serial number, the merchant ID, and sometimes account details and the email addresses that are attached to that account. With that information, you can find out where the money’s going.

“A few years ago, we hit on an account linked to three different card payment machines. They were all in premises in the local area that were linked to illicit cigarettes. In about an eight-month period, there was £1.2m going through these machines,” Wright adds.

“The money goes through a number of levels where it is thoroughly laundered. It’ll go through business accounts that have a stooge director set up. They’ve never really existed other than at Companies House for the purpose of setting up a bank account.

From those businesses it goes on to other businesses. They’ll go through that process a number of times before it gets to its final destination.”

It’s a similar story in Rochdale, says Hughen. “We have 88 barbers. That’s a lot of haircuts – but you go past them and there’s no one in them. So you know they’re laundering money. To combat this properly, you need regional Financial Investigators looking at where the money’s going. Because we know now it’s not just cash – when we go into one of these shops there’ll be three or four payment card devices.

“A lot of the time these businesses are positioned in a triangular format with a nail shop and a convenience store, and they’re all moving criminal goods between them or storing them in different areas. But the links there are the actual personnel. If you look at a convenience store, within five doors up the road there’s always going to be a barber shop.”

Illicit cigarettes seized in Essex during Operation Machinize

Tobacco and cigarettes in a concealment in Derbyshire

On our doorsteps Just as the shop-floor workers in illicit retail premises are often pawns in a larger game, rogue trading outfits frequently use frontmen as the public face of their illegal operation while those raking in the profits remain invisible further up the ladder.

One recent case prosecuted by Hertfordshire Trading Standards began as a doorstep crime incident in which a vulnerable resident was robbed of £15,000.

After putting pressure on the victim’s bank and managing to recover her money, the Hertfordshire team pursued the case as a money laundering investigation. They identified other victims in the South East of England, and realised they were looking at a large, organised criminal endeavour which had defrauded multiple people out of a combined total of more than £350,000.

According to Dr Tim Day, Senior Trading Standards Officer at Hertfordshire County Council and CTSI Lead Officer for Doorstep Crime, “This case was all about money laundering. The ‘front director’ in some respects, was taken advantage of

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Journal of Trading Standards

A tobacco detection dog finds illicit goods in Cheshire

In total £75,000 worth of goods were seized in Essex

Bin bags full of illicit tobacco seized in Clacton

Illegal vaping products hidden in a specially built hide

A tobacco detection dog sniffs out more illicit products

Officers in Braintree find illicit goods in a vehicle

himself. But had we not prosecuted him, we wouldn’t have been able to recover the £29,000 we restrained under the Proceeds of Crime Act during the investigation.

Ultimately that money went back to the victims. The business itself was just a shell and the front director enabled the real fraudsters to remain invisible and untraceable. They had a business name, and were signed up to Companies House to give it an air of legitimacy.”

According to Sophie Bee, Financial Investigator on the case, “There was a high turnover in the account – things moving in and out very quickly. Other groups were using him; victims would pay money into his account and then he would withdraw that in cash and hand it to whoever he was working for. He was facilitating rogue trading and allowing it to continue by enabling them to clean their money.”

In their most recent reports to CTSI Council (see page 10) for example, Lead Officers for Food Standards & Nutrition, Corinne Lowe and Dean Cooke, highlight “increasing evidence of organised crime groups moving into the retail sale of noncompliant food and drink, with much of this activity taking place in high street shops such as mini-markets and vape shops which are linked to other illegal activity.”

In the London borough of Westminster alone, Trading Standards Officers have seized more than £1m in fake and unsafe goods over the past two years, including from notorious ‘American candy stores’ on Oxford Street, one of the UK’s most high-profile retail destinations. One raid in early December yielded £9,000 of illegal goods, including ‘cannabis cookies’, vapes and fake Labubu dolls.

The Journal has previously reported on criminal gangs’ involvement in illegal puppy imports, with Lead Officer for Animal Health & Welfare, Steph Young, noting “this is part of serious international organised crime”. In

December, Royal Assent was granted to the Animal Welfare (Import of Dogs, Cats and Ferrets) Bill, which limits the number of pets that can be transported in one vehicle, but there remain concerns that animals could still be smuggled into the country by gangs using vehicles equipped with cramped concealments.

Likewise, organised crime is prevalent across all of the UK’s four nations. In Northern Ireland, the latest Organised Crime Task Force (OCTF) report highlights several incidents in which the Trading Standards Service (TSS) stepped in to tackle consumer detriment linked to organised crime, including in the used car market and online scams.

In Wales, Operation Usk (see the indepth report in the Summer 2025 issue of the Journal) marked a landmark victory in the fight against a local organised criminal network. The estimated value of the fraud involved in that case was £3.84m, in addition to money laundering offences of more than £2.9m. Work to address similarly serious criminal activity is ongoing.

Everything everywhere all at once That case – and many others like it – shows how organised crime overlaps with the entire Trading Standards portfolio.

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By Richard Young

In Scotland, almost 200 businesses were visited as part of Operation Machinize, yielding substantial seizures of illicit goods and multiple arrests. As David MacKenzie, Trading Standards Manager at Highlands Council and Chair of CTSI notes, “Organised crime is not just a thing in the big cities – it has reached small towns and villages in all of our regions and nations.”

And last but not least, in its 2025-26 business plan, National Trading Standards (NTS) flags organised crime as a key priority. The body, which coordinates regional investigation teams, has seen several successes in bringing organised criminal groups to justice, including the recent prosecution of a large-scale fraud and money laundering operation which preyed on vulnerable victims across Wiltshire, Oxfordshire and Herefordshire.

Emotions run high While successful prosecutions, convictions and Proceeds of Crime Act (PoCA) seizures are an important part of the fight back against organised crime, and they undoubtedly cause significant disruption to the individuals and groups involved, in and of themselves they are rarely enough. After all, tackling organised crime groups is like fighting the hydra of Greek mythology – you can cut off one head, but two will grow back in its place.

So how can the problem be addressed in a more long-term way? Elijah Gantz cautions that enforcement activity, seizures and arrests are only a part of the solution. “It’s good that people are paying attention to organised crime on the high street because it’s been proliferating and it’s an eyesore,” he says. “But a lot of the time people’s interest in this is based on a nostalgic element – the sense that things are not what they used to be. The public’s response becomes rather emotive. It’s been, ‘Let’s go after them; let’s shut them all down; let’s arrest them all’.

“There’s really little evidence to suggest that’s a meaningful response; there’s a difference between the operational success of seizures and arrests, and the strategic success of reducing the size of overall criminality.

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Fake Labubus and non-compliant vapes were among the items seized in Buckinghamshire and Surrey

I would hope that as people get more invested in this, they understand that arresting and prosecuting a handful of people will not necessarily move the needle. We need to think about how we design our systems to prevent this crime from happening. It’s about the Government leaning into the evidence rather than leaning into a message of trying to get as ‘tough’ on it as possible, or being seen to be tough.

“You can’t just throw more money at the problem,” Gantz adds. “So how do you think innovatively about responding?

How do you harness data? How do you harness public-private partnerships?

How do you get the private sector to think innovatively about how they design platforms and products to make life harder for criminals?”

A problem shared At the ACG, Lewis believes that the key to addressing the problem is intelligence-sharing. “No single authority, no government or business sector, is going to defeat this on its own,” he says.

“You simply can’t. It’s too big, and it’s stretched across the world.

“My view always has been that there’s a crucial need to create a common

methodology to track counterfeiting across all sectors, public, private and borders.

Unless we dare to share intelligence, we can’t fight an enemy like this until we actually size them up. And the golden thread is intelligence-sharing. Border Force, for instance, might be the first ones to see a new suspect product coming in.

Sharing that intelligence with business and vice-versa creates a more concerted effort and fosters real cooperation.

“We need to create genuine dialogue and strategies to be able to fight this.

Without shared intelligence, we can’t identify common goals and we are decisively on the back foot.”

From the police perspective, Ricci Dolan at SEROCU agrees that collaboration is key. “In the South East, we understand that we can’t just police our way out of individual serious organised crime threats through enforcement. We have to use our partner agencies either to support disruption, or for enforcement and prevention – because prevention is just as useful as pursuit.

“There’s work ongoing at the moment where we are going out quite a lot with Trading Standards, coordinating and bringing in immigration enforcement, because we understand that businesses

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Journal of Trading Standards

OPERATION MACHINIZE IN NUMBERS

3,114

premises raided

959

arrests

£10.7m+

suspected criminal proceeds seized

£2.7m+ illicit goods destroyed

selling illicit tobacco are also likely to have illegal workers, or people living in the shop. Can fire and rescue put in disruption plans or prevention orders to stop people from living there? That makes it harder for the owner of the shop. One agency on its own would struggle, just with one high street in one town,” he adds.

Shutting up shop Back in Rochdale, Dennis Chalmers says that strengthening the efficacy of the legislation would go a long way towards making life harder for the criminals.

As he points out, “It’s a bit disheartening when you’ve got a closure order from the court, you’ve put the sign up and locked the premises down, and then you look over the road and the same people are opening another shop within 24 hours.”

At present, the maximum period a closure order can be imposed is three months, with no requirement for predetermined criteria to be met before a premises can reopen. “I think threemonth closure orders need changing to twelve months so there’s more of a deterrent there,” Chalmers says. “Three months is neither here nor there, bearing in mind the time and resources it takes to get a closure order.

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“I also think we’re missing a trick; we should be targeting the landlords.

In effect, they are receiving money from criminal activity to pay for the lease, and they’ve got resources we can go after. Once we’ve warned them that they’re breaking the law, they need to do something about it or face a fine. I think that would tackle it more than just closure orders and doing enforcement.”

It is a sentiment endorsed by Andy Wright in Lincolnshire, whose team have achieved results by looking beyond the shop counter. “What I have found to be a decent strategy is to look at the landlords, because whilst the tenant might change on a two- or three-monthly basis, the landlord is pretty much always the same person,” he says. “I look at money laundering offences by the landlord, because he’s accepting money from the tenants that is derived from crime, essentially.”

Wright also emphasises the public health and community safety implications of organised crime. “We’ve found that shops that sell illegal cigarettes and vapes are 14 times more likely to sell them to people under the age of 18 than legitimate retailers,” he says. “That’s something we mention when we’re applying for closure orders – the effect on the local community.”

He also echoes Chalmers’ frustrations with the current limitations of closure orders: “In the past two and a half years, I’ve applied for about 140 of them across Lincolnshire,” he says. “No matter how bad the shop is though, the maximum period of closure is three months. We’ve got numerous premises in Lincolnshire which we’ve closed about five times. The ability of the court to impose a longer closure period would be very beneficial.”

What went wrong?

It is notable that the increased presence of organised crime on the UK’s high streets has coincided with an assault on Trading Standards’ funding and capacity.

Budgets and resources have been slashed over the past decade-and-a-half and, as CTSI has pointed out repeatedly, an overstretched and underfunded Trading Standards service means vast swathes of illegal activity are effectively being

‘decriminalised by the back door’. While recent developments, such as the Autumn Budget’s announcement of funding for 45 new Officers to support Trading Standards, in addition to the previously announced £10m cash boost for new apprenticeships (see page 52) have been welcomed, only time will tell whether the investment will be enough to make a significant impact.

One of the questions frequently asked of local councillors or MPs when they are being encouraged to allocate more funding to the service is: ‘What would a country without Trading Standards look like?’

Well, in many ways, we already have a pretty good idea. The prevalence of organised crime and a looming ‘shadow economy’ is a reminder that without a robust and effective Trading Standards service, the public are at risk.

Addressing the problem requires funding, of course, but it also requires legislation suited to the needs of those who have the most to lose – including consumers, legitimate businesses and victims of crime. It also requires an openness to innovation and intelligencesharing, and a rejection of territorialism and traditional prejudices.

If there is any silver lining to the growing influence of organised crime in our cities, towns and villages, it is that it has encouraged that approach. Speaking to people in Trading Standards, the police, the private sector and elsewhere, many of them agree that the past few years have seen a shift towards greater collaboration, and a willingness to forge networks that are up to the scale of the challenge – with Operation Machinize serving as a case in point.

Crucially, the issue has also caught the attention of politicians, with increased cross-party pressure to stem the flow of illicit tobacco and other goods through legislation – the upcoming Tobacco and Vapes Bill, for example, will strengthen Trading Standards’ ability to impose substantial sanctions on criminal shops.

It is also increasingly clear that Trading Standards has a key role in combating organised crime; and a widespread realisation of that can’t come soon enough.

After all, as the Rochdale team’s work on ghost plates shows, it’s scary out there. l

| 19

OPINION

Jessica Merryfield CTSI Head of Policy and Campaigns

Banging the drum CTSI is planning for a busy 2026, with a series of events, initiatives and resources to help support and guide the profession through turbulent times There are many wonderful things about the Trading Standards profession: the variety of areas it covers, the unique and vast skill set it develops and how it is woven into the very fabric of our society and economy. The wide-ranging benefits that the work of the profession brings are hard to quantify but would be quickly noticed if they were missing. As a former colleague (who was also the person who inspired me to join the profession) once said to me: “We are a hidden profession; the public won’t see what we do, and how much we do, until we stop doing it.”

Incredibly wise words which resonated strongly then and still do now.

Wherever I have worked, whether it be in the public, private, or not-for-profit sector, those words have been applicable to every situation in which I have used my Trading Standards knowledge, experience and skills to benefit the public in some way, shape or form. Since joining CTSI, I have continued to meet and be inspired by the amazing tapestry of Trading Standards professionals working hard in every sector, ensuring consumers are protected and confident when making their purchases,

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public health is maintained, and legitimate businesses are not undermined by illegal products or practices. It is my pleasure and privilege to be part of the organisation that represents those professionals, and makes the public and government aware of the value of their work at a local and national level.

Infographics and templates With a profession so rich in variety, the lovely problem I have is deciding where to start and what to focus on!

To start us off, we have created a series of infographics which give an overview of what the profession does and the added value it brings to society and the economy, the public health benefits it creates and how Trading Standards is alongside you throughout every single stage of your life.

These infographics can be used by anybody within the profession to show the impact that their role has and why it matters.

For local authority Trading Standards professionals, aspiring leaders, managers and Heads of Service we have also created a set of template letters which individuals can either send as they are or amend

and mould to fit a specific local authority area, or to help showcase the work of the profession. These can be combined with the infographics to provide conversation openers with senior leadership teams at local authority level to make the case for a strong, robust and sustainable Trading Standards service, especially when the leadership may be new and inexperienced.

Our support for Heads of Service and managers at local authority level is continued by the addition of a local government reorganisation impacts document, co-created with the support of our colleagues at the Association of Chief Trading Standards Officers (ACTSO). This document can be used as a standalone piece of work or combined with the letters and infographics. We are very grateful to our ACTSO colleagues for working with us and supporting us on this.

Year Ahead Conference Speaking of leaders and aspiring leaders, we are excited to announce that we are hosting our popular online Year Ahead Conference, in partnership with the Chartered Institute for Environmental

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Journal of Trading Standards

With a profession so rich in variety, the lovely problem I have is deciding where to start and what to focus on!

Health (CIEH). This will be held on the mornings of the 5 and 6 February 2026 and will showcase the influence and impact the Trading Standards and Environmental Health professions have on public health. Likely topics include local government reorganisation, leadership and management in times of change, Primary Authority as well as AI, the digital landscape and what it means for our professions. Whilst we finalise the agenda and the speakers, please do put these dates in your diaries and don’t miss out on what is shaping up to be a fantastic event.

Following feedback from our Law in Practice and Conference sessions on the Digital Markets, Competition and Consumers (DMCC) Act (see page 24), we have created a special interest group to help create a practical toolkit for local authority officers and their legal teams to use when taking civil sanction enforcement activities, particularly around the provisions of the DMCC Act. We hope that this toolkit will encourage confidence and consistency in approach and is being contributed to by officers from all nations.

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The toolkit should be ready to launch at CTSI Conference in Glasgow on 9-11 June 2026 and will be available through your local branch afterwards. The group will then continue to meet and refine the toolkit using shared learnings and updates to keep the toolkit as relevant and accurate as we possibly can.

In creating this, we appreciate that there may be support needed on this subject for our private sector members, so I would welcome your thoughts as to what that could look like and what is needed.

