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James Munro Chair, CTSI
After 35 years in the job it still amazes me how varied the work of Trading Standards actually is. In this issue alone we are focusing on food, including labelling, allergens and imports (see page 14); there are also articles on used car admin fees (page 22); ticket touting (page 46); animal welfare (page 20) and product safety (page 28), among many other things. With the variety of our work, however, comes the risk of spreading ourselves too thinly or becoming the jack of all trades and master of none. Targeted government funding is welcome but can sometimes shift the focus of local authorities to the detriment of our traditional areas of work.
“Getting qualified and competent officers into the profession continues to be a priority”
Getting qualified and competent officers into the profession continues to be a priority and I’m pleased we are now seeing apprentice and student numbers on the rise (see pages 50 and 52). The current conversation about the structure of the Weights and Measures qualification (see page 58) also needs your input, so please speak with your Council representative or local Branch.
Recognising the differences in our devolved nations has to be fundamental to our approach as a truly national Institute. I’ve heard about some of the challenges experienced by colleagues when it comes to getting their views heard and I’ve used my involvement with CTSI Board and Council to make sure those voices are front and centre in everything that we do.
Conference is just around the corner and this issue’s preview sets out some of the highlights (see page 56). This year at the Royal Armouries Museum in Leeds we will welcome colleagues from Environmental Health to discuss cross-cutting topics such as food and housing, as well as leadership and EDI issues which affect us all (see pages 32 and 38). It will be an event to remember so please book your place if you haven’t already done so — there really will be something for everyone.
The opportunities to get involved with the Institute are many and varied, and I encourage you to help shape the way it works for our members. This is your Institute and the future of the profession is in your hands.
Editor-in-Chief: Kerry Nicol
Editor: Richard Young
Designer: Sam Millard
Contributors: Robert Grice, Juanita Headley, Abbie Hunter, Danny Maxim, Jessica Merryfield, James Munro, David Sanders, Vincent Searle, Valerie Simpson, Giles Speid, Duncan Stephenson
Writers: Matt Allwright, Aaran Fronda, Helen Nugent, Richard Young
Article suggestions and feedback should be sent to:
editor@JournalofTradingStandards.co.uk
Editorial Board: Damien Doherty, John Herriman, Tendy Lindsay, David MacKenzie, James Munro, Phil Owen, Giles Speid, Gareth Walters 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
© 2024, Chartered Trading Standards Institute. All rights reserved. Views expressed by the authors are not necessarily the views of CTSI.
Upfront News of recent developments and successes, as well as updates from CTSI Lead Officers and TSOs on the front line.
| Opinion: Matt Allwright The human cost of allergen mistakes. 24 | Opinion: Jessica Merryfield CTSI's new Head of Policy and Campaigns shares her priorities for the year ahead.
28 | Parallel problems An international view of product safety.
30 | Sponsored: shared goals Inter Scientific supports vape compliance.
32 | Opinion: Abbie Hunter Top tips on building a diverse team. 34 | A helping hand The UKICC's role in helping UK consumers. 36 | Life after Trading Standards
Three former TSOs talk about the importance of serving their communities.
38 | The self-starter Valerie Simpson offers words of wisdom.
46 | Ticket to jail Taking down a family of ticket touts.
48 | CPPD: Contract Law basics The key points of contract formation.
50 | Reaching out Spreading the word about TS careers. 52 | Everything to play for Recent TS recruits discuss their ambitions. 54 | The big picture Why accurate intel benefits enforcement.
56 | CTSI Conference 2024 Previewing this year's event in Leeds.
56 | Opinion: Danny Maxim Weighing in with metrology concerns.
Food for thought
From allergen labelling to vegan food definitions and food imports, how can TS ensure that what reaches our tables is safe?
Putting a foot down
How a London-based project to clamp down on used car admin fees helped protect motorists and bolster compliance.
Sound the alarm
We look at the worrying rise in anger, hostility and aggression encountered by TSOs while going about their duties.
Paying the price
A new CTSI policy paper calls for reform of current animal welfare law, which is costing animals and local authorities dearly.
Gold standards
David Sanders and Robert Grice go behind the scenes at the Royal Mint to examine the past, present and future of Hallmarking.
The Devil's in the detail
The story of CTSI's involvement with the DMCC Bill, which will lead to major changes in online enforcement.
CTSI has called for extra resources for Trading Standards enforcement, stronger protections at the UK’s ports and borders, and clearer legal duties for online marketplaces in its recently launched manifesto.
The Institute has also welcomed the announcement that the next general election will be held on 4 July, calling it “an opportunity for renewed investment in the vital work of Trading Standards”.
In its manifesto, CTSI urges the next government to introduce school lessons on consumer protection rights, bring in a licensing system for traders operating in the green energy sector, and to appoint a new national Consumer Champion.
According to CTSI Chief Executive John Herriman: “Our manifesto sets out the bold and necessary action we believe is vital to protect consumers and law-abiding businesses.
“The UK’s Trading Standards profession is at the heart of protecting consumers, and we provide a significant layer of defence. But this layer has been decimated in recent years, with the consequence that consumers are at an all-time high of being ripped off, and susceptible to buying products that may be substandard, counterfeit or dangerous.
“Now is the time that we must build back the Trading Standards workforce so that consumers can once again be confident, which is vital for the UK’s economic growth and prosperity.
“These measures, along with the urgent need for resources, are an investment in UK consumers
and our economy — without them, the UK will remain a dumping ground for unsafe and substandard products, criminals will continue to have the upper hand and consumers will suffer. Inaction is no longer an option — our system is at breaking point — and the next government must grasp this nettle.
“CTSI is calling for a small investment of £100m in Trading Standards, which would be recouped more than ten-fold by reducing the detriment consumers face, increasing the tax revenue by clamping down on counterfeit products and averting future product or food safety crises that cost us millions.”
CTSI's call for action has won support from influential figures across the consumer protection landscape. Professor Christopher Hodges OBE, Chair of the Regulatory Horizons Council, said: “Maintaining consumer protection faces serious threats of various kinds, particularly from diminished resources and from online and AI technologies. It is important to refresh local and coordinated arrangements across the nation now.”
Katrina Phillips OBE, Chief Executive of the Child Accident Prevention Trust, said: “We fully support CTSI’s manifesto for change. Too often, we see the devastating consequences of unsafe products for children and their families.
“Families need better protection through investment in Trading Standards and regulation of online marketplaces. And reputable
“Inaction is no longer an option — our system is at breaking point — and the next government must grasp this nettle”
businesses need protection too. Investing in consumer protection will reduce NHS costs and support the economic growth we all want to see.”
Lesley Rudd, Chief Executive of Electrical Safety First, commented: “We strongly back the calls in CTSI’s manifesto for proper resourcing of the UK’s Trading Standards infrastructure at ports, borders and across the country. Without this critical line of defence, consumers are at risk of dangerous products, which often should never have been available for purchase in the first place.”
CTSI is calling for:
l Stronger protections at the UK’s ports and borders –with almost half of goods entering the UK found to be unsafe or counterfeit, CTSI wants to see an additional 400 staff and greater resources allocated to undertake checks on goods entering the UK.
l Clearer legal duties on online marketplaces such as Facebook Marketplace –less than half of consumers see these as trustworthy places to shop.
l Introduction of lessons for young people in schools so that they know their consumer protection rights.
l Licensing of tradespeople who are involved in the green energy sector –this market is estimated to be worth £1trn over the next five years and Trading Standards Officers are concerned that consumers will be susceptible to criminal activity from fraudsters.
l The appointment of a Consumer Champion in government.
l Investment in the Trading Standards workforce, including considering alternative methods of funding to plug the gap with more than 2,000 Trading Standards posts nationally. Over the last decade funding has been cut by half and almost 50% of the workforce has been lost.
The Competition and Markets Authority (CMA) has called for grocers to prioritise accurate pricing after finding errors in 14.4% of symbol convenience stores, 7.8% of independent food stores, 5.6% of variety stores and 4.2% of supermarkets. It has also published business guidance in conjunction with CTSI on compliance with price marking legislation.
Scammers are targeting bereaved families with bogus donations and fake online funeral services, information received by CTSI shows. Criminals are seeking out funeral notices and setting up fake Facebook accounts which claim to offer opportunities to donate money in memory of the deceased, or to watch a live stream of their funeral.
Citizens Advice has revealed that last year its Consumer Service received a complaint about a used car every three minutes. The charity, which helped with almost 43,000 complaints relating to used cars in 2023 alone, found the majority (66%) of complaints were about defective goods, while 13% concerned safety issues.
Fashion retailers ASOS, Boohoo and George at Asda have undertaken to only use accurate claims about the environmental credentials of their products following a landmark investigation by the Competition and Markets Authority (CMA). The regulator launched its investigation in 2022 after identifying examples of ‘greenwashing’ in the sector.
CTSI research has revealed that 70% of beer and wine sold in hospitality establishments in the UK is short measured.
National fieldwork carried out by local authority teams across the UK found that 86% of beer and 43% of wine was short measured. The average deficit for beer found in the survey was 4%, while for wine it was 5%.
The largest short measure was a deficit of 15%, found on a 175ml glass of wine in Walsall, with the drink costing £3.20.
The findings come at a time when the price of alcoholic drinks is at an all-time high: according to the Office of National Statistics, the average price of a bottle of red wine has increased 8% over the past year, while the average cost of a pint of lager is up 5.6%.
CTSI Chief Executive, John Herriman, said: “While this is a snapshot, it is the first time that we have been able to build a national picture of how widespread short measuring of alcoholic drinks is, and the potential detriment to the average consumer of around £115 every year suggests there is the need for more comprehensive research to better understand the impact of short measures,
70% of drinks came up short
not just for alcoholic drinks but across a broader spectrum of consumer goods.
“Weights and measures is a key role for local authority Trading Standards, but right now we simply don’t have the resources to allocate, and even the equipment to use, to undertake spot checks that ensure consumers are getting what they pay for.
“We are calling on the hospitality sector to ensure that consumers get value for money by making sure they are correctly measuring the drinks they are serving to customers in the nation’s pubs and bars, and for further research in this area.”
CTSI Vice President, Jess Phillips MP, said: “The cost of living means people can hardly afford a drink. To discover you’re being served short measures
New rules requiring UK payment services providers to reimburse victims of authorised push payment (APP) fraud will come into force on 7 October. However, the mandatory requirement, which replaces a voluntary code, has led to
concerns that financial firms will be incentivised to ignore fraud cases. According to CTSI Lead Officer for Doorstep Crime Dr Tim Day, “Fraud is already a low priority, even where financial losses are huge. If victims are able to recover their losses, I
adds insult to injury. A short measure cheats us all, but affects those worst off the hardest.
“Being able to afford to go out for a drink is not easy and you should get what you pay for. In this current climate, it is great to see this campaign from CTSI raising awareness of the important work of our Trading Standards profession.”
CTSI also commissioned public polling to discover whether consumers believe a pint measure of beer should include the frothy head or not. Legally, the head is included — however CTSI found that 35% of the public felt the head should not be included in the pint measure. The Campaign for Real Ale (CAMRA) maintains that the pint measure should not include the head, and that consumers should have a right to a 100% liquid pint.
CAMRA National Chairman Nik Antona said: “The idea that 70% of all beer bought at the bar is being short measured in the UK is extremely concerning.
“This latest study is another worrying indication of an issue that has been affecting consumers for a number of years now and should hopefully provide a catalyst for change.”
have a feeling that it’s only going to be further decriminalised by enforcement authorities.”
The result of that, Day says, is that cases going unrecorded could enable banks to evade responsibility: “Financial institutions are very worried about the impact this is going to have, and I think they will look to find ways to limit liability and loss.”
A ‘vicious cycle’ of shame and under-reporting has led to a National Trading Standards (NTS) campaign that aims to take the stigma out of being scammed.
The #NoBlameNoShame campaign is urging people to talk more openly about scams, and aims to create an environment in which victims feel more able to report their experiences.
NTS research shows that 19 million UK adults have lost money to scammers, with the average amount lost standing at £1,730 — but just 32% of victims have reported it. According to the research, the most common response among
scam victims was feeling angry with themselves (46%), as well as feeling ‘stupid’ (40%) and embarrassed (38%). Fewer than a third (32%) reported the crime, and 42% did not tell their bank. Two thirds didn’t even tell a relative or friend they had been targeted.
Louise Baxter, Head of the NTS Scams Team and CTSI Lead Officer for Consumer Advice & Education, said: “Fraud and scams are at a high, but if victims do not report because they are ashamed or feel they will be blamed, shamed and not supported, it’s impossible for us to build a true picture of the
problem. This makes it harder to catch the criminals, but more importantly doesn’t allow us to help and support the victims.”
Lord Michael Bichard, Chair of NTS, said: “Scams and fraud blight every part of society and it is time for society to fight back.
“If we can strip away the shame associated with becoming a victim of fraud or scams, by bringing the issue out into the open and discussing our experiences as families and communities, we can reduce the power of the criminals to do harm. Education is key to prevention.”
(For more on the reporting and recording of scams, see page 54)
Nottinghamshire County Council is selling metrology equipment dating back to the 19th century to raise funds for the council's Trading Standards service.
Councillor Gordon Wheeler said: “There are so many wonderful looking items, including Victorian apothecaries’ weights, beam scales and egg grading poises, still in their original boxes.
“For antique collectors and enthusiasts, the future auction will give them a unique chance to purchase a bit of Nottinghamshire’s history.”
The date of the auction is to be confirmed.
Trading Standards enforcement and prevention activities making a difference across the UK
A fish and chip shop owner who charged customers for making card payments without their knowledge has made a £6,000 donation to a food bank following a prosecution by Anglesey Trading Standards. Councillor Nicola Roberts presented a cheque to Roy Fyles of Anglesey Food Bank (pictured) since not all of the victims could be traced.
A couple who ran an illegal dog breeding operation have been sentenced following action by Caerphilly Trading Standards. Colin Williams was jailed for 16 weeks and banned from keeping animals indefinitely, while his wife Ruth Williams received an eight-week suspended sentence and a 10-year ban. Each must also pay costs of £5,944.
A shopkeeper who repeatedly sold vaping products to people under the age of 18 has been banned from selling vapes for 15 months following an investigation by Highland Council Trading Standards. Adnan Abbas was found to have sold vapes to underage test purchasers on two separate occasions between July and October 2023.
A pair of rogue letting agents who scammed tenants and landlords out of more than £24,000 have been brought to justice by Barking and Dagenham Trading Standards and the NTS Tri Regional Investigation Team. Sultana Akther and Skeena Noor Rashid failed to return rent deposits, stole holding funds and did not pay collected rents to landlords.
A used car dealer who sold ‘deathtraps’ to his customers and committed multiple frauds has been jailed for four years following an investigation by Stockton-on-Tees Trading Standards and Cleveland Police. Simon Retallick sold dangerous vehicles with major faults and no MOTs. He also took money for vehicles and then failed to deliver them.
Activities: Worked on the CTSI campaign for changes to the Animal Welfare Act 2006 (see page 20).
Notes: In England, Animal Penalty Notices Regulations came into force in January 2024, allowing an ‘enforcement authority’ to issue a penalty notice for certain animal health and welfare offences in lieu of prosecution. The cost of living remains an issue, availability of winter feed has reduced and the land has been too wet to turn livestock out. This is leading to corners being cut, and significant non-compliance.
Activities: Worked on the progression of the DMCC Bill (see page 42), which will introduce monetary penalties to bring the UK in line with many other countries, as well as other changes, including to the Alternative Dispute Resolution (ADR) regime.
Notes: Training will be needed on the new provisions of the DMCC Bill to support Trading Standards colleagues with the changes and allow them to advise businesses. The EU's recent ‘Digital Fairness for Consumers’ report brings up interesting discussion of consumer law in a digital world.
Activities: Engaged with officials from the Department for Business and Trade (DBT) on the DMCC Bill (see page 42).
Notes: This engagement has led to successes, including changes to detail in the CPRs, a new banned practice of fake reviews and the extension of powers in relation to Online Interface Orders. Other matters remain unresolved, although DBT has promised ongoing engagement on issues such as Trading Standards' powers regarding Cloud storage and the liability of platforms and fulfilment houses.
Activities: Responded to ad hoc queries of CTSI members and facilitated on the Electronic Crime Group on Knowledge Hub.
Notes: In recent years, queries about e-crime tend to have been referred through to the NTS eCrime Team – rightly so given their level of expertise and their involvement in matters of a national interest. The Online Safety Bill still presents some interest to the Trading Standards profession, although much of the enforcement aspect falls to Ofcom and outside of the Trading Standards remit.
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
Activities: Supported the launch of the NTS 'No Blame No Shame' campaign (see page 6). Have also presented to the Home Affairs Select Committee on Fraud and Scams, and delivered training business on consumer vulnerability. A Consumer Friend campaign focused on consumer rights and teeth whitening.
Notes: A huge amount of work needs to take place to support businesses to provide inclusive services, support consumer vulnerability and increase access to redress.
Consumer & Product Safety
Activities: Contributed to product safety committees including those run by RoSPA, DEFRA, Electrical Safety First and the OPSS National Product Safety Group.
Notes: We are still awaiting the outcome of two consultations – the Product Safety Review and the Furniture and Furnishings Fire Safety consultation. Market surveillance by OPSS, the BTHA and Electrical Safety First have found a significant proportion (85%) of products purchased online are non-compliant and many pose a high risk.
Activities: Contributed to CTSI's Manifesto, which calls for the licensing of the home repair industry (see page 5), as well as NTS's 'No Blame No Shame' campaign.
Notes: The Payment Services Regulator is introducing new regulations for financial institutions in relation to reimbursement of Authorised Push Payment fraud victims. This alters the landscape for many fraud victims and makes reimbursement compulsory, except in cases where victims have been ‘grossly negligent’ (see page 6).
Activities: New competencies in product safety, feed and food have been approved. The Modern Apprenticeship in Regulatory Services – Scotland is well underway for first delivery this autumn.
Notes: The Qualifications Panel is opposed to the creation of a Weights & Measures Market Surveillance Officer qualification. Legal Metrology is a cornerstone of Trading Standards, and the Inspector of Weights & Measures is the only legally recognised professional qualification in the TS toolbox.
Activities: Presented at the ACTSO Autumn 2023 business meeting, helped plan the plenary session on day two of CTSI Conference, and met with Ofgem.
