Journal of Trading Standards Winter 2025

Leader

Let’s

make things possible

As I take up the role of CTSI Chair, I feel it is important that my first leader column for the Journal should be about getting involved in our profession. During my 30-year career in Trading Standards, I have seen the importance of our Institute and how it can ensure that our work has a meaningful impact which resonates far and wide. It is essential that we focus on ways to inspire the next generation, nurturing the talent that will make our profession fit for the future.

All colleagues in Trading Standards have a great deal to offer in terms of unique perspectives, fresh ideas and remarkable dedication but for one reason or another, they don’t always put themselves forward to participate in CTSI Branch Executives, Council or the Board. I would really like to encourage more members to take that first step towards getting involved in our leadership.

“It is essential that CTSI members step forward and get involved for the future of our profession”

It is amazing how much has changed within Trading Standards over the past few decades, with a more representative and diverse workforce better reflecting the communities and businesses we safeguard and serve. There are more women in the profession than ever before and more Officers with diverse experiences of life and wider perspectives. It is vital that this diversity is reflected in our Institute’s leadership, and everybody should feel that it is possible to get involved in shaping our profession for the better, regardless of gender, age, race, or any other factor.

Supporting our profession can take many forms. It can come through actively participating in Branch activities, through becoming a Lead Officer, or through contributing to policy campaigns and stakeholder consultations. Getting involved helps us celebrate all the aspects of our work which can inspire and ignite our passion.

We must also strive to create the conditions in our Institute that make it possible for anyone to get involved. We need to focus on inclusive communication, and make sure no one feels excluded because of a perceived lack of opportunity. Having a hearing disability means I have a strong personal interest in working to ensure that nobody is left out of the conversation, especially when important decisions are being made about our Institute and our profession.

As we seek to attract more apprentices and new recruits, it is vital that we talk about just how rewarding a career in Trading Standards can be, and that CTSI members step forward and get involved for the future of our profession.

Editor-in-Chief: Kerry Nicol

Editor: Richard Young

Designer: Sam Millard

Contributors:

Matt Allwright, Iain Bailey, Jo Cooper, Tendy Lindsay, Jessica Merryfield, Kerry Nicol, Stuart Radnedge, Edward Skinner

Writers: Helen Nugent, Richard Young

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

Article suggestions and feedback should be sent to:

editor@JournalofTradingStandards.co.uk

The Journal of Trading Standards magazine and website are produced on contract by Fourth Estate Creative Ltd. www.fourthestatecreative.com connect@fourthestatecreative.com

Printed in the UK by Manson Group Distributed by Gold Key Media

Published by the Chartered Trading Standards Institute, 1 Sylvan Court, Sylvan Way, Southfields Business Park, Basildon SS15 6TH.

www.tradingstandards.uk 01268 582 200

© 2024, Chartered Trading Standards Institute. All rights reserved.

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

Nikki Pasek Chair, CTSI

5 | Upfront

Recent developments, success stories, initiatives and updates from CTSI Lead Officers and TSOs on the front line.

15 | Opinion: Matt Allwright

With so many things competing for our attention, scams demand our full focus.

16 | Opinion: Kerry Nicol

Trading Standards’ biggest fan hits the road to promote the profession and its aims.

18 | Opinion: Jessica Merryfield

As AI and other innovations become a reality, the profession must keep pace.

32 | Taking the lead

We hear from some of CTSI’s new Lead Officers about their interests and priorities.

35 | Obituary: Andy Allen

Remembering a dear friend and colleague who made a lasting contribution to CTSI.

40 | A job well done

As he prepares to take a well-earned rest, Peter Tompkins reflects on a Trading Standards career spanning 60 years.

42 | The acid test

A new Home Office and LTS-supported project is preventing dangerous substances getting into the wrong hands.

44 | Interview: Justin Madders MP

The new Consumer Minister on policy, funding and the role of Trading Standards.

50 | CPPD: Financial investigations

Examining how a joined-up approach to financial investigations can reap rewards.

52 | Spreading the word

Why education and awareness will be vital in Trading Standards’ fight against crime and a host of consumer protection threats.

58 | Opinion: Tendy Lindsay

Why we must all be mindful of the words we use in the workplace and the wider world.

Out with the old

The Government’s agenda for regulatory reform has been 14 years in the making. What will it mean for Trading Standards?

Winter is coming

Scotland's Heat in Buildings Strategy is an opportunity to reduce carbon emissions from homes. Is Trading Standards ready?

Hide and seek

From remote-control hydraulic mechanisms to magnetic trapdoors, we uncover some bizarre attempts to conceal illicit tobacco.

A burning issue

Fires started by e-bikes and e-scooters have cost lives and caused horrific injuries. What can be done to ensure the devices are safe?

Can-do attitude

Why Trading Standards Officer Kristina Hann has always had a positive and tenacious approach to her life and career.

CTSI Hero Awards 2024

The passion and dedication of some of consumer protection’s brightest stars were recognised at a ceremony in Westminster.

Upfront

Joining the fight against knives

Barking & Dagenham Council Trading Standards has been taking a proactive stance on knife crime with a range of partnership initiatives designed to tackle underage sales, teach emergency wound treatment and address the root causes of kniferelated youth violence.

The Trading Standards team have been central to a councilwide approach to the problem, which is particularly acute in a borough that has seen a spate of serious knife-related crimes. Over the last two years alone, there have been 67 recorded knife attacks in the borough in which a young person has been injured. Through initiatives including test purchases and a responsible retailer scheme, Barking & Dagenham Trading Standards hopes to make it as difficult as possible for knives to fall into the wrong hands. The council has also delivered specialised first-aid training to Year 12 students in the borough to equip them to save lives. That training has also been made available to all frontline staff in the council’s Regulatory Services and Community Hubs, including Trading Standards and Environmental Health.

In addition, the council has funded 10 wall-mounted bleed kits for all Community Hubs and

“We see the work that Trading Standards do, and it’s really important”

major public buildings in the borough, as well as 20 mobile bleed kits for frontline teams.

Barking & Dagenham Council Trading Standards Service Manager, Nazir Ali, is passionate about tackling knife crime on his patch, and his efforts and those of his colleagues were recognised at this year’s CTSI Hero Awards (see page 54).

In July he took part in a Knife Crime Symposium organised by the Barking & Dagenham Community Safety Partnership. “I presented the role of Trading Standards in tackling knife crime using test purchasing projects, responsible retailer schemes, prosecutions and enhanced comms,” he explained. “I also showcased the importance of using alternative sanctions and Proceeds of Crime funding to deliver preventative interventions such as bespoke first-aid training.”

Lost Hours Project

A key part of the strategy has been a link-up with the Ben Kinsella Trust, which was founded in memory of a 16-year-old schoolboy who was stabbed to death in 2008 during a night out with friends in London.

The charity educates young people about the dangers of knives, promotes awareness of knife crime in policy circles, and campaigns for action and justice for those affected by knife crime.

Through the Lost Hours Project, the Ben Kinsella Trust has worked with Barking & Dagenham Council to get the message out. The campaign was created in response to a rise in youth violence and anti-social behaviour

in the borough between the hours of 3pm and 7pm when children finish school and their parents get home from work. The charity also brought its ‘Choices and Consequences’ exhibition to Barking & Dagenham, providing workshops to young people.

The Ben Kinsella Trust’s Chief Executive, Patrick Green, told the Journal: “We’re big supporters of Trading Standards, not just in Barking & Dagenham, but throughout the country. We see the work that they do, particularly with test purchasing, and it’s really important.”

The Ben Kinsella Trust was among those pushing for tighter controls on knife sales, with

Left Barking & Dagenham Council hosted a Knife Crime Symposium in July through its Community Safety Partnership. The event brought together key stakeholders to discuss knife crime, with Trading Standards Manager Nazir Ali (second right) giving a presentation on Trading Standards' crucial role.

Left Barking & Dagenham Trading Standards has been working with local retailers on the MOPAC Responsible Retailer Scheme for knives, which provides training on best practice for knife sales. There are currently 15 premises signed up to the scheme for 2023-24.

The actor

Trust

has been working with the charity on the 'Don't Stop Your Future' campaign, which called for an immediate ban on 'zombie knives' and machetes, along with increased funding for youth services.

the actor Idris Elba lending his support to its ‘Don’t Stop Your Future’ campaign.

In September the Government announced a ban on ‘zombiestyle’ knives, a move which Green welcomed – but he believes there is more work to be done. “Our big concern at the moment is with online sales,” he said. “We've seen vast quantities of knives of the most gruesome type available, being shipped to people with little or no age verification, and there have been a number of incidents where these knives have been used in murders.

“We’re now pushing the Government to do more in terms of regulation on age verification.”

Left

Idris Elba with Ben Kinsella

Chief Executive Patrick Green. Elba

Checks in the post: MFBs in the spotlight

Mail-forwarding businesses (MFBs) and their clients should face tighter controls to prevent consumer harm, according to Islington Trading Standards Manager Alonso Ercilla.

MFBs and virtual offices, which charge a fee to receive companies’ post and then forward it on, are popular with many small businesses and start-ups because they can be used to give the impression that a business is more substantial than it is, or that it operates from a prime location.

However, Ercilla believes, they can create a lack of transparency which results in confusion for consumers and problems for enforcers, many of whom are reluctant to investigate companies that are based on their patch but use the services of an MFB.

“The whole thing is fascinating from a Trading Standards perspective – it's a really under-enforced area of law that other local authorities should be considering,” Ercilla told the Journal. “Even if you haven’t got an MFB in your area, I can guarantee that you will have businesses that use one.”

At present MFBs are governed by the London Local Authorities Act 2007, and London is the only part of the country where they are required to register (and only if the relevant provisions of the Act are adopted by the local authority in question). This means, in effect, that businesses based anywhere in the UK or overseas can legally operate from the capital, placing a disproportionate enforcement burden on Trading Standards teams there.

“It’s a frustration for London borough Trading Standards services,” said Ercilla, whose team recently prosecuted an MFB which accepted fake identification documents from clients. “We've got one MFB, for example, that hosts about 40,000 businesses. These businesses aren't based in Islington, they are based all over the country and some of them are actually abroad.

“But when we go to other local authorities and say, ‘Look, we’ve identified that the person running this business from their laptop at home is in your area,’ they’re not interested.

“The biggest lesson I've learned from this is that we have to move on as a profession and understand that the public don’t want Trading Standards saying, ‘It's not my problem.’ Most people now buy online and the businesses that sell online, particularly the micro ones, are the highest risk – the ones we should be focusing on most.”

To complicate matters, many of the companies which provide an MFB’s address on

their documentation have no right to do so: “Whenever we get a complaint about a business based at an MFB, we verify with the MFB whether it’s a client or not,” Ercilla said. “We find with about 50 percent of complaints, the business is pretending to be based there.” (See graph, above).

Room for improvement

To address the problem – which affects consumers around the country – Ercilla suggests that the current legislation is in need of an update. “MFBs should be regulated nationally, not just in London,” he said. “I also think they should be licensed, not just registered. Given the high risks posed by businesses operating from these addresses, the MFB should be subject to tests to ensure it is fit and proper.

“We’ve prosecuted one company but can’t revoke its licence because the requirement is only to register.”

Ercilla believes that MFBs’ clients should be required to register as well: “You might have somebody in Wales, for example, running a business from their

Far left Islington Trading Standards has found that companies often pretend to be registered with an MFB.

Left Disruption work by Islington Trading Standards has yielded positive results.

spare room. I think that person should have to register with their local authority because they're hidden at the moment – their local authority has zero idea that somebody's running a business there unless we go and tell them. And the only way we can find that out is by going to the MFB and requesting documentation.

“Partnership working with the MFB is vital in our approach to enforcement,” Ercilla added. “However, the big missing link is with the other local authorities where the problem traders are based – they should be involved in policing businesses based in their areas that use an MFB as their shopfront.”

Finally, Ercilla suggested, there should be a requirement for businesses to be transparent about their use of MFBs. “When a business is using an MFB address, customers are likely to think it’s a bricks-and-mortar address where the business is based. Companies should be required to indicate that they’re using an MFB, and they should do that on all of their correspondence or websites.”

Cash for crash team hit the throttle

So-called ‘cash for crash’ fraud has been in the sights of the City of London Corporation Trading Standards and the City of London Police Insurance Fraud Enforcement Department (IFED), with Officers visiting garages in the capital to check for mopeds involved in crime.

‘Cash for crash’ scammers put the safety of innocent motorists and pedestrians at risk by deliberately causing accidents that form the basis of fraudulent insurance claims. Garages can sometimes be unwittingly drawn into the scams by housing or repairing mopeds that have been used to commit fraud. Others

are suspected to profit from the crimes knowingly.

Officers from IFED accompanied City of London Trading Standards during inspections of three premises in Croydon, Harlesden and North Finchley this summer. IFED officers also visited two premises in Clapham and Newham to speak to employees.

One person was arrested on suspicion of immigration offences and three mopeds were seized in connection with stolen vehicle reports. Hundreds of moped license plates were also identified and logged for research purposes,

with a number linked by the Insurance Fraud Bureau (IFB) and Metropolitan Police Service to known ‘crash for cash’ reports.

Reports from multiple insurers of induced collisions involving mopeds across London show that moped-enabled ‘crash for cash’ fraud is on the rise.

More than 2,250 people in the capital were affected in the two years leading up to June 2023, according to the IFB.

City of London Trading Standards’ Steve Playle said: “This is a great example of collaborative working between Trading Standards and our enforcement partners.”

COMMUNITY SERVICE

AI scam gran

Telecoms company O2 has appointed a new recruit in the fight against scams in the shape of an AI-generated ‘granny’.

Daisy has been designed to waste as much of fraudsters’ time as possible with rambling, meandering conversations –meaning they are kept too busy to talk to real people.

Trading Standards enforcement and prevention activities making a difference across the UK

IN THE HOT SEAT

North Tyneside Council Trading Standards has issued suspension notices to a furniture retailer in South Shields after its products failed fire safety tests. Flammable and potentially dangerous armchairs, sofas, mattresses and electrical cabinets were then disposed of, and the retailer was given advice on labelling and product safety.

COUNTER MEASURES

Trading Standards Officers across Northern Ireland seized counterfeit goods with an estimated retail value of more than £200,000 during two days of targeted inspections in October. Products including fake designer clothing and footwear, handbags and phone chargers were found at five retail premises in Bangor, Belfast, Lisburn and Derry.

UNDER COVER TESTS

Nottinghamshire Trading Standards found 60% of electric blankets tested during a series of recent community events were unsafe. The initiative, in which free tests were offered, followed a series of fatal house fires caused by defective electric blankets. A total of 282 items were tested and 170 failed, with some found to be more than 50 years old.

SLIM SHAM

The owner of a sports nutrition company which sold fake ‘slimming pills’ has been fined following an investigation by Hull City Council Trading Standards. When samples of the 'Slimbod' pills, which were distributed by WHS Sports Nutrition, were analysed, they were found not to contain the ingredient choline, which can support weight loss.

SHARPENING UP

Undercover test purchases by Lancashire Trading Standards have revealed a lack of compliance among shops that sell knives. When volunteers visited 59 shops in November, 24 of them failed to ask for identification and illegally sold a knife to a young person. Four traders failed for the second time this year and now face further enforcement action.

FRAUD

SCAMS

IF LOOKS COULD KILL

An upcoming CTSI campaign will warn about the risks posed by unsafe cosmetics. Following the previous 'Cost of Beauty' campaign which looked at teeth whiteners, skin lightening creams and gel nails, the focus is now on nasal tanning sprays, lash lifts and nail adhesives. For more info, visit www. tradingstandards.uk/cosmetics

PARKING SCAM WARNING

CTSI is urging motorists to be on guard against bogus text messages claiming that they have outstanding car parking charges. The messages, which have dramatically increased in frequency over the past six months, include a link to a convincing copycat Government website, complete with accurate fonts, branding and logos.

LOAN SHARKS CIRCLING

Illegal money lenders are using social media to identify and target vulnerable people, the Scottish Illegal Money Lending Unit (SIMLU) has warned, with up to 300,000 people in Scotland at risk of falling victim to loan sharks according to the latest data. SIMLU is supporting victims with debt and welfare advice alongside ongoing enforcement activity.

OUT OF TUNE

Hundreds of Oasis fans have reported being the victim of ticket scammers in the run-up to the band’s reunion, with some victims losing as much as £1,000. The figures were released by Lloyds Bank, which found that around 70% of reported ticket scams since 27 August relate to the Oasis reunion. More than 90% of the cases originated on social media.