Please do get in touch if you have any ideas or thoughts on this; I would love to hear from you.

APPG inquiry Finally, it is no secret that the Trading Standards profession has been undervalued, underappreciated and underfunded for decades. The true effects of this on consumers, businesses, public health and the economy have yet to be fully explored and understood. As our Chief Executive John Herriman stated at Conference earlier this year, we are launching an All Party Parliamentary

Group (APPG) inquiry into the consumer protection landscape to explore this issue, drawing on views from experts and relevant stakeholders across the four nations of the UK. The inquiry will look to dive into this issue, exploring the situation from all perspectives and suggesting solutions to uphold consumer protection, which will also ensure a level playing field for businesses and shine a light on the professions involved in delivering these outcomes.

Once completed, the report containing these details will be published by CTSI and used to make specific, evidencedbased calls to campaign for long-term, sustainable changes to protect the consumer, the legitimate business, the professional, society and the economy.

Representing, supporting and leading the profession are at the heart of all CTSI does, especially during these times of change and potential uncertainty.

One thing you can be sure of is CTSI’s unwavering commitment to continually raising the profile of this fabulous profession, in every sector within which we operate. We will keep banging that drum and shouting from the rooftops at every opportunity we get; please join us in making this louder by using, sharing and supporting the work we do. l Further information The set of infographics is available here: www.tradingstandards.uk/news-policycampaigns/campaigns/making-the-case The new template letters are a memberonly benefit and are available to download from the CTSI Member Area.

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EDI

By Richard Young

GAINING

MOMENTUM

Everyone has a stake in Trading Standards being fair and inclusive.

Now a special CTSI committee is working to ensure equality is front and centre of the profession.

Karen Tillett

Kristina Hann

Why did you feel it was important to be part of the committee?

I have been part of the London Race & Equalities Group since it started and wanted to translate the good work and some of our initiatives to the national stage. It is an area that is directly relevant to me and my work colleagues, and I have seen and experienced the negative effects that behaviours such as racism, sexism, and other forms of discrimination can have. Through committee membership I would hope to be able to improve the culture within the profession for the benefit of all.

Why did you feel it was important to be part of the committee?

For me, joining the committee wasn’t just about representation – having the use of one arm my entire life has meant navigating a world and a workplace that often wasn’t built with people like me in mind. The attitudes of others on what I can or can’t do in life has not always been positive. I have even been told I should not exist. I wanted to be part of the committee to help challenge those behaviours, to advocate for real change, and to ensure that no one else feels as isolated or undervalued as I once did.

What do you hope the committee achieves?

The main objective is to engage with all parts of CTSI membership so that they can be heard and have input towards EDI policy and practice, and directly influence CTSI through the Council. One of the main focuses is to establish EDI networks to enable members to communicate with like-minded people in a safe space. It is my hope that we will successfully establish the first two networks to cover race and neurodiversity, and that these can be used as a blueprint for other networks that follow on.

What do you hope the committee achieves?

I hope the committee becomes a driving force for genuine inclusion – not just in policy, but in everyday practice. That means creating safe spaces; educating colleagues; embedding accessibility into everything we do; and holding the organisation to account. Ultimately, I want the committee to help build a workplace where people are seen for their strengths, not judged for their differences. Where respect is the norm, and where no one must hide who they are to feel safe or accepted.

Can you recommend something that might help people think differently about equality?

Wahala by Nikki May is a cracking read! It follows the lives of three Nigerian-British best friends living in London. They have all experienced racism in their everyday lives but haven’t allowed it to hold them back. The book explores the mixed-race experience and the challenges faced by women of colour. There is also an unexpected plot twist!

Can you recommend something that might help people think differently about equality?

Most media portray disability through a lens of pity or inspiration.

But the TV series Speechless flips that. It shows a disabled character, JJ, who’s not defined by his limitations but by his personality. That’s powerful. It’s not about making him ‘fit in’ to a world that wasn’t built for him – it’s about showing how the world needs to change to accommodate everyone, not just the majority. I’d also recommend comedy show The Last Leg as two of the hosts are amputees like me and their dark sense of humour matches mine.

Chair, CTSI Race & Equality Committee and Trading Standards Manager, Merton Council

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Specialist Trading Standards Officer, Essex County Council

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Journal of Trading Standards

In April 2025 CTSI announced the formation of its Race & Equality Committee, a group of 14 Trading Standards professionals dedicated to supporting and driving a more inclusive environment and culture within the Institute and beyond. The committee, which builds upon the groundwork laid by the CTSI Race & Equalities Working Group, will scrutinise and approve CTSI’s annual equality, diversity and inclusion (EDI) action plan, and will be consulted on policies, practices and processes. We spoke to four members of the committee and asked them to explain why they got involved, and to tell us about their personal passion for equality.

CTSI members who would like to make suggestions or seek advice can get in touch at equality@tsi.org.uk

Lewis Collantine

Valerie Simpson

Why did you feel it was important to be part of the committee?

I was on the previous Race & Equalities Working Group as Vice Chair and then Chair, so it’s something I’ve been committed to for a long time. We weren’t able to achieve as much as I wanted us to, so it’s important for me to continue with that, and to continue being a critical friend of CTSI, making sure they are progressing the work in this space and not taking their foot off the gas.

Why did you feel it was important to be part of the committee?

I am currently Chair of the Association of Chief Trading Standards Officers (ACTSO) Equality, Diversity and Inclusion (EDI) Group. For the last few years there have been discussions between ACTSO and CTSI about being more aligned, and working more collaboratively on EDI issues. It felt important (and a natural progression of that earlier dialogue) that I should put myself forward, as the ACTSO representative, to support CTSI’s ambition to become a more equitable, diverse and inclusive organisation.

Product Safety Consultant and Chartered Trading Standards Practitioner

What do you hope the committee achieves?

One key thing is launching EDI networks, for example on Race and ethnicity and LGBTQ+, and I’ll be helping to launch the Neurodiversity network. I’m really excited about that. It will allow people in the profession to connect, to share experiences and best practice, and to feed issues specific to them into the committee to make sure that we’re hearing their voice. We’re also helping CTSI to launch a fund which will support people from underrepresented groups to progress into leadership roles.

Can you recommend something that might help people think differently about equality?

A book called The Velvet Rage by Alan Downs, a counsellor and therapist who found common themes among the gay and bisexual men that he supported.

He coined the term ‘gay shame’ to refer to a specific experience of shame that many gay and bisexual men experience through childhood and adulthood.

It’s been one of the most powerful books in recent years in my own development. For anyone who would like help understanding some of the experiences that are shared by gay and bisexual men, it’s a really powerful read.

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Assistant Director of Regulatory Services, Hammersmith & Fulham Council

What do you hope the committee achieves?

I want the committee to create an inclusive membership where everyone feels a sense of belonging, members are united, and diverse groups are represented.

Can you recommend something that might help people think differently about equality?

I would highly recommend attending ACTSO’s EDI Discussion Group sessions. They are currently held online four times a year; they are an hour long and are open to members and non-members.

Topics that we have covered so far have included: career progression; development and leadership; CTSI’s EDI survey; EDI and language use; gypsy and traveller culture; inclusive recruitment; intersectionality; the potential disadvantage created by ‘normal’ practices in the workplace; and neurodiversity. [For more on neurodiversity in Trading Standards, see page 48.]

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Legislation

By Richard Young

Putting theory into practice

The landmark DMCC Act introduces a range of new tools for Trading Standards. With the first part of the legislation now in effect and more on the way, we hear from CTSI Lead Officers about how it is working in the ‘real world’ The Digital Markets, Competition and Consumers (DMCC) Act 2024 represents a significant overhaul of legislation relating to the provision of goods and services online. It introduces new enforcement powers for Trading Standards and the Competition and Markets Authority (CMA), as well as enhancing the range of civil penalties that can be applied to businesses which fail to comply with the law.

Because of the scale of the legislation, the consumer protection aspects of the DMCC Act are being implemented in phases; the first of those, the replacement of the Consumer Protection from Unfair Trading Regulations (CPRs) which now specifically includes fake reviews and ‘drip pricing’, came into force on 6th April 2025 and its impact is already being felt, with the announcement in November of a major CMA investigation into pricing practices (see page 5). The second tranche of the legislation, relating to alternative dispute resolution (ADR), subscription contracts and savings schemes, will be rolled out in 2026.

CTSI Lead Officers were instrumental in the consultations that fed into the DMCC Act, providing expertise and case studies based on their interactions with businesses, consumers and other Trading Standards professionals.

So have there been any significant challenges in implementing the new rules so far? According to Sylvia Rook, CTSI Lead Officer for Fair Trading, “It’s actually been surprisingly smooth. We were expecting there to be a lot more complex questions coming our way and, while there are

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some – interpretation is always going to be interesting – the biggest problem for people at the moment is the crossover between the DMCC Act and the CPRs. The concept of ‘invitation to purchase’ in the area of pricing has generated a lot of discussion, particularly with businesses as they try to navigate the new requirements.

The CMA have recently issued their new guidance on price transparency (CMA209) to give practical assistance.”

The DMCC Act’s red-letter day of 6 April serves as a watershed for enforcement action. Offences which took place up to three years before that date must still be investigated under the provisions of the CPRs, whereas if they took place on or after it, the new rules will apply.

As Jemma Cox, CTSI Lead Officer for Civil Law points out, “There’s also been a big change on the civil enforcement side because the new monetary penalties wouldn’t apply before 6 April if you were pursuing a case under Part 8 of the Enterprise Act, but they would be an option if it was after that date.”

Those new civil penalties can be substantial; the maximum penalty applicable if a company breaches an undertaking that it has agreed to, for example, can be up to 10% of the business’s turnover or £300,000, whichever is higher.

According to David MacKenzie, CTSI Lead Officer for e-Commerce, “Any time any legislation comes in that replaces something that was there before, there’s a transitional period – this is not a new concept for us, but it’s probably as

complicated as anything we’ve ever dealt with. It has actually been quite well handled though I think – in the DMCC Act there’s a specific schedule [Schedule 19] which in fairly plain language explains when the old law applies – it actually uses those phrases ‘old law’ and ‘new law’.

“We have had quite a few queries about real cases – this isn’t just theoretical,” MacKenzie adds. “For example, I had a case recently where I was helping colleagues in a neighbouring authority, and almost all of the trader’s activity was prior to 6 April 2025, so it really had to be done under the CPRs and the Enterprise Act. “For some cases there’s a genuine choice though; if there’s significant activity both prior to and after April 2025, it’s possible to use either process depending on the circumstances.”

Keeping things civil One of the DMCC Act’s defining features is its emphasis on civil enforcement. This is largely in recognition of the fact that most prosecutions under criminal law are subject to lengthy court delays and are immensely resource-intensive – and, in a lot of cases, they don’t necessarily produce the desired outcomes of improved business compliance and consumer redress anyway.

As MacKenzie explains, “The origins of the Government wanting there to be more of a focus on civil enforcement is that it can act as a lever to enable solutions that

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Journal of Trading Standards

Civil enforcement can act as a lever to enable solutions that are prior to court

Left The DMCC Act bans practices including fake online reviews and ‘drip pricing’

are prior to court, like a trader signing an undertaking or giving refunds – we’re quite happy with that in most cases. With the DMCC Act we have the extra lever of saying to businesses, ‘If you don’t cooperate here, we could take you to court and you could be hit with a substantial penalty.’

“Court delays can always be an issue of course, even with the civil process,” MacKenzie adds. “But in general a civil case is likely to get to court much quicker than a criminal one. I think we see prosecution delays everywhere in the country now. For example in my area of the Highlands, we had one case that took three years to reach a conclusion with a £200 fine, despite a lot of work and Officer time. We tend to do a lot more cases through the civil process now, often concluding in a matter of months.”

Cox agrees that, in some cases, the civil route is likely to prove most effective.

“A big theme across Trading Standards is about making sure that we are protecting consumer rights, and looking at how legislation works to achieve that in practice,” she says. “We’re seeing across all areas of our work that we might have the law in place – but can we actually enforce it in a timely manner that’s meaningful for protecting consumers?

“We’re hoping as Lead Officers that the civil process will be used more. It’s a step-by-step process and the starting point is consultation with the trader.

Then you increase the action if needed

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– it’s a proportionate approach and the hope is that by strengthening these civil powers you won’t need to go as far as an application to court. Obviously criminal prosecutions will still be more effective in some circumstances, but it’s about Trading Standards using our full toolkit.

“At the moment it’s still too early to tell whether that’s being realised in practice because there’s a big difference between what we hope this will achieve and what we actually see on the ground,” Cox adds.

Rook is also somewhat cautious about how the new rules will play out in the real world. “The new civil regime is really quite interesting because of the new financial penalties,” she says. “Now if we ask for information from a business and they don’t provide it, there is a financial penalty associated with that, but we have to apply to the courts to get that penalty imposed. The Government wanted Trading Standards to take fewer prosecutions to free up court time, but if we want to take formal enforcement through the civil route we still have to go through the courts – they’re different courts and have a different process, but often they’re equally slow.”

Some of those pressures may be alleviated by a new emphasis on ADR in 2026. Under new rules designed to enhance impartiality and consistency, ADR providers will be required to be accredited and their fees will be capped.

Businesses will also be required to ensure that the ADR services they use comply

with the new rules. According to Cox, “The changes to ADR we’re waiting to come in in 2026 are important to help tackle consumer detriment and build marketplace confidence. CTSI have set up an ADR Steering Group to look at these changes and what they will mean for Trading Standards services.”

Listening exercise To ensure that the DMCC Act is working effectively for their Trading Standards colleagues, Rook, Cox and MacKenzie all welcome questions and feedback from the profession (see email address, below). CTSI has held a series of online training sessions and webinars to help enforcers and businesses get to grips with the new rules, and the Business Companion website has a wealth of useful guides and resources. CTSI has also set up a new Civil Enforcement Special Interest Group which is creating a practical toolkit for civil enforcement investigations under the DMCC Act. As Cox says, “We’ve had lots of enquiries about both civil and criminal issues, and we are really happy as Lead Officers because we can use these examples to help support any members or local authorities who have questions.”

Those enquiries can also be fed back to the Government in any future consultations, Rook points out: “We have queries of our own that we’ve raised with the Department for Business and Trade about the interpretation of things which we’ve highlighted, and we’re trying to get answers for the profession.”

“We’re not just looking at this from an enforcement perspective,” Cox adds.

“Trading Standards are really well placed to give feedback on the application of the law in practice, as we work with both businesses and consumers in our day jobs.” l Further information To contact Lead Officers with questions about the DMCC Act, email: DMCCtraining@tsi.org.uk Written guides, training videos and other resources relating to the DMCC Act are available at businesscompanion.info

| 25

Case study

By Richard Young

Business unusual Running a busy Trading Standards service is a challenge at the best of times. But when a council goes bust, how can local enforcement demonstrate its value?

There is no such thing as a ‘normal day’ in Trading Standards, as soon becomes apparent when speaking with Russell Denney-Clarke, Trading Standards and Licensing Manager at Slough Borough Council. Despite being one of the UK’s smallest unitary authorities by geographical area and population size, Slough is one of the most ethnically diverse places in the country, serving as home to a rich and varied array of businesses.

Slough is also one of several local authorities in England to have been put under a Section 114 notice in recent years, meaning that the council is, in effect, bankrupt.

As Denney-Clarke explains, “A Section 114 notice means that the council can’t cover its costs. Since 2021 there have been central Governmentappointed commissioners who have been working with senior managers within the organisation. That puts in lots of spending control measures and the council can only spend money on what

“I often say that Trading Standards is the ‘Swiss army knife’ of the council”

Russell Denney-Clarke 26 |

is deemed essential. In general terms that would be wages, as well as stuff that you either must provide as a statutory function, or stuff which would result in serious consequences if you didn’t do it.”

Trading Standards certainly qualifies on both of those two latter points; UK councils have a statutory obligation to operate a Trading Standards service, including a qualified Weights and Measures Inspector. And, as this issue’s cover story sets out (see page 12), the diminishing of Trading Standards funding has serious consequences.