Notes: The Government has made significant changes to the timetable for achieving net zero by 2050 by extending the deadline for new petrol/ diesel cars to be sold, changing rules in relation to the installation of new gas boilers on domestic premises and changing rules for Energy Performance Certificate (EPCs) in relation to rented properties.
&
Petroleum
Activities: Represented CTSI and the profession on the Association for Petroleum and Explosives Administrative Council.
Notes: Scottish Government had intended to introduce a licensing scheme for persons with intent to purchase fireworks, but it has been postponed. The Petroleum Consolidation Regulations 2014 are due to be reviewed and this may affect fees associated with storage of petrol at filling stations. When this review is done, guidance to petroleum officers will need updating.
Activities: Continued work on the DMCC Bill, drafting amendments for the House of Lords with CTSI policy team and other Lead Officers (see page 42). Have also spoken with the CMA about reference pricing and ‘Online Choice Architecture’, and have been looking at unit pricing and drip pricing.
Notes: The DMCC Act will have a big effect on Officers’ work, and training will be needed as the Consumer Protection from Unfair Trading Regulations (CPRs) are being replaced and many definitions are changing.
Activities: Represented CTSI on the Food Hypersensitivity Group, DEFRA's Authenticity Steering Group, the Government Chemist Steering Group and the Food Standards and Information Focus Group. Notes: There is a lack of overall direction from central government about food standards, and product innovation is placing increasing pressure on Trading Standards Officers to make decisions about legislation that is not designed for the current marketplace. (For more on food issues, see page 14.)
Activities: Progress has been made on definitions for precious metals such as recycled gold to better define where potential misdescriptions may exist.
Notes: Lack of resources remains a barrier to effective consumer protection. For the new DMCC Bill to achieve success for consumers, consumer education must be reinstated. And vulnerable consumers will need additional help from local authorities if they are to benefit from the new redress scheme. (For more on hallmarking, see page 26.)
Activities: Participated in ABTA's Code of Conduct Committee and on the Department for Transport's Air Transport Insolvency Protection Advisory Committee to regulate the ATOL Scheme.
Notes: The Department for Business and Trade stated that it would be helpful to use possible increased powers under the DMCC Bill to reflect on our position on the Package Travel Regulations. The CMA is publicly supportive of Trading Standards getting new administrative powers under the DMCC Bill.
Activities: Worked as project lead for Operation CeCe for NTS, liaising regularly with HMRC. Operation CeCe tracks illegal tobacco routes into the UK and has made seizures totalling £14m. Notes: Civil sanctions (under Tobacco Track & Trace Regulations) can be applied by making a referral to HMRC, but only once the local authority has signed a memorandum of understanding with HMRC. There are ongoing productive discussions with HMRC on future funding of Operation CeCe to continue to tackle illegal tobacco.
Activities: Participated in the IP Crime Group Advisory Committee, IP Crime Group Enforcement Committee, the National Markets Group, the Real Deal for Fake Free Markets Campaign steering group and the Internet Intermediaries Working Group (IIWG). Contributed to UNECE Working Group meetings on the Use of Market Surveillance Infrastructure as a Complementary Means to Protect Users against Counterfeit Goods.
Notes: We continue to monitor the effect of artificial intelligence on intellectual property rights.
Activities: Working with CTSI and UK Weighing Federation on an upcoming policy project. Met with the Education Team and the Qualification Panel to discuss the proposal to create a two-tier legal metrology qualification linked to the Level 6 apprenticeship.
Notes: Proposals for a two-tier qualification, even limited to the Level 6 apprenticeship, presents a threat to the profession; dismantling the Weights & Measures Inspector role will have unforeseeable consequences. (For more on Legal Metrology, see page 58.)
Activities: Participated in the Vehicle Safe Trading Advisory Group and the Motor Ombudsman, ICAP, NTS Used Car Group. Notes: The decrease in the artificially high prices of used cars following covid has put dealers under pressure, with highly priced stock and falling prices. Chinese manufacturers are hitting the UK market via mainstream dealers. Subscription-based services can now change cars' performance, while clocking takes on a new form in mileage blocker devices. (For more on cars, see page 22.)
Activities: Keeping updated with the Renters Reform Bill and leasehold reform. Engagement with EPC accreditation schemes has been very positive to help drive up intelligence-sharing with local authorities.
Notes: An emerging issue is alternative deposit schemes. There are concerns over agents having Client Money Protection (CMP) membership because banks are asking for separate accounts for each client, which is potentially unreasonable –we have flagged this with DLUHC, who approve all six CMP schemes.
Activities: Delivered training for TSOs and Businesses in various aspects of vape regulation under the banner of Operation Joseph. Hosted ministerial visits and took part in government meetings and roundtables to discuss the future of vaping regulation.
Notes: Ongoing key areas of focus include the Call for evidence on youth vaping; the creating a smokefree generation and Tackling Youth Vaping consultation; legislation to ban the sale of single-use vapes; and the consultation on an excise duty on vape products.
RYAN MCKEEGAN TRADING STANDARDS INSPECTOR, NORTHERN IRELAND TRADING STANDARDS SERVICE
What has been your main area of focus over the past six months?
I qualified as an inspector in July 2023 and since then have worked within the metrology team in the Northern Ireland Trading Standards Service (NI TSS). My main areas of work have been the inspection and testing of liquid fuel measuring systems, weighbridges, testing pre-packaged products and inspecting livestock markets.
I have taken a lead role into the inspection and testing of weighing equipment at livestock markets. This is an area that NI TSS has not been involved with
“It is important we are out there testing equipment to ensure consumer protection and build confidence within the market”
for several years and I feel it is an important area of work considering Northern Ireland’s reliance on the agricultural economy.
Since qualifying, I have also gained invaluable experience working in our UKAS-accredited lab, and I am working towards becoming a calibration officer within our lab.
Are there any emerging issues?
The cost of living remains a prevalent issue for many consumers in Northern Ireland, with the cost of energy being of particular concern for many households.
The majority of properties in Northern Ireland depend on oilfired central heating and as such Northern Ireland has a higher density of oil tankers on the road in comparison with GB.
The metrology team regularly carry out routine inspections of this industry for accuracy and market surveillance purposes, and this summer we will be conducting a targeted project focusing on the inspection and testing of oil meter measuring systems.
As the home heating oil sector is unregulated, it is important we are out there testing equipment to ensure consumer protection and build confidence within the market.
We also continue to complete proactive checks on pre-packed food essentials and staples in
“Considering our authority covers all of Northern Ireland, it can be difficult ensuring that our presence is felt in all parts of the country”
grocery shops to monitor compliance. As part of the process, we will note prices so that if non-compliance is uncovered we can calculate the level of consumer detriment and advise the packers appropriately what impact any level of non-compliance is having on consumers.
What are the obstacles to tackling these issues?
The main obstacle impacting the metrology team is the lack of qualified inspectors. Including myself we have three full-time inspectors and one part-time inspector.
Considering our authority covers all of Northern Ireland, it can be difficult ensuring that our presence is felt in all parts of the country.
We are very fortunate to have new trainees working through the qualification at present, with three due to qualify this summer. However, it will take some time before the remaining trainees are fully qualified and can help alleviate some of the workload.
Recent issues for Trading Standards teams include livestock weighing equipment, compliance at caravan parks, youth vaping and rogue builders.
MURIEL
ALLAN PRINCIPAL TRADING STANDARDS OFFICER, MORAY COUNCIL
What has been your main area of focus over the past six months?
We have two trainees at the moment, one working towards completing Stage 1 of the qualification and one doing the metrology and investigations modules of Stage 2. Our main focus has been supporting the trainees with their study and completing Stage 2 portfolios. We are also focusing on criminal investigations, so haven’t really had much time for other initiatives or project work.
Are there any emerging issues?
We receive regular complaints about caravan parks, both residential and for holiday use. The complaints include mis-selling
“We have our fair share of complaints about home improvements businesses, including builders and roofers”
“We are a small team so have to prioritise our work. There are lots of things that we would like to do but are just not possible”
of mobile homes, failure to abide by the written statements and aggressive practices by park employees. The main issue is that the industry is not specifically regulated, with very little protection for mobile home owners.
Left Iain Bailey won the College of Fellows Prize after completing the Diploma in Consumer Affairs in 1996
have resulted in us doing a lot of test purchase operations and unannounced inspections, resulting in some large seizures. Our local police have been very supportive and we continue to develop partnerships to improve understanding of the law and our role.
JO BOUTFLOWER HEAD OF TRADING STANDARDS, NORTH YORKSHIRE COUNCIL
We also have our fair share of complaints about home improvements businesses, including builders and roofers, both local and based in neighbouring authorities.
We don’t use the Enterprise Act to its full potential due to lack of resources so are left with other enforcement options such as prosecution. The types of issues complained about are predominantly civil so don’t sit comfortably within criminal legislation unless we can make a case for fraud.
What are the obstacles to tackling these issues?
Definitely resources. We are a small team so have to prioritise our work. There are lots of things that we would like to do but which are just not possible. Also, a centralised Scottish legal resource for dealing with Enterprise Act enforcement work would be fantastic.
(Business Companion’s guidance for holiday park owners and operators is available at www.businesscompanion.info)
What has been your main area of focus over the past six months? Alongside the day to day complaints and investigations (involving a lot of vapes!), I have been working on corrosives and other regulated chemicals, alongside policy colleagues in the Home Office who have launched a trial of business advice about these chemicals.
My focus has been developing the London Trading Standards (LTS) explosives precursors and poisons (EPP) database for officers (and potentially businesses), which will tell them what rules apply to what products they may find available for sale.
Now the new burdens funding has come through I am hoping that all the regions will sign up to use the database as a tool to aid officers’ understanding and help develop competency.
Are there any emerging issues?
Community concerns around the accessibility of vapes to young people, and vapes containing unknown drugs causing hospital admissions of young people,
What are the obstacles to tackling these issues? The secure storage of seized vapes is proving problematic, with a lack of sector-wide advice as to how and where these may be safely stored. The expense of disposal is also a significant issue. With the ban on disposable vapes now announced these problems will only get worse.
We need a clear agreed national policy on where and how to store vapes safely which is practical and does not involve excessive costs, and a similar cost-effective route for combined disposal across regions for economies of scale.
(Business Companion’s guidance for businesses that manufacture, import or sell vapes is available at www.businesscompanion.info)
“We need a clear agreed national policy on where and how to store vapes safely which is practical and does not involve excessive costs”
What has been your main area of focus over the past six months? Two themes have dominated our work recently: complaints about house extensions and other small building projects, and underage and illegal sales of vapes.
Are there any emerging issues? There seems to be a trend for builders and other tradespeople to take payments upfront to buy supplies, but then failing to start the work or supply materials, despite reassurances that goods are on their way. Banking records can show that the trader has spent significant sums on gambling and the demands for payment to consumers may become more outlandish or aggressive as they try to recoup losses with further gambling.
What are the obstacles to tackling these issues?
Tradespeople affected by addiction are unlikely to respond to advice, and enforcement usually comes too late to help consumers recover money. Working with a suitable partner to divert traders from the behaviour seems a better resolution for both consumers and tradespeople.
CTSI is warning consumers of the dangers posed by illegal cosmetic products and urging online retailers to improve their levels of compliance following a spate of dangerous cosmetics being intercepted at ports and borders.
The #CostofBeauty campaign highlights the harmful sideeffects of non-compliant cosmetic products such as skin lightening creams, teeth whitening kits and gel nail systems, which can include burns to the skin, pregnancy complications and long-term health problems.
Trading Standards teams around the country have seized large amounts of dangerous
The #CostofBeauty campaign highlights the risks of unsafe cosmetics
cosmetics over the past year, with 88% of products checked by the Suffolk Trading Standards Imports Team alone being found to be unsafe or non-compliant.
Illegal skin lightening creams have been found to contain banned ingredients including hydroquinone, while illegal teeth whitening kits containing as
much as 300 times the 0.1% legal limit of hydrogen peroxide have also been seized.
Christine Heemskerk, CTSI Lead Officer for Product Safety, said: “Cosmetic products should attract compliments, not complications. These dangerous goods can leave the public with serious life-long side effects.
“Trading Standards will remove these products from sale and take action where needed, but online sellers need to take responsibility for the goods on their websites. Turning a blind eye is not an option... online marketplaces can and must do better.”
This year marks the 80th anniversary of the D-Day landings, when Allied troops landed in Normandy to repel the Nazi forces and liberate France.
The first Allied soldier killed on the first day of the operation — a decisive turning-point in the Second World War — was part of the Trading Standards family.
Lt Herbert Denham ‘Den’ Brotheridge of the 2nd Battalion, Ox and Bucks Light Infantry, was just 28 years old when in the early hours of 6 June, 1944, he landed by glider at the Caen Canal Bridge in Bénouville and led the first platoon across,
silencing one German machine gun post before being hit in the back of the neck by a bullet and succumbing to his wounds.
The attack has become famous as the first action on D-Day, and the bridge where Brotheridge died was later renamed Pegasus Bridge by the Royal Engineers. Brotheridge, whose daughter Margaret was born two weeks after his death, is buried in the war cemetery in Ranville Churchyard.
In civilian life, Brotheridge was a Weights and Measures Inspector at Aylesbury Borough Council and a member of the Incorporated Society of Inspectors of Weights and Measures, which later merged with the Institute of Trading Standards Administration to become CTSI.
Brotheridge’s sacrifice will be marked at this year’s CTSI Conference (18-20 June) with a special memorial address at the Awards dinner.
Retired CTSI member Colin Hoskins said: “Some things need to be remembered and I’d like to think that the Institute can take a bit of pride from this act of heroism by one of its own.”
As well as Brotheridge, 15 other members of the Institute lost their lives in the Second World War, along with many other weights and measures staff. May they all rest in peace.
Allwright Journalist and presenter of Watchdog and RogueTraders
The past few years have seen improved protections for people with allergies. But there is still much to be done to make unnecessary deaths a thing of the past
Anaphylactic reactions are cruel, and can render us powerless. In a few seconds you can lose someone who is otherwise in good health to an allergy they didn’t know about, or couldn’t defend against.
While our understanding of allergens and their effects is growing, the number of fatalities from food allergens, when compared to something like road traffic accidents, is still comparatively low at around one per two million people. But of course, that’s a statistic that means nothing if that one is your child. It also takes no account of the near misses, or lives limited by allergies through the fear that accompanies every unlabelled snack, every lunch on the go.
We’ve seen huge changes in the way that our food is labelled in the past few years, driven largely by the efforts of the EdnanLaperouse family, who lost their daughter Natasha in 2016 after eating sesame seeds baked into a prepackaged sandwich. They have worked tirelessly to ensure that the fourteen major allergens are always listed on prepacked food, a move which could have saved Natasha’s life. Her allergies were
apparent from an early age, and she knew exactly what she could and couldn’t eat.
Natasha’s parents Nadim and Tanya have fought and got results, but they’ve also met resistance. The labelling standard they’ve battled to make law can be expensive, and requires evidencing and documenting, a substantial burden on food businesses which are often start-ups and sole traders. It’s not always being done well, with lists of allergens too small to be meaningful or legible, and in some cases it simply doesn’t happen, as enforcement on food standards has taken the same hit as other regulatory services over the past decade. If no-one’s checking, it can be easy to assume it doesn’t matter that much.
So where do we draw the line on regulation? How many lives lost do we say is too few to warrant a costly new burden on businesses who may already be operating on tiny margins? Pushing back against progress will always be those forces which want to to sweep away bureaucracy, free up enterprise, and are quite happy to accept that there may be a cost to doing that, even in human life. But what those
Many of us are focusing harder on all ingredients, and asking tougher questions about where they came from and what they do
voices miss is that in addition to lives saved and changed, the allergen labelling effort forces food businesses to better understand what goes into their products in a way that we’ve been ignoring for years.
As a by-product of Natasha’s law, along with what science is starting to tell us about ultra-processing, and revelatory moments like the horse meat scandal, many of us are focusing harder on all ingredients, and asking tougher questions about where they came from and what they do. If we stop talking about bureaucracy and regulation and start talking about understanding, trust and confidence, the argument changes. It’s no longer a war between those who regulate and those who burn red tape, but a common quest to know what we’re eating, where it comes from, and whether it will do us harm. ● For more on food & allergies, see page 14
From allergen labelling to vegan food definitions and imports of non-compliant food, how can Trading Standards meet the challenge of ensuring that what reaches our tables is safe and accurately described?
‘A matter of life and death’ can sometimes be an overworked cliché, but when it’s applied to food labelling, it’s all too true.
In the UK, around two million people are thought to have a diagnosed food allergy. A recent study by GS1 UK found that more than half of those with food allergies have had an allergic reaction as a result of mislabelled or unclear food packaging. The research also discovered that nearly a quarter of respondents suffered multiple reactions, with seven in 10 allergy sufferers saying they felt nervous eating food not prepared by themselves or a family member.
And it’s not just the issue of labelling that’s of concern. Imports of noncompliant food and drink are problematic and pose real challenges to Trading Standards, as does the emergence of new food products such as plant-
based ‘meats’, and the ways in which manufacturers choose to describe these new lines. Then there’s the lack of a legal definition for vegan food, which takes us back to the risks posed to people with allergies. Food — and how it’s categorised — can be a minefield.
Look at the labelling
Of the recent developments surrounding food labelling, perhaps the most significant is what is commonly known as ‘Natasha’s Law’. A gifted artist and talented figure skater with dreams of gaining a private pilot licence, Natasha Ednan-Laperouse was just 15 when she passed away in July 2016 due to a severe allergic reaction. A lifelong allergy sufferer, Natasha died after eating sesame seeds that were baked into the dough of a baguette. The label on Pret A Manger’s
packaging didn’t include this ingredient, which was invisible to the naked eye. As Natasha was on a plane when she ate the product, she had no way of receiving urgent medical care. The subsequent inquest concluded that Pret A Manger’s allergy labelling was inadequate.
Natasha’s parents set up the Natasha Allergy Research Foundation and campaigned for increased transparency around UK food labelling requirements as well as a change in the law. Their dedication and resolve resulted in the Food Information (Amendment) Regulations, which stipulate that any business selling foods that are prepackaged for direct sale (PPDS) must include a full list of ingredients on the product label, with an emphasis on allergenic ingredients. The rules came into force on October 1, 2021.
Natasha’s mother, Tanya EdnanLaperouse, says: “We hear from people every day about how much Natasha’s Law means to them and what a difference it makes. There are so many people who have been locked out from being able to safely and with confidence eat this food. Now they can look at a food label and decide whether or not it’s safe for them.