ENERGY-EFFICIENCY

TSW offers free energy toolkit

Trading Standards Wales (TSW) has published a toolkit to help local authority enforcement officers in Wales improve compliance with domestic energy-efficiency regulations.

The toolkit focuses on the Energy Performance of Buildings (England and Wales) Regulations 2012 (EPC Regulations); and the Energy Efficiency (Private Rented Property) Regulations 2015 (also known as the Domestic Minimum Energy Efficiency Standard (MEES) Regulations).

The EPC Regulations set out which buildings require an Energy Performance Certificate and how that information is to be communicated to buildings’ owners, while the MEES are designed to improve the standard of energy-efficiency

Energy-efficiency is a hot topic

in both the domestic and nondomestic private rented sectors.

TSW has made the toolkit available free of charge to enforcement authorities, and has granted permission for it to be re-used in any format or medium.

The toolkit, which has been designed to promote awareness of energy-efficiency legislation and boost consistency in enforcement, includes template

documents such as letters to landlords and penalty charge notices, as well as information about exemptions and examples of penalty amounts applicable in different scenarios.

The initiative forms part of Trading Standards’ ongoing work to address the causes of climate change and support businesses and consumers struggling with high energy bills.

According to the document's authors, “You can ask for help at any time – please contact us at the Knowledge Hub group for further information.

“Officers always learn via experience and best practice. Sharing experiences is fundamental to all of us.”

For more on energy-efficiency and EPCs, see page 28

Reimbursement decision slammed

CTSI has voiced ‘significant concerns’ about the decision of the Payment Systems Regulator (PSR) to reduce the amount that fraud victims can reclaim from their banks. The PSR decided to reduce the cap for reimbursement for victims of authorised push payment (APP) fraud from the initially proposed £415,000 to £85,000.

According to UK Finance, APP fraud – in which criminals trick consumers into sending money to bogus accounts – cost consumers £459.7m last year.

CTSI said in a statement: “The [PSR’s] decision came after lobbying from sections

of the payments industry, despite a lack of clear evidence supporting the need for such a drastic reduction.

“The new cap could leave many victims – particularly those caught in high-value frauds like investment and property scams – struggling to recover their full losses.”

CTSI is urging the PSR to review the cap within the first 12 months of its implementation in October 2024. “An increase in the reimbursement cap would ensure that victims, especially those caught in largescale frauds, are adequately safeguarded,” the Institute said.

CTSI, along with the National Trading Standards (NTS) Scams Team, participated in the PSR’s consultation and expressed concerns about the potential impacts on victims.

The NTS Scams Team estimates that fraud and scams result in £5-10bn of detriment to UK consumers annually.

Reducing the threshold could disproportionately affect victims who may already be facing emotional and financial distress, according to CTSI. It also has concerns about the specific vulnerability of consumers using alternative payment methods such as cryptocurrency.

FRAUD

FACTS & FIGURES

The latest Intellectual Property Office Trading Standards

IP Crime survey provides insights into the ongoing fight against counterfeit goods

(Source: IPOTrading Standards IPCrime Survey2023-24; *IPO Innovation and Growth Report 2023-24)

80% of TS teams said cigarettes and tobacco were the counterfeits they investigated most 81% of TS teams said traditional retail premises were the locations they investigated most

£1.5bn

of fake goods seized as part of Operation Vulcan, a Manchester-based anti-counterfeiting initiative*

75% of TS teams were supported by the police in IP investigations

42% of IP investigations revealed links with organised crime groups

Stuart supports victims

The broadcaster Moira Stuart has been raising awareness of financial scams after almost losing money to criminals posing as bank representatives.

“About three years ago, a very convincing scammer got through to me,” Stuart said. “They said they were calling from my bank, told me someone had removed money from my account, and instructed me to withdraw cash from another branch. It wasn’t until I was at the bank that the teller saved me.

“I was absolutely devastated, embarrassed, and angry with myself. It feels like you’ve let yourself down and everyone who knows you. I want to make sure no one else feels like this. If they can get through to someone like me, they can get through to anyone.”

Stuart is working with AbilityNet (abilitynet.org.uk), a charity which helps people of all ages and abilities to use technology safely. Its latest campaign, which was launched

Stuart is working with AbilityNet

in partnership with BT Group, has been helping older people learn about the dangers of online scams. “That’s what attracted me to this initiative,” Stuart added. “I want to update my own skills and ensure nobody else has to feel like I did.”

Stuart’s experiences chime with research by National Trading Standards (NTS), which found that scam victims often feel embarrassed or ashamed about being targeted, with fewer than a third (32%) reporting the crime to the authorities. For more on consumer education, see page 52

Over a million vapes seized

Data published by National Trading Standards (NTS) and the Department of Health and Social Care (DHSC) show that more than a million illicit vapes were seized by Trading Standards teams in England in 2023/24.

The vapes were seized as part of Operation Joseph, a joint project by NTS and the DHSC to combat non-compliant vaping products and the illegal sale of vapes to under-18-year-olds.

A total of 1.19 million illegal vapes were removed from sale across England, a 59% increase on the previous year. The products seized failed to meet UK safety standards, with most containing excess nicotine levels.

Kate Pike, CTSI joint Lead Officer for Tobacco and Vaping, said: “These figures show we are working incredibly hard to remove illegal vapes from our communities and to support businesses not to sell to children.” For more on new legislation to tackle illicit vapes, see page 20

60

SECONDS

ANIMAL HEALTH

Trading Standards Wales (TSW) has published its latest animal licensing report, including the outcomes of the Operation Cabal initiative to target illegal dog breeding. Between January 2021 and 31 March 2024, 281 dogs were seized and 10 arrests were made, with TSW finding there are substantially more illegal breeders in Wales than licensed breeders.

CRACKING CODES

CTSI has welcomed the Government’s response to the CMA market study into housebuilding, which calls for a single mandatory consumer code in the sector. CTSI Chief Executive John Herriman said: “No sector should police itself. The Approved Code Scheme ensures that there is independent oversight, free from the interests of industry.”

SWEET AND SOUR

CTSI has issued a stark warning about unauthorised additives in imported American snacks, sweets and fizzy drinks. The products are flooding UK high streets, posing serious health risks to children. During a recent pilot project funded by the FSA, Staffordshire County Council Trading Standards team seized 3,378 items from local shops.

ONLINE SAFETY FAILINGS

Consumer group Which? has revealed serious shortcomings in the measures online marketplaces take to monitor the products listed on their platforms by posing as a seller of potentially dangerous and illegal electric heaters. Which? found that there were no effective measures in place to prevent the heaters being listed on any platforms.

SCAMS VAPES

Animal Health & Welfare

Activities: A key focus has been the CTSI campaign to improve animal health and welfare through changes to the Animal Welfare Act 2006. Lead Officers met with Chris Loder MP to discuss challenges and the necessity of changes to the law.

Notes: In England, Animal Penalty Notices Regulations came into force in 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, with many farms struggling.

in

e-Commerce

Activities: We have had detailed involvement in CTSI’s extensive liaison work during the passage of the DMCC Act, including a wide range of meetings with DBT officials, MPs, peers from the House of Lords and other regulators. We are now discussing in-person training sessions for TSOs, to be delivered jointly with other Lead Officers and the DBT.

Notes: The DMCC Act and the new proposed Product Regulation and Metrology Bill will have big repurcussions for Trading Standards (see page 20). The DMCC Act includes

Civil Law

Activities: Continuing to work on the DMCC Act and liaising with the CMA and the Department for Business and Trade (DBT) to organise the training of TSOs in preparation for many parts of the Act coming into force in April 2025. I have also received numerous media requests and requests for advice from TSOs.

Notes: There is a continuing need for training on civil enforcement at an Officer, managerial and legal level, including covering the new monetary penalties that will be coming into force with the DMCC Act.

important changes affecting e-Commerce, including giving Trading Standards the power to apply for Online Interface Orders (OIOs) to take down offending online content, extensions to civil enforcement powers and new provisions on subscription traps. These are expected to come into force in spring 2025.

The Product Regulation and Metrology Bill is likely to include provisions in relation to the obligation and liabilities of online marketplaces and other intermediary platforms. CTSI plans to work with NTS, Trading Standards Scotland and the national chief officer groups to forge a joint approach on this.

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

Consumer Advice & Education

Activities: The CTSI Consumer Empowerment Alliance and Consumer Friend have launched a new campaign warning consumers of the dangers of rental scams. Action Fraud reports the average rental scam victim in the UK loses £1,400.

Notes: The DMCC Act will bring changes to consumer rights, and tenants will be affected in many ways by the Renters’ Rights Bill (see page 20). The Payment Systems Regulator’s (PSR) decision to reduce the level of reimbursement for fraud victims is highly problematic (see page 8).

Consumer & Product Safety

Activities: We have represented CTSI on groups including the RoSPA National Home Safety Committee, DEFRA UK Chemical Stakeholders Forum, Electrical Safety First Product Safety Committee and the OPSS National Product Safety Group.

Notes: Ongoing divergence caused by EU exit means designated standards continue to lag behind or are published with significant restrictions. Despite activity by RoSPA funded by OPSS, we are still a long way off from achieving a much-needed injury database.

Doorstep Crime & Scams

Activities: Representing CTSI on the NTS Doorstep Crime Group and the Coercive Control Taskforce.

A key area of focus has been the PSR’s decision to reduce liability of payment service providers to reimburse APP fraud victims from £415,000 to £85,000 (see page 8).

Notes: The continued migration of doorstep criminals onto approved trader platforms, affording them an air of legitimacy, is a concern. The ongoing potential for industrial-scale fraud relating to new and emerging green energy products is also worrying.

Education & Training

Activities: Involvement with the CTSI Qualifications Panel and the CTSI Northeast Branch Executive, as well as scrutinising the Product Regulation and Metrology Bill.

Notes: We must be aware of the Product Regulation and Metrology Bill’s potential to repeal any provision of the Weights and Measures Act 1985. A two-tier Weights and Measures Inspector proposal is likely to come back to the table; we need to be mindful that the only statutory qualification this profession has is that of a Weights and Measures Inspector.

Energy & Net Zero

Activities: We have been working with the Consumer Protection Partnership on Net Zero and the Microgeneration Certification Scheme on a major piece of work. Met with Consumer Scotland to discuss concerns in the energy sector and provided recommendations.

Notes: Main areas of concern have been nuisance calls in relation to energy-efficiency followed up by the mis-selling of spray foam insulation at inflated prices. False and misleading statements are also being made in relation to government grants being available.

Explosives &

Petroleum

Activities: Represented CTSI on the Association for Petroleum and Explosives Administrative Council, and provided a training course on fireworks licensing and safety on behalf of OPSS.

Notes: The Petroleum Enforcement Liaison Group (PELG) has published a ‘Red Guide’ for petrol station operators and intends to update other guidance which has become obsolete. I have written to the secretary of PELG regarding the lack of a standard licence for the private storage of petrol asking for comments.

Fair Trading & Pricing

Activities: The DMCC Act has had a big impact on Fair Trading, and meetings have continued with the DBT and CMA. The Act is now in force, but parts 3 & 4, which are most relevant to Trading Standards, will not be implemented until April 2025.

Notes: The CMA and Government are reviewing dynamic pricing, and we expect further guidance or, possibly, legislation. Discussions on unit pricing have continued with Which? and the CMA, and issues relating to loyalty card pricing are being looked at.

Food Standards

Activities: Representing CTSI on the Food Hypersensitivity Group, the DEFRA Authenticity Steering Group, Government Chemist Steering Group and the Food Standards and Information Focus Group.

Notes: The latest development in this policy area is the new Food Standards Agency (FSA) Codes of Practice. In addition, several allergen control issues have become quite high-profile. The big issues right now are imported food products, allergen controls, EU exit challenges, as well as the new FSA Codes of Practice.

Hallmarking

Activities: Through contacts made at Conference I have been able to increase awareness-training of fraud in the jewellery industry to TSOs.

Notes: There is further evidence that consumer losses are increasing through chronic underfunding of the public sector. The vast majority (93%) of jewellery sold in this country is made abroad. Items are often imported in small packages, invoiced as individual gifts to jewellers. Some agencies don’t even check on the goods on arrival as they appear to be small quantities.

Holiday & Travel Law

Activities: Representing CTSI on ABTA’s Code of Conduct Committee and the Department for Transport’s Air Transport Insolvency Protection Advisory Committee. I am in regular contact with the DBT regarding the Package Travel Regulations consultation and our ‘Wish you were clear!’ policy paper.

Notes: Chargebacks have become important after a recent court case. Problems arise when chargebacks are erroneously and sometimes fraudulently made against travel agents who have no legal or contractual liability.

Intellectual Property

Activities: Representing CTSI on the IP Crime Group Advisory and Enforcement Committees, the National Markets Group, Real Deal for FakeFree Markets Campaign Steering Group, and the Internet Intermediaries Working Group. I have also delivered training courses and contributed to UNECE Working Group meetings on the Use of Market Surveillance Infrastructure as a Complementary Means to Protect Users against Counterfeit Goods.

Notes: The effect of AI on intellectual property rights and on business in general is a big issue.

Legal Metrology

Activities: Representing CTSI on the National Legal Metrology Group and working with the UK Weighing Federation on a policy project which will culminate in a policy report. We have also been busy with training, examining and moderating for the examination cycles.

Notes: Weights and Measures inspections must be highlighted to the profession as most important during uncertain times and the cost-of-living crisis. The profession must continue to invest in future Officers to ensure a skilled and competent workforce.

Motor Trade

Activities: Representing CTSI on the Vehicle Safe Trading Advisory Group, The Motor Ombudsman Independent Compliance Assessment Panel, and the NTS Used Car Group.

Notes: An increasing range of electric and hybrid vehicles are being introduced to the market, as well as dealer networks taking up Chinese imports. The motor industry has changed over the years and is now dominated by multiregional businesses which are very open to Primary Authority, ADR and partnership schemes to aid compliance.

Vaping & Tobacco

Activities: Representing CTSI on the Vaping Expert Panel, the CTSI Race & Equalities Working Group and the Cross Government Regulatory Group for Disposable Vapes. We have also been working closely with the Medicines and Healthcare products Regulatory Agency (MHRA) on vapes.

Notes: The Tobacco and Vapes Bill will progressively increase the age at which people can be sold cigarettes and tobacco products, and impose limits on the sale and marketing of vapes (see page 20. The Environmental Protection (Single-use

Property & Lettings

Activities: Representing CTSI on the NTSELAT Home Buying and Selling Group and at the Lettings Industry Council.

Notes: The Renters’ Rights Bill will impact other Lead Officer areas due to links with energy, construction and the CPRs. It will bring a new focus on tenant rights and a new Ombudsman is being talked about, as well as a portal for property information. Leasehold and freehold reform will impact property sales. It might push more people towards shared ownership, which isn’t fully understood by many consumers.

Vapes) (England) Regulations 2024 are still in draft form and have not yet been made a statutory instrument.

We are hearing about a lot more convictions in court by local authorities prosecuting businesses for the supply of non-compliant vaping products, and there has also been an increase in the use of closure orders where local authorities have found continual breaches of vaping legislation. The MHRA has received several reports from law enforcers identifying products with non-compliant claims on the product packaging which have been used to market vaping products to consumers.

Upfront

VOICES FROM THE FRONT LINE

Trading Standards team

DORSET COUNCIL

What has been your main area of focus over the past six months?

We’ve continued to focus on supporting Dorset businesses and protecting vulnerable consumers. We actively promote the Friends Against Scams initiative and currently have more than 4,500 ‘friends’ signed up.

We estimate we’ve saved residents more than £1m in the past year through our scam and doorstep crime interventions. We’ve made good connections with local fraud prevention and consumer protection partners, including Dorset Police, Citizens Advice and Dorset Victim Support. And we’ve continued to offer business support by partnering

“We’ve saved residents more than £1m through our scam and doorstep crime interventions”

with business organisations like the Dorset Growth Hub, Farming Community Network and local schools and colleges to promote our work, including Primary Authority, Buy With Confidence and metrology calibration services which give businesses bespoke access to our expertise.

We continue to support the Operation Joseph and Operation CeCe initiatives with good results and have a number of financial investigators to support our case load with money laundering investigations. We have a dedicated rural team who focus on animal health and welfare, feed hygiene and disease control.

Are there any emerging issues?

Building, roofing and home maintenance fraud continue to be a high-risk area for us and generate a number of complaints. These are typically multi-victim, resulting in large investigations.