So how has the Section 114 notice affected the department’s day-to-day work? “It means you have to be very good at prioritising the workload and making sure it’s directly targeted at the residents of the borough rather than some of the wider national work,” Denney-Clarke says. “We’ve been ‘intelligence-led’ since about 2015, in line with what’s been going on elsewhere.

“Even though we’re a small local authority, we’ve got all the same responsibilities as the large county councils. We’ve got the whole plethora of businesses because we border Heathrow, so we’ve got a lot of imports and exports, we’ve got manufacturing, distribution and retail.

“Because our hands are tied with the financial issue we need to be reactive.

We monitor Citizens Advice complaints that come in, and our new case-handling software has got a dashboard which pinpoints what we should look at next.

“We haven’t got the resources to deal with individual complaints any more. It’s not like it was 20 years ago when we had consumer advisors, and Officers could go out and either nip criminality in the bud or do an investigation. We’ve only got four

operational officers – and of those, only one is full-time.

“An acute problem is unsecured airport parking because of our proximity to Heathrow,” Denney-Clarke adds.

Because these services do not tend to be used by local residents however, and because the airport itself sits out outside Slough’s jurisdiction, the team does not have the resources – or the remit – to address the problem directly.

Knowns and unknowns Slough is a multilingual place, with lots of traders who do not speak English as a first language. When it comes to getting Trading Standards messages out in the most effective way, Denney-Clarke has found that a no-frills approach is key. “We try to keep it simple and use basic English.

We do that with educational leaflets that we send out to businesses periodically, particularly if there’s a problem.

“That was fundamental in our approach to the single-use vapes ban,” he adds.

“We produced a leaflet advising of the practical steps businesses can take to make sure they’re in compliance. It went to about 250 businesses.

“Vapes in general are not just in the ‘standard’ shops. They’re often sold in mobile phone shops – we’ve even got a laundrette that’s selling them. These non-

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Journal of Trading Standards

Left A selection of non-compliant vapes seized by Slough TS Right Recent enquiries have included the importing of giant snails

standard shops are where we prioritise our face-to-face visits because the premises like off-licenses, petrol stations and national retailers tend to already be aware.

“We have our known businesses, but there are also unknown businesses; we went to high-density shopping areas where the known businesses are, but we also wanted to find and educate the ‘unknowns’.

There was about a 90% level of acceptance that what were doing was helpful, and businesses asking for more information.

“Of the hundred-or-so face-to-face visits, there were around 50 businesses that became targets for seizures as soon as the ban came into force on 1 June. Unhelpfully that was a Sunday, but despite our financial status, I managed to get overtime signed off – so we actually went out and did the enforcement on a the day of the ban. We saw it as a chance to demonstrate to our community and businesses that Trading Standards doesn’t stop – it’s not just Monday to Friday, nine to five.”

When it comes to occasional hostility from businesses, Denney-Clarke says, “Some people think authorities are always bad people. This is where it’s been helpful doing the educational piece first by introducing ourselves and saying, ‘Hello, we’re nice people. We want you to do well. We’re not here to be horrible, we are here to help’.

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“Trading Standards Officers are very much doers and problem solvers, and I think that’s something that many people higher up in councils, or council members, don’t appreciate. You can throw a problem in front of us and we go off and find the answer. We’re a bit like the AI of the council, or an encyclopedia.

“When I explain Trading Standards to anyone new to the organisation, I often say that Trading Standards is the ‘Swiss army knife’ of the council because we have to do so much.”

Shell company One of the more exotic problems that has landed on Denney-Clarke’s desk in recent months is giant African land snails. “A local business that wanted to import them in tins registered as a food business,” he explains.

“An Officer went out to do the initial inspection, discussed the product, and made sure the labelling was in compliance with the various different regulations.”

During that conversation, “The business owner said she wanted to import live snails from Nigeria and breed them in the UK. We’ve now got to research what laws or procedures she may need to follow to transport live animals into the country, and what she needs to do to slaughter them.

“This is one of the random oddities of Slough,” Denney-Clarke adds. “We’ve got lots of certain types of business, like food businesses, and shisha bars, and not many of others. We don’t have a lot of pasture land, for example, so we don’t have a lot of commercial animals.” (Apart from giant snails, naturally.)

Along with snails, vapes and shisha, enforcement of Sunday trading rules has been another recent focus – and Denney-

Clarke believes that can be an innovative way for Trading Standards to reassert its Weights and Measures role. “Since the Sunday Trading Act came into place in 1994, high streets and shopping districts have become a completely different kettle of fish,” he says. “There’s been the diminishing of the high street and the big names are moving out of the larger stores.

People are moving into these stores who think they can trade on a Sunday the same as any other day of the week.

“The Act was introduced to restrict retailers with larger premises from opening at certain hours on a Sunday, in order to give smaller businesses a chance. Since the mantra of Trading Standards is to create a fair and level playing field, ignoring the Act is unfair to those that are complying with the law. So we sent Weights and Measures Inspectors out with a laser measure to work out the area of the shop floors.”

Under the Sunday Trading Act 1994, shops with accessible floor space below the 280 sq m threshold can stay open for as long as they want on a Sunday; those above it can open on Sundays, but only for six consecutive hours between 10am and 6pm. They must also stay closed on Easter Sunday and Christmas Day. “The main reason we did it was that it was a creative use of Weights and Measures Inspectors; one of the primary functions of Trading Standards is legal metrology, and it gets overlooked as a benefit,” Denney-Clarke explains. “The Officers who were trained in this area were able to go out with authority. And most of the time, if a shop is doing one thing wrong, it’ll be doing other things wrong – there’s also a trickle-down factor, where if shops see others breaking the rules, they start to think they can as well.”l

| 27

Qualifications & training

Take the next step

CTSP status is the recognition of an individual’s high standard of professionalism and expertise by their Institute and peers When CTSI was given Chartered status in 2015, it reinforced the Institute’s official role in protecting consumers and promoting fair trading. It also meant CTSI members could apply for the status of Chartered Trading Standards Practitioner (CTSP).

Becoming a CTSP provides clarity to individuals, local authorities and private sector organisations, ensuring a consistent understanding that the professional status of someone with the letters after their name is recognised in statutes.

CTSP status is also recognised internationally, including in the EU, where it serves as an indication of the holder’s professional qualifications. It also indicates that the holder’s knowledge and skills are up to date, since retaining it requires continual professional and personal development (CPPD).

Last but not least, CTSP status provides individuals with the opportunity to promote not only themselves but the Trading Standards profession as a whole.

On these pages we hear from two proud CTSPs, who tell us what earning the status means to them. And if you are considering taking the journey to CTSP status yourself, the key information is included opposite.

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Vincent Searle, Principal Trading Standards Officer & Team Leader at Newham Council, and a member of the CTSI London Branch’s Race and Equalities Working Group, sees CTSP status as vital in strengthening the profession “Chartership is about defining why we do what we do, and why professional standards and public trust matter. It is an opportunity to formalise the values our profession has quietly upheld for decades – integrity, consistency, and accountability – and to future-proof them in a fast-changing world.

“Chartership moved me from seeing professionalism as compliance to understanding it as contribution, a responsibility to make regulation visible, accessible and relatable.

“My work with the CTSI London Branch Race and Equalities Working Group has also been important. It showed me how inclusion strengthens professionalism and how visible role models can inspire confidence across the workforce.

“Chartership is one of the strongest drivers of fairness in our profession.

It sets a shared standard for everyone.

It gives every professional the same opportunity to be measured It gives every by merit, not professional the circumstance, same opportunity and that makes to be measured our culture fairer. by merit, not “If someone circumstance is considering applying for CTSP status, they shouldn’t wait for perfect conditions. Chartership helps you think differently about your development and gives you the confidence to take the next step. If you care about your professionalism and your contribution, then CTSP is an honest reflection of that.”

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Journal of Trading Standards

Gillian Bates, Regulatory Compliance Manager at Tesco and member of CTSI’s Business Members’ Group, believes demystifying the chartership process could encourage more professionals to take that step “Working towards CTSP status was very much a personal motivation.

I wanted to do it for my own sense of achievement; to recognise the competency I’d built up over the years. I’ll be honest: I was aware of the scheme but often had self-doubt I would achieve it. With the support from fellow CTSP work colleagues I realised I absolutely could do it.

“I found that the process wasn’t complicated; it was really about showing my competence and staying committed to personal development across the year. Once I realised I could dovetail my CTSP plan with my Personal Development Plan at work, it all became much more manageable.

“The biggest commitment is time.

You have to give yourself the space to do it properly. My advice would be to do your CPPD throughout the year, not cram it in at the end. If you build it into your

working practice, it becomes part of what you do, not another task on the list.

“Gaining chartership was a real confidence boost. I actually wish I’d done it sooner. I work alongside a strong team of capable individuals at Tesco; achieving CTSP made me think about my own professional development more actively. It’s encouraged me to keep learning.

“I don’t think we celebrate chartership enough or explain it clearly.

From the outside it can look like a big, formal process. But it isn’t about being an academic. If you’re committed to your role, reflective about your work, and willing to develop yourself, you can absolutely achieve it. More people would apply, I think, if they had a clearer picture of what assessors look for and what ‘good’ looks like. There’s definitely more we can do to demystify it.

“Chartership brings value to the

wider Trading Standards profession by encouraging people to focus on their professional development. Once you start thinking in that way, you naturally begin asking: ‘What else can I learn?

How can I improve?’ That strengthens the discipline Gaining chartership as a whole – whether was a real you work in confidence boost. business or I actually wish I’d in a local done it sooner authority.

We’re all Trading Standards professionals and we’re all working to protect consumers. Chartership supports that shared purpose.

“When I see CTSP after my name I feel genuinely proud. I set myself a challenge, I pushed through my doubts, and I achieved it. Now I want to maintain that standard and keep that knowledge up to date.”

CTSP requirements

(for the calendar year), using the mandatory form 2 (see link below); • Completed Evidence Schedule using the mandatory form 4 (see link below).

of 20 hours of CPPD, with a minimum of 10 hours of core Trading Standards activities to be demonstrated. Events where no certificate was issued should be listed on the Evidence Schedule and signed by you and your internal line manager. Should you not receive, or lose, a certificate, the submission should be accompanied by an agenda and learning outcomes from the event in question. If neither are available, a CPPD claim form should be completed and signed by the candidate and line manager; • An Evidence Schedule document (using the mandatory form 4) listing training courses attended that relate to the above certificates, to be signed by you and your internal line manager.

• Full membership of CTSI; • Completed CTSP application form (available via the link below); • Evidence of up-to-date CTSI or employer CPPD, with a requirement of 20 hours in total over the calendar year; • Evidence of a Degree or NQF level 6 form of study (Level 9 SCQF), or a reflective statement in lieu; • Copy of appropriate Trading Standards qualification (DTS/DCA 1&2/ DCATS/Trading Standards Practitioner Diploma or antecedent), or a reflective statement demonstrating Trading Standards knowledge; • Evidence of a Personal Development Plan

All submissions for CTSP status are scrutinised by an external verifier.

CTSP retention

In order to retain CTSP status, you must submit the following each year to prove ongoing competency is being maintained: • A Personal Development Plan for the forthcoming year (using the mandatory form 2), to be signed off by you and your internal line manager; • Copies of certificates showing a minimum

Further information www.tradingstandards.uk/practitioners/training-development/chartered-status

Winter 2026

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Trader licensing

By Richard Young

REDRESSING THE

BALANCE

Rogue traders can ruin more than just buildings, causing untold damage to their victims’ lives and livelihoods. Could a mandatory licensing scheme tip the scales in favour of the consumer?

If I wanted to play a record in a public place I would need a licence. If I wanted to open a boarding kennel I would need a licence. If I wanted to work as a nightclub bouncer or drive a taxi I would need a licence. But if I wanted to come into someone’s home and demolish a wall, tear off the roof and dig up the foundations, I would be able to do so with no legal requirement to demonstrate any level of competence or skill.

According to an increasingly loud choir of voices including CTSI, many Trading Standards Officers, building industry bodies, members of Parliament and, perhaps most importantly, the victims of rogue traders themselves, that needs to change.

Mark Garnier, MP for Wyre Forest, is among those calling for a licensing scheme in the sector. In October 2024 he put forward a Private Member’s Bill, the Domestic Building Works (Consumer Protection) Bill, which has a second reading scheduled for early 2026. In its current form, the Bill calls for companies carrying out building works without a licence to be fined; the appointment of an ombudsman to resolve disputes between licensees and consumers; sanctions for breaches of licensing conditions; the payment of compensation to consumers; and the creation of a licensing body to administer the scheme.

Garnier’s interest in the matter stems from his own experiences. When he hired

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a contractor to carry out renovations on a property he owns in the South East of England a few years ago, he says, “We signed contracts for the work to start in the July, and be finished by February of the following year. To start off with they made a few ‘schoolboy’ mistakes, but basically the quality was okay. They started running massively over time though. It became very problematic; they were never there and we were getting to May or June, well past the agreed completion date, and they were a long way from finishing it.

“We were getting to rather a difficult place. An extension still hadn’t been built and they’d taken up the floor of the cellar, which needed a lot of work doing to put right. They’d done probably half the job in twice the time. Then they sent the bill – we thought it was the final bill, but they said no, we’ll send you that after you’ve made this payment. We paid £20,000, then they sent us a bill for £110,000, of which £60,000 was for their accommodation after they should have finished.

“Then we discovered that none of the subcontractors were getting paid. This horror story went on and on.”

THERE’S AN AWFUL LOT OF PEOPLE WHO LOSE OUT, NOT JUST THE CUSTOMERS

Garnier’s experience is by no means unique. According to the Federation of Master Builders (FMB), a lack of regulation in the sector has cost UK homeowners £14.3bn over the past five years. The FMB found in its ‘Licence to Build’ report that 33% of UK homeowners have been affected by poor workmanship and that 81% would support the introduction of a licensing scheme.

Interestingly, there is also widespread support for the idea within the industry itself, with 86% of builders wanting to see a scheme that protects both the trade and consumers, according to the FMB. The Campaign for Accountable Skilled Trades (CAST) is an independent, not-forprofit group formed of people who have been harmed by rogue traders. Claire Dickenson from CAST says: “My husband and I have lost approximately £25,000 to a rogue builder because we’ve had to pay someone else to complete the work, not to mention to correct all the shoddy workmanship we’ve discovered.

“I could not believe when I was going through the process of trying to get redress that there is nothing anybody can do to help you. You go to the police, you get told it’s a civil matter. You go to Action Fraud, and they just log it. I went to Trading Standards, and while they did more than anyone else, there seemingly is nothing they can do to help you either. They dragged the guy in for a meeting and gave him some business advice and guidance,

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Journal of Trading Standards

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Trader licensing

By Richard Young

but it did not make a jot of difference to me recouping my lost £25,000.

“Everybody is now left with going through a civil court case. That’s not too bad if you’re owed less than £10,000 because you can go through small claims court and it’ll probably cost you about £450. But for anything over £10,000, it’s going to cost between £6,000 and £9,000 to actually prosecute, with no certainty that at the end I am going to get any money back. Even if you get the County Court Judgment they don’t pay, or they fold the company.

“I cannot believe in a country where everything is so highly regulated that the building world is basically like the Wild West,” Dickenson adds.

Like many others in Trading Standards, Bev Ditch, Senior Trading Standards Officer at Brighton & Hove City Council, has been dealing with the problem for years. And now she believes enough is enough. “The only way forward is mandatory registration – end of,” she says. “How can consumers be expected to trust their life savings to a business that is not regulated?

“Of course the elephant in the room is the serious reduction of TSOs in the UK. We have recently seen the police taking action for fraud in some places, which is great, but not all police authorities will take alleged fraudulent activities on board.”

Ditch has put forward her own proposals for a mandatory registration scheme, born out of her frustrations, and those of a senior building control inspector, with “the level of incompetence in respect of unacceptable and unsafe standards of construction works carried out to domestic properties, confirmed by the increasing number of complaints received by Trading Standards”.

“There have been cases where houses have collapsed,” Ditch notes. “In one case a contractor did not follow the guidance of a structural engineer; fortunately the homeowner was away when the house did actually collapse, but this scenario could have resulted in a fatality. Sadly it may take such a scenario for this to realised.”