“Natasha’s inquest and then the subsequent campaigning put food allergies on the map. People were talking about it. There’s still a long way to go but progress is happening. Certainly, the speed at which Natasha’s Law was passed through parliament was second to none. It was very, very quick. And I think that really showed how important it was to get this law out.”
But what of the enforcement required for the legislation? The same rules apply to major high street chains making large numbers of PPDS food on the premises as to small independent corner shops.
David Pickering is one of CTSI’s Lead Officers for Food. He says: “I think that for the bigger nationwide businesses, it’s probably easier for them to deal with. But it’s the smaller local businesses who haven’t got a clue because the only information they ever get is when we go to see them, which is becoming increasingly less because we’ve got fewer people.”
Sampling work by the Food Standards Agency (FSA) has shown that compliance is lower among small businesses. It tested 47 PPDS foods for various undeclared allergens including peanut, walnut, hazelnut, cashew, milk, gluten and fish. A total of 17 samples were found to have allergens present without the required labelling and, in addition, 10 samples were reported to have labelling issues. There were no failures in compliance with the sampled products sold by supermarkets or other larger food businesses.
There’s still a long way to go but progress is happening. Certainly, the speed at which Natasha’s Law was passed through parliament was second to none
Pickering says that, of the authorities he has been in contact with, enforcement action is very much complaint-driven.
“If you get complaints from consumers or businesses, because it’s an allergen issue it goes to the top of the priority pile. It’s similar to a product safety issue because it’s a risk to health.
“Most Trading Standards work these days is very much targeted. We don’t have the ability go down a high street and visit everybody. I’m not saying that’s the right thing to do anyway — and it’s not that we don’t want to do it, it’s more about having to use what we’ve got in the best way that we can.”
Pickering has noticed that complaints from consumers tend to be from people who are already aware of the laws surrounding allergens, often because they have allergies themselves or because their children have allergies.
In terms of enforcement, CTSI’s other Lead Officer for Food, Corinne Lowe, says
that Trading Standards supports the legislation on labelling. But she agrees with Pickering that resources are a factor, as are the specific challenges facing local businesses.
“You also get the issue that when small premises start labelling ingredients, they might get their bread from one place one day and buy it from somewhere else another day, or the margarine or whatever, but the ingredients can be different. Then you’re looking at the cost of having to change the labels as well.”
Other Trading Standards Officers have found that larger businesses are “largely compliant” when it comes to PPDS, but there is a concern about staff training.
“I think there is a general lack of acknowledgement and full awareness,” says Steph Young, CTSI Lead Officer for Animal Health & Welfare, and Team Leader for Food, Feed and Animal Health at her local authority. “I’m not convinced we’ve got the training right for some
It's the smaller local businesses who haven't got a clue because the only information they ever get is when we go to see them
of our larger organisations at the moment. They’ve got the structures in place, they’ve got the policies in place, but I’m not convinced the training has got down to the grassroots level, that the staff actually implementing the policy understand the law that sits behind it.”
Of the various issues faced by Trading Standards, Young says they include labelling in a language other than English as well as imported delicatessen items sold on shop counters, meaning that many people won’t be able to decipher any potential allergens.
“And where we have had overstickering that’s been put on to some of these labels, the over-stickering in itself
is incorrect. So, a person can’t make an informed choice on whether or not that product is suitable for them.”
When it comes to the hospitality sector, Young says that allergen complaints can mostly be traced back to the serving staff.
“That’s what it boils down to. Nine times out of 10, it’s normally been a lack of training somewhere where it’s not been communicated correctly by the person who’s been taking the order if it’s been in a restaurant.”
A campaign to change the law related to allergy labelling in restaurants has been gathering pace in the past few years thanks to the concerted efforts of Owen Carey’s family. In April 2017, Owen had just turned 18 and was celebrating his birthday on a day out in London when he collapsed, having suffered a massive anaphylactic reaction following lunch at a Byron Burger restaurant. Despite
explaining his allergies to the server and being assured that his grilled chicken burger was safe to eat, the chicken had been marinated in buttermilk. Owen only ate a small amount but, tragically, it proved fatal.
Currently, food businesses providing non-prepacked food, such as a restaurant, are required by law to tell customers if the food they provide contains any of the 14 mandatory allergens as an ingredient (either verbally or in writing). However, in December 2023, the board of the FSA agreed that it would like to see written allergen information mandated in the non-prepacked sector.
At present, the FSA is working to develop strong guidance for food businesses on how to provide written allergen information to help drive up compliance and make it easier for people with a food allergy, intolerance, or coeliac disease to protect themselves when eating out.
In addition to providing written information, the FSA board has also acknowledged that there should be an expectation for a verbal conversation to take place between customers and food business staff, to ensure an added layer of protection for consumers.
More recently, the FSA launched a campaign highlighting the risk of food labelled as vegan to people with allergies. In March, it published new research showing that 62% of people who react to animal-based allergens, or who buy for someone who is, are confident that products labelled ‘vegan’ are safe to eat, which is incorrect and may be putting them at risk.
While CTSI supports the FSA’s consumer campaign, its own recent policy report shone a spotlight on the potential dangers for allergy sufferers and the need for a legal definition for
76.4%
of consumers think food labelled as vegan should be completely free of anything derived from an animal
vegan and plant-based food, stating that the ambiguity around these terms can have disastrous and sometimes tragic consequences for those with allergies to animal-derived allergens.
At the moment, 4.5% of the UK population follows a meat-free diet, with 1.5% classing themselves as vegan. According to CTSI, 76.4% of consumers surveyed believed that food labelled as vegan should be completely free of anything derived from an animal. As things currently stand, there is no legal definition for vegan or plant-based food, which leaves the responsibility down to food businesses.
Among CTSI’s policy recommendations is a legal definition of vegan food, which would include legal thresholds for what constitutes animal-free food, an education campaign to raise awareness of what to look for on a label, and further stakeholder engagement to explore the steps required to produce updated guidance to be in line with international counterparts.
Jessica Merryfield is Head of Policy & Campaigns at CTSI. Referring to the policy paper, she says that it’s important
to note that CTSI is not stating that veganism is wrong.
“What we want to make sure is where you say something is vegan, it truly is vegan, that there is no misleading at all, there’s no ambiguity and people aren’t abusing that term, and that consumers are empowered. We just want it to be safe, we want it to be legal, and we want it to be fair.
“We all have to eat, we all have to consume food, it’s the basic provision to be able to consume food and to live. The spirit of the law we enforce today is about making those informed choices, and you should have sufficient information to make an informed choice. If we don’t give them that information, then consumers cannot make an informed and sometimes safe choice.”
I'm not convinced the training has got down to the grassroots level, that the staff actually implementing the policy understand the law that sits behind it
Merryfield explains that, because veganism is a term that
isn’t legally defined, it is open to interpretation.
“This can be a good thing because it allows people to make decisions themselves, but then there’s no consistency. From my experience, businesses need consistency and clarity to be confident about what they’re giving to their consumers, which then in turn gives us confident consumers.
“But you might have different standards across industry as to what certain terms like ‘vegan’ may imply.”
She adds: “And what does plant-based actually mean? Is it based in plants but may contain meat? It’s a very vague, ambiguous term with very different connotations, and every person will interpret it differently.”
Trading Standards Officers concede that government officials are reluctant to commit to strict definitions for food, preferring to allow for what they regard as personal choice. But there’s a difference between food that represents a lifestyle choice and food that is a safe choice.
“People are becoming ill and dying because the term ‘vegan’ isn’t defined
and it is so subject to interpretation that it’s confusing for businesses and for consumers,” says Merryfield. “So, we are seeing an appetite from industry, consumers and regulators that we just need that clarity please. We just need to know, where are we drawing that line?”
While the prospect of a legal definition for vegan food is still uncertain, there is new legislation for imports. The Border Target Operating Model (BTOM) came into effect at the end of January, with the second phase introduced on April 30. A further phase surrounding safety and security declarations is scheduled to come into force on 31 October, 2024.
Under the long-delayed scheme, the new post-Brexit border checks mean that animal and plant products which are deemed ‘medium-risk’ or higher will face physical checks at the Port of Dover and the Eurotunnel. However, alarm has been previously raised over potentially dangerous or non-compliant food coming into the UK. At the beginning of 2024, Beverley Edmondson, Port Health Manager at Dover District Council
62% of people allergic to animal-based allergens incorrectly believe that products labelled ‘vegan’ are safe to eat
and Port Health Authority, wrote in an article for the Chartered Institute of Environmental Health’s EHN magazine that “we are seeing unprecedented quantities of illegal, non-compliant meat, unparalleled at any other point of entry”.
As far as Trading Standards is concerned, the new rules have had an impact, as Lowe explains.
“On the import side, it’s increased workload because businesses now are having to comply with all these import rules. We’re having to give advice or at least refer them to the relevant places to go. So, we’ve had quite a big increase in workload on that.”
Also, Trading Standards’ enforcement of imported food products is more focused on items that have already made it to market, including via social media which, inevitably, makes them difficult to trace.
The spirit of the law we enforce today is about making those informed choices; you should have sufficient information to make an informed choice
Pickering says: “Regarding
imported food, I think we are starting to see a bigger increase in online sales through social media pages. And I think that’s where the food supplements thing comes in. You order all this stuff from America for personal use and then people think they can make a few quid by getting a few more and selling them on. And then suddenly you’ve got this small marketplace emerging.”
Lowe adds: “We had somebody on their personal Facebook page admitting that they were putting food supplements in the equivalent of birthday card envelopes otherwise they would get stopped at the border when they were being imported. So, whatever the supplement was, they made it look like a birthday card.”
She continues: “American imports in general have been a major issue — things like sweets, confectionery, drinks and breakfast cereal products. There are issues around the lack of traceability, in terms of where the suppliers are getting them from. The shops just see the latest craze and stock up on it. And they are reluctant to give you the traceability which is an offence in itself. But, by being persistent, we get it eventually.” l
Current animal welfare legislation is an obstacle to effective
enforcement
— and animals are suffering as a result, according to a new CTSI report
Within Trading Standards’ portfolio of responsibilities, animal health and welfare is among those that really tug at the heartstrings. Cases of cruelty and neglect are all too common, and the details of such cases can be harrowing. Alongside the suffering, there are also significant public health and economic consequences that can stem from poor animal husbandry, with disease outbreaks having the potential to cause widespread disruption and harm.
Despite the importance of the issue however, the tools available for animal health and welfare enforcement are simply not up to scratch, according to CTSI’s new policy paper, ‘(Tackling) Animal Harm’. Because of problems with the wording of the current legislation, court backlogs and funding shortfalls, CTSI argues that there is an urgent need for review and reform of the Animal Welfare Act 2006.
CTSI Lead Officer for Animal Health and Welfare, Steph Young, and Georgie Cottell, Policy and Public Affairs Associate at CTSI, worked together on the paper. According to Young, “There are just so many barriers in place at the moment that we need a real review and an overhaul of the legislation. Animals are suffering and they will continue to do so because of these barriers.”
Under Section 18 of the Animal Welfare Act, local authorities have powers to take animals into their possession to prevent suffering, illness and the spread of disease. Section 20 of the Act enables a court to make an order for the subsequent treatment, rehoming or disposal of the animal.
The costs associated with this can be astronomical however, often in excess of £100,000. In several current cases costs are expected to exceed £200,000, and
one ongoing case has already cost more than £1.5m. Delays in the courts can lead to protracted, time-consuming and costly gaps between the implementation of Section 18 and Section 20, with no guarantee of reduced animal suffering at the end.
Research by CTSI has found that for 84% of local authorities, cost is the most significant barrier to enforcement of animal health and welfare. More than a third (39%) said the duration of the court process is another substantial barrier to enforcement action.
Because of this, many local authorities are unwilling to take animals into their care at all. They are able to do this as a result of the wording of the Animal Welfare Act, which states that a local authority ‘may’ appoint inspectors — not that it must. As a result, there is no statutory obligation on the local authority to enforce the legislation.
Even when animals are taken into the possession of a local authority there are further hurdles; in addition to the eye-watering costs, appropriate facilities have to be found for their care, staffed by people with the willingness and expertise to deal with complex health and welfare problems — no easy feat.
“We don’t go out with the expectation that we need to take animals — it’s a rarity, it’s not the norm,” says Young. “We’re having to jump through hoops to make sure we comply with the law, and there are only a few individuals around the country who will actually assist us in dealing with this type of work.”
And even when these individuals have stepped in to help out, there is the likelihood that an offender — whether they be a farmer, a livestock trader or an unlicensed dog breeder — will restock
with more animals while awaiting trial. At times the experience of frontline Animal Health Officers can feel sisyphean. According to Young, “It’s really frustrating when you come across a severe animal welfare case, you take intervention to stop that individual from having animals, you remove animals from the environment they’re in, and you can’t stop that individual from going out the next day and buying more animals.”
“The fact that we can’t stop farmers restocking when Trading Standards has taken possession is just insane,” Cottell adds. “The fact that you can have Officers going in because there’s a serious compromise of welfare, taking animals away, and within a week they’ve restocked their entire farm, means you’re just funnelling money into something that could be dealt with so much earlier.”
Among CTSI’s calls for reform (see boxout below) is a change to how animal health and welfare cases are funded. As Young points out, “no money has ever been
given to local authorities to fund animal welfare cases. Local authorities cannot afford to absorb these costs and the Secretary of State has a responsibility to ensure resources are available.
“Court delays do not assist in matters,” Young adds. “When I first joined the local authority 25 years ago, we had eight courts and we’re now down to two. The level of offending hasn’t changed but the level of funding has declined over those years.”
While it is clearly a major stumbling block, funding isn’t the only problem though. “When you look at what this is costing local authorities, a lot of that is down to issues with the legislation,” says Cottell. “Although funding is definitely needed, if we were to fix the legislation, it would cut down on those costs tremendously, which would be a real benefit to local authorities.”
Key among these fixes would be banning people whose animals have been removed under Section 18 of the Act from keeping animals again — at present, disqualification cannot be enforced until after conviction, which
l The introduction of pre-conviction sanctions and an interim disqualification of offenders in cases where animals are taken into possession
l Devolved governments, rather than local authorities, to fund complex animal welfare cases where animals are taken into possession
l Provision for the voluntary surrender of an animal
l A duty on the Courts to hear Section 20 hearings within 21 days
l Valuations of confiscated animals to be carried out by an independent third party
l Clarification on powers on entry in Scotland
l An amendment to strengthen disqualification from keeping animals
l England and Wales to mirror provisions in Scotland concerning the seizure of animals in the Animals and Wildlife (Penalties, Protections and Powers) (Scotland) Act 2020
There are just so many barriers in place at the moment that we need a real review and an overhaul of the legislation
may take years. “Disqualification is at the discretion of the courts post-conviction, and courts don’t necessarily always give the disqualification,” Young says.
“Even if they give a disqualification, the individuals then will typically get another family member to take the animals for them. You get the same problems all over again, but a different family member’s name is on the paperwork.
“As local authority inspectors we don’t have the resources to keep going back onto the same premises time after time after time. Where you’ve got serious offending, particularly when it’s quite clear it’s cruelty, there should be an automatic ban. If you were found guilty of drink-driving, they’d take your license away straight away, and you’d have an interim ban — we need a similar approach to animal welfare cases.”
In terms of what happens next, Cottell says CTSI has developed good relationships across the political spectrum, including with Conservative MP Chris Loder and the Office of the Shadow Minister for Environmental Protection and Animal Welfare, Ruth Jones MP.
“Having spoken to different Trading Standards Officers and other local authority staff, we have collated all of the issues, laid out what the problem is, and offered some solutions,” Cottell says.
“Our engagement with politicians has been really productive; it’s obviously a topic that is really emotive, it’s a public health issue as well, and it’s costing local authorities more than it should — all because of inefficient legislation.” l
Used cars routinely top surveys of the most complained-about consumer goods and, deservedly or not, the stereotypical ‘used car salesman’ has become synonymous with underhand business practices and shady dealings. The practices engaged in by the rogues — even if they do constitute a minority of the sector — are well known, with car clocking, doctored service histories and non-existent after-sales care among the tactics used to make a quick buck at the expense of consumers. But when a new practice started to come to light a few years ago, Trading Standards was quick to hit the brakes.
When he was based at Barking & Dagenham Trading Standards, Cenred Elworthy (who is now Trading Standards Manager at the Royal Borough of Greenwich) started to notice a rise in complaints about ‘administration fees’ being added to the price of used vehicles. These fees — usually ranging from around £50 to £200 — were being sneaked into sales contracts in an apparent effort to circumvent consumer protection laws.
“In London there are particular boroughs with large numbers of used car traders,” Elworthy says. “In those boroughs, there are lots of small traders dealing with things like crash repairs, or quite low-end cars being sold for £1,000 to £2,000. When you go around to industrial units, you’ll often find businesses that are just two or three guys working on one or two cars to then sell on.
“Sometimes those cars will be absolutely fine, and sometimes they’ll be absolutely terrible. It’s really about the
after-care for the people who are buying them,” he adds.
When the Consumer Rights Act was introduced in 2015, new protections for consumers, including new rights to return unsatisfactory vehicles or to have them repaired by the dealer, were brought into force. That coincided with a rise in small, independent traders selling vehicles online, often from outside residential properties and with little scrutiny. Elworthy felt there was an opportunity for Trading Standards to kill two birds with one stone: to update TSOs’ knowledge of the new legislation, and to bring the growing online used car sector into compliance with the law.
“I thought the best way to train ourselves up was to go face to face with the traders and explain the new rules,” Elworthy says. “I realised when I was talking to colleagues in other London boroughs that we were quite a way ahead in terms of the advice being given to traders. We shared a lot of the guidance informally, without it being a London-wide project.
“Once we started putting the word out though, we started receiving complaints about people being charged really excessive admin fees. Under the new right to return, people would buy a used car, drive it away, work out it was terrible, then go back to the trader and say, ‘I want my money back’. Traders were allowed to make a very small deduction for the usage of the car — but if someone’s only driven it a few miles, the amount that they can claim for the loss of value is going to be very minor.”
To compensate for the hit to their pockets, traders brought in admin fees
— often without making it clear to the consumer beforehand, and sometimes even over-stamping existing contracts — which they claimed they were entitled to hold on to even when the price of the vehicle had been refunded.
“The use of admin fees became really pernicious in the car trade,” says Elworthy. “When people do a search on a used car website, they might set the filter to find a car costing less than £2,000. They then go to look at it, only to be told actually it’s £1,999 plus a £100 admin fee; it’s very useful for traders because then the negotiation becomes focused on the admin fee, rather than the actual market price of the vehicle.