This year we did some new work exploring compliance with

the Offensive Weapons Act 2019 in respect of sales of corrosive substances. Intelligence showed that acid attacks were thankfully rare in Dorset, but our pilot project inspected a small number of businesses to review their due diligence procedures. Compliance was very good, and where there were gaps in businesses’ systems, they were willing to adopt additional measures to shore them up even further.

A new issue we’re concerned about is the availability of bladed articles via online platforms popular with younger people. We’re seeing increased availability of bladed articles disguised as keyrings or other novelty items.

What are the obstacles to tackling these issues?

The ease with which sellers using online marketplaces can close down and restart under a different identity makes our role more challenging. Many items are shipped into the UK directly from overseas, with limited controls in place. A partnership approach between different enforcement agencies at every level of the supply chain is needed to make sure that goods sold via these platforms are safe and legal.

As resources become more stretched, we will need to adopt a more preventative approach to help people understand how to shop safely.

Bouncy castles, rogue traders, imported foods and the continuing fight against illicit vapes and tobacco – it’s all in a day’s work for Trading Standards

Robert Andrews SCAMS LEAD, LONDON BOROUGH OF BARKING AND DAGENHAM TRADING STANDARDS

What has been your main area of focus over the past six months? Being an outer-London borough, Barking and Dagenham has significant issues with doorstep crime and rogue trading activities. Since July 2021, I have been the Scams Lead, which means I investigate cases from phone scams and cold calls to big cases where serious fraud has been committed.

I look at trends and use data and relationships with other boroughs to establish what’s going on. For example, after high winds or a big weather event, I post on social media about cold callers and rogue roofers to make people aware of emerging issues. I also signpost people to the Trading Standards-approved Buy with Confidence scheme. I attend things like coffee mornings to talk to residents and help them be scam-aware. I also give out leaflets and take-away information for them to read.

I’m currently attending GP popups and tailoring my advice to the theme of the day. The latest one is aimed at older people, so to accommodate that I will be giving away ‘no cold calling’ stickers to residents who want them and giving bespoke advice to anyone who would like to stop and chat. I do regular stalls in Barking and the Heathway; these focus on everything from e-bike safety to scam and fraud awareness days. These days are a great opportunity to talk with the residents and are usually a great success.

I have branded uniforms with corporate logos to show residents how easy it would be for people to turn up unannounced pretending to be officials, and performing distraction burglaries by gaining their trust.

This work does get results; I have been working with our Officers and recently handed a case of high-level fraud to our specialist investigations team. This case is about a rogue trader who started work and took the money, but never finished the job.

In 2023 Robert received a London Trading Standards Award in recognition of his community safeguarding work.

Barry Jackson PUBLIC PROTECTION OFFICER, DENBIGHSHIRE TRADING STANDARDS

What has been your main area of focus over the past six months?

Illegal tobacco products and their sale in pop-up shops operated by Organised Crime Groups has been a big area of focus. I’ve also been assisting colleagues in their underage sales work and ongoing work to tackle illegal vapes.

Other work has included a large seizure of illegally stored fireworks; running a project to update car traders on their responsibilities; and a series of IP projects focused on printers and retailers of novelty goods, including bouncy castle manufacturers.

Within our team we have also been preparing for an office move and the downsizing of our storage facilities, as well as the retirement of our Trading Standards and Licensing Manager.

Are there any emerging issues?

The biggest issue that we have is the prevalence of illegal tobacco and vape shops. We have had an issue with illegal tobacco shops for some 10 years and managed to deal with them accordingly with landlords. However, recently we have seen tobacco and vape shops pop up in every town in

our authority – far quicker than our resources and staff numbers can cope with. We are approaching them in the same way, but the numbers and amount of work that they create make it difficult to keep up with them.

Running alongside that we have noted an increase in the sale of American imported foodstuffs including CBD products – none of which appear to have been tested or checked by the retailers.

Being a seaside resort, we also have a massive tourist trade, which brings with it IP issues relating to novelty seaside shops. This has also created a market in the past 12 months for street sellers of perfumes and aftershaves originating from the travelling community.

We are concerned about the growing links between the shops mentioned and organised criminals operating them. We have clearly shown the links between the car washes/barbers and illegal tobacco/vape shops – but there simply aren’t the resources available to tackle them within the local authority. We also have a major issue getting these groups onto the radar of our Police Authority regardless of the approach.

Being on the North Wales coast we have a large retired community who are easy targets for doorstep crime. Again, resources and staff simply can’t concentrate enough time on the subject as we are firefighting other issues.

Something that has been noted and discussed across North Wales is the decline in complaints coming into the service – we can’t say this is because of a lack of knowledge about Citizens Advice

“Illegal tobacco products and their sale in pop-up shops operated by Organised Crime Groups has been a big area of focus”

and their services, or whether it’s due to alternative ways people deal with issues, like naming and shaming on social media.

What are the obstacles to tackling these issues?

Having been reduced to the staffing levels we are currently at is a major hurdle. The recent loss of our manager is also another blow. The authority intends to replace internally, creating a Lead Officer for Trading Standards which again removes Officer time from dealing with these issues.

The cut in budgets is huge –we don’t have resource for any internal projects these days, and no sampling or testing. We rely solely on funding for projects and surveys etc – which is not ideal. Staff numbers and lack of training budget is the biggest issue that we have, but that costs and I can’t see this getting any better.

To overcome this we work with neighbouring authorities and try to share resources, looking at alternative ways of dealing with issues such as approaching landlords of problem properties.

If you would like to be featured in Voices from the Front Line, or if you would like to nominate a colleague, please email editor@ journaloftradingstandards.co.uk

Robert attends local events and engages with residents

Upfront

Jay Moran TRADING STANDARDS OFFICER, COMHAIRLE NAN EILEAN SIAR

What has been your main area of focus over the past six months?

I moved from Cheshire, England to the Outer Hebrides, a chain of beautiful islands off the west coast of Scotland in November 2021. I have been welcomed so warmly by the community, my local authority and Trading Standards teams across Scotland, who are very supportive in every way.

There are just two of us in the team in Stornoway on the Isle of Lewis, which has the highest population and the most active Trading Standards matters to work on, but we also travel throughout all the populated islands. With this small team we work fantastically well together and try our best to ensure the job is performed to the best levels possible.

We are not unlike other services throughout the UK in the issues we face or the work that we do; it’s very dynamic and wide-ranging. We divide the Lead Officer roles for the Trading Standards subject areas between ourselves and review them on a regular

“It is enjoyable visiting the crofters and helping to ensure the food chain is protected”

basis. We also support each other on issues that may require additional input, for complex investigations or where two Officers are required to attend an activity. It really helps having a second person to consult with and we are led by a great manager, who despite having an Environmental Health background has strong Trading Standards knowledge.

Over the past six months the main areas of focus have included completing many of our animal feed inspections and sampling obligations. We are usually assigned around 30 feed businesses to visit each year, mostly to crofts. These are usually inter-generational family-run small agricultural holdings where sheep or cattle are kept and bred for market. Crofting is a traditional way of life in the Outer Hebrides and is a very important part of how a community lives, works and even socialises together. It is enjoyable visiting the crofters and helping to ensure the food chain is protected and that animal health is maintained.

Other work has involved raising awareness of scams as part of the national Shut Out Scammers campaign led by Trading Standards Scotland. There have been a small number of itinerant traders visiting the islands over the summer, knocking on doors and touting for business, which required several interventions.

Weights and Measures is a very important subject in Scotland, and it’s been great to be out on inspection to test goods and equipment at a range of retail and manufacturing premises.

We have hundreds of cruise ships docking each year and so

we enjoy the presence of an increased population during the summer months. We have been busy providing advice to start-up businesses producing artisan gifts and souvenirs for visitors to take home with them.

A number of new distilleries producing spirit drinks have also launched this year and we have helped them understand their legal obligations for making and selling these products.

Are there any emerging issues?

The two key issues that have required significant investment of time and resources are the prevalence of access to vapes by children and the rebuilding of our IT infrastructure following a criminal cyber-attack on the council in November 2023.

In response to reports of child vaping we set up an action group between ourselves, Police Scotland and the local high school to devise a coordinated strategy, share information and intelligence and to reduce or eliminate this problem. This work is ongoing and has seen good results so far.

The cyber-attack meant that we lost access to almost all of the information held on council

drives. We also lost all our internal Trading Standards files. I would urge all Trading Standards teams to consider what the likely impact would be if this happened to them and to take the best measures they can to prevent any loss of data.

What are the obstacles to tackling these issues?

National statistics on child vaping state that most sales are made through retailers, but I do not think that is the case here as we only have a very small number of retailers and compliance seems to be high. Internet sales are something we need to consider and how we approach that will be looked at over coming months.

The obstacles to this would be the use of covert internet surveillance and test purchasing which will require a greater level of procedural methodology to be learned and implemented if we choose that investigative route.

As for the obstacles to rebuilding our own IT systems, fortunately we had several external platforms in use which were unaffected. For all the main data drives however, we had to start again and are now using a cloudbased system.

Jay checks to ensure the alcohol content of spirits is as described

Weapons of mass distraction

With so many parts of modern life constantly vying for our attention, we are all becoming increasingly prone to scams

I’m going to keep this short and to the point. I’ve recently been giving a lot of my focus to the Attention Economy. I first came into contact with the idea a few months ago, despite the term being coined in 1971 (the year after I was born) by economist Herbert A Simon. Here it is: we all have only so much attention to spend, it’s under siege from information and we have to spend it wisely.

Having been raised on Wotsits and Saturday morning telly, I’m easily distracted, but recently it’s reached a worrying level. My wife had noticed that even when my phone was out of reach, I would still be checking my smart watch notifications to see what I was missing. Screen Time on my iPhone showed that I could spend a full working day face-lit, with headaches, incomplete tasks and poor sleep the result of my self-distraction to destruction. But the more I read, the more I realise that it’s not just me. The world we’re living in means many of us are struggling to keep our focus when we need it most, and the effect on our ability to protect our communities –and on society in general – is hugely damaging.

to our financial safety, and our chances of finding out about it are slim to zip.

On the other side of that equation, the length of time that a hashtag topic stays in the top ten on X is coming down all the time, a clear sign that we’re giving every subject less attention each year. The significance of this is that even if a scam warning breaks through the white noise to reach us, it’s competing with the endless scroll of global terrorism, dogs in hats, Ronaldo’s greatest goals and flash-mob wedding dances for our attention. Quite frankly, it doesn’t stand a chance without the power those things have to shock us or be cute.

Scams can be complex, nuanced and difficult to get to grips with, requiring sustained focus

Scams are the perfect expression of this. Let’s take number spoofing, a method fraudsters regularly use to imitate a trusted telephone number like a bank on caller ID, in order to convince us to part with money. Identifying a fake source is key to avoiding scams, but spoofing became possible around 20 years ago without fanfare or a public information campaign which could have helped protect us. In fact, the first I knew about it was when I did a TV piece in about 2011. So up pops a substantial new threat

Scams can be complex, nuanced and difficult to get to grips with, requiring sustained focus. To win the battle for the attention of our communities, scam stories need to reflect the emotional impact, rather than the financial loss attached. But then once we have that attention we need to honour it, by keeping things very simple indeed. This means broad, useful messages that stick, rather than swamping us with technical detail we can’t use. Thank you for your attention. l For more on consumer education, see page 52

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

Kerry Nicol External Affairs Manager, CTSI

Hitting the road

Trading Standards’ biggest fan has spent the past few months travelling the country, meeting with movers and shakers, and promoting the profession

What a six months it has been! I feel like I’ve travelled the globe to promote Trading Standards, but in reality, I haven’t left England – always the drama queen, as my dad would say.

My ‘globetrotting’ started in June at the flagship annual CTSI Conference in Leeds. It was a fantastic Conference, as has been demonstrated by the wonderful member and stakeholder feedback we have received. I really value the opportunity to connect with so many of our members and stakeholder partners at our yearly event, which is sometimes the only chance to meet with key people in person. Online meetings have certainly streamlined the way we work, but face-to-face interaction is still very important to me.

I had the opportunity to lead two seminar sessions to talk about two of the big projects I have been working on this year; the Cost of Beauty campaign and our APPG report looking at online marketplaces and the supply chain. I thoroughly enjoyed talking through the

issues we have identified with two panels of experts and exploring solutions with our audiences.

My next big outing was to Liverpool for the Labour Party Conference. Now this really was an experience; I had an allaccess pass, which granted me admittance into all the main plenary sessions and key speeches. Witnessing the pantomime-style shouting first-hand was a revelation – I felt at times that I needed popcorn and some 3D glasses! The ongoing theme of every session I attended was ‘Britain is broke’. I was quietly observing and wondering where we might gain any gleams of hope for some additional and much-needed resources to help with the new Government’s ambitious aims (see page 20).

Government engagement has been a key focus since the election and we’ve spent time writing to new Ministers for key portfolio areas to highlight who we are, who we represent and what we see as the key issues in the areas for which they are responsible. We’ve had some great

responses back and this outreach work will be ongoing over the next six months. Next I was off to the Local Government Association Conference in the stunning town of Harrogate, where I took my Cost of Beauty bar to display my vast array of unsafe cosmetic products that I have collected over the past year. Funnily enough, almost everyone at the event thought I was there to give out free manicures and facials! “Not with these products,” was my candid reply to reel them in and tell them more. The event had a real buzz about it and I met some really interesting people who work in local government, including some council chief executives who hold the Trading Standards portfolio. It was the perfect opportunity to make sure they know exactly how brilliant their Trading Standards teams are, and how they are no doubt performing at an exceptional level under immense strain and pressure.

I then had the pleasure of representing my team at the CTSI AGM to highlight

how are we are influencing the consumer protection landscape to better support our members. I talked through our key activity and the areas that we have had a significant impact on, such as vaping, unsafe products, the Digital Markets, Competition and Consumers (DMCC) Act, challenges with the supply chain and imported American candy.

I really enjoy giving these updates to members as it’s a nice opportunity for me to look back on the great things we have achieved over the past few months.

Taking the lead

The next big event in my calendar was the annual meet-up of our Lead Officers, and this one was particularly special as we made it a two-day event to encompass some media training, which was something our Lead Officers had asked for. Day one had a real buzz about it; we have gone through a robust recruitment process to grow our Lead Officer network to bring in some much-needed capacity to take

some of the strain from our current Lead Officers, particularly in the busy portfolio areas (see page 30). We’ve also added some new portfolios to keep an eye on emerging issues, such as AI and Digital. It was wonderful to have so many of our new Lead Officers there and to share their knowledge and expertise with our stalwart crew.

On day two we had media training delivered by Liz Barclay, the Small Business Commissioner and long-standing supporter of CTSI. Liz has a wealth of media experience and her training did not disappoint. She put us all through our paces and I can confidently say that every single person left that room armed with some really great tips and tricks of how to tackle media interviews.

Government engagement has been a key focus since the election and we’ve spent time writing to new Ministers for key portfolio areas

Left CTSI’s 2024 Conference in Leeds provided a great opportunity to reconnect with colleagues and share ideas

Our Lead Officer network remains

one of my favourite things about working at CTSI – I don’t think many people can say that in their day jobs they get to interact with those at the pinnacle of their profession on a daily basis.

As I’m writing this we are fast approaching our annual Hero Awards event, and this year is as looking to be as exceptional as always (see page 54). I still pinch myself that I get to regularly visit and hold events at the House of Commons. We are receiving a keynote address from Rhys Hurley, Head of Intelligence Partnerships at the Intellectual Property Office,who will also present the awards to the winners of that category. We also have a good number of MPs confirmed to attend, which is another opportunity to showcase just how wonderful you all are, and what a huge impact you make to society.

I look forward to more chances to keep shouting about our wonderful profession in 2025 and I can’t wait to update you all on what I get up to next. ●

Jessica Merryfield Head of Policy & Campaigns, CTSI

Future-proo ng the profession

From AI chatbots to scams and ‘scam-baiters’, new technology presents both challenges and opportunities for Trading Standards. CTSI is determined to keep up with the pace

We live in an increasingly digitalised world, with new and emerging technologies shaping and influencing our professional and personal lives. With new technologies come new opportunities, but also new risks and challenges as we venture into the unknown.

In my time as a Trading Standards Officer, I saw the rise of technology change the way we understood and delivered the work. I started my regulatory career using carbon copy pads which would be typed up back at the office before being posted out to the businesses concerned; I finished it using digital tablets to record work such as inspections, the outcome of which could be shared with the business either at the time or very shortly after.