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33%

of UK homeowners have been affected by poor workmanship in domestic building projects

£14.3bn cost to UK homeowners of lack of regulation in building sector over the past five years Source: Federation of Master Builders

Equity of risk It seems there is a broad consensus that a licensing or registration scheme is necessary in some form or another. As to the specific details of how such a scheme would operate in practice though, those are up for debate.

Dickenson cites the example of Australia, where regionally administered licensing schemes require traders to be vetted for competence and experience, to be insured, and to show their licence to the homeowner before beginning any work. “What we are ultimately looking for is a redress of the balance that doesn’t currently exist,” she says. “Once you have a trader in your home, the balance of equity is unfair. The customer has everything to lose. The trader has nothing to lose. We also stand for helping legitimate traders who’ve been done over by the rogues. My new electrician lost £8,000 to a builder who just went, ‘No, I’m not going to pay you’.

“So we are not against traders – we also recognise there are ‘rogue customers’ out there; but if you regulate the builder, you also regulate the customer.”

Garnier also came up against an ironically sturdy brick wall when trying to

I BELIEVE A MANDATORY REGISTRATION SCHEME SHOULD AND MUST BE PUT IN PLACE

pursue redress. After making complaints and seeking legal advice, he realised that even a successful prosecution was unlikely to actually get him his money back. “I had to pay [the contractor] £55,000 just to get them to go away, which was nuts. It was just sickening,” he says.

“Being in the position I am though, I can do something about it.”

As he looked further into the problem, Garnier came to understand its scale and repercussions. “There’s an awful lot of people who lose out, not just the customers, but building materials suppliers, contractors, the people who rent out the plant and machinery who don’t get paid – all of those other people who are being screwed as well by this.”

There are cases where victims of rogue traders have committed suicide, Garnier notes. He also points out that the problem causes untold damage to consumer confidence: “Rogue builders have a huge economic impact on the sector because it means people don’t trust builders.”

Like Dickenson, he highlights the ‘inequity of risk’ that exists between rogue builders and their customers. “If a builder has a licence which they can lose, it will stop them working in the industry ever again, from being a company director down to a hod carrier. So there would be an incentive to keep your standards up and behave responsibly. And if you do it without a licence, it should be a criminal offence.

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Journal of Trading Standards

81% 86% of UK homeowners support the introduction of a licensing scheme

of builders support the introduction of a licensing scheme

“Another thing worth bearing in mind is financial compensation. If, for example, you lose your money in a pension scam, the Financial Services Compensation Scheme [FSCS] means money is available to sort the problem out. All the other pension companies pay into the FSCS, and that means they’re all looking at each other to see if there’s any malpractice because there’s an incentive for the industry to improve standards.

“There are amazing people out there doing amazing building work,” Garnier adds. “I’m not looking for something that is very onerous and difficult. What we want is something which is relatively straightforward and simple.”

Getting organised CTSI Lead Officer for Doorstep Crime, Dr Tim Day, has long called for a trader licensing scheme and recommended it in his doctoral thesis in 2019. “The debate about whether there’s a need for a licensing scheme has so far focused almost entirely upon ‘rogues’, ‘cowboy companies’ and ‘shoddy work’,” he says. “This overlooks the extent to which organised crime is involved. Professional, organised doorstep criminals currently operate freely in the home improvement sector, with the ‘trade’ they represent merely a vehicle for them to perpetrate fraud.” (See more on organised crime on page 12.)

“It is virtually impossible for consumers to be able to distinguish the

Winter 2026

legitimate businesses from the organised criminals due to the lack of regulation and the ‘legitimate guise’ tactics the fraudsters use so convincingly.

“However, getting their case heard, or getting redress once they’ve been defrauded, is currently out of reach for the vast majority of victims. My doctoral research showed levels of complaints regarding electric and gas works, which do require a licence, are far lower than for the trades where the is no licensing requirement. I believe the only way to deal effectively with this is to try to root out the fraudsters before they reach their victims and that means a compulsory licensing scheme is essential.”

Gap in the system?

To many people, it comes as a surprise that such a scheme doesn’t exist already.

According to the FMB, almost half (47%) of UK adults incorrectly believe that builders are required to be licensed at present. “I think it amazes people that it’s the only bit of the process that isn’t regulated,” Garnier says. “Let’s say you want to put an extension on your house.

You’re going to go to an architect, who can’t practice without being part of a trade association. To pay for it you might need to take out a loan, so you might go to a mortgage broker or a bank, regulated by the FCA. You then need a solicitor, who’s also regulated. You then go to the local authority to get planning permission.

“You go through all of this and at the end of it, having had all of those different stages of regulation, you hand the money over to somebody who you’ve never dealt with before.”

Garnier put the issue before Parliament for a debate in Westminster Hall in November. Although his call for increased protections for consumers in the sector received widespread support, the Government’s official line is somewhat circumspect. Consumer Minister Kate Dearden MP said: “Consumers have a right to expect that work undertaken in their homes will be performed competently and that there will be redress if the work does not meet acceptable standards of quality and safety.

“The Government’s aim is to improve the market and to support honest and competent tradespeople and firms, working with the industry and with local authority Trading Standards. […] The Consumer Rights Act 2015 sets out the standards that consumers can expect in relation to the supply of goods and services, including building work, and the remedies available to them.

However, Dearden added, “Few evaluations have been undertaken of the effectiveness of [licensing schemes in the US, Australia and New Zealand]. The available evidence suggests that they can deliver some benefits, such as increased quality, but that they can also have detrimental effects, including increasing prices for consumers. There is also no clear evidence that the existence of licensing schemes reduces the incidence of poor-quality work. The schemes are reliant on audits and inspections of work to identify incompetent builders, which is similar to the approach of the TrustMark and competent person schemes in the UK. “There are also questions of how licensing schemes would be funded and administered, the implications for existing schemes in the UK, and the resourcing of the organisations responsible for the schemes. Any proposal to introduce a licensing scheme in the UK would have to be based on an assessment of costs and benefits, and would have to address those issues.”

According to Bev Ditch, “Just how the Government can improve standards of consumer redress [without a licensing scheme] beggars belief. We all know the limitations of the Consumer Rights Act, and any consideration to litigation also is a pointless exercise. These rogue traders simply disappear, dissolve their businesses and we see them ‘phoenixing’ again and again.

“I believe a mandatory registration scheme should and must be put in place to prevent significant financial loss and to safeguard the public against poor and potentially dangerous standards of building work. Government has a duty of care to protect consumers.” l

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Carer fraud

By Kuldeep Maan

Kuldeep Maan Principal Trading Standards Officer, Dudley Council

Duty of care

Carer fraud devastates the lives of some of society’s most vulnerable people, but all too often there is no justice for the victims – until Trading Standards steps in “They’re just friends. A friend can give their money away and even buy a house for another friend. It’s not a crime.”

Those words have echoed in my mind ever since I first heard them ten years ago, spoken with smirks and confidence by two senior police detectives. I can still picture that moment vividly. Their words were dismissive, even casual, but the situation was anything but.

Let me take you back three months earlier. It all started when some concerned neighbours raised the alarm. They believed their 93-year-old neighbour, a partially blind World War II veteran, was being financially abused by his carer. They said he was being isolated and had even purchased a house for the carer to live in. In response, a safeguarding professionals’ meeting was convened. Representatives from different agencies came together to assess the situation and decide how best to protect the man. Based on the information shared, the police agreed to investigate and went on to arrest the carer.

At the time, it felt like the system was working. But just a month later, at a follow-up meeting, the police returned

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with a decision that left everyone stunned.

They said there was no fraud, no crime.

No further action would be taken, and they flat-out refused to reconsider.

That moment changed everything for me. I realised if this vulnerable man was going to get justice, it was not going to come through the police but through Trading Standards. That was the start of my journey. Since then, I’ve dedicated myself to investigating carer fraud, and over the past decade I’ve become a specialist in this area.

Hidden abusers Carers play a vital role in our society, supporting elderly and vulnerable individuals with daily living, health needs and companionship. The vast majority of carers are compassionate, honest and selfless. But some, unfortunately, are not. In some cases, carers exploit their position of trust for personal gain, financially manipulating or defrauding the very people they’re supposed to be helping.

This is carer fraud – a form of financial abuse – and those who commit it are known as rogue carers.

Behind every case is a grieving family, a silenced victim, and a community that deserves protection

Not all carers are regulated. If someone is employed through an agency, care home or nursing home, their employer must meet the standards set by the Care Quality Commission (CQC), including safeguarding policies, vetting checks and regular training.

But many carers work independently.

They might be self-employed, paid directly by individuals or families, or act as personal assistants through direct payments. These unregulated carers are not required to register with the CQC. They do not have to undergo any training, background checks or official oversight.

Unfortunately, the number of unregulated carers is growing. Staff shortages, low pay, difficult working conditions and stricter post-Brexit immigration rules have made carer roles more difficult to fill. At the same time, the UK’s ageing population means the demand for care is rising – and many families are turning to cheaper, unregulated options.

Carer fraud can happen in any setting: in the victim’s home, in care homes, and even by family members or trusted friends. Carer fraud is often a hidden crime. Victims may not even realise they’re being exploited. They might be scared to speak out, especially if they rely on the abuser for daily care. Or they may want to protect the abuser, particularly if it is someone they love or trust.

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Journal of Trading Standards

Sadly, many professionals also struggle to spot the early warning signs. That is one of the key reasons these crimes continue to slip through the cracks.

According to Age UK, a fraudster targets an older person every 40 seconds.

Researchers estimate that between 1% and 2% of people over 65 in the UK have experienced financial abuse, which equates to around 130,000 elderly victims.

The Social Care Institute for Excellence found that 17% of the public knew a vulnerable adult who had been financially abused, and 24% of vulnerable adults knew another vulnerable person who had also been targeted.

Dudley Trading Standards has received around 100 referrals a year since 2021 relating to suspected financial abuse cases, many involving carers. Our investigations have ranged from carers stealing hundreds of pounds to more extreme cases involving fraud worth over £1m. This is not a local issue. This is a national problem.

Taking action Back in 2015, after the police dropped the case against the carer, Dudley Trading Standards took it on. We gathered evidence, took it to court and secured a conviction. The carer was sentenced to five and a half years in prison, the house was returned to the victim, and the proceeds of crime recovered.

Winter 2026

I have now investigated more than 50 carer fraud cases. I have seen this fraud carried out in every setting imaginable, by agency staff, care home workers, private carers, and victims’ family members and friends. After a decade of investigating these cases, one thing has become crystal clear: we need to get better at spotting carer fraud.

Most of the referrals we get come too late. Often, the victim’s life savings are gone, or the victim has passed away and family members discover something does not add up with the estate.

This is why our work matters. We must push for stronger enforcement and greater understanding. Right now, when adult safeguarding refers such cases to the police, too many are dismissed unless they fit neatly into a simple definition of theft or misappropriation.

Officers often struggle with the concept of capacity. The very first question asked is: “Does the victim have capacity?”

If the answer is yes, or if no formal assessment has taken place, the case is often returned without any meaningful enquiries being made.

But capacity is rarely the issue here.

The real question we should be asking is: “Was there coercion? Was there controlling behaviour that exploited vulnerability?” Far too often, this critical line of inquiry is overlooked. When a new Will suddenly appears naming a carer of just a few months as the sole beneficiary, these cases are too frequently dropped into the ‘too difficult’ box.

Yes, these cases are complex. Yes, they demand time, persistence and careful investigation. But difficulty should never be an excuse for inaction.

Behind every case is a grieving family, a silenced victim, and a community that deserves protection.

I have seen families come to us in tears, heartbroken to discover a loved one’s Will has been altered in secret, with relatives replaced by someone who only recently came into the victim’s life. Time and again, police dismissed these as ‘civil matters’.

And yet, when we step in and uncover the fraud, and justice restores the rightful will, the impact is profound. These are the

moments that remind us why this work is so important, and why it is so rewarding.

It is also vital that Trading Standards departments recognise that carer fraud does fall within our remit. For those consumers who self-fund care, the protections under the Digital Markets, Competition and Consumers (DMCC) Act 2024 (see page 24) are directly relevant – they are at the very heart of what we do.

Admittedly, the law is more limited when care is arranged by the self-funder but paid through local authorities, who then invoice the self-funder. It is still the self-funder who pays for the care but they have less protection, even though the care sector is worth more than £30bn annually.

Even then, other avenues exist. The Fraud Act 2006, particularly abuse of position of trust, provides a powerful tool.

Proving dishonesty may be challenging, but not impossible, and with persistence it can be done. This is why raising awareness became my mission. I wanted to help people spot the red flags early, to stop these crimes before lives are destroyed.

In 2024 I founded Insight Essential Training with the mission of empowering the public, professionals and investigators to better understand and combat the diverse landscape of UK fraud. That same year, I launched the UK’s first dedicated carer fraud awareness training, delivered to both professionals and the public.

Dudley Metropolitan Borough Council saw the importance of this training and its benefits for their residents, and in 2024 made carer fraud awareness training mandatory for all adult social care staff.

The council even offers it to elected members to help them better support their constituents.

Insight also provides advanced training for investigators, helping them identify, build and prosecute carer fraud cases effectively. Carer fraud is real. It is happening now, and it is ruining lives; know the signs, unmask the fraud and make a difference. l Further information To find out more, visit www.insightessentialtraining.com

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College of Fellows

By Richard Young

Back to College

Although the CTSI College of Fellows and the Trading Standards Fellows’ Charity are now recognised as two separate entities, they remain unified in their ongoing support for the profession For the past year-and-a-half, change has been afoot at the CTSI College of Fellows. As the organisation’s Secretary, Brian Stone, puts it: “We’ve done a lot of thinking over the last 18 months and have had a lot to wrestle with. Now we’re trying to make it work.”

Up until now, the College of Fellows – which was set up in the early 1950s with the charity being formally established in 1957 – has had a dual and at times somewhat confusing structure. It used the same umbrella term for its roles as a membership organisation and a charity, which over the years has made it difficult for each to forge a distinct identity.

Now, for reasons of clarity and transparency, the College has been split into two separate entities. The first of those is still called the CTSI College of Fellows, and comprises a group of CTSI members who have been elected by their peers in recognition of their exceptional dedication to the profession. The College of Fellows is part of the Institute and is required to report its activities periodically to CTSI Council.

The newly renamed charity is the Trading Standards Fellows’ Charity, which exists separately from CTSI and its governance structure, and has its own board of Trustees. As before though, the charity has two primary functions: the relief of financial hardship for members of CTSI and their dependants; and support for education and research which promotes the interests of Trading Standards and consumer protection.

As Stone explains, “Historically people have referred to the ‘College’, when in fact

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they meant the Charity. We’re now trying to differentiate – and one of the pluses that’s come out of this review is that we’re now looking at what the College actually does in real terms.”

College of Fellows Chair, Chris Armstrong, says election to the College is “a recognition from your peers of what you’ve contributed to the profession in all sorts of areas. We try not just to look at people doing a good job because that’s what they’re paid to do – we’re looking for something extra, like maybe taking on voluntary service in their Branch.

We try to recognise contributions across the board.”

“Those who are elected are often very shocked and staggered that their peers have recognised them,” Stone adds. “Once you’re a Fellow there’s no obligation to do anything, but the trustees of the Charity are drawn from the Fellows, and we’re all looking at succession planning.”

“One of the first things I said when I took over as Chair was that my first job was to find somebody younger to succeed me,” Armstrong chuckles. “We have got some very worthy people who would do an excellent job. I’m not so sure there are many who would be able to do Brian’s job – but it’s easy being Chair!”

Opening up Alongside the restructure, a key focus in recent years has been on ensuring that the College of Fellows more accurately reflects both the CTSI membership and the wider Trading Standards workforce. According to Armstrong, “the gender make-up of the College has changed dramatically – it

wasn’t that long ago that there weren’t any women involved, and I can even remember a time when there were no women in Weights & Measures at all.

“There has also been a change in terms of ethnicity and other forms of minority groups – it’s changing, I would say quite slowly, but it’s happening.”

Stone agrees that while a lot has improved on the diversity front, there remains much progress to be made. “In the past few years we’ve seen an increase in Fellowship nominations for people from other than white backgrounds, and that’s been fantastic,” he says. “The London Branch have very much led the way in that, which has been great.

“I got involved in about 2014, and at that point the charity board was all white, all male, all old.