“It’s a bit like joining a gym — they’ll say, ‘don’t worry, we’ll knock the admin fee off for you’, and people think ‘great, I’ve saved myself £100’, without having a discussion about the vehicle’s price.”
While there isn’t an outright ban on admin fees, the law requires them to be completely transparent, and a consumer must be made aware of them before making any transactional decision.
£882,370 in consumer harm was prevented by Operation Regal
As Elworthy and his colleagues began to gain a better picture of the scale and nature of the problem, they also noticed that their advice to traders had started to pay dividends, with a drop in consumer complaints relating to businesses they had spoken to.
That initiative laid the groundwork for a London Trading Standards project in 2019. With £16,000 in funding from National Trading Standards (NTS), Operation Regal was launched to tackle the supply of unsafe and substandard used vehicles in the city, as well as misleading business practices such as the use of counterfeit car stamps and service books, and the imposition of admin fees when purchasers seek refunds.
With Trading Standards teams
287 traders were given advice
26% of traders issued illegal admin fees
being stretched across the capital, and with some services having just three or four TSOs (and sometimes fewer), Elworthy saw Operation Regal as a great opportunity to provide additional support and take a proactive stance to address an important area of consumer harm.
Operation Regal would take a two-pronged approach: part of the focus would be on the fair trading aspects of the used car sector, with the other looking at product safety issues.
The project was signed off, with support in place from the DVLA — and then, as with so much else around that time, things were brought to a screeching halt with the arrival of the Covid pandemic.
However, says Elworthy, once things started opening up again after the lockdown, “we realised this was an ideal
project to get Officers back out there; we could do things like socially distanced forecourt visits. The project had to be modified quite a bit; we did use some DVLA people and they were great, but they probably didn’t have the capacity to assist us to the degree we were expecting when the project was initially planned. But because we had the resources from NTS, we were able to use private vehicle inspectors, and to work with traders to promote a general fair trading environment.
“Trading Standards has really strong powers to stop dangerous vehicles being sold — we can issue a notice that a car is unsafe, and we have the powers to withdraw it from sale. A lot of TSOs probably weren’t 100% up to speed with their powers as they applied to vehicles, including myself at the time. I thought there was a skillset there that could really be emphasised.”
The success of Operation Regal speaks for itself: from the initial £16,000 NTS investment, London Trading Standards calculates that a total of £882,370 in consumer detriment was prevented — £55 saved for every £1 spent.
The project reached 287 used car dealers across 17 London boroughs, and found that 26% were issuing unfair admin fees, with 27% of vehicles inspected deemed to be unsafe.
Elworthy singles out his former colleague LeAnne George, who was brought in to administer the project, for particular praise. “She did really sterling work at London Trading Standards, bringing everyone together for it,” he says. And, as one of the driving forces behind the project from its inception, Elworthy adds: “It’s something I’m quite proud to have been involved with myself.” l
Jessica Merryfield CTSI Head of Policy & Campaigns
CTSI’s new Head of Policy and Campaigns shares her thoughts on the key priorities for the year ahead
Those of you who already know me will know that I am passionate about the work of Trading Standards, and about representing all those who undertake that work. Having spent two decades in a variety of Trading Standards regulatory roles, in both the public and private sector, I know I am not alone in having this passion. I have been blessed to work with, and alongside, so many exceptional professionals in my career to date and I know this will continue. The variety and breadth of work we do is captured so well in the ‘Anything But Standard’ video, launched at CTSI Conference 2023, which also really showcases the dedication of those who do it.
Over the past year or so, there has been some excellent policy and campaign work by CTSI, and it is my aim to build on those solid foundations and continue the momentum kickstarted by the recently launched CTSI Manifesto.
Trading Standards is a unique and wonderful profession, not without challenges and complexities, but one that I truly believe would be missed by the public if it were not here. The work we do impacts the lives of humans, animals and society as a whole, across all aspects and stages of life. Our profession is even mentioned in the Bible – which, as
a Christian, delights me. There are not many professions that can make these sorts of claims!
Championing the Trading Standards workforce, encouraging inclusivity and diversity, and creating effective policies and campaigns in this space is one of the first areas I will be working on. From my time in the profession, I recognise that it has seen many changes over the past two decades – and that is before you consider several financial crises, Brexit, a global pandemic and global conflicts. All these things have impacted the work of Trading Standards professionals, with the knockon effects on the global economy and supply chains being keenly felt by both businesses and consumers. What has been wonderful to note is the pragmatism, commitment and hard work undertaken by all Trading Standards professionals to provide solutions to the challenges faced; I have been very proud to be part of this profession and witness the dedication of colleagues over this period.
the CTSI Manifesto, and we are being vocal in our calls to build back Trading Standards services. To do so would benefit both consumers and law-abiding businesses, and support our local and national economy as well as our communities.
However, despite all this excellent work, it is disheartening to see funding to Trading Standards and staffing levels having been eroded to critically low levels. This is recognised and reflected in
To do this, we need to ensure that we have new people entering the profession, that we have professionals fully reflecting the diverse communities and businesses we serve, and that we have enough experienced professionals to train them. Having been through the training process, receiving exceptional training and mentoring myself, and then trained and mentored others in turn, I understand and appreciate the value of investing
Above Pushing for a legal definition for vegan food is among the list of policy priorities
in the pipeline of Trading Standards professionals. We need to encourage new talent into the profession, retain those already in the profession and look for ways to encourage the return of those who have left.
The world has changed, and we need to change with those times. We have seen an increase in funding from various government departments to support work at the ports and borders, which has helped deliver vital support to protect public health and safety, and to address consumer vulnerability. However, we also need to look more widely at the general funding and resourcing of Trading Standards to ensure it is sustainable and protected at a local level.
Another key area that I will be working on is the creation of CTSI policy and campaigning in food standards, one of CTSI’s identified seven ‘Policy Priorities and Opportunities’ areas. Some of you may already be aware of the CTSI Policy Paper on Vegan and Plant-based Foods, which was launched last year. The paper calls for legal definitions around non-defined terms like ‘vegan’ to ensure clarity for both businesses and consumers. It is an example of how we listened and responded to concerns raised by our members, undertook and collated the necessary research to create policies that are based on evidence, and then campaigned for the needed changes.
The work we do impacts the lives of humans, animals and society as a whole, across all aspects and stages of life
Looking at this policy in particular, campaigning by CTSI in this area has led to increased discussions, engagement, and action by key stakeholders across the food standards space. We have seen industry backing our calls for legal clarity over what ‘vegan’ means, as well as changes to industry guidance and consumer educational pieces. However, we must not rest on our laurels and CTSI will continue to campaign for a legal definition of what ‘vegan’ and ‘plantbased’ foods are, to ensure these terms are legally protected, defined and that consumers are not misled when these terms are used on foods.
We will also continue to encourage and facilitate engagement with members to ensure we are capturing the key issues facing food standards. As an example, I am also aware of the need for a legal definition of ‘pre-packed for direct sale’ or ‘PPDS’ in the food standards space. This is currently missing in the food standards regulatory landscape and a legal definition would clarify interpretation, application and enforcement, especially in relation to Natasha’s Law.
CTSI is a member-led organisation; members are at the heart of all that we do. In my role, I will be aiming to meet as many of you as possible, from both the public and private sector, to listen to your thoughts and ideas for how we address the challenges we face. Using this, we will be creating policies and campaigns which truly reflect the issues seen. I look forward to meeting you! l
David Sanders CTSI Lead Officer for Hallmarking
Robert Grice CTSI Fellow
A recent behind-the-scenes tour of the Royal Mint provided a valuable opportunity to explore the links between Hallmarking’s history and modern-day consumer protection
The Royal Mint was, for centuries, in London. It started life inside the Tower of London, and subsequently moved to Tower Hill as more space was needed. By the 1950s the growing population and more coinage in circulation made the need for further expansion a priority. The deciding factor was decimalisation. This would only be achieved by the Mint producing the old coinage system as well as sufficient metric coins for transition on a single day. A new site would be needed. The Chancellor of the Exchequer of the day (and also Master of the Mint), James Callaghan, was MP for Cardiff South and may have influenced the decision to choose Llantrisant as the site of the new facility.
The Royal Mint now occupies 30 acres at Llantrisant, enabling it to control directly more of its operation through an on-site smelter. In spite of centuries-old tradition, the Royal Mint is very forward-looking. It produces gold on site by recycling vast quantities of old computer boards, and recovers silver from used X-ray photographic plates. These raw materials
are then used to produce jewellery.
The Mint also has room for its own wind farm for on-site electricity. The masts for the turbines are unique in being painted pale green — and the turbines look like huge daffodils.
Today the King’s Assay Master, Dan Thomas, holds an historic role. One of his responsibilities is to ensure the rigorous quality standards imposed upon the Royal Mint and the four Assay Offices — which are central to the enforcement of Hallmarking — are met.
Arriving at 10am on a very wet day in March, we were warmly greeted by Royal Mint Staff. Once wearing protective clothing we commenced our tour of the production facilities. We saw rolls of coin metal weighing around two and a half tonnes being cleaned, before being fed into stamping machines that punch out the coin blanks, and the rolls then being returned to the smelter for re-use.
The Mint, being the largest facility of its
type in western Europe, not only produces UK coins but currency for more than 60 countries around the world. It also produces commemorative coins and medals such as those for the 2012 Olympics.
We then observed the process of turning the blanks into coins. This often involves more than one pressing. The images are produced using stamps prepared on site by extremely skilled engravers, in an ultraclean environment to exacting standards. The embossing stamps may last less than one day but, in that time, they press out half a million coins.
After coin production we visited the jewellery department which produces small items of jewellery under the ‘886’ brand, named after the date coins were first produced at the Tower of London. Whilst the British Hallmarking Council is responsible for the management of the Hallmarking system, the King’s Assay Master is responsible for quality assurance at the four UK Assay offices, and he is keen to set an example for quality. All the jewellery is subsequently
assayed at the Birmingham Assay Office and marked accordingly as either 9ct or 18ct gold or Sterling Silver, in strict compliance with the Hallmarking Act.
The Royal Mint Museum Director, Kevin Clancy, then offered a unique and special opportunity, not available to the public, to tour the museum. The museum contains more than 2,000 years of coins from around the world. Old balances and various weights are on display, together with many other fascinating exhibits. It was a great pleasure for us to be able to spend time in the museum — and a great privilege.
We expressed our gratitude for the invitation by presenting a copy of the book Touchstone, Trade and Transgression – Fraud in Precious Metals
“It was a great pleasure for us to be able to spend time in the museum –and a great privilege”
to both Kevin and Dan on behalf of CTSI. Additionally, Robert presented two photographs that he held of work at the Royal Mint taken around 1900. These showed the weighing of gold bars.
We also had a brief discussion about how the Hallmarking system can be kept relevant in the 21st century and offered some suggestions. Dan was interested to explore these and further discussions will take place.
Although the museum is private, the Royal Mint Experience is very much open to the public. It is a wonderful exhibition set out in a very interesting and engaging way (each exhibit and explanation is given in both English and Welsh). It is certainly worth a visit, explaining as it does the process of coining and assaying throughout the centuries.
There is of course a shop where coins, medals and other memorabilia are available (apparently Harry Potter merchandise is particularly popular), and Kevin Clancy’s book The Royal Mint,An Illustrated History is recommended. l
The
Below left A sample of
The Royal Mint is a unique institution, and the process of assaying coins of the realm will certainly be of interest to all TSOs. Hallmarking is a fascinating subject as well as being the oldest and most recognised system of consumer protection in the world. However, if the public is to be protected, then the Hallmarking Act needs YOU to enforce it.
We would highly recommend that you:
l visit the Royal Mint
l learn all you can about Hallmarking
l contact your local UK Assay Office for advice and assistance; they will provide technical expertise and help you carry out inspections
l speak to CTSI’s Lead Officer for Hallmarking
l buy a copy of Touchstone, Trade and Transgression (proceeds from all sales are given to the CTSI College of Fellows to assist in their charitable activities)
…and then, go out and enforce the Hallmarking Act!
We speak to Dr Catherine Niven, an Australian academic who specialises in product safety, about how the state of play down under reflects issues here in the UK
Consumer protection professionals in the UK often cite the same frustrations and obstacles in their working lives — at the top of the list being political inertia, lack of joined-up thinking and, of course, restricted resources. So how do their international counterparts tackle these issues — and what lessons can we learn from them?
Dr Catherine Niven’s background is in law and international business. She has previously worked in policy and legal roles at Queensland’s state regulator, before completing a PhD in child product safety in 2020.1 In the course of her research, she has examined how regulators in the US and Australia respond to product safety issues, identifying similarities, gaps, and opportunities for improvement.
Niven is now a Research Fellow at the Queensland University of Technology, where she works to develop injury surveillance methods and identify evidence that can be used to support regulatory responses, education programmes and safer product design.
reported — maybe because of a change of government — and the reforms haven’t advanced. That’s a real missed opportunity to arm our regulators with the tools they need to respond to some of the developing issues, particularly around e-commerce, and identify who’s responsible for putting unsafe products into consumers’ hands.”
Among the key concerns raised by Niven and her colleagues at that time were potentially harmful chemicals in children’s products. “That’s an area where the US has more regulation than we have in Australia,” she says. “The US has also put in place a number of mandatory standards for infant products. We have some gaps there, but our government says this is now a priority and they’re starting to look at those issues.”
The UK’s own Product Safety Review was published in consultation form in August last year, after years of delay due in large part to continued political turmoil (the outcome of that consultation is still being awaited).
is a voluntary initiative under which signatories — currently AliExpress, Amazon Australia, Catch.com.au, eBay Australia and MyDeal.com.au — commit to actively improve the safety of products sold online. They are also required to report annually to the Australian Competition & Consumer Commission (ACCC) on their performance.
“We’ve been quite interested to look at how the EU is dealing with online marketplaces through the General Product Safety Directive, and how they’re trying to ensure its applicability to online marketplaces and encourage more accountability,” Niven adds.
In Australia, the hurdles to better product safety will likely sound familiar to many here in the UK. “We had some proposed reform that went out for consultation back in 2019, looking at ways to improve the effectiveness of our product safety regime,” Niven says. “Unfortunately, the consultation results haven’t been
But it isn’t just in the political sphere that the UK and Australia have shared problems. With online marketplaces, Niven says, “we have very similar issues to what you’re seeing in the UK. There are five signatories to our Product Safety Pledge, which is seeing some good progress, but there are many more players entering the online market now.”
Australia’s Product Safety Pledge
Greater accountability for online marketplaces is also addressed by the UK’s new Digital Markets, Competition and Consumer (DMCC) Bill (see page 42) — although the fast-moving, often opaque nature of the sector means there is still much room for improvement.
In 2022 Niven and her colleagues conducted a survey of international experts about emerging product safety risks.2 “We
asked what products they were concerned about, and there was a lot of consensus — 76% of respondents mentioned electrical connection and distribution products, particularly lithium-ion and button batteries — these are issues that we can see in the US, Europe and the UK.
“The other issue that came through quite clearly in the survey results was concern with infant sleep products. Our regulators take a broad view of this product category — it includes inclined products like a rocker or a bouncer, noninclined products like cots or bassinets, as well as sleep-related products like sleep positioners and comforters.
“The ACCC is looking at whether a broad mandatory standard needs to be introduced for all of these sorts of products. In the meantime, they’ve issued some guidance to suppliers which talks about making sure the marketing of products follows public health guidance — so not having a pillow in a cot for example.”3
At the other end of the generation spectrum, Niven adds, “our research program is currently focused on evaluating product safety risks for older
people — an area where we have identified a significant knowledge gap”.
The appliance of science
When it comes to sharing data and intelligence about high-risk products or product categories, how does Australia measure up? “The ACCC seems very active on the OECD Working Party for Consumer Product Safety,” Niven says. “They also have good liaison with overseas regulators.
“To communicate at the state level, we have very active collaborative groups. We’ve got one here in Queensland which has been operating for over 10 years. We meet every two months for a couple of hours to discuss emerging issues, share evidence and discuss product safety issues in depth.
“These groups include regulators, representatives from the Health Department and the Children’s Commissioner, as well as academics and charities. It’s amazing how much you can pull out from a data-sharing point of view when issues arise and we need to respond quickly.”
The ACCC also convenes a Consultative Committee at the national level which,
Niven says, “has been really good for information sharing. But I’m not sure how far that extends to the international level.”
It’s amazing how much you can pull out from a datasharing point of view when issues arise and we need to respond quickly
The UK has the OPSS National Product Safety Group, as well as initiatives such as the BSI’s Consumer & Public Interest Network (CPIN) and committees run by the Royal Society for the Prevention of Accidents and Electrical Safety First. However, the recording and analysis of data remains a problem for many on the Trading Standards front line (see page 54). That chimes with the experiences of Niven and her colleagues: “The need for accessible injury surveillance data is a shared priority for all stakeholders to inform regulatory responses, standards, product designs and public safety awareness campaigns,” she says.
In addition, Niven says that because of the global nature of modern supply chains, there is a growing need for a more international approach to product safety. “The OECD Working Party on Consumer Product Safety had a project a couple of years ago that was going to develop a uniform system for injury surveillance and a global injury data portal unfortunately that project seems to have stagnated.
“The way we describe products in Australia is different from the US and the UK, for example; even if we just had uniform ways of product identification, as well as standardised data collection, that would be really useful to enhance international information exchange.” l
1. Niven, Catherine: ‘Evaluating Australian and US consumer product safety regulatory responses to hazardous children’s products’. Queensland University of Technology, 2020
2. Niven, Catherine et al: ‘Navigating child product safety: Perspectives from experts on international challenges and priorities in regulation and research’. Australian and New Zealand Journal of Public Health, 2023
3. ‘Infant sleep products – Product safety bulletin’. ACCC, 2024
A new data-sharing initiative is just one of the weapons Inter Scientific is providing to Trading Standards in the war against illicit vapes
Inter Scientific provides laboratory testing and regulatory compliance services to businesses and enforcers with the same goal in mind: to promote compliance and, thereby, improve safety standards to the consumer. Having recently moved to a larger headquarters in Liverpool, the company has its sights set on expansion whilst supporting enforcement agencies — and is offering cash-strapped local authority Trading Standards departments access to a free members-only vape compliance database tool that could prove invaluable.