I can clearly remember using disposable cameras to record evidence and having to rush through the development and printing of the photos. This contrasts with the smartphones

of today that take digital photos which are available to see and share instantly. From a business practice perspective, we are seeing an increase in businesses interacting with consumers via chatbots, which often field a lot of the initial customer service enquiries. We are also seeing artificial intelligence (AI) tools being used to write product descriptions on websites. This can help transcend language barriers, but can also create issues if the descriptions are not checked for compliance with legislation relating to things like health claims.

Whether we like it or not, emerging technologies such as AI are here and already integrating into our daily lives. We started the conversation on this at our successful 2024 Conference with plenary sessions themed around the ‘Digital Future’, and feedback obtained showed it was clear that this is an area of increasing interest to Trading Standards professionals.

Safer innovation

Looking more widely at emerging technologies, they are at the heart of global innovation, and it is recognised that innovation in this space is needed to grow economies. The question being asked is: “How do we ensure that innovation is allowed but effectively regulated to ensure safety?”

We need to share the research and learnings in the AI space to improve, develop and innovate. It's important that technological solutions also bring trust to that regulatory programme, so technologies need to be tested before bringing them to market to ensure they are safe and compliant, and that they work.

To place this in a Trading Standards context, let’s look at the Toys (Safety) Regulations 2011, and the increasing number of toys with integral AI being placed on the market. The AI system installed in the toy would not likely or usually be considered a safety component

but there are concerns about what happens if the AI system goes wrong. For example, the integral AI tells the child to do something that is harmful to their physical, mental or emotional wellbeing –such as giving the child an instruction to jump out of the window – or tells the child that they are ugly. In those situations, there is a risk to the safety of the user but in a way that the legislation has not had cause to consider before now.

That may be an extreme example, but we do need to understand how emerging technologies can affect both the average and vulnerable consumer, as well as the end user. The Digital Markets, Competition and Consumers (DMCC) Act updates the definition of ‘average consumer’ and widens the definition of ‘vulnerable consumer’ so it will be interesting to see how emerging technologies work alongside, and within, these definitions and whether the technology itself creates

Whether we like it or not, emerging technologies such as AI are here and already integrating into our daily lives

vulnerabilities for consumers, or groups of consumers, depending upon how it is used and accessed.

Technology is ever changing, evolving and developing. There are some positives and opportunities regarding how emerging technologies could benefit the work of Trading Standards. We are already seeing colleagues at the Advertising Standards Authority (ASA) using AI to scan the web for non-compliant advertising. Telecoms giant Virgin Media O2 recently unveiled ‘scam-baiter’ Daisy, a human-like AI granny who talks with fraudsters and keeps them engaged in rambling chat to prevent real people being scammed (see page 7). While it is not clear whether Virgin Media O2 is going to share this technology with other telecommunications companies, the creation is another potential weapon in the arsenal against scams.

Daisy is an example of an indirect and positive use of AI and emerging

technologies helping to protect consumers and support Trading Standards in the fight against scams. But how can AI and similar technologies be useful in helping with the day-to-day role of a Trading Standards professional?

In our upcoming legal metrology paper, we discuss how AI could be used to remotely monitor measuring equipment such as petrol pumps, which is already being developed in Germany. There could also be an opportunity for emerging technologies to play an important role in imported goods checks, scanning for products which are at risk of being noncompliant and should not be distributed into our economy.

At CTSI, we recognise that this is an area of interest to our members and the profession. As such, we are delighted to announce that we have appointed Cenred Elworthy as a Lead Officer to help us understand the area of AI, Digital Markets and Emerging Trends. Cenred will be helping us gain understanding in this area and he will be in a strong position to respond and comment on any developments or discussions that may affect the Trading Standards professional in this space. In our recent member ‘Pulse Survey’, it was clear that that members want to discuss this further and would like a webinar on this topic, so we will work on putting something together to build on the conversations we started at Conference. Watch this (digital) space! l

OUT WITH THE OLD

THE GOVERNMENT’S AGENDA FOR SWEEPING LEGISLATIVE

AND REGULATORY REFORM HAS BEEN 14 YEARS IN THE MAKING. BUT WHAT WILL IT MEAN FOR ALREADY OVER-STRETCHED TRADING STANDARDS SERVICES?

A change of government can have seismic implications for a country. This is particularly true when one party has been in power for a considerable amount of time. So, when Labour wrested control from the Conservatives after 14 years, it was reasonable to expect that deep-rooted change would soon be afoot.

Before the General Election took place in July 2024, many pieces of legislation were working their way through parliament, and under the new government they are getting ever closer to being passed into law. What do they mean for Trading Standards? Let’s take a closer look.

Product Regulation and Metrology Bill

Unveiled on 4 September 2024, the Product Regulation and Metrology Bill (PRMB) follows a 2023 consultation by the Department for Business and Trade (DBT) and Office for Product Safety and Standards (OPSS) on proposed reforms to the UK’s post-Brexit product safety framework.

Cognisant of the fact that the nature of products and the way that people buy them have altered significantly in recent years, the Bill is intended to address these developments, not least the massively increased volume of online sales. The

Bill represents a sea change in the UK’s perspective on product safety and when enacted (possibly before Spring 2025), it will have a significant impact on businesses and consumers.

CTSI has long been pushing for a robust and modernised product safety system, most recently in its ‘Mind the Gap Between the Chain and the Platform’ policy report.

Christine Heemskerk is CTSI joint Lead Officer for Product Safety. As she explains, the PRMB is a mechanism that will enable the Government to introduce a number of regulations to the UK’s product safety and compliance framework.

“In the Bill, they’re talking about bringing online marketplaces into line. But we don’t know how detailed that will be because, currently, online marketplaces are totally unregulated. They just rely on their third parties, and usually these third parties are based abroad. When something goes wrong, no one is responsible because the online

marketplace is not responsible under our current legislation. Obviously, if the thirdparty seller is based in China, it’s very difficult to get them to do anything.

“It’s the same with fulfilment houses, which are not dissimilar to online marketplaces. They just store items and then they send out on demand. Again, they’re not responsible for anything that’s in their warehouses.”

According to the consumer group Which?, 95% of UK consumers have made purchases through online marketplaces at least once in the past two years, with around 23.4 million UK consumers making monthly transactions. Meanwhile, OPSS research found that a staggering 81% of products available through online marketplaces have failed safety tests.

Heemskerk is keen that the Government ensures online marketplaces and fulfilment houses are forced to have responsibility for products where there is no UK presence.

“If the third party is based in the UK, it’s not a problem because you can tackle them. But where the third party is not based in the UK, there is just no responsibility for unsafe products.”

CTSI is concerned that, when it comes to buying products from online marketplaces, UK law has stood still and We want to make sure there’s a consultation... It can’t be left in the hands of Ministers. They’re not close enough to the issues

23.4m

UK consumers buy something at least once a month from an online marketplace, according to Which?

thereby created a dangerous blind spot that allows unsafe products to flood in.

Kerry Nicol, External Affairs Manager at CTSI, says that the Institute welcomes the Bill, which has been a long time coming. “Product safety, especially with online marketplaces and third-party sellers, has been a wild west,” she believes.

“We’ve had some wariness around the scrutiny of the Bill. In the Bill, it talks about Ministers being able to make decisions on secondary legislation. That’s all well and good, but we want to make sure there’s a consultation process that goes with that where they’re talking to key individuals and partner organisations. That’s really, really important. It can’t be left in the hands of Ministers. They’re not close enough to the issues.”

Tobacco and Vapes Bill

While product safety is crucially important, it’s perhaps the Tobacco and Vapes Bill that has received the lion’s share of press attention. This piece of legislation has been promoted as a landmark step in creating a smoke-free UK. It aims to achieve this by gradually

81% of products available through online marketplaces failed OPSS safety tests

phasing out the sale of tobacco products across the country, making it an offence to sell tobacco products, herbal smoking products and cigarette papers to anyone born on or after January 1, 2009. The Government anticipates that children born on or after this date will never be legally sold tobacco products, breaking the cycle of addiction and disadvantage.

Introduced to parliament on 5 November 2024, the Tobacco and Vapes Bill has far-reaching implications for Trading Standards. While the profession has welcomed the Bill and its various proposals, it has emphasised that the enforcement of various new measures will need to be enabled by proper resourcing of local Trading Standards.

As for the sale of vapes, on 24 October new legislation to ban the sale of singleuse vapes (from 1 June 2025) was

We want to make sure there’s a consultation... It can’t be left in the hands of Ministers. They’re not close enough to the issues

laid before parliament. This will also be an enforcement responsibility for Trading Standards.

Kate Pike is joint Lead Officer for Vaping for CTSI. She says: “We will have more responsibility to deal with vapes that are illegal under this piece of legislation. But, to be honest, we’re already seeing products which comply being introduced. This is such an innovative marketplace. They are so fast-moving, there are already lots of products coming out which comply with that ban.”

She adds: “But the legitimate market and the legitimate businesses will need some support. So CTSI will be working hard to try and ensure that people understand the responsibilities and what products they should be looking for. And CTSI will be working really closely with OPSS, who are responsible for the disposal schemes, so that people can ensure that these products are recycled safely and effectively.”

Looking to the future, new laws concerning tobacco products won’t come into force for a few years, meaning that Trading Standards will have time to

We will have more responsibility to deal with vapes that are illegal under this piece of legislation

educate businesses. But, as Pike says: “It’s really important that funding is built in to enable that to happen, that businesses really understand what their responsibilities are. In many ways, it should be more straightforward for them going forward.”

Renters’ Rights Bill

Another key piece of consumer protection legislation, the Renters’ Rights Bill was introduced to parliament on 11 September 2024. Its aim is to deliver the Government’s manifesto commitment of transforming the experience of private renting, including ending Section 21 ‘no fault’ evictions. Among the measures in the Bill is the strengthening of tenants’ protections, including new rights to challenge rent increases and to request to keep a pet.

In England alone, there are 11 million private renters and 2.3 million landlords. Some of the statistics surrounding this sector are alarming. Consider this: according to the national news outlet ‘the i’, almost one in five lowincome households receiving benefits

11

million private renters in England alone

have reported falling behind on rental payments.

Alison Farrar is CTSI’s joint Lead Officer for Property and Lettings. Regarding the new legislation, one of her main concerns centres on a Decent Homes Standard.

“What they’re proposing is that every property in the private rented sector will be inspected, probably by environmental health or housing teams, and that they will need to be brought up to a Decent Homes Standard. There will be consultation and a lot of work going on around how that is done. My concern, from a Trading Standards’ point of view, is the traders that will need to do this work.

“This is an opportunity for us at Trading Standards to set up our trusted trader Buy With Confidence schemes or whatever other schemes we have. There will be a need for the traders to do all the kind of work to bring these properties up to that Decent Homes Standard. But it could also provide an opportunity for rogue traders.”

In towns and cities where demand for traders is already high, particularly

during the summer months when student digs are repaired and revamped, new rules governing rental properties could leave landlords, as well as ordinary householders, struggling to find specialist workmen.

Farrar says: “We need to make sure that we’re doing a lot of consumer education to make sure that people are using the best traders, and that there isn’t a window for these rogue traders.”

Farrar also points to the issue of discerning whether a landlord is a business or a consumer. “There needs to be a discussion about this because we all know that legislation crosses over a bit. We will need some clarity on whether these landlords are consumers.”

As for no-fault evictions, Farrar says that CTSI is encouraged that elements of the new Bill improve upon its former incarnation, including a proposal that a landlord can’t re-let the property for 12 months rather than three months.

Regarding the Bill coming into law, the ambition within parliament is early Spring, but there’s an acknowledgment that some elements may take longer to resolve.

Planning and Infrastructure Bill

As for the forthcoming Planning and Infrastructure Bill, the Government claims that it will “unleash the biggest building boom in half a century”. Introduced in the King’s Speech back in July 2024, this new legislative move aims to accelerate the development of infrastructure and the construction of 1.5 million new homes.

The Bill, slated for introduction early in 2025, seeks to streamline the planning system, including reforming compulsory purchase rules in order to unlock more land for development, modernise planning committees and boost capacity in local planning authorities.

At the beginning of December 2024, Ministers reiterated the pledge to deliver more homes and announced that planning decisions on at least 150 major infrastructure projects would be taken during the lifetime of this parliament.

Tim Day, joint Lead Officer for Doorstep Crime, Scams and Consumer Vulnerability for CTSI, sounds a note of caution about the impact of the Bill when it finally becomes law. “If we’re going to speed up the planning process and we’re going to do more building, then obviously

1.5m the Government’s new home building target for this parliament

we need to see a concomitant increase in the amount of tradespeople available to do it. And it’s not just about a lack of those tradespeople, it’s about also being aware that fraud is such a big thing, and so professionalised in its nature, that there will be people who are looking at this as an opportunity already. So, unless that is factored in and checks are built into the process, then it’s going to be an issue.

“It’s one of the reasons that I’ve been so keen on putting forward a registration and licensing scheme for the trades, so that we know who they are, we know where they’re based, and we can have some sort of audit situation going on before they get on schemes such as this.”

At present, there is no licensing scheme in place covering traders in the construction sector – and little prospect of one. Given the Government is intent on speeding up the planning process,

We need to make sure that we’re doing a lot of consumer education to make sure that people are using the best traders

there are concerns about the potential for mis-selling of new homes if requisite oversights are not in place or aren’t able to be enforced properly.

Day says: “The imbalance of power between the consumer and the trade they’re dealing with is enormous, and it’s amplified by the amounts of money involved and the timescales when everyone wants it done quickly. It’s a hugely stressful time during a transaction that consumers aren’t experts in, but in which they have a huge stake.”

When it comes to consumers choosing a trader, Day says that matters are complicated by the fact that various trade body and professional membership schemes have different membership criteria and different checks, vetting and auditing in place.

“The landscape for the consumer is really, really difficult… the marketplace is such that you can do everything that you’re supposed to do, and expected to do, and still be at risk [of hiring a rogue trader].”

He adds: “I think that regulation is so important, and I think that a licensing scheme for the construction industry,

If we’re going to speed up the planning process… then obviously we need to see a concomitant increase in the amount of tradespeople

for the trades, is so important because you could root out fraud at the outset. Consumers are not in a position to identify it, so something needs to happen here.”

It also seems that the issue of rogue traders was exacerbated by Covid.

Day says: “Because rogue traders couldn’t go out cold-calling during the pandemic, there was this migration onto these approved trader platforms. And that makes everybody vulnerable. When younger people need something doing, they go online to these schemes and call somebody up. The difficulty you have there is that the potential victim has already bought into the idea that they need something doing… because they’ve had reason to call someone out and, as a consumer, are convinced that the work needs doing. That has meant there’s another whole demographic of potential victims.”

Resources and implementation

It’s clear that the UK’s legislative agenda is jam-packed. But how will Trading Standards deal with all these new laws that require more work?

Over the past decade, spending on Trading Standards has been slashed by more than 50%. During the same period, staffing levels have declined by between 30% and 50%. Many local authorities no longer have sufficient resources to enforce all the consumer protection legislation for which they are responsible.

In order to build back Trading Standards, CTSI has called for a continuing investment which would create 2,000 more Trading Standards posts, including 300 apprenticeship places across the UK. CTSI also wants phased, additional ring-fenced investment in Trading Standards services, rising to £100m after four years.

So far, however, the Labour Government has been silent on how it will pay for an increased enforcement burden on Trading Standards. With any piece of legislation, it’s only as successful as the enforcement surrounding it. Within the profession, it is generally accepted that Trading Standards is at a breaking point.

A spokesperson for the Ministry of Housing, Communities and Local Government says: “We recognise the challenges that local authorities are facing as demand increases for critical services. This is why we announced £1.3bn of new grant funding in 2025/26 for councils to deliver core services.”

Nicol says: “When there’s an emergency, who does the Government call? It’s Trading Standards Officers who step in to save the day. They’re always the ones who give that bit extra. They find those extra resources and that bit more capacity to carry out something when it’s needed the most.

“But we’re at the point where there is nothing left. So, Government needs to listen seriously to what we’re saying.” l

NEW LAWS AT A GLANCE

Product Regulation and Metrology Bill

This will address the changing ways in which goods are bought and sold, particularly focusing on the safety and compliance of products available through online marketplaces.

Details of the Metrology aspects of the Bill remain scant, but it is hoped it will mean improved clarity and fairness for consumers buying goods online and elsewhere.

Digital Markets, Competition and Consumers Act Examined in detail in the last issue of the Journal, this landmark legislation will tighten controls on businesses selling online, as well as bolstering enforcement powers with new tools such as Online Interface Orders.

Tobacco and Vapes Bill The legal age of purchase will rise each year, meaning that anyone born on or after 1 January 2009 will never legally be able to buy tobacco products. New enforcement powers will mean the introduction of on-the-spot fines of £200 for retailers found to be breaking age-restricted sales laws, and there will be a new licensing scheme for retailers that sell tobacco, vaping and nicotine products in England.