We’ve now got 50 percent female We’ve now got 50 representation on percent female our Trustee board, representation on which is fantastic. our Trustee board, We were delighted which is fantastic when Valerie

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Journal of Trading Standards

Far left Brian Stone and Chris Armstrong at the CTSI Hero Awards 2025 Left CTSI Fellows at the 2025 Conference in Blackpool (left to right): Samuel Abdullahi; Valerie Simpson; Ron Gainsford OBE; Chris Armstrong; Alexandra Connell; Tendy Lindsay

Simpson stood this year as a new Fellow and as a Trustee of the Charity – it’s a step towards trying to broaden our diversity so that we can do what needs doing.”

Friends indeed Despite its new moniker, the Trading Standards Fellows’ Charity fulfils exactly the same important purpose as before.

When CTSI members and their families are experiencing hardship – often as a result of poor health or bereavement – it is there to help, spending more than £8,000 on worthy causes in the past year alone.

“It’s something we hope we never have to pay out, but obviously these things happen,” says Stone. “It’s hard to think in this day and age that people would be in a position where they need financial help, but not everybody’s on massive salaries and, especially if there’s a family involved, we’re prepared to step in.”

In addition to emergency financial support for CTSI members, the Charity has also made available bursaries so children who have lost a parent are able to pursue further education.

Winter 2026

All applications for support are treated confidentially and, in many cases, the recipient has not put themselves forward but has instead been brought to the Charity’s attention by a concerned colleague. Support is not means tested and, Stone says, the criteria are very broad; if somebody’s got a need and they’re struggling, we will do what we can to help them.”

The other aspect of the Charity’s remit is about investing in Trading Standards’ future through support for education and research initiatives. Over the past few years this has included helping to fund academic research (see page 38) and support for a project on livestock transportation.

Stone says he sees this as “an investment in Trading Standards’ future”.

“The charity has a legacy of supporting the profession, and often people who have had a career in Trading Standards are looking to ensure that there is a viable service for people who are coming in as the next generation,” he says.

A good example of that investment in the future is Dr Tim Day’s research, which has helped increase understanding of doorstep crime among policymakers and enforcers, and provided a solid evidence base that scams and rogue trading should be dealt with as a criminal, rather than civil matter. “We were happy to help him disseminate his research,” says Armstrong. “Only yesterday, I was talking to a colleague who said that Dr Tim was doing a presentation and it was captivating

– he’s got so much interest in this within the I’ve always had profession and this thing about beyond.” protecting While on the people, including topic of ‘giving colleagues at work back’ to the profession: what, I wonder, motivates Armstrong and Stone to keep working away on Trading Standards’ behalf even after their respective retirements – rather than, say, spending their afternoons in a Wetherspoons? (“How do you know I don’t?!” is Armstrong’s initial response.)

“I’ve always seen that on the one side are the crooks, rogues and robbers, and on the other side are the people that have suffered at their hands – and then you see people within your own profession that are suffering,” Armstrong says. “I’ve always had this thing about protecting people, including colleagues at work – if they have a problem, everybody comes to ‘Granddad Chris’.” (Armstrong’s decades of commitment to Trading Standards were recognised with the Institute’s Hero Award in December (see page 54).)

Similarly, says Stone, “When I retired I thought, OK, I’m not an active TSO anymore – how can I stay involved?

I’ll support the Institute. I’m a ‘critical friend’ – quite a cynical critical friend normally – but I believe in what the Institute does, and that people who work in the profession should be members. I’ve always felt, don’t moan about it if you’re not involved in it!”l

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Research

By Andrew Passenger

Andrew Passenger Trading Standards Officer, Carmarthenshire County Council

Guardians of principle A recent research project which strengthens the efficacy of call-blocking systems also highlights the age-old golden thread that runs through consumer protection work Since early civilisation, the work of guardians and overseers of official weights and measures has, in one form or another, been integral in shaping the modern world. It reflects a universal scientific accord, from maintaining the integrity and principles of instruments used in the construction of ancient monuments and mapping and circumnavigating the globe, to ensuring that goods are traded honestly and fairly.

It provides some of the earliest evidence of scientific and official regulatory oversight, not only in preserving the foundations and integrity of objective science, but also in policing consumer fraud. Weighing scales are depicted throughout history as symbols of justice and fairness, underpinning much that today can be taken for granted.

It is only fitting then that the work of modern-day Trading Standards operates at the forefront of such objectivist thought as it relates to fraud prevention. Many readers will be familiar with the trueCall nuisance call-blocker as a staple in the armoury of Trading Standards, the police, and health and social care for well

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over a decade. It is highly effective as a situational crime prevention measure, serving to increase the security of people subjected to nuisance and fraudulent telephone calls.

However, whilst trueCall presents an intuitively compelling and epidemiologically informed situational crime prevention measure, much in the same way that locking one’s front door controls access and prevents theft, its efficacy in the face of determined criminals may be compromised when depended upon in isolation. That is especially so without the continued engagement of users, not only in their use of such devices to their full potential, but also in their perception of the risks precluded by their installation.

Enter Seraphim These ideas led to the development in Carmarthenshire of a novel programme of situational crime prevention called the Seraphim Telemarketing Fraud Prevention Programme (STFPP).

The STFPP seeks to use trueCall call log metadata to enhance the use of the trueCall nuisance call-blocker as a

situational crime prevention measure and prevent user engagement with telemarketing criminals.

The programme works by formally monitoring and policing the channel through which telemarketers engage with potential victims through the use of a novel inference engine and alert system, Seraphimbeta, to deliver proactive paternalist intervention and victim support services in cases where it is identified that criminals may have engaged with ‘at risk’ persons subscribing to the programme.

Early iterations of Seraphimbeta were piloted with a number of trueCall projects across the UK, followed by more formal pilots of Seraphimbeta Version 2.0 with Orkney Islands and Buckinghamshire & Surrey Trading Standards services.

This led to the development of a more systematic approach to proactively monitoring a fleet of trueCall devices and a programme of welfare intervention for ‘high risk’ users.

To this end, the Seraphimbeta inference engine has undertaken 8,858 automated monthly monitoring actions on Carmarthenshire trueCall devices

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Journal of Trading Standards

I hope that the underlying principles of the programme can be put to use in other policy and practice areas

Above The Tholos of the ancient Agora in Athens provides some of the earliest evidence of formal weights and measures regulation Left Andrew Passenger took the CTSI message to ancient Athens as part of an international criminology conference

and generated 155 intervention alerts followed up through programme officer intervention.

Programme outcomes In addition to the statistical data relating to calls blocked – some 155,000 calls in Carmarthenshire since 2022 – qualitative outcomes of STFPP programme interventions for vulnerable users and their families include the identification of unreported telemarketing fraud victimisation, enhanced informal and formal guardianship, and the prevention of distressing interactions with aggressive telemarketing callers. This has led to reduced emotional harm, reduced user and carer anxiety, improvements in user and family member wellbeing, and the continuation of protective telemarketing fraud prevention services in the wake of the digital telecommunications switchover.

Evidence of programme outcomes, including why and how the Carmarthenshire programme works, has further been captured through my own academic research evaluation as part of my studies with Cardiff University.

I recently submitted my doctoral

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thesis, which provides a scientific realist evaluation of the Carmarthenshire trueCall programme. With the generous support of the Trading Standards Fellows’ Charity (see page 36), I presented some of my findings at the prestigious European Society of Criminology (ESC) 25th Anniversary Conference in Athens in September 2025.

I am very grateful to the Trading Standards Fellows’ Charity for helping support my attendance and presentation at the ESC conference, and for the opportunity to promote the work of Trading Standards in the UK to a global network of criminological scholars and law enforcement stakeholders. It enabled me to contribute valuable insights into the work of UK Trading Standards to the scarce academic literature in this area.

I am now awaiting viva voce examination for the degree of Doctor of Social and Public Policy, and intend to disseminate my published thesis among CTSI members and Trading Standards Officers, as well as wider academic, professional and policy networks. I hope the research will provide a catalyst for the Carmarthenshire programme and for the Seraphimbeta inference engine to be

further developed and scaled up for use in other authority areas.

I also hope that the underlying principles of the programme can be put to use in other policy and practice areas – for example, in the identification and support of loneliness and social isolation, the early onset of cognitive decline, or in policy areas where there may be obligations to identify vulnerability, and where the deployment of early intervention strategies using risk-based, epidemiologically informed alert systems may have further practical application.

In closing, I’d like to note that the ESC conference provided a fascinating insight into the high level of criminological research being conducted globally.

However, regulatory services such as Trading Standards and Environmental Health, and their global counterparts, were conspicuous by their absence.

The lack of research into the activities of Trading Standards and other regulatory services should serve as a siren call for further research into the impact and evaluation of regulatory services as significant contributors to the law enforcement and crime prevention landscape. I believe there is much regulatory work that remains unrecognised, unresearched and undervalued by policymakers. l About the author Andrew Passenger is a philosophy graduate, former Citizens Advice Bureau generalist adviser, Financial Conduct Authority Money Advisor and level 7 Advanced Investigator, and is a full member of CTSI with more than 15 years’ experience in Trading Standards.

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Product safety

By Richard Young

One step at a time

Unsafe ladders being sold on online marketplaces pose a serious threat to consumers, traders and legitimate manufacturers Like a lot of the stuff lurking in the recesses of our sheds and utility cupboards, ladders are not among the most exciting things in the world. They have a utilitarian function which many people take for granted, just as they take for granted the idea that if something is being sold via a well-known online retailer, someone somewhere has checked that it is safe and up to the job.

But, as everyone in Trading Standards knows, that isn’t necessarily the case.

As with so many other goods, an influx of cheap, non-compliant and potentially dangerous ladders has flooded online marketplaces over the past few years.

Now the Ladder Association, an organisation founded in 1947 to promote safety and standards in the manufacturing and use of ladders, is stepping up its efforts to ensure that when consumers engage in a spot of DIY, dusting or decorating, or when traders use ladders in their daily work, they can be confident that the equipment is fit for purpose.

As Don Aers, Technical Manager at the Ladder Association, explains: “We have been working on a number of research projects where we’ve looked specifically at telescopic ladders, and at the quality of them across the market. Telescopic ladders in particular retract down to a small size, so importers can fit a lot of them into a shipping container.

“On online marketplaces you tend to see exactly the same product from lots of different sellers, and they’re all equally dubious. Frankly, they don’t meet the standard, which is quite robust. A lot of these ladders are not.”

The British Standard for ladders, BS EN 131, applies to ladders designed for both professional and non-professional use, and among its requirements are that all ladders

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are able to support a load of at least 150kg; that ladders more than 3 metres in length have a wider base for added stability; and the inclusion of detailed user instructions with clear pictogram markings displaying critical safety information.

In a previous project undertaken by the Ladder Association in partnership with the Test & Research Centre, East of England Trading Standards Association (EETSA) and Suffolk Trading Standards Imports Team, more than 80% of commercially available telescopic ladders tested failed to meet the minimum safety requirements.

Their latest study found that out of 18 telescopic ladders tested, 14 failed to comply with BS EN 131. Of those, ten were purchased from Amazon – all of which were advertised as ‘top sellers’ in the category.

Amazon was approached for comment about the products available on its platform which fail product safety tests; the company failed to respond.

Race to the bottom John Darby is General Manager at the Test & Research Centre, which regularly assesses ladders for compliance with safety standards. He has seen a recent increase in unsafe ladders imported from overseas which he worries is part of a wider trend.

“I worked for ten years in development, design and manufacturing,” he says.

“Testing was part of that – it’s just what you did. Recently though, my eyes have been opened to the fact that if the rogue manufacturer doesn’t do it, no-one cares.

“Online marketplaces have facilitated third-party sellers, and at least 80% of the ladders that we find and test are coming direct from them. The online marketplaces have created this problem and it really should be on them to fix it. But they’re making too much money out of it.

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“The trouble is the knock-on effect on legitimate and responsible businesses.

There are safe products out there, being sold or stocked by trusted manufacturers and suppliers, but they’re fighting on price. These non-compliant products are eating the market.”

As well as hurting legitimate businesses, non-compliant ladders are also harming their users. In one incident, electrician Joffrey Bogemans fractured a rib and suffered injuries to his shoulder and hip after falling from a height of 4.5 metres when a ladder he had purchased from Amazon buckled underneath him. Unable to do overhead work as a result of his injuries, he independently developed FOLOUP (Flagging Online Listings of Unsafe Products), a platform which identifies, tracks and reports unsafe products sold on online marketplaces.

Above, left and below 80% of commercially available telescopic ladders failed safety tests carried out by the Ladder Association in partnership with the Test & Research Centre and Trading Standards

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People before profits If dealing with the online marketplaces is difficult, getting hold of the often China-based manufacturers is nigh on impossible. As Aers points out, “It’s very, very diffcult to get in contact with them because the addresses and contact details they give just don’t exist. When we have had conversations with some overseas manufacturers in different forms, they’ve basically said, ‘What would you like written on the ladder? How much weight do you want written on it? Whatever you want, we’ll put it on’ – regardless of whether that accurately reflects the specifications of the product.

“It would be nice to have an international standard for ladders but it’s got to work from the highest safety requirements, not from lowest,” Aers adds. “Unfortunately, people would pick the cheapest ladders conforming to lesser requirements, and unscrupulous manufacturers and suppliers won’t agree to higher requirements as that would mean increasing their prices. It’s highly unlikely we will see an international ladder standard in the foreseeable future.

“These things are getting into the country. The manufacturers are making

money, they don’t really care, and they’re quite happy to keep doing what they do.”

The Product Regulation and Metrology Act, introduced this year, places additional responsibilities on online marketplaces for the safety of products sold on their platforms. Aers believes that is a step in the right direction, but he thinks better communication and a change in the mindset are also vital.

“We should be looking for regulations that make our standards mandatory,” he says. “We’d also like to encourage a dialogue with the online marketplaces themselves; we’ve had discussions with some of the bigger ones and in a lot of The online instances, they don’t marketplaces seem to know what have created this ‘good’ looks like and problem and it what questions to really should be ask suppliers. We’re on them to fix it more than happy to have conversations to try and help them.

But there’s got to be a willingness to put people before profits.”

In the mean time, Darby says, it is important to continue safety testing so potentially dangerous products can be removed from sale. That work, carried out with the support of Trading Standards, also helps build an evidence base. “We’ve developed a good relationship with Trading Standards to the point where we’ve managed to refine the testing requirements down to a handful of certain key requirements, which makes it more cost-effective,” he says.

“It’s about sharing knowledge, and spreading awareness of the problem.

Everyone’s either already got one or at some point is going to need to buy one – do they go for the £40 one on the internet that turns up tomorrow, or do they do a bit of homework to make sure what they are buying is safe?” l Further information ladderassociation.org.uk/step-up testandresearch.org foloup.info

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I want to ensure that if consumers are doing all the right things, we are doing whatever we can to reduce the vulnerabilities

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In conversation with: Sarah Adcock

Journal of Trading Standards

I N C O N V E R S AT I O N W I T H

SARAH ADCOCK The Director of Consumer and Competition Policy at the DBT explains why consumer protection is the foundation of a healthy economy

BY RICHARD YOUNG

Sarah Adcock’s straight-talking approach comes across even before we sit down to conduct this interview. When making the preliminary arrangements, she suggests that her preferred setting would be a beach with a few cocktails on hand; budgetary constraints being what they are, we opt for a Teams meeting instead, but her remark makes for a refreshing contrast with the usual strictures of civil service ‘comms’ channels.

A career-long civil servant, over the past 23 years, Adcock has worked across various Government departments. “For quite a significant chunk of my career I’ve been some form of negotiator, whether it was a technical negotiator or a negotiator within the EU system or Brexit... unfortunately,” she says, a slightly faraway look momentarily coming into her eyes on that last point. (Her patience and perseverance during the fraught Brexit years were recognised with an OBE in 2021.) Adcock then spent a couple of years in the sunlit uplands of Defra, where she co-ran the Natural Capital and Ecosystem Assessment programme, before heading to the Department for Business and Trade (DBT) in 2024, where she took on her current role as Director of Consumer and Competition Policy.