Tom Coleman, Inter Scientific’s Customer Solutions Advisor, has done a lot of work with Trading Standards teams over the past few years, and that relationship has only become stronger as time has gone on. “We’ve been working with Trading Standards since September 2022,” he explains. “It started off with just a couple of officers in Liverpool and Newcastle who needed vapes that they’d seized tested for compliance of fill volume and nicotine content.”
From that initial trickle, just like Trading Standards teams across the country, Inter Scientific quickly found itself faced with a deluge of noncompliant vapes with tank capacities well
beyond the two millilitre maximum, and nicotine contents far in excess of the legal limit of 20 milligrams per millilitre.
“Of the hundreds of vapes we have tested that Trading Standards send in, 78% are non-compliant with regulations for fill volume,” says Coleman. “We’ve had some as high as 20 millilitres. We’ve also encountered samples with up to 50 milligrams per millilitre of nicotine, 2.5 times the legal limit, which is incredibly strong and potentially dangerous.
“We’re finding that there is a huge epidemic of illegal products being sold on the market, either displayed freely in shops or hidden away.”
An area of concern is vapes that are being sold as nicotine-free, but which on subsequent laboratory analysis prove to be anything but. Indeed, in 27% of vapes tested nicotine is present and at levels close to the maximum legally permitted.
“The issue is that 0% nicotine vapes are not regulated or required to be notified in the UK at the moment,” says Coleman. “If a product is sold as 0% nicotine then tank volumes don’t have to be compliant to 2 millilitres — they can be sold online, and over the counter to under-16s. Trading Standards Officers in general are not
currently seizing these products because they’re not covered under the Tobacco and Related Products Regulations 2016 (TRPR).”
However, says Coleman, “We’ve had samples sent to us that had been labelled as 0% nicotine, and we found that about 50% of them did actually contain significant amounts of nicotine — a few of them even beyond the maximum legal amount.”
Inter Scientific uses UKAS-accredited methods to test samples and then produce certification confirming whether they are compliant or non-compliant, with typical turnaround times under 10 working days. The company can also provide Section 9 witness statements which can be used as evidence in any subsequent prosecution.
Inter Scientific has worked with Trading Standards teams across the UK, including recently on a project for the 22 local authorities in Wales.
There is a huge epidemic of illegal products being sold on the market, either displayed freely in shops or hidden away
To support Trading Standards in the fight against the illicit vape trade, Inter Scientific offers supported pricing to help local
regions maximise vape testing budgets and protect public health.
Julia McLachlan, the company’s Chief Commercial Officer, says: “Although Inter Scientific’s core business has historically centred around analytical and laboratory compliance testing linked to nicotine-containing products, there are many compliance commonalities that span into other regulated markets and segments. Expanding our capabilities and offerings in these areas could present further opportunities for Inter Scientific to support Trading Standards more widely than just with vapes, in areas such as cosmetic brand authenticity.”
As Inter Scientific received more and more samples from the fragmented Trading Standards regions, it was becoming increasingly clear that there was duplication in the products being tested. And in the age of squeezed budgets and constrained resources, the opportunity to cut down on unnecessary duplication can be a real game-changer. As Coleman explains, “We’ve got a lot of data that we’ve collected
over the past 18 months from Trading Standards on which vaping products are consistently showing up across the regions. To aid compliance transparency to enforcement agencies, we have developed and launched a vape compliance tool, a database containing results of all vape products that Inter Scientific have tested on behalf of Trading Standards.”
Trading Standards teams are now able to create a complimentary account on Inter Scientific’s Vape Aware platform, and see test results for samples that have been sent in by other teams elsewhere in the country. “Officers can look at and see which products are non-compliant, and then hopefully that will help them know whether they need to target specific brands, or they can use those results to provide evidence against the manufacturers of these products that keep ending up on the market,” Coleman says.
“We recognise how the budgets for Trading Standards in the fight against illegal vapes are relatively small,” says McLachlan. “We also noticed that different siloed regions were asking us to do repeat analysis on the same manufacturers or brands. The same analyses kept being done on the same products, which led us to
ask, how can we support Trading Standards holistically and help them to maximise their budgets effectively, by sharing that data across the different regions and councils. So, for example, Officers in Manchester can see what’s been tested for colleagues in Newcastle — and that could really help maximise budgets.”
As well as working side by side with enforcement agencies to tackle the illicit vape trade, a big part of Inter Scientific’s work is supporting responsible manufacturers of nicotine-containing products. “We remain impartial,” says McLachlan. “We support responsible manufacturers with analytical and regulatory compliance, ensuring that products put onto the market are fully compliant within the intended geographical region.
“We recognise that nicotine-containing products such as vapes offer a reducedrisk option and a valuable tool for adult smokers on their smoking cessation journey. Our compliance testing services support that only responsible manufacturers and regulatorily compliant brands and products — which adhere to established laws, regulations, and testing requirements — reach consumers.
“Our mission is for Vape Aware to become the trusted source of vape product compliance data in the UK, allowing consumers and retailers to determine whether products are notified and complaint. With that in mind we will be launching in the very near future Vape Aware phase 2, targeted with vape producers and associated supply chain partners in mind. Our goal being to drive an industry-led initiative for every batch of vape products in the UK to appear on the Vape Aware database so that consumers can ensure that their vape products are legal and compliant. l
Further information www.inter-scientific.com
The Vape Aware platform can be accessed at: vape-aware.com
Abbie Hunter People and Culture Manager at CTSI
Struggling to attract the best talent to make your Trading Standards team as highly skilled, motivated and diverse as possible? Here are some tips
Recruitment. It’s one of the tasks that comes with being a manager; surrounding yourself with staff and skills that complement your own and work together harmoniously to get the job done to the highest possible standards. Get it right, and the team goes from strength to strength and your reputation as a manager grows, but get it wrong and it’s catastrophic. So, what can you do to ensure that you get it right when recruitment isn’t your specialist skill?
If you work at a local authority, you are likely to have an HR department who can work with you to hire the right person for the right role. However, these people, much like myself, are often not experienced in Trading Standards, so I encourage you to understand the needs of your department and the communities you work in, to help the professionals hire the right people to the right seats. Alongside considering what experience is needed for the role — such as ability to address criminal offences and enforce consumer protection regulation, ensure legal compliance in inspections, advise and guide traders in areas of specialism — it’s also important to understand there are other important elements of recruitment. So, here are my top three considerations for hiring in 2024, as well as details of what CTSI is developing to support you.
The first thing to consider is the demographic of your team. In the CTSI 2023 Member Survey, only 7% of respondents were under 35, compared to 13% of respondents who were aged 65 or over. Whilst it is essential to retain these staff and allow them to pass knowledge onto the new recruits of any age, the lack of younger people in the profession significantly impacts the future of Trading Standards. If there’s no one joining to carry on learning the skills, there will be no profession to run.
So, ask yourself what options you have: can you take on an apprentice; what local schools and colleges have career days that members of your service can attend to attract younger people into the profession; and are you advertising in the most popular places? For example, Indeed has the highest number of active applicants across all job boards, but there are also specialist boards for demographics that you may need to hire.
The second area, with no less importance than the demographic of the team, is the demographic of the communities you serve. In the 2021 Census 18.3% of the UK population identify as an ethnicity other than White, but the CTSI 2021 EDI Survey identified 9.5% of Trading Standards Professionals
as belonging to an ethnic group other than White. This is extremely important when thinking about issues that may be present for specific ethnic groups, such as beauty products that are used by nonWhite consumers. There are also issues that will impact LBTQ+ communities, those with disabilities, and more, that may not be fully understood within your team. Additionally, some communities may not reach out to Trading Standards if they don’t see themselves as being represented by the service.
Finally, hiring in 2024 comes with nuances that were not present prepandemic which have positively affected many of us, including working parents and carers. In a 2024 survey by YouGov 57% of workers in the UK want the option
for remote working, almost half of young workers will not work for a company that requires them to work in an office full time. The Chartered Institute of Personnel and Development (CIPD) also notes that two million people changed jobs in 2023 specifically in order to be able to work more remotely.
Other than the advantages of reducing commute times and costs, home working also allows for a better work/life balance, improved happiness, and career fulfilment; studies by Care. com and Mother Honestly have showed that 66% of employees have other care responsibilities, and 73% have children who they are able to dedicate more time to. Offering flexibility in working location will help attract younger workers, workers
who have care responsibilities, and those who may find travel difficult due to physical or mental impairments.
So you’ve got your attraction strategy down, you’ve nailed the benefits and you’ve placed the best advert you’ve ever written onto the website that will generate the most candidates. The final hurdle in identifying your next colleague is the interview process. Interviewing has become easier with the introduction of remote working.
Candidates no longer have to book time off to attend in person, physical accessibility needs are met by eliminating any physical barriers, candidates can turn on captions or questions can be written
Alongside considering what experience is needed for the role, it’s also important to understand there are other important elements of recruitment
in messaging functions on most online platforms. For those interviews that need to be done face to face, it is important to remember to ask if there are any adjustments that are needed; in a 2022 survey by Prospectus Recruitment only 33% of candidates were asked if they required any adjustments for interview. This small oversight could reduce your pool by 67% and could leave you with pressure to hire anyone rather than the right one, which in itself then causes more issues when having to manage the person you’ve hired because they are not the right person for the job.
At CTSI we are developing a Tool Kit to enhance your skills as a manager. The goal of this is to raise awareness of the issues that impact recruitment in 2024, highlight areas of best practice to position you as a good employer, and give you the templates and skills to hire the best people to your team. We also have apprenticeships on offer, and we are actively working to develop new apprenticeships with authorities in each of the four nations, to ensure the future of Trading Standards is secured. We can also help you identify demographics that may need attention, and help you to influence your HR Department to improve your chances of hiring the best person. l
For more information about how CTSI can support recruitment, visit www.tradingstandards.uk/about-us/ equality-diversity-and-inclusion-2/
Juanita Headley Consumer Advisor, UKICC
The UK International Consumer Centre continues to assist UK consumers in resolving disputes with overseas businesses, as illustrated by some recent success stories
As the world continues to rebuild in the aftermath of the Covid pandemic, there have been great shifts in the way consumers buy and traders sell. Never before has it been so easy to purchase food, clothing, electronics and digital content with just the click of a button from the comfort of one’s own home. In fact, nowadays the availability and accessibility of goods and services knows no bounds, which unfortunately has its downside namely the ever-evolving rise in scams and counterfeit goods.
The good thing to note however, is that help is at hand from Emmanuella, Afzal, Harry, Patrick, Lauren, Beth and myself at the UK International Consumer Centre (UKICC). Our dedicated and hardworking team of legal minds has the drive, determination and commitment to fight on behalf of consumers.
With a 17-year history, the UKICC is still standing strong despite changes in government, Brexit, and recent organisational restructures. There’s now even more good news as the UKICC
recently relaunched its phone service, enabling consumers to have their queries more quickly resolved by phone rather than just via email.
The UKICC is making a difference, whether that’s through a consumer’s use of template letters, web advice, email support or phone consultations.
One consumer who was helped by the UKICC was C. She purchased flights directly from an airline, received her e-tickets and was eagerly awaiting her departure. To her dismay, however, the flight was cancelled, and her trip postponed.
C contacted the airline to request compensation and a refund of her ticket; however when six months later she had yet to be reimbursed, C contacted the UKICC to request our intervention. C understood that we are not an enforcement agency and that although there are limitations on the scope of our service, we could still provide a degree of mediation by contacting the airline on her behalf.
Consequently, a short while after we contacted the airline, we were thrilled to inform C that the six-month wait was finally over as the airline had agreed to refund the cost of her ticket and compensate her for the flight cancellation.
In another success story, a different consumer, E, was emailed a few days before her flight and offered a complimentary helicopter ride from the airport to the city. Prior to her return trip she contacted the helicopter company and the airline to request another complimentary flight. Her request was denied; however, E was informed by the helicopter company that she could get another helicopter ride on her next trip.
E emailed the helicopter company four months before her next trip to request a helicopter. Her request was denied, and she was directed to the airline, which also denied her request.
Two weeks before her upcoming trip E contacted the airline through its online chat platform and was informed that as
she was not a loyalty member she was ineligible for a helicopter ride — she was also told that she should not have been offered a ride previously, and that it had not been a system error.
Unwilling to settle for the airline’s lack of explanation — or its denial that E was ever on board a helicopter — she contacted the helicopter company again, after speaking to the UKICC, and informed them that one of their employees had promised her a helicopter ride and that the airline had not honoured this. Her persistence paid off and the helicopter company informed her that although the airline was no longer offering the complimentary helicopter ride, they would make an exception and book her a flight.
Another consumer, B, had booked a motor home for a week’s hire period during the summer. Two days before the end of the hire period, whilst B was attending an event, he witnessed another driver cause scratches to the side of his rental vehicle.
With a 17-year history, the UKICC is still standing strong despite changes in government, Brexit, and recent organisational restructures
B immediately informed the rental company, completed all the relevant forms, and returned the motor home, knowing that the other driver was responsible for the damage and had liability assurance.
When the rental company failed to return B’s deposit, he contacted the UKICC. We contacted the rental company and within nine days B was fully refunded.
When M found a hair inside a burger from a well-known fast-food chain, she immediately contacted both the company and an Environmental Health officer following advice from the UKICC. The chain wrote to M offering a £10 voucher for her next order which she declined, requesting £50 instead — and the company agreed to honour her request.
In another case, J had used multiple
credit cards to pay for a one-week training course. Although she was already an expert in the subject matter that was being taught, she wanted accreditation which the course was offering. Due to lockdown restrictions the course went ahead remotely. However, to J’s disappointment and despite all that was advertised, there were not multiple trainers, the course content was basic, and the promised certificate was never awarded.
J requested a full refund from the educational establishment and the three credit card companies. Two of the three creditors worked with J to get a refund; however the third company sent J on a wild goose chase, giving misinformation and eventually denying her claim.
One and a half years later with the use of a template letter, a deadline of seven days and the ‘threat’ of further legal action, J received a refund for the third payment directly from the educational establishment itself without the help of the third creditor.
These are just a few of our many success stories. Whether it was direct involvement in a case by speaking to a trader, providing advice or guidance, empowering a consumer concerning their legal rights, or the self-help material and templates on our website, the UKICC continues to be a great source of help, with legal advisors available to respond to consumers’ letters, emails, and phone calls between the hours of 10am-4pm Monday-Friday. l
The UKICC can be contact by phone on 01268 886690 or via email at UKICC@tsi.org.uk
Giles Speid
Team Manager in Public Protection & Licensing, City of Westminster
‘To serve them all my days...’
Retirement from Trading Standards doesn’t always mean an end to participation in the profession, as three energetic and passionate former TSOs demonstrate
In RF Delderfield’s novel To Serve Them
All My Days, a soldier returns from World War I shell-shocked from his time on the frontline and goes on to become an inspirational teacher because he feels it is his duty to continue to serve the public. Like him, many of those who once worked in our profession continue to assist the public as it is in their nature.
Retirement can leave one feeling slightly traumatised — interactions with colleagues are missed, along with the pressure of deadlines, meetings, and decision-making. Many people still feel the need to continue to work — albeit in a different, more relaxed capacity, providing encouragement, advice, help and guidance.
I know of three former stalwarts of the Trading Standards profession who continue to make a difference to people without financial reward, out of a desire to help family, friends and consumers.
Chris Armstrong, Marcia Brown and Nora Walsh are all unsung heroes, still making a difference to the profession and those it serves. They are not social media types who are posting their every move or looking to become influencers — they are doing their voluntary work for the love… not for the likes.
Chris Armstrong
Having started his career at Margate Trading Standards, Chris has remained in the profession all his working life. Chris started his career in 1965 and moved to other authorities, climbing the ladder before ending his career at Newham Trading Standards.
“I always did charitable work outside of Trading Standards and I am a trustee of a local charity called Cottage Community, supporting elderly people with minibus trips to sightseeing areas,” he says. “We take them out as often as we can, because people are struggling at the moment.”
I have witnessed Chris’s commitment first hand, when he had to drop out of a meeting to deliver ‘meals on wheels’ lunches — he was many of the recipients’ only contact that day. He does this three days per week.
Following Chris’s retirement he has continued to work, doing admin for the CTSI London Branch. He is currently secretary of the London Branch Race and Equality Group. “I volunteered to go on
“The more I say I need to slow down, the more they find for me to do!”
this group straight away as I have always believed in equality and inclusion,” he says. In addition to this, Chris was appointed to his role as Chair of the College of Fellows in 2020. In 2023 Chris received the Special Award from CTSI for outstanding contribution for his work.
“The more I say I need to slow down, the more they find for me to do! I don’t mind really, it’s nice to be wanted,” he adds.
Marcia Brown
Marcia started her career with Brent Trading Standards in 1987, then moved on to working for Bedfordshire Trading Standards before taking early retirement from Waltham Forest Trading Standards in 2021.
In the midst of her career, Marcia took time out to have children. “We moved to Thailand where my husband was a teacher,” she says. “I lived there for three years and volunteered whenever I could. The difference in culture didn’t frighten me as I knew I was going to welcome it.
“When I returned to England three years later, I resumed my career in Trading Standards.
“I ended my career as the Chief Weights and Measures Inspector at Waltham Forest but found myself still volunteering to help make the profession
for Islington Trading Standards.
a better place to work. I continue to work with the CTSI London Branch.
“Even though I have event-filled days, as a former Trading Standards Officer, I still find myself giving consumer advice to people in my village, as well as to friends and family, on consumer matters such as Section 75 of the Consumer Credit Act 1974, scam advice and business compliance.
“I recently volunteered to attend the REACH Society Careers Conference in London (see page 50). It was wonderful to engage with young people and introduce them to the world of Trading Standards.
“I am a mentor on the Ubuntu inclusive mentoring programme, where I get an opportunity to share my lived experiences with other managers, Heads of Service and executives within the Trading Standards service. This is rewarding and challenging in equal
“I still find myself giving consumer advice to people in my village” “I want vulnerable people to know how to deal with cold callers”
measure. I never expected to be able to share my experiences, and it gives me an opportunity to help them see things through a different lens.”
Nora Walsh
Nora Walsh may live in the countryside, but says she is still very much part of London: “I go back every few weeks where I still have family and friends.”
Having been born and brought up in the multicultural area of Tottenham, Nora says, “I remember having curried goat as a child and I can still understand the Jamaican dialect without a problem. I have always been part of a multi-cultural community, especially when I was a manager in Hackney.”