Single-use vapes ban From June 2025, it will be illegal to sell single-use vapes in England under a ban being introduced by DEFRA on environmental grounds.

Planning and Infrastructure Bill

A flagship plan to ‘streamline’ and speed up planning measures to get more housing and associated infrastructure built, including the ambitious target of building 1.5 million new homes over the course of the parliament.

A burning issue

Fires started by e-bikes and e-scooters have cost lives and caused horrific injuries. With new legislation in the pipeline, what can be done to ensure they are safe, and that those selling unsafe devices are held accountable?

There are few things more terrifying than a house fire. The smoke, the sound, the scorching heat – flames can take over in a matter of seconds, turning a place of safety into a death-trap. When a blaze broke out at Scott Peden’s house in Cambridge in June 2023 he almost lost his life, suffering burns and other serious injuries. He emerged from a coma four weeks later, only to be told that his partner Gemma, eight-year-old daughter Lilly and four-yearold son Oliver had all died in the fire.

The tragedy is one of an increasing number believed to have been caused by lithium-ion batteries contained in e-bikes and e-scooters which, when being charged, can overheat and explode with devastating results. According to the latest Home Office figures, between January 2021 and September 2023, in England alone there were 263 fires caused by e-bikes and e-scooters, resulting in 70 non-fatal casualties and five deaths.

However, the National Fire Chiefs Council (NFCC) told the Journal, “we believe these figures are on the conservative side and believe the scale of the issue to be greater”.

In the year following the tragedy, Peden has added his voice to a growing number of calls for urgent action to prevent more fatalities. In a hard-hitting video produced by the charity Electrical Safety First, he describes his experiences: “Before the fire, I had no idea about the dangers of these lithium-ion batteries. I bought my battery online and just assumed it would be safe – I never imagined it could be so dangerous. The battery exploded under my stairs whilst my family was asleep. Flames were coming up the stairs like a flamethrower. The fire and smoke filled the house up in seconds. I

told them to jump but they couldn’t get out. I’ve lost everything from that one night and my heart has been left broken.”

Wayne MacKay is Head of Policy and Public Affairs at Electrical Safety First. He and his team have been sounding the alarm about the threat posed by e-bikes and e-scooters, and urging the Government to address the issue in its upcoming Product Regulation and Metrology Bill (see page 20).

“We first looked into the issue last year because of our conversations with the London Fire Brigade, who were witnessing an exponential increase in fires caused by e-bikes in the capital,” MacKay says. “In our ‘Battery Breakdown’ campaign, we looked at issues to do with consumer behaviour, appropriate use and charging, as well as conversion kits and e-bike design standards. It was a complete 360-degree overview and from that work, we identified some really clear key issues that are causing the fires.

CTSI is also calling for additional responsibilities on online marketplaces. As a result of its work with the APPG for Consumer Protection, the Institute produced its ‘Mind the Gap’ report which recommends, among other things, the introduction of clear legal duties for online marketplaces.

The NFCC has likewise demanded action: “We have long been warning of the fire safety risks posed by poorly manufactured or converted e-bike and e-scooter batteries, and calling for urgent regulatory and legislative changes to help keep people safe,” said a spokesperson.

“When these fires occur, they can develop quickly and without warning. This sometimes makes it harder for people to escape from buildings, particularly if the scooter or bike has been stored in a hallway or stairway, compromising escape routes. The result can be catastrophic, and we have sadly seen a number of serious injuries and deaths as a result of these fires.

When these fires occur, they can develop quickly and without warning… the result can be catastrophic

“We need to tighten up the procedures and the sanctions on online retailers and third-party sellers on online marketplaces who are selling dangerous products. Reputable retailers by and large provide devices which are safe – if you use them according to the instructions, you should be fine. But when you try to convert your bike with kits from an unregulated online marketplace, or if you purchase an additional charger that hasn’t come with your existing bike and is incompatible, that heightens the risk.”

“NFCC is working with Government departments and other partners to try and reduce the risk to the public, and to raise awareness of what people can do to minimise those risks. For example, we urge people to buy these batteries from reputable retailers, to follow the manufacturers’ instructions when charging, and avoid storing or charging e-bikes and

e-scooters in escape routes like hallways.

“NFCC has also supported calls by Electrical Safety First for regulation that mandates third-party safety assessment for e-bikes, e-scooters and their batteries before market release.”

Double standard?

According to rules currently in place on the parliamentary estate in Westminster, ‘E-bikes, e-scooters and/or detachable battery packs must not be brought into any parliamentary building for charging or any other reason. This is to prevent the potential fire risk posed by e-scooters or e-bikes.’

No such blanket ban applies to ordinary residential buildings though. Does that mean the safety of MPs is more important than that of the general public? When approached for comment on the apparent discrepancy, a Government spokesperson said: “We take the risk of e-scooter and e-cycle fires very seriously, which is why this Government is acting to overhaul our product safety laws to help address the associated fire risks and remove unsafe products from the market swiftly.

“Users should ensure that they use only the charging equipment supplied with the device and should not tamper with the battery or settings.”

In February the Department for Transport published guidance on the safe storage and charging of the devices,

Below Scott’s children Oliver and Lilly lost their lives in the blaze, along with their mother Gemma

alongside specific guidance for premises managers. However, the Government spokesperson said, “It is ultimately for building owners and managers to make decisions about the charging and storage of e-cycles and e-scooters on their properties in accordance with the guidance.”

Cause for optimism

At the time of writing, the Product Regulation and Metrology Bill is making its way through parliament, and it does look set to address at least some of the issues surrounding e-bike and e-scooter safety, with the framework governing lithium-ion batteries expected to develop following the publication of the UK Battery Strategy in November 2023.

According to a Government spokesperson, “The Department for Business and Trade is acting now to overhaul our product safety laws to ensure authorities can remove unsafe products from the market as soon as possible.

“The dangers of lithium-ion batteries used in e-bikes/e-scooters and the risk of fire/explosion remain a key issue. The Office for Product Safety and Standards (OPSS) is working cross-Government on a range of activity including enforcement, research and consumer awareness messaging. This is a complex issue, and the powers in the Product Regulation and Metrology Bill will allow us to determine

what updates to our regulations may be needed to ensure the best protections for consumers and consistency with the majority of reputable retailers.”

In response to the launch of the Bill in draft form, Electrical Safety First’s Chief Executive, Lesley Rudd, commented: “We welcome the Government’s publication of the Product Regulation and Metrology Bill. UK consumers are at risk from the neverending tide of dangerous electricals sold via online marketplaces and this has to stop.

“Equally, e-bikes, e-scooters and their batteries must be classified as high-risk and require third-party certification to prevent the increasing number of fires. We are encouraged by the Government’s prioritisation of these important issues. However, the devil will be in the detail. The legislation must be robust enough to prevent bad operators from risking the lives of UK consumers.”

Someone else who believes there is no room for complacency around e-bike and e-scooter safety is Scott Peden, who knows all too well what is at stake. “If my story doesn’t show the desperate need for a change in regulation, then I don’t know what will,” he says. “I’m urging all the political parties to come together to tackle the issue of e-bike fires so that no one has to go through what I did. My life has been ruined but I can help to save someone else’s.” l

Left Scott Peden’s burnt-out Cambridge home

WINTER IS COMING

The Heat in Buildings Strategy represents a once-in-a-lifetime opportunity to reduce carbon emissions from Scotland’s homes. But is Trading Standards ready for the challenge?

The Heat in Buildings Strategy (HiBS) is an ambitious initiative by the Scottish Government to improve domestic energy-efficiency and promote the use of low-carbon heating systems. Among its goals are a 68% reduction in carbon emissions from buildings by 2030, with all of Scotland’s homes achieving at least an EPC band C rating by 2033. There is also the intention that at least 1 million homes – around half of the country’s total number – will be completely zerocarbon by 2030, with the entire housing stock reaching that landmark by 2045. To support those targets, the Scottish Government will be pumping money into the domestic energy-efficiency sector, with an expected investment of at least £1.8bn over the next five years according to the University of Strathclyde.

On paper at least, that all sounds promising. After all, the climate emergency affects everyone, and any opportunity to reduce carbon emissions –with the added potential bonus of cutting home energy bills – should be grasped with enthusiasm.

But as the countdown clock ticks closer to those key dates, there exists a yawning gulf in consumer awareness and understanding about energyefficiency products, a shortage of skilled traders qualified to take on the task, and a prevalence of rogue practices in the sector which are causing real concern for Trading Standards.

To start with, says Diane Bryson, CTSI joint Lead Officer for Energy and Net Zero, the Energy Performance Certificates (EPCs) which will provide a crucial measure of HiBS’s success or failure are poorly understood and vulnerable to exploitation. “EPCs can have a real effect on consumers but there hasn’t been enough information about them promoted towards the public,” she says. “A lot of companies will exploit that, saying they can offer their own EPCs, then trying to mis-sell different products so consumers can qualify for them.

“There’s also a risk that consumers could be given fraudulent EPCs. There have been discussions at some of the meetings I’ve been to that when a

householder goes to sell their home, they may find that the EPC they thought they had isn’t the correct one, and they have to do a lot more work before it can be sold.”

Fiona Richardson, Chief Officer of Trading Standards Scotland (TSS), shares those concerns. “EPCs are going to be vital in terms of determining where consumers are in their journey to comply with HiBS,” she says. “My concern is that there’s not enough information about that and there are potential weaknesses in the system, and in the balance between incentivisation and penalisation of consumers who do and don’t make changes to their homes.

This is going to affect every single citizen in Scotland, and I don’t think there has been any understanding of that

“All of those things combined just heighten the risk for consumers. There’s a great deal of complexity in the market and a great deal of uncertainty.

“This is going to affect every single

By Richard Young

citizen in Scotland, and I don’t think there has been any understanding of that. I don’t think the scale and the impact of this piece of legislation has been properly considered,” Richardson adds.

Disease and cure

Just one example of consumer detriment in the sector is the spray foam insulation bait-and-switch; householders across the UK, not just in Scotland, have been targeted in recent years by crooks misselling insulation, with promises of lower bills and improved energy efficiency. Many of these installations have, however, proved to be worse than useless, resulting in damp and mould problems, and affecting whether properties can be mortgaged or sold.

Now, some of those same companies which offered spray foam ‘solutions’ are selling bogus remedies, further ripping off consumers by charging to remove the offending installations.

According to Richardson, spray foam scams illustrate the need for more stringent vetting of the domestic energy-

efficiency sector, with a need for licensing as well as a greater focus on public education and upskilling of the workforce. “There are a lot of novel products that people don’t understand, and there aren’t enough legitimate businesses in the sector to squeeze out the more problematic ones,” she says.

While certification and vetting initiatives – such as the CTSI-backed Approved Code Scheme – do exist to promote best practice in the sector, there is currently no legal requirement for businesses to be authorised to install energy-efficiency measures, or to have certain qualifications or training.

“They’re putting in these products – solar panels, air source heat pumps etc – but they’re not necessarily doing it properly,” says Richardson. “The consumer doesn’t know whether or not things are fitted properly, but it’s having a big effect on their bills. And that could have an effect on EPC ratings.

“There’s no control over the sector. If [the Scottish Government] is hoping to roll out a lot of things very fast to

reach their targets, I think further down the line, there’s going to be a big backlog of problems when things are not functioning properly.”

There’s going to be a big backlog of problems when things are not functioning properly

At present there are several certification schemes with different and sometimes overlapping areas of specialism, a host of acronyms and technical jargon relating to the technologies involved and their supposed benefits, and a complex array of financial incentives available, all with their own byzantine terms and conditions. Even those who specialise in consumer protection can find it bewildering – so what hope is there for consumers themselves?

“I think it would be easier if anybody working in the sector just had to be authorised by a particular body and that was it,” Richardson says. “It’s very confusing for consumers who may not realise that because a certain trader wasn’t authorised, they couldn’t get a certain certificate. And it’s not entirely the trader’s fault because there was no legal requirement for them to be authorised anyway.”

David Mackenzie, Trading Standards Manager at the Highland Council and former Chair of the Society of Chief Officers of Trading Standards in Scotland (SCOTSS), cites the Gas Safe Register as a template which could be adopted in the domestic energy-efficiency sector. “The best-in-class model has to be the Gas Safe Register,” he says. “As far as we know there are not an awful lot of dodgy gas installations that go on because there’s a competence test, and that’s what we need here. It’ll cost a lot of money, and it’s going be really difficult to do. But it’s necessary because this is going to be a disaster without it.”

Making progress

HiBS has been subject to a lengthy consultation period in which views from across the regulation, enforcement and business spectrum were sought – and much of the fine detail of the strategy has yet to be established.

Among those who contributed to the consultation was the statutory body Consumer Scotland, which recommended that “further modelling and analysis of the impact of [HiBS] on consumers should be undertaken before the Scottish Government reaches decisions on key aspects of the Bill in order to avoid any unintended detriment”.

In the most recent update (October 2024) on the progress of HiBS, the Scottish Government’s Acting Minister for Climate Action, Alasdair Allan, wrote: “Our next step will be to set out the long-term direction of travel and provide certainty to both homeowners and the supply chain…. We are completing our consideration of the responses to this consultation, and aim to confirm next steps shortly.”

Bryson, Richardson and Mackenzie are all in agreement that Trading Standards’ expertise needs to inform what those next steps should be, and they and their colleagues have been instrumental in ongoing discussions about how consumers can best be safeguarded.

If someone’s lost £10, whether they’ve been scammed or whether some incompetent guy’s just made a complete hash of it, they’re still £10 down

And they have no illusions about the scale of the challenge.

“It’s important to look at the future,” says Mackenzie. “In broad terms, this is the biggest thing since devolution.” The new Scottish Housing Bill includes proposals for rent caps in certain areas which, says Richardson, “is going to put increased pressure on landlords. We have a housing emergency. All of these factors are coming together to create a bit of a perfect storm.”

“The key issue for me is that the market’s not ready for the scale of this,” Mackenzie adds. “It’s fertile ground for scammers and there’s a gap in the market for them to move in and completely defraud people as we’ve seen with spray foam, but on an even bigger scale.

“There will also be people who are well meaning but don’t really know what they’re doing. Some of the issues we’ve seen with heat pumps aren’t necessarily caused by scammers, but by people not knowing the bigger picture, not having the necessary range of skills and knowledge to properly advise people as to what they really need.

“But if someone’s lost £1,000, whether they’ve been scammed or whether some incompetent guy’s just made a complete hash of it, they’re still £1,000 down. These are equally bad situations.”

Funding and incentives

Poor quality installations can have an adverse effect on consumers, but so too can some of the financial mechanisms used to fund energy-efficiency work. To support HiBS, the Scottish Government has committed to establishing a Green Heat Finance Taskforce which will “develop a portfolio of innovative financial solutions for building owners” and “explore and potentially pilot new and value-for-money innovative financing mechanisms for individual and community level investment”.

Getting that ‘innovative financing’ right will be essential if HiBS is to avoid perpetuating existing problems. The ECO4 scheme, for example, is a government-funded program that provides grants to help homeowners and private tenants improve their home’s energy-efficiency. But, says Bryson, “There have been quite a lot of problems with that – sometimes traders have taken the money, maybe done half a job or it hasn’t gone right, leaving the consumer struggling to get them to come back and fix things. Then there are problems with trying to find out who’s liable – if it’s the trader, the energy company, or Ofgem.

“The only positive bit in that is that the consumer isn’t actually parting with any money, but they can be left with

damage to their property and their bills can increase if it’s not done properly,” Bryson adds. “The other side of it is the Home Energy Scotland loans and grants, which the consumer has to apply for themselves. We have had problems with companies saying that they could get the grants and loans on behalf of consumers, which they can’t do.

“Then you have general traders that would doorstep or cold-call, saying that they have grants or they’re working with the Government and can act as a credit broker and sign you up to some sort of finance agreement. There are lots of ways that it’s possible to be financially exploited.”

Knowledge is power

Arming consumers with the information they need to make good decisions is perhaps the most effective way the Scottish Government can ensure the success of HiBS. “There’s a need for a massive and sustained public information campaign, which is really difficult to do,” Mackenzie believes. “But they have to have a go at it.”

But what is the most effective way of getting the message out to the right people at the right time? Richardson has a pragmatic and practical suggestion. “In my view, it should actually be part of the

There are lots of ways that it’s possible to be financially exploited

“In terms of funding, it is absolutely down to the Scottish Government. It’s their role to make sure that people are aware of their policies and the implications of them. I also think for this to work effectively, there needs to be some enhanced enforcement around it. And that requires extra money for Trading Standards at a local level to be able to provide business advice, as well as to deal with issues when they come up.”