Adcock’s grounding in economics, which she studied at university, has given her a pragmatic, fiscally focused worldview, she says: “When you study a particular thing you think in a particular way, in terms of value for money, doing the best with very limited resources – which is obviously quite relevant.”

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It certainly is. Adcock comes to the DBT at a time of ongoing upheaval for consumers, caused by years of austerity and the spiralling cost of living, as well as the emergence of disruptive business methods which create new inroads for potential consumer detriment.

“What drew me in particular to this job was the policy aspect – the idea that through Government action and regulation we can improve the experience of the consumer in making choices,” she says. “We want businesses to behave themselves in order to make every penny count in a consumer’s pocket.

The principle of effective competition is paramount for effective markets, which then leads to growth, consumer choice and better outcomes.”

Adcock also has responsibilities for examining how data is harnessed to create ‘smart’ products and services like open banking. A key priority is “ensuring that consumers’ data is released for their benefit,” and there is a broad spectrum of sectors where that applies: “What could we do in the energy space? What could we do in the property space? What's possible in agriculture, in food shopping? The world's your oyster in terms of helping consumers know the value of their own data and how it can be used to help them,” she says.

Growth agenda With uncharted territory like open data and artificial intelligence sitting alongside more prosaic concerns like how to feed a family on a limited budget, I wonder whether Adcock perceives a ‘golden

thread’ running through consumer protection, encompassing both the new, technology-driven paradigm and more traditional ideas like quality and fair play?

“Yes, I do. And it is all about growth,” she says. “If you have a strong consumer policy, you’re more likely to encourage repeat spending.” A key focus, Adcock adds, is on questions like: “How can we set the framework that gives consumers trust in the system to part with their hardearned cash? How can we help them make the best informed choices pre-purchase, and then solve any problems that might arise without being a ‘nanny state’?

“There are two reasons for that: one is for consumers to get the best deal possible; the other is to raise the standard of how businesses interact with consumers. We can support that directly through trying to set a level playing field with things like ADR [alternative dispute resolution] and Consumer Codes, and incentivising businesses to take those on board.”

Consumers themselves also have a role to play in encouraging businesses to behave better, she adds: “More informed consumers are likely to be regularly knocking on the door of a business [to complain], which might make them go, ‘We’ve got to buck up our ideas, otherwise we’re going to lose business.’

“So it’s a bit of ‘carrot’, a bit of ‘stick’, and not just Government doing it; if we empower consumers more, businesses will realise what is right and proper.

Consumers being more aware of their rights is paramount here, particularly in a world with no money,” she adds.

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In conversation with: Sarah Adcock

Adcock says she fully supports CTSI’s calls for mandatory consumer rights lessons in schools as one means of empowering consumers. “I would absolutely love that,” she says, noting that November’s announcement that lessons on mortgages and personal finances will be introduced to the curriculum by 2028 “might mean a door is opening for this kind of thing in the future”.

Walking the tightrope Pejorative terms like ‘nanny state’, ‘red tape’ and ‘regulatory burden’ have become synonymous with a certain agenda that, at its most extreme, casts anything short of unfettered corporate self-interest as a stifling constraint on economic growth. Even in more levelheaded climes those ideas can create a degree of tension between consumer protection and the proclivities of a free market. So what are Adcock’s thoughts on how those differences can be reconciled in a modern economy that works for the many, not the few?

“There’s always a fine line, there’s always tensions in what we're doing,” Adcock acknowledges. “In my experience at DBT though, those tensions are significantly less than anywhere else I’ve ever worked in Government because ultimately, it’s two sides of the same coin; businesses want to make money by selling goods and services to consumers, and if their goods and services are shoddy, they’ll be a onehit wonder, and they’ll be gone.

“That’s why the Minister [Kate Dearden, Parliamentary Under-Secretary of State for Employment Rights and Consumer Protection] has ‘consumer protection’ in her title; it’s been very clearly delegated to her that she has got to be the Government’s champion for consumers. And while we’ve got an agenda that looks at ‘regulatory burdens’ and business growth, that should not be at the expense of the consumer.

“Is it a fine line? Yes. Is it something I’m willing to walk along and fight for?

Yes. Have we got really strong allies in the department and elsewhere? Yes.”

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The progress paradox Technology has, I suggest, created something of a paradox for consumer protection; on the one hand, it has given consumers a platform from which they can vent their frustrations and engage in a dialogue with businesses.

On the other, it has made it easier for businesses to circumvent their responsibilities and keep customers at a distance by concealing their contact details and using things like AI chatbots as complaint-handling mechanisms. Is it an analysis that Adcock recognises?

“I was thinking about this recently,” she says. “I don’t complain on social media – if I’ve got a problem with a company, I will first and foremost spend ages trying to find the contact details. I purchased something just this morning online which had a discount. It was in my basket and when I logged in, the discount disappeared. I’d already hit ‘pay’, so I tried to go straight to the contact details, and couldn’t find them.

“What I really want to do is help consumers direct their voice. I want to ensure that if they’re doing all the right things, we are doing whatever we can to reduce the vulnerabilities. That means looking at online choice architecture, drip pricing and fake reviews, things we’ve done just recently [see pages 5 and 24]. My team are doing a research project on online choice architecture at the moment. We will do whatever we can to close those loopholes down, and we will do that through regulation and things like Consumer Codes.

“It doesn’t matter to a consumer whether they’re contacting Citizens Advice for information and advice, or ensure information is passed to their local Trading Standards service – at the end of it, all they want is redress and to make sure their voice is heard. So what are the sensible steps for them to take, and how can we make it so the handoffs are invisible, that they are treated with respect throughout, and that they are empowered to make decisions themselves? Ultimately, it all needs to be channeled in the right direction.”

As well as muddying the waters for consumers seeking redress, technology has also enabled online marketplaces to shirk their obligations, using disingenuous arguments about ‘third-party sellers’ to flood the market with substandard goods and undercut legitimate traders, meanwhile reaping extraordinary profits and cultivating a ‘family-friendly’ brand image. Many ‘ordinary consumers’ are, I observe, surprised when they learn about the lack of due diligence companies like Amazon apply to the products sold on their platforms (see page 40). While the Product Regulation and Metrology Act is designed, in part, to clamp down on such behaviours, there has yet to be any major enforcement action taken against online marketplaces – meanwhile the problems confronting consumers and bodies like Trading Standards or the fire services persist with deadly results. Does Adcock agree with that assessment?

“You’re absolutely right, she says.

“If I’m buying something out of the back of someone’s car, for example, I know I’m participating in shady business and

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‘Empowering consumers’ is vital to economic growth, Adcock believes

probably something illegal. If I’m buying off Amazon, I’m not in that space. I’m buying from a reputable company.

“I think there’s this two-pronged attack where we’ve got to get the marketplaces in particular to up their game in terms of their protections and the information they offer,” Adcock adds. “Price is always going to be a marker of quality, but in terms of the safety aspects of a particular product, all of that information needs to be available in an accessible form. As we are moving into this digital space that changes the way we buy goods, it also changes the things we have to think about when we’re buying those goods. Online shopping is convenient, it’s fantastic. But it’s got a downside that we need to make consumers more aware of.

“I’ve been talking to the Office for Product Safety and Standards [OPSS] about the level of information that should be available to consumers and, of course, they’re really keen on the materials used and the safety features of goods and services. We’re hand-in-hand about how we can do that from a regulation point of view, and with the online platforms in particular.”

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Less talk, more action Sticking with the theme of collaboration, one of Adcock’s other main priorities is ensuring that the Consumer Protection Partnership (CPP) is functioning as effectively as possible. The CPP, an alliance of consumer protection bodies including Trading Standards, Citizens Advice, the Financial Conduct Authority (FCA), the CMA and others, exists to tackle consumer protection threats, allocating expertise and resources accordingly. So what does Adcock think isn’t currently working – or could be working better?

“I met the CPP in its entirety for the first time in September and I was genuinely blown away by the commitment and dedication of all of the organisations involved,” she says. “The benefit of a well-organised CPP is the sharing of intelligence and deciding collectively who is best placed to do X versus Y. The CPP felt to me a bit like a place where people were coming to talk, and what I want is a bit more action – not to say no-one was taking action, but I think if we share that action a bit more broadly, we will become more than the sum of our parts.

“From a Government perspective, it has been really clear what our priorities are. We are looking for the most egregious harms that you can find. For CTSI, we want you to really focus on supporting businesses to understand what is right and proper behaviour; for NTS, it’s about taking forward those cases that cover more than one or two Trading Standards services; for the Citizens Advice consumer service, it’s about gathering intelligence and ensuring that everyone knows what’s going on.

“I did think my meeting with the CPP was really inspiring though. I’ve been a civil servant all my career – I genuinely love public service – and to see all these other organisations having exactly the same mindset and wanting to work together is very moving,” she adds.

The issue of funding is unavoidable in any conversation about Trading Standards, and has been for many years.

So how does Adcock perceive her role, and that of the DBT, in helping to alleviate

some of the pressures the service is under? “I am quite big on speaking the truth,” she says. “There's no way to fix the very unfunded local Trading Standards services. We need to be honest about what’s available. There's not enough money in the system. There’s no magical money tree. So how can we make the best use of the intelligence, the resources, the expertise we’ve got?

“Trading Standards teams already have more than 260 obligations in law to enforce; that is insanity. I think consumer protection is vitally important but they’ve also got things like getting illegal vapes and tobacco off the streets, and ensuring that the local restaurant is not serving poisonous food. I am not going to sit here and tell a local authority Trading Standards official that they should be prioritising my thing over something else – they are the ones with the expertise and the knowledge in the local area.

“But if I can at least make your worry list shorter, I would count that as a ‘win’.

If I could make it so that there are things that you don’t even have to worry about or enforce because we found an alternative way to do it, I think that’s a great outcome.

“We’ve got to find an alternative way to fill an enforcement gap that isn’t about putting any blame on Trading Standards.

I recognise as a Government official when we are looking at regulation it’s quite easy to go, ‘Okay, we’ll just add that to the local enforcement agenda’; whereas actually it might need more people, money, resources, expertise or training to get it out the door.”

Finally, I ask about the bigger picture: how does Adcock perceive the links between consumer protection and the fundamental values of a fairer, safer, healthier society? “It’s all connected,” she says. “I don’t think we do enough to promote what the outcome of that work looks like though – so if NTS, for example, has taken a national case and an injustice was put right, we need to do more to promote that. And we need to get into the hearts and minds of consumers where they recognise that it’s not about complaining for complaining’s sake; it’s complaining for the benefits of society as a whole.” l

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Legislation

By Pauline Lloyd Roberts

Pauline Lloyd Roberts Operation Jigsaw West Midlands Regional Lead

Joined-up thinking Trading Standards teams share many of the same priorities and goals as their Housing colleagues, making them perfect partners in enforcing the new Renters’ Rights Act The Renters’ Rights Act is a landmark piece of legislation that strengthens existing protections for tenants, improves standards in the private rented sector and, ultimately, holds landlords to account. But while the legislation is powerful, on its own it will not change lives. It takes knowledge, skilled investigation and enforcement to ensure that rights on paper become a reality.

To an outsider, Trading Standards and Housing teams seem to operate in different worlds. Among many other things, one focuses on fair trading, product safety and consumer rights, the other on tenancy law and property conditions. Yet they are similar. Both protect the public, safeguard the vulnerable, and ensure businesses and individuals operate within the law.

Housing teams are used to working closely with residents, offering support, advice and reassurance to help them navigate their rights and responsibilities.

Their approach is often trust-based, encouraging compliance through dialogue.

By contrast, Trading Standards Officers usually engage with consumers in the context of complaints or enforcement action, using a more investigative focus to gather evidence and analyse intelligence to prioritise workloads. Trading Standards Officers therefore have an invaluable toolkit, comprising:

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• the collection and sharing of intelligence; • investigative and interviewing skills; • experience in building evidence and producing robust case files; • expertise in encouraging compliance, and if necessary bringing a prosecution; and • partnership working, from collaborating with police to liaising with other regulatory teams and national regulators.

These are precisely the skills that Housing teams will need to draw on if the Renters’ Rights Act is to be effective.

Why partnership matters Housing teams will face challenges under the new Act when it comes to identifying unlawful practices, gathering admissible evidence and taking proportionate action against landlords who flout the rules.

Resource constraints, along with possibly limited enforcement experience, could mean that cases stall before they reach a tribunal or court. By working alongside Housing colleagues, Trading Standards teams can support them to: • develop intelligence-led enforcement strategies across the sector that make best use of resources, enabling them to target the worst offenders;

• develop evidence-gathering skills; and • conduct effective interviews to enable them to prepare high-quality case files.

The result will be better protection for vulnerable tenants and greater confidence in the private rented sector.

CASE STUDY:

Collaboration in action

Some housing teams have already taken the step to engage fully with their colleagues in Trading Standards. That has been demonstrated in Wolverhampton, where a Trading Standards Officer worked directly within the council’s Housing team.

The Officer led an investigation into a landlord who had repeatedly failed to meet legal standards, leaving tenants in unsafe and unacceptable conditions. By combining Housing expertise with Trading Standards’ investigatory and evidence-gathering skills, the case was built and presented with the rigour necessary for bringing a prosecution.

The result was a successful action against the landlord, not only providing justice for the tenants involved but also sending a clear deterrent message across the private rented sector. Importantly, it also showed how using Trading Standards expertise within a Housing team can work.

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OVERVIEW:

The Renters’ Rights Act will:

Abolish section 21 evictions and move to a simpler tenancy structure where all assured tenancies are periodic. l Ensure possession grounds are fair to both parties and introduce new safeguards for tenants. l Ensure tenants are able to appeal excessive above-market rent increases. l Introduce a new Private Rented Sector Landlord Ombudsman. l Create a Private Rented Sector Database. l Give tenants strengthened rights to request a pet in the property. l Apply the Decent Homes Standard to the private rented sector. l Apply ‘Awaab’s Law’ to the sector so landlords must take action to make homes safe. l Make it illegal for landlords and agents to discriminate against tenants in receipt of benefits or with children. l Prohibit landlords and agents from asking for or accepting offers above the advertised rent. l Strengthen enforcement with expanded civil penalties, new investigatory powers and a requirement for local authorities to report on enforcement activity. l Strengthen rent repayment orders. l

The local government maze One of the key barriers to closer working is the way responsibilities are divided.

Trading Standards is delivered at a county or unitary authority level, while Housing enforcement is generally the responsibility of district and borough councils. That divide can risk leaving gaps in enforcement, with neither side having sufficient resources to act.

But this challenge can be overcome.

There are already successful models of cross-authority collaboration in other areas, such as food safety, scams teams and regional partnerships. The Renters’ Rights Act provides a fresh opportunity to build similar models.

A practical approach could include: • formal joint working protocols between counties/unitaries and their districts, setting out clear referral and support pathways; • shared training and joint investigations; • sharing intelligence so information about rogue landlords is captured and acted upon in a coordinated way; and • secondments embedding Trading Standards Officers within Housing enforcement teams for specific projects.

If adopted, these ideas could actively strengthen working relationships across local government.

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Our intelligence analysis already shows that Trading Standards teams are targeting the same problem areas as Housing officers. For example, shops selling vapes and tobacco under the counter often have overcrowded or unsafe rental premises upstairs, and occasionally the tenant is forced to store the illegal goods as part of the rental agreement. The landlords and tenants are often involved in organised criminal activity such as modern slavery, and the police regularly find cannabis grows connected to these properties (see page 12).

The Renters’ Rights Act provides an opportunity for Trading Standards teams to improve intelligence-sharing and collaboration, but also the provisions of the Act will assist our investigations. A new Private Rented Sector Database will hold all landlord information and a new Ombudsman will be created to handle disputes with landlords, in addition to the current requirements for sales, letting and property management agents to belong to an approved redress scheme.

The Decent Homes Standard will require all rented properties to reach a level of good repair, and this will mean that builders and other traders will be required to complete rectification work after the Housing team’s inspection.

Trading Standards can put increased pressure on rogue traders by promoting trusted trader schemes and encouraging landlords to check traders’ credentials.