During her career Nora also held roles at Enfield and City of London Trading Standards, and at the time of her retirement in 2021 she worked
“When I was working in Enfield, I was aware of the ‘A10 divide’, where life expectancy can differ by as much as 10 years depending on what side of the tracks you are from. It was important to recognise that when helping people who need your services.
“When I left Trading Standards in 2021, I ended up Volunteering for Age UK Cheshire East for several hours per week. I really want vulnerable people to know how to deal with cold callers and other scams.
“When you are helping and advising people you have a lot of experience and knowledge in you, and sometimes it’s difficult not to take control, but you don’t because people are doing their best. I am there to help and provide support,” Nora adds. “The help we provide crosses all demographics. Having the experience of working in London makes dealing with all races second-nature.
“Occasionally people see me and assume I may hold the same views as them when they are complaining about migrants. I stop them and say, I am a daughter of migrants from Ireland. That usually stops them in their tracks.”
The Age UK team, including Nora, were presented with a CTSI Hero award in 2023 and featured in the Winter 2024 edition of the Journal of Trading Standards l
Valerie Simpson Assistant Director of Environmental Health & Regulatory Services, Hammersmith & Fulham Council
Ever since Valerie Simpson began her career in Trading Standards 30 years ago, she has been determined to make the most of every opportunity that comes her way
Like many people who have made Trading Standards their career, when I started out I knew very little about what the job involved. It was the mid-1990s and I was studying law at evening classes when I saw an advert in the local paper for a job at Croydon Trading Standards which got my attention. Having some legal knowledge and working as a Parking Control Officer, I was able to demonstrate transferrable skills in the use of PACE notebooks, evidence-taking and interpretation of the law. I quickly completed the Diploma in Consumer Affairs to get the qualification under my belt, and to familiarise myself with the wide-ranging aspects of being a Trading Standards Officer.
I knew quite early on that I wanted to become a manager. Back then, there was more of an emphasis on having the weights and measures qualification for managers — and to be honest, that’s something I didn’t feel much of an affinity for. There were, however, many aspects of the job that I absolutely loved. There are so many opportunities to learn and develop on the job. As well as the technical knowledge that you gain regarding specific laws, you can develop
other management, IT, professional and interpersonal skills; like customer care, presentations, training skills, time management, conflict management, auditing as well as managing people, budgets and organisational change. There were also opportunities to move quite seamlessly between authorities, especially in London. Doing that can give you a perspective into other cultures, experiences, and different ways of doing things. One of the things that really appealed to me was the fact that you have a high level of autonomy in managing your own day — and with the support of your manager and your team you can discuss ideas to get second opinions (we are not backwards in coming forwards with opinions in Trading Standards!). It’s good to hear as many voices as possible to get a balanced and considered view.
I got my first team leader management role a few months after being weights and measures qualified and I didn’t practice much metrology after that! It was worth getting the Diploma in Trading Standards (although I will never forget that ‘dreaded’ oral exam at Teddington), and I think the qualification gives you that extra edge.
Changing with the times
One of the key changes I’ve noticed during my time in Trading Standards is that we are responsible for a lot more areas of enforcement, and we have less time to engage with the public. I was reminiscing with some colleagues recently at the REACH Conference (see page 50) that we used to do a lot more community engagement; we’d get out in the community at least once a month and speak to residents about what we do.
A lot of that has stopped now and to a large extent we work behind closed doors at arm’s length from the public, particularly now there is no direct point of contact with consumers making complaints. I think that is a real shame, and hopefully community engagement is something we can start focusing on again — CTSI’s manifesto (see page 5) includes a call for the introduction of consumer education lessons in schools, and things like the REACH Conference and the Young Consumer Hopefully community engagement is something we can start focusing on again
Influencer of the Year award are a fantastic opportunity to rebuild those links.
When I was starting out, there was almost a competitive rivalry between Trading Standards and Environmental Health, and the two professions were almost seen as ‘us’ and ‘them’. But over the years I’ve seen greater alignment and more similarities than differences, and there are a lot of opportunities for the two disciplines to work collaboratively.
The National Trading Standards Estate and Lettings Agency Team (NTSELAT) is a great example of bringing these two disciplines together for a common aim. Trading Standards has a role to play in making sure that tenants aren’t being short-changed and Environmental Health tackles disrepair and health and safety issues in private sector housing. My authority is participating in a regional London-wide project which is encouraging people to report through a single route, no matter what their housing issue is.
Similarly, Licensing has been a great driver in bringing Trading Standards and Environmental Health professionals
together. It’s really important to be able to pool our resources to tackle key issues, like safeguarding the vulnerable from financial abuse, tackling food fraud and energy-efficiency. Adopting a multipronged, ‘one council’ approach can help us to be more effective and impactful.
Like many of us, I’ve always had a high work ethic and I’m a keen advocate of continuous professional personal development. That being said, it would be remiss of me not to mention any personal challenges or barriers.
Experiencing explicit discrimination is rare these days, but speaking to colleagues it is clear that there are subtle ways to hold people back from their full potential. Similar to myself they have not always had the support, mentorship and encouragement that perhaps some of their peers may have had.
I’ve always tried to grasp opportunities as they come. As a senior manager, it’s become more apparent that there aren’t many visible people at senior levels who look like me. Having only a few Black female senior managers with responsibility
for Trading Standards and Environmental Health teams has stimulated me to help promote equity, diversity and inclusion (EDI), in all forms, across both professions. I have done this as Chair of our London Strategic Regulatory Network, by facilitating training and networking, surveying businesses and sharing best practice. But London is very diverse and I am pleased that ACTSO has signed up to the Race at Work Charter and their EDI Working Group is active on the topic of inclusion too.
Over the years I’ve seen a big shift and there are definitely a lot more women now in the Trading Standards profession, and a lot more female managers. However, there is still a need for continued efforts to make the profession as diverse as possible in terms of age, race and other protected characteristics — doing that can only strengthen us and enable us to stay relevant and better serve our local communities. Qualifications are useful to evidence knowledge and technical ability, but I think experience counts for more. You can’t go on a course to learn some of the things that you might need to know in this job, such as managing budgets, relationships with Councillors and embracing change — you can only pick them up through practical experience. I encourage my managers to grab opportunities that provide them with a chance to try something new and I support them to gain as many transferrable skills as they can.
I was encouraged to get experience of other disciplines beyond Trading Standards, which has helped with my personal development and networking. Going to events like Conference and volunteering to sit on working groups provides opportunities to meet new people. I’m really pleased that CTSI and CIEH are joining forces for Conference this year.
My advice to anyone starting out in Trading Standards would be to stay focused, set some development goals early on, and stick to the journey towards that. Get qualified, get experienced, keep up to date with legal changes —and learn all the countless acronyms! l
How should the profession respond to the rising level of anger, intimidation and physical aggression directed towards frontline Trading Standards Officers going about their duties?
No one should have to endure harassment at work. But for many Trading Standards professionals, this has long been part of the job. It’s not right and it’s not acceptable, but it happens. In a recent online poll carried out by CTSI, every single respondent said they had experienced some kind of harassment while going about their duties.
Furthermore, Officers believe that intimidation towards the profession has risen in recent years for a number of reasons, including a widespread, and growing, lack of respect for people in positions of authority. Katherine Hart is
CTSI Lead Officer for Doorstep Crime, Scams and Consumer Vulnerability. During the course of her career, she has been sworn at, spat at, pushed, and told “I hope your baby dies” when she was pregnant.
“It’s such a changing world out there,” she says. “Now we deal with serious and organised crime groups. There is knife crime. The time of just tackling a local rogue trader or someone who hasn’t done a good job has gone. We are now looking at a much more serious element to the criminals that we are seeing.”
Hart believes that new requirements on
Trading Standards to tackle different issues have created new challenges. “I feel that people don’t respect the local authority in the same way any more. We are not seen in the same light as some other enforcement authorities, and I feel that we are now being put at risk, with criminals who are on a different scale than they ever were before. As a result, because of this lack of understanding and a lack of respect about what local authority enforcers do, I feel that we are in a situation where it makes us more vulnerable.”
Marsha Bell, CTSI Lead Officer for Vaping and Regulatory Services Lead Practitioner, Trading Standards & Licensing at Salford City Council, agrees that the landscape has changed, leading to more intimidation and harassment of Officers. “I’ve been in Trading Standards
In the last 12 months, I’ve had Officers who’ve been threatened with shotguns
“Speaking to peers and colleagues, it feels like it’s escalating across the board, not just in Trading Standards. You speak to Environmental Health colleagues, and they’re experiencing more hostility within their profession as well.”
Steph Young, CTSI Lead Officer for Animal Health and Welfare and Trading Standards Team Leader for Food, Feed & Animal Health at Staffordshire County Council, agrees that harassment is a real problem. “I’ve seen it rise over the last couple of years and I think it has got worse. If you look at the health and safety reporting that I keep, you can see the majority of the reports relate to fear of aggression towards Officers. In the last 12 months, I’ve had Officers who’ve been threatened with shotguns and we’ve reported it to the police. Even though we’ve got it on bodycam footage, the police have taken little action.
“We’ve had Officers who have been threatened to be shot and put into a wheelchair. One of my colleagues in Wales has got video footage of one of her Officers being headbutted.”
Don’t suffer in silence
for over 18 years now, and I feel like it’s escalating,” she says. “I’ve always had issues in certain areas. I’ve spent a lot of time seizing counterfeit goods and illicit tobacco. You’d find that you get a little bit of hostility because you’re taking people’s goods and, in essence, you’re taking the money from them. But I feel like, more recently, you’re getting hostility for just going into a business because some businesses automatically think that you’re there to punish them. You find that you’ve already got the business’s back up just by your presence.”
She adds: “I think it’s definitely got worse. Looking at the experiences of my colleagues, we’ve got Officers doing food standards visits and getting hostility on a level that we’ve not come across in the past.
While the provisions in place to protect Officers vary across the country, Trading Standards professionals are advised to perform dynamic risk assessments when visiting premises, to report any incidents of abuse to managers and, if necessary, to the police. Logs of incidents should also be recorded by departments so that problem traders can be identified ahead of visits.
Young says that it’s vital that local authorities embrace the health and safety needs of their Officers, including having policies in place relating to remote working. “For our complaint-driven work, you’re always going to be sending in more than one Officer. You could not send one Officer in now to deal with the complaints whereas, years ago, we’d have thought nothing of it.”
Hart believes that it’s crucial to ensure there’s an adequate risk assessment and that the relevant tools are available:
“I’ve worked with local authorities who have taken time to do really good risk assessments and provide the right PPE and the right training, which is paramount. However, I’ve also seen certain local authorities that don’t see it as the same priority. They feel that personal safety can be dealt with by an online training video, or they think that just installing something like an app on a phone will suffice.”
She adds: “The most important thing is that you’ve got to speak out about it, because how can your bosses know that there’s an incident, whether it be a serious incident, a near miss, or just the fact that you felt uncomfortable? People don’t talk about it because sometimes they feel as though they will be viewed as being weak or vulnerable, and that is not the case at all.
“We always ask victims of crime to speak out. We’re urging people to speak out all the time. But our own Officers also need to speak out”.
Meanwhile, Bell says that harassment should not be the norm. “It shouldn’t be something that we just deal with. People are becoming more open to being verbally and physically abusive while Officers are undertaking what, a lot of the time, is statutory work. We have a duty to enforce different pieces of legislation. We shouldn’t be abused for enforcing the rules and regulations.”
CTSI Chief Executive, John Herriman, says: “Accounts of aggression and physical violence directed at Trading Standards Officers are a real cause for concern to the Institute, and to anybody who values common decency and the rule of law. It is upsetting and disturbing that our colleagues are facing such anger and obstruction when going about their duties.
“Trading Standards teams go above and beyond to keep the public safe, and they deserve to feel safe while doing so. We will be raising this issue with government and local authorities, and pushing for more resources and training to protect Trading Standards professionals while they carry out their vital work.” ●
The DMCC Act is a landmark piece of legislation with implications for everyone in Trading Standards. From its conception to its imminent launch, CTSI has had a role in steering it through its various stages
“One of the biggest changes to our legislation in the last 10 years — it really does matter.” That’s how CTSI Lead Officer for Fair Trading, Sylvia Rook, describes the Digital Markets, Competition and Consumers (DMCC) Act which, after several years of consultations, committee hearings, amendments and parliamentary scrutiny, is due to come into force later this year.
Rook is well placed to understand the importance of the DMCC Act and its ramifications for Trading Standards. Along with her colleagues, CTSI Lead Officer for e-Commerce David MacKenzie and CTSI Lead Officer for Civil Law, Jemma Cox, she has been instrumental in ensuring that the voice of Trading Standards was heard loud and clear throughout the Bill’s long gestation.
Between them, and with the support of well-placed allies in Parliament, they advocated for greater powers for Trading Standards — and consequently greater protections for consumers — to be included in the legislation. And, while not everything on CTSI’s wishlist will make it into the DMCC Act’s final version, the productive nature of the discussions means that the Institute and its experts are likely to have a seat at the table when any future conversations about amendments and related legislation take place.
Long time coming In the government’s words, the purpose of the DMCC Act is to “provide for the regulation of competition in digital markets; to amend the Competition Act 1998 and the Enterprise Act 2002 and to make other provision about competition law; to make provision relating to the protection of consumer rights and to confer further such rights; and for connected purposes”.
If that sounds complicated, wideranging, and somewhat vague, that’s because it is. The DMCC Act encompasses huge areas of online activity relating to communication and commerce, only some of which are relevant to Trading Standards. Among these are new rules relating to the display of pricing information and hidden fees; fake and misleading reviews; and new powers for Trading Standards Officers.
It’s a word here and there that makes a significant difference to things that happen in the real world
others,” says MacKenzie. “A lot of that is in the detail; it’s a word here and there that makes a significant difference to things that happen in the real world.”
While CTSI has been calling for enforcement powers to be updated in line with online buying and selling practices for many years, its involvement officially began during the DMCC Bill’s initial consultation and planning stage back in the autumn of 2022.
“We were happy with a number of things that were in the first draft of the Bill, many of which were included as a result of previous lobbying by Sylvia and
When the process began, the Department for Business, Energy and Industrial Strategy (BEIS) was responsible for the DMCC Bill; it has since been rebadged as the Department for Business and Trade (DBT). In late 2022, BEIS asked CTSI for input on potential amendments to the Consumer Protection from Unfair Trading Regulations 2008 (CPRs), Cox explains. “Around that time, they were reviewing the sunset clause of the Retained EU Law Bill and essentially, this was an opportunity for us to save our main piece of fair trading legislation by moving it into primary legislation.
It also went hand in hand with all of the campaigning work that was being done by CTSI to save our legislation and safeguard our standards around that time.
“We had some liaison meetings with the Competition and Markets Authority (CMA) in November 2022 to discuss areas where we have common interests. We were able to feed into the draft of the DMCC Bill in February 2023 and provided detailed feedback, some of which made it into the definitions and changes that are in the final version of the Bill.
“When we were looking at our priority areas we were aware, even from those early stages, of what was likely to be included anyway,” Cox adds. “So we turned our attention to the big issues for enforcement officers. As Lead Officers,
it’s really important for us to think about which areas are the most important so that our colleagues, the Officers on the front line, are able to do their job.”
Among the important aspects of the DMCC Act which touch on Trading Standards’ work are a ‘rewrite’ of the CPRs, with improved definitions of ‘misleading actions’ and what constitutes a ‘vulnerable consumer’; additional banned practices, including around the wording that can be used in health claims; a clearer concept of aggressive practices; and a new mechanism for the Secretary of State to create new banned practices.
On the issue of consumer vulnerability, the DMCC Act states that a group of
It’s really important for us to think about which areas are the most important so that our colleagues are able to do their job
consumers may be considered vulnerable as a result of (among other things) their age, their physical or mental health, and their circumstances.
Rook says she is pleased that this has been factored into the legislation: “The definition of ‘vulnerable consumers’ has caused us problems right from the start,” she observes. “A lot of the definitions have now been simplified, which has made things better for consumer protection and enforcement. It’s good that somebody can be considered vulnerable because of the circumstances they’re in; that really does help and it will make enforcement easier.”
The DMCC Act also contains new ‘punitive’ measures for civil enforcement cases, including mechanisms to supplement ‘injunctive’ and ‘restorative’ measures already in place, and new monetary penalties for failure to comply with information notices. There will also be strengthened court options and new ‘levers to bring about positive informal outcomes’, as well as some new investigative powers for Trading Standards.
Among the latter, perhaps the most significant is the extension of powers so that Trading Standards can apply through the courts for Online Interface Orders (OIOs) against traders that mislead consumers. An online interface can be defined as ‘any software, including a website, part of a website or an application, that is operated by or on behalf of a trader, and which serves to give consumers access to the trader’s goods and services’.
OIOs are important to Trading Standards because they will make it easier to carry out investigative and enforcement action online. Up until now, only the CMA had the ability to apply for an OIO, and the fact that they are now part of Trading Standards’ toolkit should help disrupt persistent problem traders. And, theoretically, at least, they will be applicable to giant online marketplace platforms as well as the small third-party sellers that operate on them.
According to MacKenzie, “Originally the takedown powers made possible by OIOs were only going to be given to CMA. It’s important, partly for us to be taken seriously as regulators, that those powers have been extended to Trading Standards.”
Partial victories
Another thing that the CTSI team pushed for in their discussions with government was the banning of fake reviews. Here they achieved what Cox describes as a “partial win” — under the new legislation, the use of fake reviews will be classified as a civil infringement, rather than a criminal offence. “Getting fake reviews included in the Bill was really important for us,” Cox says. “But it wasn’t a full win, because we still believe that they should be criminal.”
However, MacKenzie observes, the influence that CTSI was able to exert stands Trading Standards in good stead to keep up the pressure for future changes to the legislation. “If you look at the things that we were pushing hard for, once the Bill was being discussed in Parliament, we knew we wouldn’t get all of them. But part of it was about positioning for the future, and I wouldn’t want to present that as a failure,” MacKenzie says.
Rook is disappointed that fake reviews have not been criminalised, but like MacKenzie and Cox, she is philosophical about the progress that has been made. “I think the frustration was the fact that we didn’t say we want to prosecute everybody who gives a fake review — what we said was, we wanted fake reviews to be on a parallel with the other banned practices,”
It’s important, partly for us to be taken seriously as regulators, that those powers have been extended to Trading Standards
she points out. “We want to have the option of taking criminal or civil action depending on the circumstances, because it is a fraudulent practice — there’s a deliberate ploy, if you’re buying or giving fake reviews. If that was classified as criminal, then there are tools like the Proceeds of Crime Act that could be used. If it’s a civil matter, we don’t have that option.