“Clearly there’s going to be increased work for Trading Standards in this, so the funding has to be thought about,” Mackenzie says. “There has to be money for us but it’s not really serious money in the context of this enormous multibillion pound thing.”

whole conveyancing process when you’re buying and selling a house,” she says. “There should be something linked to the sales process, saying these are the things that you should be considering about this purchase in some way or another.

“If you’re an individual who’s looking at making improvements to your house, then those are the points where that information matters to you. And it should be easy to access across the system. I have long said that there should be one single portal that a consumer who is wishing to make energy-efficiency measures to their home should be able to access, and it should lead them through that process, in a simple way.

HiBS goals in numbers

A 68% reduction in emissions from buildings by 2030, compared to 2020

At least 22% of heat in buildings to come from renewable sources by 2030

At least 1 million homes currently using mains gas and most off-gas homes to convert to zero emissions heating by 2030

Expressing legitimate practical concerns about the implementation of HiBS – or any other initiative to protect the environment – should not be mistaken for naysaying or a rejection of the reality of man-made climate change. But Trading Standards, along with other regulators and enforcers, has a responsibility to ensure that efforts to address climate change don’t end up doing more harm than good.

“We are daily faced with the evidence of climate change and we have a responsibility to take action to ensure the security of the citizens of this country,” Richardson says. “We are going to face more extreme weather incidents on a more frequent basis, and transport and home heating emissions are among the biggest causes of carbon emissions.

“Efforts to tackle climate change have to happen across the world, but we in this country have benefited from the things that have driven climate change to a vast extent. There is a responsibility on us to take steps which are relatively simple. These are not enormous changes to people’s lifestyle. They are about making changes to how you heat your home and how you travel around the country, and they can have a huge effect.”

“We’re not saying this cannot be done,” Mackenzie concludes. “What we’re saying is this cannot be done on the cheap.” l

Taking the lead

Several new CTSI Lead Officers are taking on Trading Standards’ ever-expanding range of responsibilities. Over the next few pages they discuss what inspires them about their jobs, their key priorities in their new roles, and how to get in touch

Diane Bryson

Joint Lead Officer for Energy and Net Zero

Joined the profession: 2014

Based at: Trading Standards Scotland

“The most enjoyable thing about working in Trading Standards is the variety of work you are able to get involved in, being able to collaborate with so many different organisations and stakeholders, and knowing the work you are doing is helping to prevent consumer harm and support legitimate businesses.”

Key priorities and concerns

The Scottish Government has set a target for reaching Net Zero by 2045, but as a result of various gaps in consumer protection relating to the sector, misleading marketing and the sale of energy-efficiency products has become a key priority area for Trading Standards (see page 28)

The industry continues to be targeted by

Dean Cooke

Joint Lead Officer for Food Standards

Joined the profession: 2002

Based at: Slough Borough Council

“The main thing I enjoy about the job is its unpredictability; no two days are ever the same and you never know what’s coming down the line next. The variety of work in Trading Standards makes it fascinating. We are constantly having to learn new things and push ourselves out of our comfort zones.”

Key priorities and concerns

Allergen control is always an essential issue and is a matter of life and death for some people, so it is imperative that everyone involved gets it right.

rogue traders who have identified consumers’ lack of understanding of both energy-efficiency products and the Government grants and schemes available, and are exploiting these vulnerabilities. Consumers have struggled for years to try to navigate the energy-efficiency sector, and despite several attempts to create a consumer-friendly framework there continue to be numerous problems and a high level of confusion.

The most problematic areas within the energy sector I have been working on are the mis-selling of spray foam insulation through misleading and aggressive sales tactics; consumer confusion around the countless schemes, authorisation bodies and organisations operating across the energy-efficiency and renewables sector; and the key enablers for mis-selling of energy-efficiency products by rogue traders such as unsolicited telephone calls, doorstep calling, and more recently online advertising.

Contact: loenergy@tsi.org.uk

The last ten years have seen a huge increase in imported foods; however, ingredients, additives and food information that are allowed in some countries may not be allowed in GB/UK. I will be focusing on enabling better communication between Officers on the ground and our enforcement partners like the Food Standards Agency, DEFRA and the Department of Health and Social Care.

From a professional point of view, we are in a very difficult situation with the plight of Public Analysts. Local authority sampling budgets are being cut and the cost of sampling is increasing while the number of analysts are declining. This requires the attention of central Government urgently, otherwise we could lose one of our most essential enforcement tools in Food Standards.

Contact: lofood@tsi.org.uk

Geraldine Cosh

Joint Lead Officer for Product Safety

Joined the profession: 2014

Based in: London

“Product safety is a personal and professional priority of mine. I enjoy training and working with various stakeholders to share knowledge on product safety topics. It is an honour to work in this area supporting Trading Standards with the work they do and protecting consumers from unsafe products.”

Key priorities and concerns

Educating businesses on product safety and sharing my knowledge about product safety are

Guy Welfare

Joint Lead Officer for Property and Lettings Joined the profession: 2023

Based at: National Trading Standards Estate and Letting Agency Team

“I love the opportunity to engage with stakeholders to move the industry forward and promote positive change.”

Key priorities and concerns

In the grand scheme of things I am a newcomer

Richard Knight

Lead Officer for Cosmetics and Beauty

Joined the profession: 1987

Based at: Essex Trading Standards

“The main thing I enjoy about my job is guiding and educating colleagues, both locally in my day job, and across the UK in my Lead role. Getting to grips with new products and practices and having the privilege of TS access to the under-the-bonnet workings of commerce also continue to stimulate my interest.”

Key priorities and concerns

In 2024 I have been involved in CTSI’s #CostofBeauty campaign, culminating in a session at the Conference in Leeds. I am now engaged

my main priorities. I have worked with CTSI to develop the Business Certificate of Competency in Product safety (BCCPS), which is currently on its second cohort, and I am also supporting the Professional Competency in Product Safety competency for market surveillance authorities. I also work on various webinars for both Trading Standards and businesses.

I feel that working together collaboratively, we can learn so much from each other. CTSI has worked with businesses and in training for a long time, and it is vital for this to develop and continue. Working together and supporting the product safety work done by businesses ultimately protects consumers.

Contact: loproductsafety@tsi.org.uk

to Trading Standards, having only joined in June 2023. I moved across from a career in lettings to my current position within the policy team of the National Trading Standards Estate and Letting Agency Team (NTSELAT). I brought with me an in-depth knowledge of how property agents run on a day-to-day basis, as well as a good understanding of how agents can sometimes look to be ‘creative’ to avoid new and current legislation.

Since joining the team I have played a major role in NTSELAT’s Material Information project.

Contact: loproperty@tsi.org.uk

with policy and campaigns colleagues in the second phase of that initiative, looking at a new set of products, including nasal inhaler self-tanning products, home lash lift kits, and nail and eyelash glues (see page 8).

Key issues include borderline products that can’t be controlled by the Cosmetics Regulation, such as Melanotan 2 inhalers and injectable aesthetic products like fat dissolvers that have the potential for significant harm, but which fall down a regulatory black hole beyond the powers of TS and MHRA. Other challenges relate to online marketplaces and the ease with which bad actors or naïve entrepreneurs can sell non-compliant and unsafe cosmetics online, including UV nail gels that should be restricted to professional use.

Contact: locosmeticsbeauty@tsi.org.uk

Robin Wood

Joint Lead Officer for the Motor Trade

Joined the profession: 2002

Based at: Bristol Trading Standards

“Aspects of my work I really enjoy are the engagement with people – both businesses and consumers, and making a difference, however small, to improve relations between businesses and consumers.”

Key priorities and concerns

There are various aspects of the Motor Trade portfolio which need attention. First, we need to look at how we differentiate our enforcement activities between larger businesses selling vehicles and

Judith Gough

Joint Lead Officer for Legal Metrology

Joined the profession: 2013

Based at: Northern Ireland Trading Standards Service

“Within Northern Ireland Trading Standards I am responsible for building our Metrology and market surveillance functions. This includes expanding our team by helping guide trainees through the qualification to become Inspectors of Weights and Measures. It is a challenging role but one that can be very rewarding.”

Key priorities and concerns

My main focus at the moment is the Legal

Richard Matthews

Joint Lead Officer for Fair Trading

Joined the profession: 1998

Based at: Heart of the South West Trading Standards

“I’ve always had an interest in fairness and a desire to help create a fairer world. Trading Standards provides lots of opportunities to do that, as well as opportunities to have an interesting, challenging and diverse career.”

Key priorities and concerns

The Digital Markets, Competition and Consumers Act (DMCCA), which comes into force from April, is going to require lots of training for Trading Standards professionals. However, the resources

smaller, independent traders. Part of that will mean looking at how the Consumer Rights Act can be better aligned with sales of second-hand vehicles. Current topics in this sector include the increasing popularity of electric vehicles and the push towards cleaner energy. There are issues around how electric vehicles are marketed and sold, as well as access to vehicle charging and the costs involved. As vehicles become more technologically sophisticated, manufacturers now have the ability to make changes to them remotely, sometimes without the owners’ knowledge. Subscriptions are increasingly common. This needs to be kept track of to ensure consumers aren’t being harmed or ripped off.

Contact: lomotortrade@tsi.org.uk

Metrology policy paper. The work on this had started before I joined as LO but we have been reviewing the contents ahead of publication.We have also been participating in the Weights and Measures Qualification Working Group.

In terms of focus areas, the cost-of-living crisis remains a key issue. Within Metrology so much of our work is vital to ensuring consumers are getting exactly what they pay for, whether it is food products and regulation within the packing industry, or fuel and our enforcement work in relation to oil, petrol and solid fuels such as coal. Fuel poverty also remains a concern, especially in NI, with 68% of homes relying on oil-fired central heating. Contact: lometrology@tsi.org.uk

aren’t there because the money for training has not been allocated – that’s an inescapable fact. One of the things that TSOs do really well though is just getting on with it, and doing the best they can. Whether or not the environment is perfect, we will make the best of it. As with any new piece of legislation where enforcement powers have changed, it will be interesting to see how it plays out.

One of the key challenges facing the profession is resilience. We are an ageing profession. That’s something I care about a lot – we need to make sure that we don’t lose that wealth of experience, and that we’re able to get new people into the profession and get them trained before we end up with a very significant knowledge and skills gap. Contact: lofairtrading@tsi.org.uk

One of the good guys

Andy Allen was a passionate advocate for consumers whose dedication left its mark on CTSI and the wider profession

Andy Allen, who passed away unexpectedly on 9 June 2024, was a much loved and highly respected part of the family at CTSI, where he led the UK International Consumer Centre (UK ICC). Hard-working and committed to helping people, Andy joined the Institute in 2012 and fought hard for the UK ICC over the past decade, ensuring its survival during the turmoil of Brexit uncertainty and budget cuts.

A proud Cornishman, Andy was born in 1968. During his early life he worked as a fisherman in Newlyn, and his love of the sea was apparent from the swallow tattoos on his hands – traditional good luck symbols promising safe passage home.

His tenacity and perseverance spurred him on to become a mature student and gain a law degree, which he put to good use by helping to support and advise consumers. He began his consumer protection career at Cornwall County Council Trading Standards, before taking up the reins at the Consumer Direct contact centre for the South West region. Upon joining CTSI, he took charge of all of the Institute’s commercial services, as well as leading the UK ICC (and the UK European Consumer Centre, as it was previously known), through a time of upheaval.

Andy’s compassion, commitment and good humour ensured he was highly popular with colleagues, and his warmth and kindness inspired many. CTSI Chief

Executive, John Herriman, said: “Deeply passionate about consumer protection and the Trading Standards profession, Andy’s knowledge, boundless enthusiasm and, above all, his mischievous sense of humour will be greatly missed by everyone who experienced it firsthand. Andy was not only a consummate professional, but also a friendly face and huge source of support to many of his colleagues, who are all devastated by his passing.

“Andy was, indeed, so much more than just a colleague to those at CTSI and to many people throughout the consumer protection landscape: he was a friend and a mentor to many. His warmth, compassion and relentless dedication will be deeply missed.”

Kerry Nicol, External Affairs Manager at CTSI, worked with Andy throughout his time at the Institute. She said: “Andy was an incredible colleague and friend to all who had the pleasure of working alongside him. He was a passionate and diligent man who always had buckets full of ideas and would give up his time to contribute with his expertise and knowledge. One of Andy’s

Andy was not only a consummate professional, but also a friendly face and huge source of support to many of his colleagues

many strengths was building meaningful relationships, and that has been proven by many colleagues from all over Europe who have left heartfelt tributes.”

In one of those tributes, the European Consumer Centre (ECC) Network described Andy as “a kind, considerate, sweet and exceptionally dedicated advocate for consumers”.

Juanita Headley worked closely with Andy as a Consumer Advisor at the UK ICC. She said: “Andy was undeniably the most amazing boss that I ever had the privilege of working with. I loved him like a friend and respected him greatly because he was fair, flexible, and maintained professional boundaries.

“The team at UK ICC and our partners at the ECC continue to mourn the loss of a dynamic, funny, hard-working, charismatic man who was wholeheartedly committed to the work of consumer advice. He left a lasting impression on us all and I believe that his memory will live on.”

Another UK ICC colleague, Harry Williams, said: “Andy was not just a remarkable leader but also a mentor who had a large impact on my life and career. I will forever be grateful for what he’s done for me and for giving me space to grow.”

Andy leaves behind his beloved partner of ten years, Louise, who worked alongside him at CTSI.

A keen animal lover, Andy will also be missed by his cats Pinot and Bob, and his dog Buddy. He also kept chickens and was well known for trying to save even the smallest insect in distress. In recent years he took up gardening, and developed a passion for growing fruit and vegetables.

A funeral service took place in Cornwall in June, attended by many of his former colleagues, who contributed to a GoFundMe campaign to raise funds for his safe passage home to his final resting place in Penzance. l

Andy Allen: 1968-2024

Can-do attitude

Kristina Hann, a Trading Standards Officer at Essex County Council, has always had a positive and tenacious approach to life despite being born with a disability. Now, with her assistance dog Louis at her side, nothing can hold her back

“It’s been a weird year. I’ve chopped my arm off. I’ve gone back to work. I’ve carried on doing my swimming and obtained my CTSI animal health and welfare qualification.” When speaking with Kristina Hann, it soon becomes clear that she takes whatever life has to throw at her in her stride.

“That last one was a really big deal for me, as I once had a senior manager refuse to let me take it because they didn’t think I could physically do the work,” she adds.

Born with a left arm that was paralysed as a result of damage to the brachial plexus nerves, Kristina is no stranger to confronting prejudices. “The worst thing about growing up with an arm that doesn’t work but is clearly visible is people don’t believe you,” she says. “At school, I got detention in PE for not being able to tie my shoelaces because the teacher said I was faking it. Why would I lie about that? It’s one of those things that you never forget.”

Kristina soon learned that her disability would influence her life in many ways – and often because of others’ thoughtlessness. “I failed my graphics GCSE exam because the pencil kept falling out of the compass, and no one would help me put it back in,” she remembers. “When I was 15, I wanted to join the Navy the following year, and no one told me that I wasn’t going to be allowed to until I went to a careers fair and was turned away.”

Kristina studied law at university, and when she graduated in 2009, a job at Hertfordshire Trading Standards caught her eye. At first though, she thought her medical history would stand in her way.

As well as having a paralysed arm, she also has epilepsy and had recently had a seizure that prevented her from driving. “The job advertisement said a full driving licence was required but I was told to apply anyway and they’d review it,” she says.

“Also, because I’d be going out and about, they needed to do a review of whether or not I’d be physically able to do the job,” she says. “I’d been through this before, so I was expecting to get turned down on medical grounds – but one of the senior managers wanted to give me the chance to prove myself. I got the job, and I then got my driving licence in 2010. There were some interesting questions that were asked of me though, like ‘how do you type one-handed?’ Me being me, I said, ‘one-handed’.”

Kristina began her Trading Standards career as a Trainee Officer at Hertfordshire Council, later earning the Diploma in Consumer Affairs and Trading Standards (DCATS). “I had maternity leave in the middle of that, but I managed to qualify at the same time as everybody else I started with,” she says. “I think taking nine months out of the process made me work a little bit harder afterwards to make sure I caught up with everybody.”