The Renters’ Rights Act is not just another piece of legislation; it is an opportunity to raise standards in the private rented sector, which is growing by the day. It is also a chance for Trading Standards to demonstrate the breadth and relevance of the profession in tackling one of today’s largest social issues. l Further information Operation Jigsaw is a Governmentfunded initiative to help local authorities prepare for and enforce the Renters’ Rights Act. For more information, visit khub.net/group/jigsaw/group-home

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Neurodiversity

By Richard Young

TRAIN OF THOUGHT Why accepting, understanding and harnessing the power of neurodiversity could be an effective way for Trading Standards to bolster its resilience According to the Institute for Workplace Studies, one in seven people in the UK are neurodivergent, meaning they have one or more conditions such as attention deficit hyperactivity disorder (ADHD), autism, dyslexia, dyscalculia or dyspraxia. And while awareness of neurodiversity has improved in recent years, partly because of better diagnostic methods, many neurodiverse people still face significant hurdles to acceptance and progression in the workplace. The Government-commissioned Buckland Review of Autism Employment for example, which was published in February 2024, identified ‘a wide range of potential barriers to work for autistic people,’ including ‘poor preparation by employers, unfair hiring practices, unclear processes and outdated attitudes’.

Lizzy Beck, a Trading Standards Officer in the West of England, has first-hand experience of many of those barriers.

When she started her career 25 years ago, she says, “the majority of adults did not know whether they had any kind of autism, ADHD or even dyslexia”. Beck was diagnosed with the latter when she was at school, but remained unaware that she had any other conditions until she entered the profession, having graduated from university and gained the postgraduate

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Diploma in Trading Standards (DTS) in the early 2000s.

“My experience of being neurodiverse firstly has been about understanding what’s ‘wrong’ with me,” she says. After a particularly trying period early in her career, one of Beck’s managers – “she was like a work mum to me” – took her aside and encouraged her to get assessed for suspected autism. “She took an interest in me, she knew that there was something not quite right and we talked about it a lot,” Beck says. “I found the straightforward, logical side of the job – the weights and measures – was fine.

But being given open-ended work, like long-term complex investigations, was a struggle. Because I’ve since learned so much about ADHD, I now understand that my brain likes lots and lots of little rewards, and that’s something you don’t get with a long-term investigation.

“I’ve also had a lot of unconscious bias towards me,” she adds. “To start with, a DTS examiner said to me that dyslexics can’t be Trading Standards Officers – they can’t possibly do the job. That person marked my paper and failed me twice. I passed on the third attempt by one percent.

“When I went into my first job, it was a very male-dominated profession. I had three challenges: being young, being

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female, and also having autism and ADHD, which at the time I didn’t know I had. Office politics was difficult – I would upset people and not have a clue why.

My intentions were always good but I found that people would put words in my mouth or they would assume that I meant something different from what I actually said. It took a long time for people to actually understand me.”

In at the deep end Connor Lamb is a relatively recent recruit to the Trading Standards profession. He is currently completing a Level 6 Trading Standards apprenticeship at Newcastle City Council, having already finished the Level 4 Regulatory Compliance Officer (RCO) apprenticeship. And while he says he has not faced discrimination in the workplace as a result of his neurodivergence, he certainly finds himself being drawn to certain aspects of the Trading Standards workload more than others.

“I’ve got a very, very keen eye for tiny details,” he says. “I feel like that’s what you need when it comes to investigations or prosecutions. When I do inspections of a premises, the majority of the time I notice things others might miss – not due to incompetence, but just because I’ve got a keen eye for the little things.

“I feel like it works to my strengths.

I don’t mean to be big-headed, but it’s different to anything that my department has dealt with before,” he adds.

Lamb was working in the Licensing team at Newcastle City Council when he was recommended for a Trading Standards apprenticeship provided by the Credit Services Association (CSA).

“I didn’t know I had any neurodiversity conditions, at least on paper, until I started the apprenticeship,” Lamb says.

“I always knew I was a bit different. I got quite good marks in my GCSEs and

www.JournalofTradingStandards.co.uk

A-Levels, but I didn’t find it as easy as my classmates, so I always had to work a little bit harder to get where I wanted to be.”

“It wasn’t until I started the apprenticeship that I did a neurodiversity screener, because [Zoe Dellow, CSA Learning & Development Operations Manager] said she noticed similarities between me and someone that had been diagnosed. I went to the doctors and that’s how I got tested and diagnosed eventually.”

According to Dellow herself, “From a training and learning perspective, it’s important to get to know the person and assess how their brain works so you can tap into their strengths and development areas. A lot of people worry about the stigma of owning up to having a learning need, and we see that a lot when we’re doing the Cognassist neuroscreener that we do with every new learner.”

The Cognassist platform used by the CSA ‘Empower[s] every learner with cognitively personalised support [...] enabling tailored strategies that improve engagement, retention and achievement,’ according to the company’s website.

“It’s a bit like a brain gym activity,” says Dellow. “You’ve got a big body of text to read and answer questions about, so there’s a bit of a memory activity. You’ll get given a diagram, then you’ll have to match it up with something else quite quickly. You get quick mental maths questions. There is a literacy test where it checks on whether you know whether a word is spelled correctly and if it’s actually an English word.

“It assesses nine areas of brain functionality: literacy, verbal reasoning, reading and decoding, numeracy, executive function, visual perception, visual information processing and speed, verbal memory and non-verbal memory.”

Once a learner has completed the neuroscreening, a recommendation is made as to whether they would benefit

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Neurodiversity

By Richard Young

“When I went into my first job, I had three challenges: being young, being female, and having autism and ADHD” Lizzy Beck from additional free support. “We’ll check in with them every couple of months to see whether those adjustments are still suitable,” Dellow adds. “We’re all from a teaching background; understanding how someone learns is massively important.”

Babington also provides Trading Standards training and apprenticeships, and like the CSA, it is geared up to cater for disparate learning needs. According to the company’s Specialist Trainer for Regulatory Compliance, Ian Simpson, “At the stage of enrolment, we ask questions about any learning needs the learner has – sometimes they might have a diagnosis from school or college – and we explore that with them.

“It’s a safe place to come to,” he adds. “If you have a need and you want further support, we can offer it. It’s a conversation where we’re not throwing it at people. Some people may say, ‘I have autism or ADHD, but I have my own strategies and I’m OK, and I’ll get on with it’. Others might say, ‘I would value that support and let’s explore it’.

“We want to encourage learners who may have a neurodiverse condition to please come forward. We will support you.

We want to open up career opportunities that may have been blocked for people who have been in Trading Standards a long time, or may be new to Trading Standards and exploring what the job is about and what course they need to take.”

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Fundamentally, Simpson says, it’s crucial that the Trading Standards workforce “mirrors the public at large, and works with people in business and elsewhere who may also be neurodiverse”.

“Developing our apprentices is about treating them all as individuals, recognising their differences and building on and celebrating the strengths they all have. Sometimes neurodiversity can be about having a very active mind, which may come across as being unable to concentrate. But what about the energy?

What about the ideas that can come from a different approach to thinking? This is not something to ‘solve’. It is something to celebrate and work with.”

Think different Lizzy Beck believes that whatever stage a neurodivergent person is at in their career, support and understanding are key. “One of the things that is really important is for managers and teams to be very committed to supporting an ADHD or neurodiverse person, not to belittle them, not to be anything other than accepting of them as people,” she says.

For neurodivergent people, Beck adds, “It is better to be open and honest with your managers, because the most important thing in any relationship is trust and respect. You cannot have that if you do not tell the full truth, especially to those who are

“I feel like I’ve been given a lot of opportunities to do what I do best” Connor Lamb

looking after you. Try to have some insights into the difficulties that you specifically have because these conditions are not the same for each person. The relationship between the individual and their manager is absolutely key and if management are not committed to supporting all of their staff, including the neurodiverse ones, then that wouldn’t be a good place to be.

“We’re not going to fit into their box – that’s not going to happen because we just can’t,” Beck says. “The problem comes, I think, less within the Trading Standards profession and more within individual authorities where we’re based.

The profession itself has improved over 25 years in accepting the challenges neurodiversity brings, but I think it is yet to harness the full potential of what we have.

“Trading Standards as a whole can be very much, ‘Here’s a rule, you must abide by it’. Neurodiverse people know that life isn’t like that. They are far more likely to give a very different view on a situation or an investigation. For example, one Officer will say, ‘Well, this trader has broken chapter and verse of this, this and this’, and I’ll go, ‘Yeah, OK, but there’s all this other stuff that’s going on. What is a more appropriate sanction? Do they actually need sanctions? Is it actually more a question of offering advice?’

“Very often with these situations, it’s six of one, half a dozen of the other. The trader is not always wrong and the consumer is not always right. Part of our job is to work that out sometimes, and neurodiverse people are actually very good at doing that. I may not pick up on the emotions of people around me immediately, but I can analyse very, very well.”

That ability to hone in on things others might miss can be extremely useful in areas like product safety, Beck believes.

“When I deal with a product safety complaint, I have a mental image of what the product is and how it works. That is common with autistic people; we don’t think in words, we think in pictures and we’re able to manipulate an object in our minds, move it around, turn it inside-out.

That is a really, really useful skill.”

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“This is not something to ‘solve’. It is something to celebrate and work with” Ian Simpson As well as often having sharpened practical skills, some neurodivergent people are also equipped with heightened ‘soft skills’ which are invaluable in everyday Trading Standards work. “Autistic people know what it’s like to be different,” Beck says. “They know what it’s like to get things wrong, and they know how painful that is. So when it comes to dealing with victims of crime, we find it very easy to put ourselves mentally in that position. We can be very empathetic. It’s not true to say that autistic people don’t have empathy.

Actually, we often have far too much.

“I’ve found that the profession in general can sometimes be so rigid in their views, and that means they don’t accept others’ differences very well either. I try to look at the whole person and the whole situation. A trader might have fallen foul of various regulations. But why did that happen? When you actually delve into that, you usually find somebody who’s struggling for whatever reason. And so you have to think about your actions because they will affect this person for the rest of their life.”

The personal touch Connor Lamb also feels he brings an extra dimension to the more peoplefacing aspects of his role. “I’m interacting with businesses and members of the public, doing a lot of face-to-face work,

Winter 2026

and it seems to work,” he says. “People like seeing the faces of the people who regulate the laws that are in place.

“If I’m helping a business with some advice, I’ll make sure it’s exactly what they need rather than just a blanket answer.

With investigations and prosecutions, the files that I put forward for the courts are jam-packed because I don’t want to miss anything out, both from our side and the business’s point of view.

“I think the work I do has implemented a few different techniques in the way we work,” he adds. “I feel like I’ve been given a lot of opportunities to do what I do best.”

Like Beck, Lamb believes that a rigid adherence to process can sometimes be a hindrance. “I feel like a lot of local authorities, not just in Trading Standards, are stuck in the old ways of doing things,” he says. “But things have to move on for the new wave of candidates coming in.”

For neurodiverse entrants to the Trading Standards profession, Lamb says, “the piece of advice I would give to anyone is ‘just go for it’. You might be stressed for however long the course is, but it’s all worth it at the end. And if you truly want to give back something to the community, it’s a perfect role to be in. I love Newcastle more than anything. It’s where I grew up, it’s where I was born and bred. And making that little bit of

“It’s important to get to know the person and assess how their brain works” Zoe Dellow

change in the city is something that I take massive pride in.”

Beck also feels that Trading Standards can be a great career choice for neurodivergent people, and that the profession itself can reap dividends from having a neurodiverse workforce. But, she cautions, everyone’s situation is different, and finding the best pathway for an individual “depends upon the person and where they are in their career”.

“For a lot of autistic people, social anxiety is a major problem so working from home might be the only solution.

I’m the total opposite – I need to be in an office because if I stay at home, I start to lose my confidence with dealing with people and it then becomes harder and harder to leave the house. If you’re feeling a bit low one day, just somebody smiling at you in the kitchen can make you feel a little bit better.

“I’m not the same person I was 25 years ago when I started. I’ve learned skills and I’ve gained knowledge and experience. Things that I struggled with when I first started, I don’t struggle with any more.

“Americans don’t say ‘reasonable adjustments’ – they say ‘accommodations’.

With neurodiversity, it’s accommodations that are needed rather than adjustments because actually within the role itself, there isn’t anything that a neurodiverse person couldn’t do. In many ways, it’s a very good job for a neurodiverse person.”

Returning to the theme of empathy, Beck concludes, “Anybody can be scammed in a vulnerable moment. It’s very easy to be misled. It’s just about learning to be circumspect, looking for evidence, learning how to navigate the world around you. You do that at the beginning of your career, and you learn from life as well. When you’re looking at a job in Trading Standards, you take every aspect of your life to it.

“It’s not just a job, it’s a calling. I think that there’s something in you that wants to put things right for others – and as long as you’ve always got that, then you’ll be fine.” ●

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Apprenticeships

By Richard Young

Send in the reinforcements

Funding for Trading Standards apprentices has given the profession a much-needed boost. We hear from London, one of the parts of the country welcoming new colleagues “Every single day there’s something different; since starting I’ve been to court a few times, I’ve been on visits to businesses, seizures, investigations.

I come in every day not knowing what I’m going to be up to – that’s a highlight.” So says Zainab Ali, one of 11 recently recruited Trading Standards apprentices assigned to London Trading Standards (LTS) as part of a £10m Department of Health and Social Care (DHSC) investment in tobacco and vape enforcement in England.

Ali is completing her apprenticeship at Barking & Dagenham, one of the 33 authorities within the LTS network.

According to Stuart Radnedge, Regional Coordinator at LTS, “there was quite the clamour for them, and we had recruited everyone by the end of September. They’re spread around London, and one of the apprentices is shared between two boroughs – which is quite a revolutionary approach.”

The DHSC’s funding was welcomed by CTSI, and came about in large part thanks to the Institute’s persistent lobbying for additional Trading Standards resources.

It will bolster local enforcement capacity, bringing approximately 80 apprentice officers into the profession in time for the introduction of the landmark Tobacco and Vapes Bill which, at the time of writing, was making its way through the House of Lords ahead of its likely phased implementation from 2026 onwards.

The Autumn Budget also committed

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the Government to ‘providing additional funding to enhance Trading Standards capabilities and fund an uplift of at least 45 additional law enforcement officers’.

While that announcement marks a step in the right direction, Trading Standards still faces an uphill struggle, with the Local Government Association (LGA) noting that ‘ongoing budget constraints have impacted councils’ enforcement abilities [...] compounded by regulatory services’ ageing workforce and a lack of new entrants’. In its major ‘Trading Standards resources and activities’ report, Which? also drew attention to ‘extreme examples of Trading Standards teams of just one or two qualified staff members serving hundreds of thousands of people, particularly in populous areas like London boroughs’.

“I want to make a career of it. I’m really interested in metrology”

Rachel Marsh

Embracing opportunities It is hoped therefore that the recruitment of the new apprentices in London and elsewhere in the country will give local enforcement something of a shot in the arm, infusing the profession with new blood and boosting the workforce.

And, while the limited number of apprenticeships on offer means that things won’t change overnight, the recruits themselves certainly have the appetite to help turn things around.

A former prisoner custody officer, Rachel Marsh is another of the new LTS apprentices. She has been assigned to Kingston & Sutton Trading Standards, where she says she is keen to embrace the opportunity to learn new things. “I applied for the apprenticeship because I thought Trading Standards sounded interesting,” she says. “I hadn’t realised before I joined the depth and breadth of Trading Standards work.”

Although she only started in September, Marsh says she has hit the ground running, accompanying colleagues on inspections and raids that

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Journal of Trading Standards

interested in metrology, as well as the product safety side of things.”

Tackling illicit vapes is top of the enforcement agenda

have yielded “huge quantities of illicit tobacco and other goods”. In one recent inspection of local shops, she says, “we seized more than 60 fake Labubus”.

The seizure of the counterfeit dolls – which have quickly become a less-than-welcome addition to the already overflowing Trading Standards workload – highlights that ‘routine’ high street enforcement work isn’t neatly partitioned, and that businesses selling illicit tobacco often have other nefarious goods on offer. So while Marsh’s apprenticeship is being funded from the DHSC’s illicit tobacco pot, she says she is also keen to find out what else the profession has to offer. “I want to make a career of it,” she says. “I’m really

“Every single day there’s something different....Everyone’s made me feel welcome”

Zainab Ali Winter 2026

Access all areas The LTS apprentices are undergoing Level 6 Trading Standards Professional Apprenticeship (Tobacco & Vapes legislation) training, provided by the Credit Services Association (CSA).