“With enforcement, there’s often a carrot and stick — and sometimes the stick is necessary. Yes, we work with businesses, and we would very rarely prosecute somebody on the first opportunity. But it’s good to have options, otherwise it can be like fighting with one hand tied behind your back.”
Another area where CTSI plans to keep up the pressure is around improvement in access to data stored digitally or in the Cloud. At present, much of the legislation at Trading Standards’ disposal was designed with physical premises in mind — which is all very well and good when you’re tackling a rogue builder or a warehouse full of illicit goods, but not so useful in the age of virtual storefronts and online marketplaces.
“At Conference last year, I bent the ears of numerous barristers, to ask them if you could virtually enter a virtual premises,” Rook says. “The answer was an emphatic ‘no’. That’s something we need to keep fighting for.”
As MacKenzie points out: “What we were trying to say really simply was, are our powers fit for this digital world? And our suggestion is they’re not. We need to have a powers review, essentially — we have raised it, and we have it documented in Hansard, which is really important.”
“I think the fact that they actually listened to us, and they invited us to further meetings, is a major positive,” Rook says. “Government is a bit like a juggernaut — you can’t just put your hand up and stop it. So if you can have any movement on it at all, then that’s a huge success.”
Kerry Nicol, CTSI’s Policy and Campaigns Executive, was also instrumental in much of the legwork to ensure that Trading Standards’ views were heard at all stages of the DMCC Act’s progress through Parliament. She coordinated meetings
and briefings with supporters and peers, including CTSI President Lord Jamie Lindsay, CTSI Vice President Baroness Christine Crawley, and Baroness Cathy Bakewell.
“We’ve never seen engagement like this from a government department on a Bill before,” Nicol says. “We had multiple meetings about how the improvements suggested would work for the people on the ground. The government has also said that they’re open to further conversations around the points that we didn’t manage to agree on.
“It’s important to say as well, that the support we had from the peers has been fantastic. They really did get behind us and took the time to sit down and understand what the issues were. And David, Sylvia and Jemma have all worked tirelessly on this on behalf of the profession — the progress we made, and what we achieved, just wouldn’t have been possible without them.”
“Having cross-party people speaking on our behalf, and having Trading Standards being talked about in Parliament — all of these things are very great positives,” MacKenzie adds.
Government is a bit like a juggernaut… if you can have any movement on it at all, then that’s a huge success
So, what next? The DMCC Act was passed on 23 May, and it is likely to come into force in the autumn. The scale of the legislation and its implications will require additional training to ensure that Trading Standards Officers are up to speed with the minutiae — and, with time and budgetary constraints affecting councils across the country, getting everyone trained up in time may be easier said than done.
Nicol says: “The concerns we’ve got are around the training that needs to happen. There have been fundamental changes, and things that Trading Standards Officers need to know about. And there’s been no offer of funding from DBT to help with that training — although they have said that they’re open to conversations about it.”
It’s a concern that Rook shares: “This is a topic that affects everyone, and I would argue that everyone in Trading Standards needs to be aware of it, because it’s so broad-ranging and basic for what we do. Pretty much everyone should be trained on this and that’s a big undertaking. With things like cascade training, which is
The DMCC Act’s key points
● A ‘rewrite’ of the CPRs, including new definitions and an improved definition of ‘vulnerable consumer’
● Reordering of the banned practices and amended wording
● A banned practice relating to fake reviews (civil only)
● Clarified rules on drip pricing and hidden fees
● New ‘punitive’ measures for Trading Standards
● The extension of online interface orders to Trading Standards
● New rules on subscription contracts
● New requirements for consumer saving schemes
● Amended powers in Schedule 5 Consumer Rights Act 2015
● New requirements for secondary ticketing facilities
what a lot of local authorities like, things gets filtered and the subtleties get lost, whereas when you hear something firsthand, you can ask questions.”
The DMCC Act’s main implications are summarised in the boxout above and there will be sessions on the Act at Conference in June, which all CTSI members are encouraged to attend (see page 56).
As Rook points out though, the scale of the legislation will mean that even those who are well-versed in its subtleties will still need to be on their guard: “It’s got 418 pages, 339 sections and 29 schedules. That’s a whopping piece of legislation.
“I am very concerned that some of the changes, although they’re subtle, are very significant. And if Trading Standards Officers and solicitors aren’t aware of them, there could be all sorts of problems down the line. For example, the schedule of banned practices has been renumbered from how they are set out in the CPRs, which could make things really difficult for enforcers who think they already know the rules. There have also been substantial changes to parts of the Enterprise Act as a result. You really have to keep your eyes open for these things.” l
An NTS-led investigation of a multimillion-pound ticket touting scam which made national headlines came to a conclusion last month with the perpetrators being brought to justice
TQ Tickets was a family-run enterprise which bought concert tickets in bulk from primary sellers online and then, once events had sold out, sold them on to consumers at vastly inflated prices.
Led by the self-styled ‘Ticket Queen’ Maria Chenery-Woods, her husband Mark Woods, her sister Lynda Chenery and the latter’s former husband Paul Douglas — who dubbed himself ‘Ticket Boy’ — TQ Tickets perpetrated a variety of fraudulent practices involving fake identities, multiple bank accounts and blatant scams.
Olga Kiptily, Senior Investigator with the National Trading Standards (NTS) Regional Investigations and eCrime Team, says TQ Tickets first came to the team’s attention in 2016 around the same time that journalists from the Guardian and regulators at the Competition and Markets Authority (CMA) were looking
into the secondary ticketing market.
“The CMA shared some intelligence with the NTS Intel Team, who looked at the top three traders there were concerns about, and those three were selected for investigation — with TQ tickets being one of them.”
Those concerns were corroborated during the course of the subsequent longrunning and painstaking investigation, codenamed Operation Zebedee.
Ruth Andrews, Regional Investigations and e-Crime Manager at NTS, says: “We looked at activity on the suspects’ bank accounts, which showed that they couldn’t possibly be buying tickets for their own consumption. Together with that, there was data obtained which made it obvious that the tickets were being purchased from primaries, then resold and marketed to consumers.”
According to Kiptily, the TQ Tickets
empire was a close-knit, family affair.
“Maria was the brains behind it all. She was mega-enthusiastic about the ticket market and about making a lot of money, buying as much as possible and covering as many events as possible.
“It emerged during the trial that Maria was not the most organised of people, so running a business really required somebody else who was a lot more business-minded. Lynda looked after that side of things, and Mark Woods provided some of the financing. Paul Douglas did a lot of the buying and selling, and he was also instrumental in recruiting individuals to assist with the purchasing.”
TQ Tickets operated out of an annex attached to the family home in Norfolk. When NTS Officers executed a warrant there in December 2017, they found the operation in full swing, with several members of staff on the premises.
“We recovered a number of computers and phones, as well as a folder of credit cards, and a list of all the cards they were using and the amounts available
This wasn’t just about making a profit on reselling tickets they shouldn’t be reselling… It was about finding multiple ways in which they could exacerbate the fraud
on those,” says Kiptily. “The scale of the operation was very telling.”
As well as a wealth of financial data, the NTS team also uncovered evidence of how the TQ Tickets scam worked in practice.
“There was a whole series of different ways in which they would commit the fraud,” says Andrews. “One was posing as consumers and not declaring that they were actually traders, which is a specific offence under the Consumer Protection from Unfair Trading Regulations 2008 (CPRs). They were also not informing consumers that the tickets might be invalid because they were breaching the terms and conditions of the original sales.”
Another tactic used was ‘spec selling’; “They were selling tickets that they didn’t physically possess in the hope that they would get them later,” Andrews says.
“When they didn’t get the tickets, they would send out false tracking numbers.
“They also sent empty envelopes that were torn, in the hope that somebody would think the tickets had been stolen in the post. They would use Tipp-Ex on tickets, and change the ticket type or the seat number. There was a whole variety of
things,” Andrews concludes. “This wasn’t just about making a profit on reselling tickets they shouldn’t be reselling. It was about finding multiple ways in which they could exacerbate the fraud and maximise their profits.”
The TQ Tickets case follows that of BZZ Ltd, which was also investigated and prosecuted by NTS. In 2020 the ticket touts behind that company, Peter Hunter and David Smith, were jailed and ordered to pay a £6.2m confiscation order after being found guilty of fraudulent trading.
The scale of the secondary ticketing market, with some tickets being sold for as much as 290 times their face value, has prompted some — including the CMA and the Labour Party — to call for tougher rules for secondary ticket sellers.
Among those arguing for a change in the law is FanFair Alliance which, says Campaign Manager Adam Webb, “was founded by managers of artists including Arctic Monkeys, Radiohead and Little Mix, to deal with their frustrations over their fans being exploited”.
“Ticket reselling is a mass market where there is zero transparency,” Webb says. “Other countries are taking a stronger line on this — Ireland being the most recent one in 2021 — to prohibit the resale of tickets for profit. I think that’s the line we need to go down, and I think that will provide clarity for consumers.
“We need to draw a line under this kind of industrial-scale touting and rip-off of British consumers, and try to grow the proper resale market where if you can’t go to a show, it’s really easy to sell a ticket, and someone else can have it.”
The DMCC Act (see page 42) includes amendments to the Consumer Rights Act 2015, including measures to prevent secondary ticketing facilities listing tickets without proof of purchase; banning resellers from selling more tickets to an event than they can legally purchase from the primary market; and requiring secondary ticketing facilities to ensure
that the face value of the ticket, and the reseller’s name and trading address, are clearly visible.
In the TQ Tickets case however, says Andrews, “The frauds were so blatant that we didn’t need any other legislation because it was so clear — all it required was access to the bank accounts, and warrants at the home addresses.”
That is not to say that the prosecution was straightforward though. Challenges around the disclosure of evidence led to delays in the trial, as did the Covid pandemic. Another obstacle, Andrews says, was “the sheer quantity of digital material being recovered. I think that’s probably one of the key learning points from this case; we are dealing with digital disclosure in an entirely different, very structured, way now.
“The other challenge was the quantity of bank accounts being used. The amount of analysis of those accounts that was required, and the need for forensic accountants, led to very significant costs. These types of big frauds where there are multiple defendants, bank accounts and digital devices, can be very expensive for enforcement. And that’s why NTS is there — we are funded to be able to deal with those types of cases where local authorities aren’t necessarily in that position.”
Mark Woods and Lynda Chenery were unanimously found guilty of fraudulent trading offences on 13 March 2024; Maria Chenery-Woods and Paul Douglas had entered guilty pleas earlier in the process. On 17 May at Leeds Crown Court, Maria Chenery was sentenced to four years in prison, while Paul Douglas was jailed for two years and five months. Mark Woods and Lynda Chenery were given suspended prison sentences for their part in the enterprise.
NTS Chair, Lord Michael Bichard, described the outcome as “another significant milestone in our work to combat online ticket touts”. l
Business Companion’s new Contract Law guide sets out the key points of contract formation under consumer protection legislation. This excerpt gives a brief introduction
Contracts set out important information about agreements between parties. This can include essential information, such as:
• the nature of the contract and what it is about;
• the benefits, detriment and responsibilities that the parties to the contract are agreeing to;
• what happens if things go wrong;
• the liability and any limits on such liability of the parties to the contract;
• the legal jurisdiction that applies to the contract in the case of a dispute.
Having a contract that clearly sets out the intentions of the parties can reduce the chances of unnecessary disputes and costs. It can also clearly set out consumers’ and businesses’ rights, responsibilities and obligations.
There are also some legal requirements that businesses must comply with when entering into contracts, such as providing certain pre-contract information in consumer contracts, and ensuring the terms of contracts are fair. Businesses often include this information within their terms and conditions to ensure they are complying with these legal obligations, but sometimes key information has to be given particular prominence. It is also important that businesses’ advertising and sales literature accurately reflects the terms of their contracts, and highlights any points that customers might find surprising or especially onerous.
Contracts with consumers must comply with the requirements of consumer law and contract law principles. Businesses must also be aware that if they enter into contracts with consumers outside of England and Wales, such as those based in Scotland or Northern Ireland, they must
ensure that their contract also complies with the laws of those nations.
The traditional way to recognise a contract is to identify whether the main elements of a contract are all present. These are:
• an offer;
• acceptance of that offer;
• consideration;
• an intention to create legal relations between the parties, which can include certainty of the terms agreed;
• that each party has the capacity to enter into the contract.
When deciding whether a contract is in place, the law considers the intentions of the parties by considering such factors as any verbal and written interactions, where the discussions took place and the actions and conduct of the parties.
An example of an offer is where one party communicates that they would like to buy or sell goods or services. The offer needs to have sufficient information to be capable of being accepted and it needs to be clear that the party (whether it is the business or the consumer) making the offer intends to be bound by their offer.
Providing a quotation for home improvement work to a customer will usually involve an offer. Quotations will often be given to a customer after a trader has visited a consumer’s home and will include a detailed breakdown of the goods and services to be supplied, and the total cost for that work, inclusive of VAT.
A trader should only give a quotation when they are happy that they understand the customer’s needs and the job has been correctly priced.
Sometimes communications do not provide enough information to be legally considered an offer. For example, the display of goods in a shop window would not usually considered to be an offer. These communications are called ‘invitations to treat’.
An invitation to treat is a communication whereby a business invites consumers or other businesses to engage in further negotiations to purchase goods or services. A common example would be where goods are on display in a shop. The invitation to treat is therefore advising other people that a business has goods or services that they may be willing to sell and that further discussions or negotiations would be needed to form a contract. If the customer is interested in those goods, they may bring them to the till with the intention of purchasing them (in legal terms, this becomes the ‘offer’, which the business can then choose to ‘accept’).
Often, businesses will give estimates to customers who are looking to cost work that they may wish to have done. These are often given before a full site inspection or survey has been conducted and at the early stages of a discussion
between a business and a customer. An estimate is not usually deemed to be an offer because it will be based on incomplete information.
The estimate should clearly state that it is an approximation of costs, and a full survey or additional information would be needed to provide a full quotation. This makes it clear to the customer that the costs could increase or decrease once full details, measurements etc. have been obtained. It is however very important that estimates are realistic and not misleading to avoid infringing consumer protection legislation.
Most businesses will advertise their goods and services online, whether that is via an online shop on a website, through influencers, or the use of general marketing campaigns. The general legal principle is that advertisements or goods on display in online shops are usually ‘invitations to treat’.
The consumer makes the offer to purchase the goods and services when they put them into their virtual shopping basket and go through the process of purchasing the goods. The business accepts the offer (usually signified by taking payment from the consumer or
Contracts with consumers must comply with the requirements of consumer law and contract law principles
CPPD MODULE 26: CONTRACT LAW BASICS
Submit your answers at tradingstandards.uk/cppdtest
1. Should key information be given particular prominence in a contract?
2. Should advertising and sales material highlight things that customers might find surprising?
3. Does contract law consider factors such as where discussions between a business and consumer took place?
4. Would the display of goods in a shop window constitute an offer?
5. Is an estimate usually deemed to constitute an offer?
otherwise stating that the order has been accepted) and goes on to dispatch the goods to the consumer.
Businesses also need to be aware that if they provide key information about a product and its price in a commercial communication that enables a consumer to decide whether to purchase that product, the business may be making an ‘invitation to purchase’ under the Consumer Protection from Unfair Trading Regulations 2008 (CPRs). For example, pages on a website displaying products that consumers can order, or prices on products in a shop, are likely to be ‘invitations to purchase’. If a business is advertising its services generally and no prices are supplied, this is unlikely to be an invitation to purchase.
If a business makes an ‘invitation to purchase’, certain information becomes ‘material information’ (a term used in the CPRs) that the consumer needs to be given in order to make an informed choice. This includes the main characteristics of the product, the businesses’ details (including its trading name and geographical address) and information such as the price (including all taxes).
A business may breach the CPRs if it fails to give consumers the information
6. Are online advertisements for goods generally considered to be ‘invitations to treat’?
7. Are pages on a website displaying products that consumers can order likely to be ‘invitations to purchase’?
8. Would a business’s trading name and address be classified as ‘material information’?
Applicants who complete the module will be given a certificate. The test must be taken by 31 October 2024. If you have any questions, please email kerryn@tsi.org.uk
Previous module answers are available on the Journal of Trading Standards website.
To read the full version of the Contract law basics guide, visit: www.businesscompanion.info
they need to make an informed choice in relation to the product if this would cause, or be likely to cause, the average consumer to take a transactional decision they would not have taken otherwise. More information about businesses’ responsibilities under these Regulations can be found in Business Companion’s ‘Consumer protection from unfair trading’ guide. ●
Vincent Searle Trading Standards Officer, London Borough of Newham
Young people were inspired and intrigued by one particular stand at a recent careers conference, thanks to the CTSI London Branch Race & Equalities Group
In partnership with REACH Society, the CTSI London Branch Race & Equalities Group took part as an exhibitor in an inspiring careers conference at the Royal National Hotel in London which attracted a turnout of more than 1,000 registered attendees.
The event, which took place in early April, served as a beacon of opportunity for aspiring individuals aged 13 and over, particularly those from Black and minority ethnic backgrounds, to explore a multitude of professional careers. These included the Trading Standards Apprenticeship programme and qualification framework.
In 2010, REACH Society was conceived by Professor Donald Palmer, Rob Neil OBE, and Dr Dwain Neil OBE in response to the government’s decision to stop funding the national REACH role model programme. Bringing together professionals from diverse backgrounds, REACH Society offers tailored services for personal and professional growth, ensuring individuals connect with inspiring role models. With a resounding motto of ‘building connections’, REACH Society inspires and empowers individuals, continuing the transformative work of the original programme.
The aim of the Race & Equalities Group at the conference was to push the Trading Standards profession’s inclusive ambition, ensuring a workforce representative of diverse communities.
In 2021, CTSI made a significant stride towards fostering diversity and inclusion by signing the Race at Work Charter. This signalled a commitment on the part of the Institute to creating an inclusive workplace where individuals from all backgrounds feel valued, respected, and empowered to thrive.
Attendees at the event gained invaluable insights into the world of Trading Standards. The interactive discussions delved deep into the critical role Trading Standards plays in addressing pressing consumer issues affecting young people today.