Kristina stayed at Hertfordshire for 13 years, learning the ropes, earning the respect of colleagues and working her way up to Senior Trading Standards Officer level. During that time, her health complications continued. “I had operation after operation to try and fix my arm,” she says. “They were talking about taking stuff out of my legs to put into my arm, but I said, ‘absolutely not, that sounds terrifying!’

Having a disability does mean that I see things differently sometimes; we can sometimes forget that there are other people out there who have a very different kind of life

“I let them do one last surgery on me in 2019, but it did not work and made things ten times worse. So I said, ‘I want rid of my arm’.

“They amputated it a year ago. It was a choice, an elective amputation. I was only off work for two weeks – and I was off swimming for three weeks, winning my first regional gold medal in over 20 years a few months later in the 200m individual medley event. The amputation was the best decision I ever made. I don’t know how to be two-handed. I’ve just got on with it.”

Finding the rhythm

When she first started at Hertfordshire Trading Standards, Kristina was keen to put her legal training to good use. As well as criminal and contract law, she says, “I had also studied holiday law, which ended up working quite well because I already knew about the Package Travel Regulations and things like misdescriptions in brochures. It’s a bit of a niche area but, in the event of things like the Thomas Cook or Monarch Airlines collapses, or the Covid travel disruption, it’s actually quite useful.”

Speaking of travel disruption, things weren’t always plain sailing at the beginning of Kristina’s career either.

“For the first year of working in Trading Standards, I have to admit, I felt completely out of my depth,” she says. “But a couple of colleagues just said to me, ‘It’s normal, trust me. After a year, you’ll be fine. It will all click.’ And they were right. Now I can’t imagine doing anything else.”

Nonetheless, in those early days, Kristina was constrained by other people’s ideas about what she was capable of.

“One of the senior officers made it very clear that they did not want me involved in dealing with rogue traders,” she says. “They didn’t think it would be a good fit, and they didn’t even really give me the chance. I just accepted it because I thought they knew better.”

Left Kristina Hann and her support dog

Louis (pictured before Kristina’s amputation)

That all changed though when Tim Day – who is now one of CTSI’s joint Lead Officers for Doorstep Crime – joined the Hertfordshire team. “When Tim started, he had a completely different opinion,” Kristina says. “He took me under his wing along with a couple of others, and upskilled us. He didn’t believe in the whole ‘let’s keep certain jobs for ourselves’ attitude which unfortunately, some people do have.

“My last investigation at Hertfordshire was a rogue trading one in which the defendants were both found guilty, and one of them did get jail time. If you’d told me when I first started that I’d be the lead on that, I’d have laughed at the idea of me going out to rogue trading incidents and dealing with some quite confrontational people face-to-face.”

While almost everyone in Trading Standards will have dealt with a fair amount of confrontation in their interactions with rogue traders or uncooperative businesses, unfortunately Kristina has also come up against some adversarial and unpleasant behaviour in the workplace.

“Trading Standards has definitely been a mixed bag and although the vast majority of people have been lovely, it’s the few that haven’t that stick in your mind,” she admits. “I’ve had an Officer make fun of my arm, and mimic how it used to look because it was quite deformed. I had the same person tell me I’d never make it as a Trading Standards Officer – which is hilarious because I’ve reached the same level as them, so I guess I did make it.

“Some people are just bullies,” she adds matter-of-factly. “It doesn’t stop when you leave school – some adults are bullies. We all know this – we see enough people getting accused of it in Parliament or on Strictly Come Dancing.

“I wasn’t the only one that got picked on by this person, and they’re no longer there, thankfully. But it was awful.”

As if dealing with rogue traders and a bullying colleague didn’t make life difficult enough, during the Covid lockdown of 2020, Kristina’s mother died suddenly and unexpectedly, and family commitments meant she needed to

move home to Colchester. “I’m the legal guardian of my severely disabled brother, and my dad suddenly got Alzheimer’s in a very aggressive form, so I’m his legal guardian as well,” she says.

When a job at Essex Trading Standards came up, Kristina made the leap, and started there in March 2022.

Dynamic duo

Following a period of momentous and stressful changes – a bereavement, new care responsibilities, a new job and a series of major health procedures – a fresh glimmer of light arrived in Kristina’s life in March 2023 in the shape of Louis.

Louis is a three-year-old black Labrador, specially trained by the charity Dogs For Good to work with an adult with a physical disability. “Part of my condition means I drop things on the floor all the time,” Kristina explains. “He’ll pick up my keys when I drop them, my purse, the remote control. He takes off my slippers, my socks, my shoes.

“Around the house, we put ropes on doors that he can use to open them. He is able to push the metal buttons that open doors in public places. If I’ve got something in my hand, I’ll just say to him the code word to open the door and he’ll stick his face in it. He’s not the most graceful with that – he will literally headbutt the thing – but he is getting a little bit more graceful as he’s getting older. He’s just absolutely brilliant at doing what he does,” she adds with a touch of unmistakable pride. Although, she points out, “He doesn’t work for free – every time he does something he’s supposed to do, he gets treats.”

While I’m speaking to Kristina over Teams, she turns her laptop around and Louis’s nose, muzzle and huge brown eyes fill the screen. It’s not unusual for people’s pets to make guest appearances on video calls, but it’s not so often that those animals double up as colleagues – and Louis has become a popular member of the Essex Trading Standards team. “I think Louis is a more valued member of staff than I am sometimes,” Kristina smiles. As well as being made an honorary CTSI

branch member, he accompanies Kristina to training boot camps. “He sat there for all the sessions but I don’t know what he’s taken away from it. He slept mostly.”

Another important person in Kristina’s life and career is her partner, Mark Winter, who made the move from Hertfordshire along with her and is now a Trading Standards Officer at Essex. His other job title, she says with a grin, is “Assistance Dog’s Assistant”.

A different perspective

Trading Standards is a varied career which requires its practitioners to interact with people with a diverse range of experiences. So, I ask Kristina, does she think her disability has made her more likely to appreciate the challenges that others might face? “I think it depends on the complaint in question,” she says. “We’ve had a lot of complaints that can be disabilityrelated, like with the motability aid sector. I’ve been able to do work on that with a different understanding perhaps to other Officers, because I know how important motability aids are to day-to-day life. If you buy something like that from a trader and it doesn’t work, it’s not a case of, ‘Oh, that’s annoying’. It can affect whether or not you’re able to do your day-to-day living.

“Going back to holiday law, there are also things like holidaying as a disabled person; whether you can use your blue badge abroad for example, and what you’re entitled to as a disabled passenger, or hotels being misleading on their accessibility.

“Having a disability does mean that I see things differently sometimes; I might overhear conversations that people have and think, wait a minute, you’re not thinking about any kind of equality or diversity issues; we can sometimes forget that there are other people out there who have a very different kind of life.

“It also means that when we intervene in vulnerability situations, I know what it is like to be deemed vulnerable and treated differently because of it. I don’t think I’m vulnerable in the slightest, but I also know that I can be sometimes – but then I also know that every single person can be. We all have the ability to become vulnerable at some point in life, and that’s how people get scammed or become victims of rogue traders.”

After fifteen years in Trading Standards, it’s fair to say that Kristina has seen the best and the worst that the profession has to offer. She has had some remarkable and supportive colleagues, she says. Alongside her partner and colleague Mark Winter,

Left Trading Standards can be a rewarding career for people with disabilities, and the profession can benefit too

I’ve met a lot of disabled people who are not upfront about their disability in job interviews, because they’re scared they’re not going to get hired. That’s not been my experience in Trading Standards

she singles out for particular praise Tim Day and previous line manager Chris Davies at Hertfordshire, her current line manager Alan Richards, Trading Standards Manager Matthew Sanctuary and the Head of Wellbeing and Public Health, Clinical, Lifestyles and Trading Standards at Essex Council, Chris French. On her current team, “Essex Trading Standards has been fantastic,” Kristina says. “My management, my team – every single time, they’ve been so accommodating to Louis.”

But her experiences of bullying and discrimination are something she looks back on with a sense of frustration. “I should have dealt with it differently,” she says. “I initially ignored it, but then they started picking on somebody else.

“That’s what set me off; I can cope with it myself, but I’m not having it happen to somebody else. When I first spoke to a manager about it, I made the mistake of accepting the defence, ‘Oh well, that’s just what they’re like. They don’t really mean it.’

But there’s office banter and then there’s bullying. I was not finding that funny at all.

“Eventually, I went to CTSI and things got dealt with. My advice is don’t ignore it, because ignoring it does nothing. Go to your line manager, and if you’re not happy with their response, you can report

these things to CTSI confidentially through their EDI rep.”

Sense of the possible

For people with disabilities, Kristina believes, Trading Standards can be a rewarding career, as long as everybody is upfront about the practicalities involved. “It’s a job that, if given the right adjustments, anybody can do,” she says. “I mean, I’ve got an entire limb missing.”

While there may be accessibility issues with site visits for wheelchair users, Kristina says, “We have to do research on where we’re going anyway, so it would just be an extra part of a risk assessment. And there is plenty of work that is available that wouldn’t necessarily mean they’d have to go out to these places anyway.

“I’ve met a lot of disabled people who are not upfront about their disability in job interviews, because they’re scared they’re not going to get hired. That’s not been my experience in Trading Standards at Hertfordshire or Essex whatsoever. I’ve been upfront. In those interviews I’ve had, I could’ve hidden my disability easily both times. I’ve never done that.

“You have to be open about what your restrictions are though. The Equality Act does state that reasonable adjustments can be made, as long as they are in keeping with health and safety, which for the most part they are. It’s about having open dialogues with the people who are going to be your managers, and knowing what the job entails.”

When she first went for her job interview at Essex Trading Standards, Kristina laughs, “I can’t imagine what they thought when I said, ‘By the way, I’m having my arm chopped off at some point in the very near future’.”

Conversations like that certainly make life more interesting, and it is clear that Kristina brings a keen sense of humour to the workplace. As the interview is wrapping up, she suddenly says, “I’ve got funny stories as well. There was the time I got my arm stuck in a vending machine, and one of my managers had to open the freaking door to get me out. My friends never let me live that down….” l

A job well done

Since he began his career 60 years ago, Peter Tompkins has seen widespread change in Trading Standards. Now, as he prepares to take a well-earned rest from his duties, he reflects on the past, present and future of the profession

As someone who has worked at all levels of the Trading Standards profession, from rookie recruit up to head of service, Peter Tompkins has seen it all. He started his career in 1964 when Trading Standards was still known as ‘Weights and Measures’, decimalisation had yet to be introduced, and the demographics – and duties – of the profession were very different. He has worked at local authorities including Worcestershire, Dudley and Leicestershire councils among others, and for the past few years has been based part-time at Sandwell Trading Standards, where he advises businesses in the West Midlands borough about their consumer protection responsibilities.

When I speak with Peter in the autumn of 2024, he is preparing to finally step down after six decades spent doing what he loves. So how did he get into Trading Standards in the first place? “This is going to shock you: I decided I’d had enough of college,” he laughs. “I said to my mum, I think I’m going to go and find a job. She opened our local paper, looked at the jobs page and said, ‘There’s one here: it’s outdoors, with good prospects, dealing with weights and measures’. I had never heard of weights and measures, but being outdoors with good prospects appealed.

We didn’t have a phone in those days so Mr Owen, who was to become my boss, came and knocked on our door one Saturday morning and said ‘the job’s yours if you want it’. I started, and I’ve loved it ever since.”

Signs of progress

Back in 1964, before the arrival of laptops, emails and intelligence databases, the day-to-day life of a Weights and Measures Inspector was very different from today. But some things never change, and the broad array of experiences which the job presented back then is still often cited by Trading Standards Officers as the thing they most enjoy (see page 30). That is certainly the case for Peter. “I’ve always loved the variety,” he says. “You get to go into all sorts of different places.”

One of Peter’s early memories is of visiting the Walter Somers forge in Halesowen, which later became embroiled in the ‘Supergun’ affair involving components for a weapon destined for Saddam Hussein’s regime in Iraq. “There was a big hoo-ha about whether or not they’d got the proper export license,” he remembers. “We used to go in there and watch the crankshafts for huge petrol tankers and ocean liners being made.

“The next minute, you’d be on a farm conducting an ‘Appeal to Cow’ inspection; if a milk sample on its way to the dairy was found to be suspect, we would go to the farm and take a sample direct from the cow. This was then used as a comparison with the original sample to show that the milk had been tampered with.

“Or you might find yourself in a pharmacy buying medicines to see whether they were within date.”

Responsibilities for checking medicines’ use-by dates are no longer part of Trading Standards’ remit, having long since switched over to the MHRA. That’s just one of many changes to have occurred during the past 60 years – but which, I wonder, has been the most notable? “The main thing is that we’ve got about an equal number of women as men in the profession,” says Peter.

“When I started in 1964 in Worcestershire, there was not a single woman in the department. We had three offices, and not one of them had a woman. The first female typist started in around 1965 and then as things progressed, we got more and more women trainees. That mainly happened as we went into the seventies, from about ’74 onwards. Now I think probably there are more women

trainees coming into the profession, and certainly more women at senior levels.”

According to CTSI data, the Trading Standards profession is now about 56% female – a remarkable shift, and one which Peter believes should be celebrated.

Another change for the better, Peter believes, can be seen in some of the legislation Trading Standards is responsible for enforcing, as well as in a more conciliatory approach to certain types of non-compliance. “At one time, we were much more orientated towards prosecutions, and ‘going after the bad guys’,” he says. “I’ve taken lots of prosecutions – and I’m never happy with them. I always end up thinking ‘there but for the grace of God go I’. There are very few cases where I’m absolutely sure that the trader has done it all deliberately.

“In fact some of them, looking back now, would appear to most people to be ridiculous because of changes in the law. The very first prosecution that I took was under the Shops Act [later the Sunday Trading Act], for selling goods on a Sunday. These days, people would look aghast at you for prosecuting somebody for selling on a Sunday.

“I’m not a prosecutions man, really, which is unlike a lot of my generation,”

Far

left The Walter Somers forge in Halesowen

Top

Sunday trading laws used to be a hot topic

Left Peter Tompkins

I’m surprised and quite proud of how well the profession has managed to continue to hold its head up after the sort of cuts that we’ve had over the past 14 years

continue to hold its head up after the sort of cuts that we’ve had over the past 14 years. But we’re gradually getting back on our feet.”

What, I ask, justifies that optimism? “I think everything is cyclical,” Peter explains. “During the 1970s, the Office of Fair Trading was established. The Trade Descriptions Act came in, and the Fair Trade Act, and the Consumer Protection Act. There was a big boom in trying to promote fair trading and protect consumers at that point.

“And then that was knocked back, and then came back again. It just goes up and down. I think we’re starting to get back to the realisation that you can’t just do away with all regulation and not have any consequences,” he adds.

he adds. “I like talking to people. Most of my job now is to advise people, mainly on food matters, talking about allergens and how to make sure that businesses don’t cause any damage to their customers by not asking the right questions. I like explaining to businesses how best they can safeguard their own backs and those of their customers.”

History repeating

Of course, not everything in Trading Standards has changed for the better since 1964. ‘Austerity measures’ have strained the profession to breaking point, with services slashed and Officers around the country having to do more with less.

Peter was appointed Trading Standards Manager at Dudley Council in 1986, and at the time had a workforce of 27 working alongside him – a number which declined over the following decade. “At Dudley, we were making cuts during the John Major years until 1997, but they were done gradually,” he says. “But under David Cameron, it was just a complete slashand-burn regime. They just cut without thinking of any consequences or how we were going to continue to provide a service. I’m surprised and quite proud of how well the profession has managed to

The tragedy of Grenfell Tower and the findings of the subsequent inquiry illustrate the true cost of deregulation and reduced protections, Peter believes: “I think that woke people up to the fact that you’ve got to have a certain degree of regulation. And if you don’t, then you’re going to have trouble.”

Meaningful, substantive improvements will only come about through increased funding though, he says.

“We need sufficient funding to be able to provide a proper service to the public, and I include traders in that. If honest traders are being undercut by people who are not trading fairly, that’s going to have an effect on them, and there’ll be a race towards the bottom.”

Finally, does Peter have any words of wisdom to impart to new Trading Standards recruits? “At the beginning of my career I was enthusiastic and I still am – and I think most of the people that start today are exactly the same,” he says.

“Get your necessary qualifications and take it from there. I always had good people with me that I could rely on, both when I was junior and when I got more senior. All the way through, I’ve been very lucky with the people I’ve worked with,” he says.