In addition to the mandatory tobacco and vapes aspects of the qualification, apprentices also have the opportunity to tailor the training to their individual interests, with modules on food standards, animal feed, animal health and welfare, weights and measures, and product safety on offer.

“In order to become a well-rounded and developed Officer, the apprentices need to focus on the whole job, although the course does focus more on the tobacco and vapes element,” Radnedge explains. “This new course is a traditional four-year Level 6 course condensed into 30-31 months. They will have completed the learning by month 25, then they have five or six months for the end-point assessment.”

Ali also sees the apprenticeship as the beginning of a journey. While she still has some way to go yet – like the other apprentices, she isn’t due to complete her training until 2028 – she says, “I would like to explore beyond tobacco and vapes, and see how everything else works within Trading Standards.”

So far, Ali says, her experiences of the profession have been positive. Aside from supportive colleagues (“Everyone’s made me feel welcome, whether in or out of the office”), she says she has been pleasantly surprised by the response from businesses themselves.

“Initially I thought that business owners and employees would be a bit more aggressive. So far I’ve only really explored around the town centre where shops are probably more compliant, but they’re very happy for you to come in and do your routine inspections.

I’ve started to become so familiar with certain spaces that it’s actually quite nice to look around.

“Apprentices and apprenticeships are the future”

Stuart Radnedge “Obviously if they’re not compliant then it’s a different story, but I haven’t come across anyone who’s been particularly violent or agitated – it’s more like they understand if they’re not compliant that they’ve done something wrong,” she adds.

Radnedge is enthusiastic about the possibilities offered by apprenticeships. “Apprentices and apprenticeships are the future,” he says. “They let you earn while you learn, and if regions can get cohorts together to go through the course at the same time, you can inject that ‘family’ feeling that Officers used to have from the way training and entry into the profession used to be delivered.

“That can only be a good thing.

We spend more time with our work families than our actual families, so building solid connections will ensure retention and, most importantly, fulfilment and happiness.”

It is a sentiment echoed by CTSI Chief Executive John Herriman, who is now calling for apprenticeship funding to be made available beyond England. “This much-needed investment for Trading Standards services will strengthen our ability to protect public health and support businesses in complying with current and future tobacco and vaping regulations,” he said. “CTSI now would welcome similar investment for colleagues in Wales, Scotland and Northern Ireland.” ●

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Hero Awards

By Richard Young

CTSI Chief Executive John Herriman presents the Business Award to the CTPA team

Rightful recognition Colleagues, peers, MPs and a former Olympic athlete turned out to celebrate Trading Standards’ best and brightest The 2025 CTSI Hero Awards ceremony, which took place in the Houses of Parliament on 2 December, was a chance for the consumer protection world to come together and celebrate those who have gone the extra mile to make the UK a fairer and safer place over the past twelve months.

Olympian Derek Redmond was the host for the evening, welcoming on stage a roll call of worthy winners, along with equally deserving highly commended nominees in many of the awards categories.

Highlights included the team from Rochdale Trading Standards being recognised for their work to tackle ‘ghost’ number plates (see page 12); Dudley Trading Standards, whose Operation Clearance also tackled the scourge of organised crime; Southwark Trading Standards, whose Operation Bantam removed meat that was unfit for human consumption from the food chain; and Hertfordshire Trading Standards’ Sue Shanahan, whose Operation Bronze secured more than £800,000 in refunds for victims of scams.

This year’s Institute’s Hero was named as Chris Armstrong, along with his late wife, Carol. The pair played pivotal roles in shaping modern Trading Standards for more than 30 years and were rightly praised for ‘their long-standing service, dedication and influence, which have created a legacy that will endure throughout the profession for decades to come’ (see more on page 36).

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The Southwark Trading Standards team collect the Megan Lee Award

Category

Winner

Intellectual Property Award

Rochdale Trading Standards Highly commended: Bobby Cranie, Consumer Protection Dogs

Diversity & Inclusion Award

Bolton Deaf Society and Deafway Special recognition: Nikki Pasek MBE

Best Product Safety Initiative

Claire Allen Highly commended: Camden Trading Standards

Outstanding Trading Standards Project

Operation Clearance, Dudley Trading Standards Highly commended: Mohammed Tariq, Birmingham City Council Trading Standards Highly commended: Swansea Trading Standards

CTSI Brian Smith Hero Award

Sue Shanahan, Hertfordshire Trading Standards Highly commended: Elaine Mount, Kent Trading Standards

Megan Lee Award

Southwark Trading Standards Food Safety Team

Business Award

The Cosmetic, Toiletry and Perfumery Association (CTPA) Highly commended: Andrew Johnson, 5 Paper Buildings

Special Recognition Award

Sheila Duffy, Action on Smoking and Health (ASH) Scotland

The Institute’s Heroes 2025

Chris Armstrong and his late wife Carol Armstrong Highly commended: Naseem Shamas, Birmingham Trading Standards

The Motor Ombudsman Star Garage Award

Napoleon Garage, Bradford

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Journal of Trading Standards

The Dudley Trading Standards team collect the Outstanding Trading Standards Project Award from Louise Baxter MBE (left)

Baggy Shanker MP (left) and UKAS’s Richard Collin present the Best Product Safety Initiative Award to Claire Allen

Awards host Derek Redmond

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Birmingham Trading Standards’ Mohammed Tariq (centre) and Camden Trading Standards were highly commended in their categories

5 Paper Buildings’ Andrew Johnson (right) with John Herriman

Ron Gainsford OBE (left) presents the Institute’s Hero Award to Chris Armstrong

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CPPD

By Steph Young

Steph Young CTSI Joint Lead Officer for Animal Health & Welfare

CPPD Module 29:

Animal Penalty Notices A new enforcement tool for Trading Standards Officers in England can encourage compliance with animal welfare laws and help local authorities recover some of their costs The recently introduced Animals (Penalty Notices) (England) Regulations 2023 allow for certain animal welfare offences to be dealt with out of court via the payment of a penalty. The regulations, which were brought in as secondary legislation to the Animals (Penalty Notices) Act 2022, are designed to promote compliance with animal health and welfare rules while obviating the need for lengthy and expensive court proceedings.

Animal Penalty Notices (APNs) complement the existing regulatory toolkit of advice and guidance, warning letters and statutory notices, movement restrictions, and cautions and prosecutions.

APNs are not intended either for serious animal welfare offences or for minor breaches where advice and guidance in the first instance would probably be sufficient. Furthermore, they are not suitable for all offences; for example, section 9 of the Animal Welfare Act 2006 (which requires a person or business to take all reasonable steps to meet an animal’s welfare needs) is in scope, whereas section 4 of the Act

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(which makes it an offence to cause an animal unnecessary suffering) is not. Additionally, not all legislation is included. For example, APNs are not applicable to the Cattle Identification Regulations, which are due to be updated.

The maximum penalty that can be charged per offence is £5,000, which the recipient of an APN must pay within 28 days of the date of issue or face prosecution. The amount owed can be reduced by 50% if it is paid within 14 days of the serving of the APN. To issue an APN, an enforcement authority must be satisfied beyond reasonable doubt that an offence has been committed (note that APNs only apply to offences committed in England). Enforcers do not have to give due consideration to the public interest test, but should be mindful of case law relating to time limits.

APNs enable local authorities to recoup costs of investigations, with a requirement for money surplus to this to be returned to central funds. There is also no ring-fencing or conditions of spend applied to the money that has been retained to cover costs.

Issuing and calculating APNs When deciding whether to issue an APN, consideration must be given to the seriousness of the offence and the number of offences committed. An APN should be issued for each individual offence, and more than one may be issued to the same person simultaneously.

The means by which an APN is issued is at the discretion of the enforcement authority. The issuing of an APN is a civil procedure; however, the burden of proof is to the criminal standard. Failure to pay an APN is not a civil sanction and local authorities cannot pursue non-payment of the penalty – but they should seek to prosecute for the animal welfare offences as a result. The local authority may decide to withdraw an APN if appropriate.

Defra’s APN calculator has been developed to help enforcement authorities determine the appropriate amount payable (see link below). Enforcement authorities do not have to use the calculator but it is recommended that they do so to ensure consistency and transparency.

Enforcement authorities can keep any money to cover their costs as a result

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CPPD MODULE 29 ANIMAL PENALTY NOTICES Submit your answers at tradingstandards.uk/cppdtest 1. How long does the recipient of an APN have to pay before they face prosecution? a) 10 days b) 28 days c) 60 days 2. How much can an APN be reduced by if it is paid within 14 days? a) 10% b) 25% c) 50%

of investigating an offence and for the issuing of an APN, but any money surplus to this must be returned to Defra to pay into the consolidated fund.

Transactions can be made at six points during the financial year and it is not necessary to inform Defra each time an APN has been issued. However, enforcement authorities are required to send Defra an annual return with information on all the penalty notices they have issued within a financial year.

If the cost of investigating an offence and the issuing of an APN exceeds the calculation, no money needs to be returned to Defra and the consolidated fund.

Where an APN is issued (and has not been withdrawn), no proceedings may be instituted for the offence before the end of the relevant period, and the recipient may not be convicted of the offence if they pay the penalty notice.

There is no appeal process to the issuing of an APN. Likewise, there is no requirement to issue a notice of intent that an APN is to be served and no appeal allowing the value to be challenged.

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Offenders should be reminded that an APN is, in effect, an offer to discharge liability from prosecution – and if a person does not wish to pay it, the outcome is prosecution. It should also be noted that although more than one APN can be issued to the same person, if they have committed several offences, or if they continue to offend, it is possible that prosecution is a more appropriate option. ● Further resources Defra has provided free training on APNs to local authorities and has made guidance and template notices available on the Local Government Animal Health & Welfare Group section of khub.net.

The full statutory guidance and Defra’s APN calculator can be found at: www.gov.uk/government/publications/ penalty-notices-for-animal-health-andwelfare-offences CTSI and Defra have produced a video training session which is available here: https://youtu.be/Razm_nwteEU

3. Does section 9 of the Animal Welfare Act 2006 fall within the scope of the APN regulations? a) Yes b) No 4. What is the maximum amount that can be charged under an APN? a) £1,500 b) £3,000 c) £5,000 5. Are sums recovered by local authorities through APNs ring-fenced? a) Yes b) No 6. Is the issuing of an APN: a) a civil procedure? b) a criminal procedure?

7. Can the issuing of an APN be appealed? a) Yes b) No 8. Can a person still be convicted of an offence if they have paid an APN which covers it? a) Yes b) No Applicants who complete the module will be given a certificate.

The test must be taken by 31 May 2026. If you have any questions, please email training@tsi.org.uk

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Hallmarking

By Robert Grice

By Robert Grice CTSI Fellow

Flower power

Above Delegates at the Sheffield Assay Office in September 2025 Below left The Sheffield Assay Office’s Tudor Rose emblem

The hallmarking enforcement initiative Operation Stamping it Out has proved to be worth its weight in gold. Now a new project, Operation Tudor Rose, hopes to replicate that success

enforcement at the CTSI Conference in June 2025. In November the winners attended Goldsmiths’ Hall in London for a special ceremony (see page 5).

Research conducted by anti-counterfeiting specialists WRi Group suggests that there could be around one million items of fake ‘gold’ jewellery being listed for sale in the UK each year through online marketplaces and in traditional retail and wholesale premises. In order to combat this fraudulent trading, the British Hallmarking Council (BHC), the UK Assay Offices and WRi Group engage in hallmarking education and enforcement operations jointly with Trading Standards.

As part of that initiative a series of events have been held, the first of which involved London Trading Standards (LTS) and Trading Standards South East (TSSE). It took place at Walbrook Wharf in the City of London in September 2024 to mark the one-year anniversary of Operation Stamping it Out, a continuing project funded by the London Assay Office and delivered by the WRi Group together with Trading Standards. Each of the London boroughs have their own particular challenges, but Operation Stamping it Out has assisted in effective hallmarking enforcement across the entire region. Tangible outcomes include: • 360 retailers being visited and issued with bespoke business advice; • 75% of retailers being found to be in

Building on success Operation Stamping it Out is now being replicated across the North of England as ‘Operation Tudor Rose’, named after the emblem of the Sheffield Assay Office. On 17 September 2025 an event was held at the Sheffield Assay Office with more than 27 delegates, representing 13 authorities, attending from across the region.

After being welcomed by BHC Chair Noel Hunter OBE and Ashley Carson, chief executive and Assay Master of the Sheffield Assay Office, delegates were treated to a series of informative and thoughtprovoking presentations. A networking lunch was followed by more presentations, a lively question-and-answer session and a tour of Sheffield Assay Office.

Finally delegates were encouraged to sign up to Operation Tudor Rose. The project is designed to support all Trading Standards authorities across the north of England, in cooperation with the Sheffield Assay Office and the WRi Group, whose expertise and support will be provided free of charge to participating authorities. ●

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breach of the Hallmarking Act; • more than 200 verbal or written warnings being issued; • increased knowledge that high-end retailers were among those in breach of the Hallmarking Act and had little regard for their regulatory obligations; • evidence that Trading Standards authorities across the region would not have been able to enforce the Hallmarking Act without the support of Operation Stamping it Out; • four active criminal prosecutions being processed, and; • 22 intelligence reports relating to online traders being referred to Trading Standards.

Will Evans, Director of the London Assay Office, said that he felt it “appropriate to step in and support Trading Standards Officers as part of our consumer protection remit”.

The initiative proved to be so successful that it resulted in the London Region submitting an application for the British Hallmarking Council’s National Touchstone Award which included detailed case studies of individual enforcement actions. Their application was successful and resulted in the presentation of the Touchstone Award for hallmarking

Further information To find out more about Operation Tudor Rose and Operation Stamping it Out, contact project lead Graham Mogg: graham@wri-group.com / 02921 202597

Winter 2026

CTSI membership fees 2026 (Not inc. branch fees)

Annual fee

Annual fee direct debit

Full Membership

£149

1£138

CTSP (additional fee)

£50

n/a

Associate Membership

£99

£93

Retired Membership

£50

£45

Affiliate Membership

£75

£66

Student Membership

£45

£42

You may be able to claim tax relief on your membership fees. Email membership@tsi.org.uk for more information

Leading the Trading Standards Profession www.tradingstandards.uk

TRADING STANDARDS DS FELLOWS’ CHARITY

Branch fees are collected nationally. Individual invoices will contain this extra amount where applicable. Current fees vary but in brief, for Full Members these are North Eastern £6.00, London £8.00, Midland £10.00, South Eastern £11.00, Yorkshire and the Humber, Scottish, South East Midlands, Northern Ireland and Welsh £5.00.Southern, South Western, North Western and East Midlands, £0. Sections of the Institute. A charge of £10.00 will be included for members of the Business Members Group. The Civil Service Forum £0. Any applicable branch/section fee will be taken in the first instalment if paying by Direct Debit Please make cheques payable to “Chartered Trading Standards Institute”. A link will be supplied with your renewal to pay your subscription online. For BACS payments, please use the bank details on your invoice, and identify the payment using your six-digit member number.

If you paid by Direct Debit last year, your discounts will automatically be given. Representative Example: Monthly Direct Debit. 0 % APR Representative. Full Membership subscription £138.00, 12 payments of £11.50.Total amount payable £138.00. For further information and finance terms please contact CTSI, 1 Sylvan Court, Sylvan Way, Southfields Business Park, Basildon. SS15 6TH .

Welfare Welf lfa lf fare Support r rt

SUPPORTING OUR MEMBERS FOR MORE THAN 65 YEARS The Trading Standards Fellows’ Charity assists with educational and other needs of dependents and d families suffering health or domestic misfortune. ne.

This includes grants for purchase of mobility aids, ds, long term illness and initial financial support.

I cannot thank you and the Trading Standards Fellows’ Charity enough for this financial support, it will certainly relieve a lot of the financial pressure we are under at the moment, and allow us to focus on his recovery.

If you would like k to ke support r the Charity rt and make k a donation, ke please scan the QR code.

The Trading Standards Fellows’ Charity Charity no. 213351

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This guide was produced as part of a business advice project by the Department for Business, Energy and Industrial Strategy and the Chartered Trading Standards Institute.