From vapes and e-bikes to intellectual property, illicit goods, cosmetics, artificial intelligence, scams and netzero initiatives, the topics covered were wide-ranging and thought-provoking. The group also explored the devastating effects of knife crime and corrosive substances, shedding light on recent changes to domestic legislation and the
role of Trading Standards in shaping law.
During the event, the group emphasised that Trading Standards is more than just a job — it’s an opportunity to make a real difference while embarking on a fulfilling professional journey, having the chance to make a real impact, and advocating for fairness and justice. The group celebrated diversity and empowerment, shining a spotlight on the indispensable role of Trading Standards professionals.
The event also featured workshops on financial literacy, bridging the gap between the world of corporate banking and the community. Expert panels provided guidance and mentorship, offering attendees useful resources to kick-start their careers.
In addition, there was a focus on
“Trading Standards is more than just a job – it’s an opportunity to make a real difference while embarking on a fulfilling professional journey”
aspirational growth, empowerment and entrepreneurial journeys as key themes, emphasising the need to support underrepresented members of society.
The Race & Equalities Group remains dedicated to generating interest in the Trading Standards profession and ensuring that all staff, regardless of background, have opportunities to excel and contribute at all levels within the Trading Standards profession.
This event served as a catalyst, unlocking opportunities and empowering young people, positioning Trading Standards at the forefront of innovation and growth. Our overarching vision is to bolster resilience within the profession and future-proof regulatory services.
The event created real interest in the Trading Standards profession from young people, professionals and parents alike. The thirst for knowledge about our career was refreshing and encouraging to see.
This was echoed by Dr Patricia Smith, Senior Lecturer in Professional Health Sciences at the University of East London and her students, who voted the Trading Standards stand as the most impactful at the event. According to the students,
“whether we are passionate about law, economics, or consumer advocacy, there is a place for us within this dynamic field”.
It was pleasing that students felt Trading Standards offered a diverse range of career paths, from enforcement officers to policy advisors and management positions, providing ample opportunities for growth and development.
The Race & Equalities Group is optimistic about CTSI’s overall commitment to investing in the pipeline of Trading Standards professionals, as set out in the Institute’s 2024 Manifesto.
In conclusion, the event served as a testament to the importance of diversity and inclusion in shaping a fairer, more equitable society for all, and one that is rich and reflective of the communities that we serve. The event also proved the necessity for continued outreach work through further community initiatives.
CTSI Chief Executive, John Herriman, who was in attendance on the day, said: “Events like this are so important to the future of Trading Standards. By speaking to young people and telling them about the work we do, we can bring new voices, ideas and perspectives into the profession.
“It was genuinely exciting and inspiring to see the students’ curiosity about careers in Trading Standards — harnessing that curiosity and passion will be vital to safeguarding the future of consumer protection.
“I would like to thank all of those who made this event possible, especially Tendy Lindsay and Valerie Simpson, and all of their colleagues in the CTSI London Branch Race & Equalities Group.” l
For more information, please visit: www.reachsociety.com
Trainee and apprenticeship programmes offer a viable solution to a cocktail of challenges facing the public sector, including an ageing workforce, budget cuts and rising youth unemployment.
The latest data from the Office of National Statistics notes that the number of young people deemed “economically inactive” (not in or looking for work) rose to 3.05 million between December 2023 and February 2024 — the highest level since records began in 1992.
Figures such as these suggest a growing sense of disillusionment among young people with the world of work, where they are often underpaid, undervalued and left to feel stuck in a job that doesn’t align with their values.
CTSI aims to improve the working lives of young people and inject new blood into the Trading Standards workforce with its apprenticeship programmes. These are designed to develop new recruits from a diverse range of backgrounds and circumstances, and give them the skills they need to forge a rewarding career.
Jack Thompson, Trainee Regulatory Services Officer at Salford City Council, says he had a variety of jobs that simply didn’t fit right after graduating from the University of Manchester in the midst of the Covid-19 lockdown.
“I ended up getting a job in a call centre — it just wasn’t what I wanted to do,” he says. “When you’re young it is very easy to fall into a job that you see as okay, but there’s no real opportunity to progress. You’re going to work, it’s not too bad, but then there’s no real reward.”
But that all changed when he became aware of the CTSI apprenticeship programme while working within the admin team in Regulatory Services at Salford City Council.
“Trading Standards is not really something I’d ever considered before,
as I’ve never worked in the public sector, but seeing the level of progression and the variety of work offered by the apprenticeship programme, I knew it was something I wanted to be involved in,” Thompson says.
The unique balance between work and study offered by the apprenticeship programme is ideal for many people, especially among a growing segment of young Britons opting out of debt-laden degrees in exchange for a role that provides practical experience and the ability to earn while you learn.
“It’s just such a unique opportunity to be able to earn money, while gaining a professional qualification at the same time — it’s rare nowadays,” says Rima Nisbet, Trainee Trading Standards Officer at North Lanarkshire Council.
Apprenticeships in Trading Standards are available in England and were recently expanded to Scotland. Further, CTSI’s Qualifications and Training team are already working closely with the relevant authorities in each of the other devolved nations to develop similar opportunities.
For those accepted onto the apprenticeship programme no two days are the same. New recruits can expect to conduct investigations into potential violations of Trading Standards law, which could involve gathering evidence, interviewing witnesses and even carrying out raids and other enforcement actions with the help of the police.
“You’re not just sitting in front of a computer all day typing, hoping it’s going to change the world, you’re out in the field talking with consumers and traders, and making a real difference,” Nisbet says.
Stephen Eaton, Trainee Trading Standards and Licencing Officer at Salford City Council, is an example of a new
recruit who has flourished within this fastpaced profession by removing any and all limitations he once placed on himself.
In his first few weeks on the apprenticeship programme he admits to succumbing to “imposter syndrome”, but is quick to point out that such feelings fell away to be replaced by a sense of belonging and a motivation to achieve.
“I’ve worked hard to get where I am, and I don’t plan on stopping anytime soon,” says Eaton, adding that he is waiting to sit final exams for his Level 4 Regulatory Compliance Officer (RCO) apprenticeship and, once completed, plans to move onto his RCO Level 6 as soon as possible. “I want everything. I want to go as far as I can in this role and there is no reason why I can’t.” he says. “I’m 25, I’m young, I’m hungry — I want to go for the best.”
There is a frustrating mass of newspaper headlines bemoaning ‘young people’s aversion to work’, but the new recruits joining Trading Standards via CTSI’s apprenticeship programme provide a solid rebuttal to criticisms of the new working generation.
The truth is that young people want to work hard too. Their biggest challenge, however, is apparently knowing where to look. Research conducted by the UK’s largest hiring platform, Totaljobs, reveals that almost half (48%) of 16-18 year olds believe they are receiving a lack of career advice at school.
Originally from Lithuania, Nisbet came to the UK to attend the Strathclyde University, admitting that at the time she lacked a clear direction in life. After obtaining a Bachelor’s degree in Business Enterprise she moved to Glasgow and found employment in the private sector, but also found herself searching for something more.
“Profit, rather than societal betterment, is the primary goal in most private sector companies,” she says, adding that this realisation led her to seek a career where she could contribute meaningfully to the local community and “feel proud” of her work. Since joining Trading Standards she has a renewed pride in her profession and one that grants her the work-life balance vital for a working mother. However, she admits that her exposure to Trading Standards was due to a fortunate stroke of serendipity.
“I was just lucky to be on the right website on the right day; that’s all it was — luck.”
When Totaljobs surveyed young people about alternative routes into employment, 57% of 16-18-year olds said that apprenticeships were an excellent way to learn, while 40% believe they lead to financial independence earlier than other routes into work.
Despite this, just 10% of 16-18-yearolds are considering a degree apprenticeship once they leave school, according to the research, with a further 35% going on to say that apprenticeships
I want everything. I want to go as far as I can in this role and there is no reason why I can’t
aren’t promoted as much as university — highlighting a lack of diverse career advice.“Ultimately, it’s about educating people,” says Eaton. “If Trading Standards Officers went into schools and universities and gave talks about what we actually do, the narrative around regulatory services that if you work in the profession you’re a ‘grass’, especially in my area, will slowly change.” (for more on career fairs and community engagement, see page 50)
Tahaul Islam, a recently recruited Trading Standards Enforcement Officer at Neath Port Talbot Council, echoes similar sentiments about the need to raise awareness and re-write the narrative around the service.
“Bearing in mind that I was in the police for so many years, I knew almost nothing about what Trading Standards did,” he says. “Spreading awareness of what we do and how important it is, is the most crucial thing the service and those working within it can do.” l
For further information visit: www.tradingstandards.uk/practitioners/ training-development/apprenticeships/
The gathering, recording, sharing and analysis of data can be a thorny issue for Trading Standards — but it is vital to addressing some of the problems the profession faces
The complexity of Trading Standards work, combined with pressures on overstretched local authorities and other public services, can mean that the details of consumer protection incidents often go unrecorded, or are not recorded properly. And for a variety of reasons — including changing consumer habits, a lack of awareness of where to report problems, and the shame that can sometimes accompany being a victim of crime — many incidents go unreported by the public.
So how can Trading Standards teams improve the ways in which intelligence is gathered and acted upon?
Since it was set up in 2012, National Trading Standards (NTS) has promoted the Intelligence Operating Model (IOM), which provides a national intelligence framework to support local, regional and national Trading Standards teams in their day-to-day work.
NTS Programme Manager, Donna Sidwell, explains: “NTS has provided funding for the NTS Intelligence Team, Regional Intelligence Teams, and encourages local authorities to have a local intelligence liaison officer. NTS pays for a number of databases and information sources. It gives funding to
help Trading Standards (in England and Wales) pay for their access to IDB, the national intelligence database.”
NTS also pays for access to the Police National Computer (PNC) and, where appropriate, can help users access the Police National Database (PND) — although only when certain criteria are met, in compliance with data protection rules. Specially trained financial analysts on the NTS Intel Team also have access to banks’ Suspicious Activity Reports (SARs), which contain data on financial fraud.
“From an NTS perspective, we very much believe in the use of intel, but it’s down to encouraging local authority Trading Standards Officers to record intelligence,” Sidwell adds. “It needs to be a standard process — to analyse and share data you need to have it in the first place.”
Head of the NTS Intelligence Team, Aaron Hesketh, believes good record keeping is vitally important. “In an ideal world, there would be more resource available to help Trading Standards services record more intelligence. Because resources are stretched, we often hear that Trading Standards services can’t always record as much intelligence as they would like. Instead, some record what
they feel is absolutely necessary, as they don’t always have the time to record all of the intelligence they gather.
“It’s always going to come back to resourcing — local authorities are struggling and Trading Standards services are getting smaller across the country,” Hesketh adds. “But in any case, we’ll continue to push an intelligence-led approach and assist Trading Standards in developing a fuller intelligence picture.”
As well as being CTSI Lead Officer for Energy and Net Zero, Steve Playle is Trading Standards Manager at the City of London, where he and his team tackle financial fraud through Operation Broadway. He has his own set of frustrations when it comes to the gathering and implementation of intelligence.
“I think it’s fair to say that, because Trading Standards Officers are so busy, not everything gets caught on the IDB,” he says. “I’m not saying I can defend that — because you should do it. But when you’ve got another 15 jobs piled up, what do you do? It’s all about that resource issue.”
Playle believes another key problem is a lack of clarity for consumers as to where they can go with complaints and concerns. “I’ve just done the the annual satisfaction survey for Citizens Advice, and I say the same thing every year: that Citizens Advice don’t advertise their
We’ll continue to push an intelligence-led approach and assist Trading Standards in developing a fuller intelligence picture
service. So there’s a lack of reporting, and people don’t know where to report incidents to,” he says.
Playle believes that Trading Standards teams can benefit from data sources outside the official channels. “As well as things like IDB, Citizens Advice and Action Fraud, some of the open source review sites have lots of really good data. Of course, there are fake reviews on there — but I’ve been working very closely with Trustpilot over the last 12 months or so for Operation Broadway, and it seems to me that they’ve got a pretty robust system.
“Whenever I get a complaint now, I always go on to Trustpilot; it gives a good indication of whether the complaint might just be a one-off or whether there’s more to it. So I think that needs to be brought into the mix. And with green heating businesses, there are so many different trader approval schemes and trade associations out there, and they have data on complaints. That information isn’t in the public domain and isn’t available to Trading Standards, but perhaps it should be.”
Playle echoes Sidwell and Hesketh in their pleas for better intelligence recording — but he has concerns over what comes next. And again, it comes back to resources: “With Net Zero, intel-gathering and analysis is a big issue. At the end of the day though, even if we had all the intel and we knew who all these
bad traders were, what are we going to do about it?
“But it’s better to know who the bad players are, and then we can start thinking about ways of disrupting them. It’s important to get that intel in place in the first place, and then decide how to use it.”
Social media could provide a wealth of data about recurring consumer problems, as people go online to vent their frustrations rather than using traditional avenues of complaint. “It is something that we do monitor, because we are finding a lot of people are not reporting issues to Citizens Advice,” says Hesketh. However, he points out, “It’s very hard to monitor something that big; we’re a very small team and we don’t have the resources to monitor social media on a constant basis. There are tools out there that can scrape social media and come back with anything that may be relevant, but they’re very, very expensive.
“There are always new ways of complaining, and the consumer landscape changes all the time. But we try and keep up with it,” he adds.
Someone else who appreciates the value of accurate, reliable intel is Dr Tim Day, CTSI Lead Officer for Doorstep Crime. In the course of his work, he has examined the dangers of letting intelligence go unreported and unrecorded, and he believes that incomplete or inaccurate recording can distort Trading Standards’ approach to certain issues.
“With a lot of doorstep crime, police control rooms aren’t identifying fraud sufficiently,” he believes. “What we have is a situation where we’re almost by default decriminalising a lot of rogue trading, which is not being picked up or identified as a crime, when it really is.” (Day recently published a paper on the police response to doorstep crime and rogue trading.1)
Playle shares those concerns: “When I have worked on doorstep crime cases in the past, some police officers thought it was OK that someone had paid £3,000 for a single roof tile. That’s not OK. That victim was pressured, coerced and
manipulated. And that isn’t a civil dispute — that’s a crime, it’s fraud.
“I think the police have come a long way since then,” he adds. “Some are really, really good. But sometimes they’re under pressure themselves, they’re under financial constraints in the same way as Trading Standards. And they just need to park reports that come in and ‘No Further Action’ (NFA) them, because they haven’t got the resources.”
According to Day, “In academic terms, there’s the ‘dark figure of unrecorded crime’. I’m all for evidence-based enforcement and an intelligence-led approach, but we have to recognise that, with current levels of under-reporting and under-recording, the picture that we’re basing our decisions on now is probably less than 5% of incidents.”
Part of the solution to that, he believes, lies in changing the tone of the conversation around scams — and he highlights NTS’s ‘No Blame No Shame’ campaign (see page 7) as vitally important in bringing about that change. “I think the societal response to scams needs to improve. We often hear that the response from victims’ families is ‘I can’t believe they’ve done this, how could they be so stupid?’ It’s an emotional response, but it’s incredibly unhelpful. People are far more likely to internalise their experience and not report when that is the backdrop.”
Sidwell says that, when it comes to the recording of doorstep crime incidents at least, things are improving. “We’re in the process of producing the NTS strategic assessment, and the figures on the intel being recorded have gone up this year. And doorstep crime is a key priority area.
“Not everything will be recorded, I appreciate that. But actually, I would say Trading Standards are doing a really good job at recording intel. And once we’re able to analyse the data, it helps inform the work to be done, and sharing intel with the police and other agencies is the positive way forward.” l
1 Day, Tim: ‘What’s not measured still does not get done: An empirical exploration of the police response to rogue trading incidents’. Journal of Economic Criminology, 2024 (doi.org/10.1016/j.jeconc.2023.100048)
Danny Maxim Former CTSI Lead Officer for Legal Metrology
Although some may disagree, legal metrology has been neglected in recent years — to the detriment of consumers and the profession, argues Danny Maxim
As I bring down the curtain on more than a quarter of a century dedicated to all things ‘weights & measures’, it seems an appropriate juncture to indulge in a little reflection and perhaps raise a plea to those who have agency to effect change.
Whilst weights and measures was very much a foremost aspect of Trading Standards when I began my career, even then it was becoming undervalued as new workstreams came thick and fast to the profession. Meanwhile, prevailing ideologies around proactive ‘routine inspection’ work began to shift towards the more reactive ‘intelligence-led’ approach familiar today, where priorities are determined by magnitude of data and perceived risks. Which is an entirely logical approach when resources are limited, but also has the effect of inhibiting the scope for initiative work in fields where problems are less self-evident.
In the case of metrology, for example, the consumer has to entirely take on trust that measurement and quantities are realised fairly and accurately. After all, there is a workforce of professional inspectors employed for the specific assignment of bringing assurance to markets, isn’t there?
While weights and measures remain a vital standard of trade, the complexity of
transactions has increased. Yet paradoxically the degree of regulatory attention given to metrology has declined significantly. Training and development structures have not been maintained, and the numbers of experienced, technically competent professionals leaving are not being replaced at the same rate. Where other aspects of Trading Standards have formally established collaborative and co-ordinating arrangements, metrology is predominantly a ‘postcode lottery’ function. This means there are in effect 200-plus individual decisionmakers deciding priority locally, which mitigates against an effective system that the economy relies upon.
Some will naturally say ‘so what — where is the evidence that systemic neglect is ultimately harmful?’ Conventional wisdom should be challenged and old orthodoxies scrutinised in contemporary context.
Trading Standards’ professional pivot away from traditional work has not been intelligently led in the least
Regrettably though, Trading Standards’ professional pivot away from traditional work has not been intelligently led in the least, rather an incoherent drift which has fostered
a culture of metrology being regarded as an archaic, legacy function.
It is understandable that with so many competing demands, heads of service and decision-makers are not articulating the immutable facts about legal metrology — there is enough to do already! The outcome is that nobody with power is championing the innate essence of our purpose or holding feet to the fire at the national regulator by demanding strategy and resource. Consequently, citizens and business are potentially being failed by the very institution which is there to serve and protect their interests. Recent studies across the UK have shown that the cost-of-living crisis is being exacerbated by widespread quantity issues, on top of poor unit pricing practices.
In neglecting to cherish our past we also risk failing to nurture tomorrow, putting in peril the foundation for all else that is done in the name of Trading Standards. As a philosopher might conclude, “If not us, then who; if not now, when?” l
To have your say about the issues raised in this column, email editor@ journaloftradingstandards.co.uk
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