“Just go for it. That’s all I could say to them really. Go for it. Enjoy it!” l

The acid test

A new Home Office campaign is making businesses that sell dangerous chemicals aware of their legal responsibilities. Following the success of a London Trading Standards-based pilot, the scheme is now being rolled out nationwide

Certain chemicals can be used in the illicit manufacture of explosives or to cause harm. To reduce the risks presented by these substances the Poisons Act 1972 sets out the obligations of suppliers in relation to regulated and reportable substances. This includes the requirement not to supply a regulated substance, above the concentration threshold, to a member of the public unless they hold a valid licence. In addition, the Offensive Weapons Act 2019 prohibits the sale and delivery of corrosive products to under-18s and the delivery of corrosive products to residential premises and lockers. Some chemicals such as hydrochloric acid, sulfuric acid and sodium hypochlorite, as well as several others, appear in both the Poisons Act 1972 and the Offensive Weapons Act 2019.

It has been identified that certain restricted chemical products such as high-strength drain cleaners are still regularly being sold by independent retailers without the necessary safeguards in place. These products can be dangerous when not used by professionals due to their highly corrosive properties and have been known to cause damage to household pipes and injury to people from accidental incidents and intentional attacks. They also pose a risk to national security as regulated explosives.

There is therefore a need to proactively notify retailers and suppliers of their legal obligations about the sale of these products, and inform them how to report suspicious activity whether that be transactions, attempted transactions, loss or theft.

Whilst Trading Standards services no longer have any statutory duties under the Poisons Act 1972, they are best placed to help by taking a holistic approach to public safety when undertaking other statutory duties including market surveillance and retailer inspections. The Home Office and London Trading Standards (LTS) agreed a joint campaign to fulfil this need and have run a pilot in London. Other regions are now being approached, and a simplified campaign drawing on lessons learned from the London pilot is being launched. The campaign consists of four steps:

• When Trading Standards Officers attend retail or wholesale premises, to look to see if they sell chemical products.

• Check whether the products contain regulated or reportable chemicals under the Poisons Act 1972 or restricted chemicals under the Offensive Weapons Act. This can be done without any expert knowledge by using the LTS Explosive Precursors & Poisons (EPP) database, access to which can be set up by emailing the link in the boxout opposite.

• If any such chemicals are found, Officers can use the information on the EPP database to provide the retailer with the necessary basic information and they should also provide them with the Home Office-supplied campaign guidance leaflet. Further resources are available from ProtectUK (see boxout).

• If there are any concerns about the retailer, refer them to the Home Office for guidance using the ‘Refer a Seller’ tool on the official guidance pages (see boxout).

The Home Office campaign guidance leaflet provides simple key information about some of the recently regulated chemicals which can still be found in certain products on retailers’ shelves.

The leaflet has a QR code for retailers that takes them straight to guidance about the Poisons Act, and the Home Office chemical reporting team contact details are listed clearly too. The leaflet gives just enough information for a retailer to know whether they need to reach out for additional support, and where to find that support.

Restricted chemical products are still regularly being sold by independent retailers without the necessary safeguards in place

The Chemical Reporting Team within the Home Office is here to support this campaign and Trading Standards services. As a team they can provide:

• Guidance on how to comply with the law relating to explosive precursors and poisons.

• A short training package on the Poisons Act 1972 and the Offensive Weapons Act 2019. They are happy to discuss the most efficient and productive way of helping your officials if this would be beneficial to them.

• Assistance in developing training materials for your staff.

• Support materials in the form of posters and leaflets and links to a short video.

OWA new burdens funding

Acid or corrosive attacks present a real threat to the public. This type of offence causes serious harm and can leave survivors with lifelong physical and psychological injuries. There are also significant negative impacts on families and communities. The purpose of the provisions under the Offensive Weapons

Act 2019 are to restrict access to acids and other corrosive products.

The Offensive Weapons Act 2019 placed new burdens on Trading Standards, and the Government is providing funding to meet these costs. Funding for 2024/2025 for England and Wales is £1.8m. It is important to embed this work into routine Trading Standards business during compliance visits to raise awareness of the legislation. Officers should take a holistic approach to these

Useful resources

Access to the LTS Explosive Precursors & Poisons (EPP) database can be arranged by contacting: epps@londontradingstandards.org.uk

The Home Office Chemical Reporting Team can be contacted at: ChemicalReportingTeam@ Homeoffice.gov.uk

Education resources, included leaflets and posters, are available at: www.protectuk.police.uk/ selling-chemicals-responsibly-leafletand-posters

Retailers that you may have concerns about can be referred to the Home Office for guidance at: https://submit.forms.service.gov.uk/ form/3069/report-a-concern-about-apoisons-act-substance/10546

issues and make the most effective use of their time when checking for other agerestricted products such as knives to also check on corrosive products.

The EPP database provides a simple, easy-to-use resource which is a valuable source of information on products for a very small sign-up cost. Each local authority has received significant new burdens funding and so funds should be available.

Where businesses are found to have poor or no understanding of their statutory responsibilities and the legislative controls on the supply of these products, then Officers should provide advice and refer sellers to guidance and the steps they need to take to comply.

Trading Standards has a vital opportunity to assist the Home Office with this campaign to keep the public safe, and prevent further serious criminality including acid attacks that can devastate individuals and undermine communities. l

About the authors

Jo Cooper is part of the Chemical Reporting Team at the Home Office; Stuart Radnedge is Regional Coordinator at London Trading Standards; Iain Bailey is an Environmental Protection Officer at Kingston & Sutton Regulatory Services, and an expert on Explosive Precursors and Poisons for London Trading Standards.

JUSTIN MADDERS

The Minister whose portfolio includes Trading Standards talks funding, policy and the key role regulation will play in rebuilding the UK’s economy

Justin Madders became the Parliamentary Under-Secretary of State and Minister for Employment Rights, Competition and Markets in July 2024. His role, which sits within the Department for Business and Trade (DBT), encompasses consumer protection and regulatory issues, and he is the primary point of contact between the Government and Trading Standards.

As Labour introduces a host of new legislation that will affect Trading Standards services (see page 20), Madders spoke to the Journal about Trading Standards’ role in enforcing new regulation while supporting economic growth. Almost half a year into his job, he has had time to get to grips with the key issues – and the monumental challenges – facing enforcers, consumers and businesses. So what is the first thing Madders thinks of when he hears the words ‘Trading Standards’? “Cowboys,” he says. “A few years ago I worked closely with my local Trading Standards, and they ended up taking a rogue garden landscaper to court who had been blatantly ripping off my constituents [in Ellesmere Port and Bromborough]. It was so blatant and widespread I was pleased justice was eventually done.”

The latest ‘Impacts and Outcomes’ report by the Association of Chief Trading Standards Officers (ACTSO) shows that in 2023-24, Trading Standards prevented more than £905m of consumer detriment in England and Wales. That equates to £8.39 saved for every £1 spent. Does Madders agree that this represents good value for money for the taxpayer? “It’s

BY RICHARD YOUNG

really helpful to see ACTSO’s assessment of the positive impact Local Authority Trading Standards Officers are having for consumers,” he says. “The Government greatly values the work that Trading Standards teams do protecting local communities. They have a key role in supporting economic growth by giving businesses a clear and level playing field, so they can invest with confidence.”

I ask whether, despite that key role, Trading Standards’ work is often overlooked or misunderstood? “I agree that this work can sometimes go under the radar with the public, particularly where it is preventative – it is often only when things go wrong that people notice, so sometimes it’s a mark of Trading Standards’ success that their work goes unnoticed,” Madders believes.

“But I know that Trading Standards departments do have a great reputation within their local communities, with both consumers and businesses, and it's important we continue to recognise their good work, such as – and this is just a few of the many examples – tackling misleading claims about sustainability, helping local businesses who repair e-bikes comply with the law, or stopping unsafe cosmetics

It says a lot about the trust Government departments have in Trading Standards that local enforcement is seen as critical to delivering protection for people in this country

getting into the hands of consumers. The Journal and CTSI also do a great job promoting Trading Standards departments’ expertise and impact,” he adds.

Money talks

New pieces of legislation such as the Tobacco and Vapes Bill, the Product Regulation and Metrology Bill and the Renters’ Rights Bill will only be meaningful and effective if the enforcement required to put them into practice is adequately funded. Trading Standards services have been drastically underfunded over the past decade or so, to the point that many are at breaking point and, according to CTSI, certain illegal activities have been ‘effectively decriminalised’ as a result. So how will the Government ensure that those tasked with upholding the law have the resources they need? And what funding commitments can Madders make?

“It says a lot about the trust Government departments have in Trading Standards that local enforcement is seen as critical to delivering protection for people in this country,” he says. “I recognise this can place pressure on services.

“The Product Regulation and Metrology Bill, which my department is bringing forward, will not itself change the enforcement activities that Trading Standards already deliver. In fact, it will allow for more efficient and effective interventions by providing new datasharing opportunities, greater digitisation and improved, streamlined processes.

It will also allow for mechanisms to be put in place to recover the end-to-end cost of market surveillance.

“It's important that Trading Standards teams were engaged in this process and I know the officials in my department leading the Bill spoke with local authorities during the consultation process, and welcomed their insight and feedback. The Office for Product Safety and Standards (OPSS) provides assistance to Trading Standards teams through things like access to free training, technical advice and funding for product testing, and I want to see that continue.” Trading Standards services are responsible for work which intersects with different parts of Government in addition to the DBT. So what opportunities does Madders think exist to approach Trading Standards’ work more holistically, and to look at the connections between things like financial fraud and its impact on health? “You are right to point to the links between different regulatory areas, and it aligns with our ambition to be a missionled Government, breaking down barriers to deliver for people in all parts of the country,” he says.

“There is a lot of work going on in DBT and across other departments looking at the overall contribution regulation makes, both in delivering important protections and in supporting growth and innovation. We have already announced the new Regulatory Innovation Office, and while that will have innovation as its main driver, ensuring different regulatory bodies work together smoothly will also be central to what it does. And, as the national regulator, OPSS helps link up the important work done by Trading Standards in their regions and sectors of expertise at a national level. Primary Authority is a great example of this.”

Innovation nation

The launch of the Regulatory Innovation Office was announced in October by the Department for Science, Innovation and Technology. It has the aim of ‘kickstarting growth’ by speeding up approvals for businesses working on new technologies

such as delivery drones or AI. Its founding serves as a recognition of the fact that the business and consumer landscape has changed dramatically in recent years; but what is the Government doing to ensure that the tools at Trading Standards’ disposal are fit for purpose and can keep pace with emerging ways of shopping, selling and doing business?

“Addressing new challenges from different models of supply is a priority for the Government as we modernise the UK’s product regulation framework,” Madders says. “The Product Regulation and Metrology Bill will give Government tools to tackle products sold and fulfilled via online platforms, and importantly it builds more flexibility into the framework so we can adapt better to future changes –be it in the ways consumers buy products and where they’re sold, or how AI and technological advancements can ensure consumers are getting the amount of product they are paying for.

“The Digital Markets, Competition and Consumers Act 2024 (DMCCA) has made civil enforcement more robust by giving new powers to the courts to impose significant penalties for wrongdoing. It has also strengthened enforcers’ toolbox for tackling online harms, including making new takedown powers available through the courts and clarifying that unfair trading rules apply to businesses that promote or facilitate transactions from third parties. The Act also bans fake reviews and the drip pricing of unavoidable fees. And we’re continuing to tackle concerning online practices as they come up – we’re currently reviewing the law on secondary ticketing, for example.”

CTSI and others have been calling for online marketplaces such as Amazon to take their responsibilities to their customers more seriously by ensuring that the products sold on their platforms by third-party sellers are safe and compliant. Among CTSI’s recommendations are the introduction of clear legal duties on online marketplaces and other online platforms; increased, ring-fenced funding for Local Authority Trading Standards services

to support enforcement activities at ports and borders; and a levy on online marketplaces and other platforms to fund regulation by Local Authority Trading Standards services. What does Madders think can be done to make online marketplaces safer and more responsible?

“Online platforms and other digital channels have opened up markets and choice for consumers in ways we probably couldn’t conceive of 10 or 15 years ago,” he says. “But this benefit shouldn’t be at the expense of consumer safety. Most of the UK’s product safety framework is derived from decades of EU law, and it is clear it requires modernising for today’s digital-first world. That’s why we are bringing forward the Product Regulation and Metrology Bill. It will ensure the UK is better placed to address modern-day safety issues, harness opportunities that deliver economic growth, and ensure a level playing field between the high street and online marketplaces. Our intention is that this will include specific duties

for online marketplaces, alongside their existing responsibilities.

“Where online platforms are facilitating or promoting consumer transactions, the DMCCA has made it clear that they have to adhere to unfair trading rules and must, among other things, act with professional diligence. The Government is working with the platforms to ensure they are clear on their responsibilities to protect consumers and are delivering on those.

“Of course, this is a fast-growing area for Trading Standards services too, as they will play a central role in delivering regulation for products sold online. I expect my officials to continue engaging with local regulators on the delivery of the Product Regulation and Metrology Bill once it is enacted, and support will be available to Trading Standards: as well as existing technical, policy and legislative advice, specific guidance will be produced on the new powers, so that local authorities are equipped to use them efficiently.”

Left The Government is looking at ways of ‘streamlining’ regulation to support the development of innovations such as delivery drones and AI

Energy and the economy

The push towards Net Zero will require consumers to be confident and educated about domestic energy-efficiency measures, an army of traders who are qualified and certified, and robust enforcement measures against the scammers and rogues seeking to exploit people’s good intentions. Does Madders appreciate how central Trading Standards will be to making that happen?

Trading Standards has always been at the forefront when it comes to tackling rogue traders and scammers whatever form they take

“Trading Standards has always been at the forefront when it comes to tackling rogue traders and scammers whatever form they take,” he says. “Local authority-operated trader approval schemes such as Buy with Confidence or Trustmark can really help consumers make informed choices about sustainable products. Delivering Net Zero is a Government-wide commitment, and in my view Trading Standards’ role is paramount here: tackling bad actors undermining our transition to Net Zero or making misleading claims about their products’ environmental credentials, and also protecting consumers who are committed to doing the right thing.”

Consumer confidence also underpins the economy in a wider sense, supporting legitimate businesses and ensuring consumers are treated fairly. What role does Madders think Trading Standards plays in helping the country prosper on a local and national level?

“As ACTSO’s figures show, the role that Trading Standards Officers play is real and quantifiable – the economic impact means people are better off and good businesses are more profitable,” he says. “For that to happen, businesses need confidence

to invest – including assurance that they won’t be undercut by unscrupulous competitors – and consumers need confidence that they are buying from reputable manufacturers and retailers.

“Regulatory certainty and consistency is essential to kickstart growth and I believe local Trading Standards departments up and down the country already do play an important role in creating that confidence. I mentioned Primary Authority – the scheme is there to have a national impact, and shows exactly how the unique expertise in regions and sectors that Trading Standards offers can be amplified for the benefit of consumers and businesses across the country.”

A new chapter?

One of the findings of the Grenfell Tower Inquiry was that previous governments’ drive for deregulation meant concerns about the safety of life were ‘ignored, delayed or disregarded’. The Government of which Madders is a part now has an opportunity to reject that ideology and turn the page on what has been described as the ‘slash and burn’ of the Tory years (see page 40) – so what role does he think regulation plays in creating a safer, healthier and fairer society?

“Good regulation helps protect people from harm and fraud, and enables people to make informed choices about their health and other aspects of their lives,” he says. “Whilst regulation has a role in protecting all members of our society, it is especially relevant for the most vulnerable. As the Minister for product safety, I have seen and heard first-hand from those affected by recent e-bike fires, for example, of the devastating impact that unsafe products can have on people’s lives (see page 26). Listening to their stories has brought into sharp focus the important role that regulation can play in protecting people from harm and the necessity for it.

“The Grenfell Tower Inquiry published its final report on 4 September. The Government is carefully considering its recommendations and has committed to responding within six months, to ensure that such a tragedy can never occur again.”l

Hide and seek

From remote-control hydraulic mechanisms to magnetic trapdoors, the ingenuity of illicit tobacco sellers knows no bounds when it comes to hiding their illegal goods

As these pictures demonstrate, the methods used by criminals are no match for the perseverance of Trading Standards teams up and down the country, combined with the dogged determination of their specially trained four-legged colleagues. With work to stub out illicit tobacco and vapes continuing as part of the Operation CeCe and Operation Joseph initiatives, we take a look at some of the more creative, unusual and downright devious places clandestine counterfeits and untaxed tobacco have been found recently. And, as the prosecutions and convictions resulting from this work demonstrate, there really is no place to hide for those seeking to put public health at risk.

01 Newham Trading Standards found a large quantity of illicit cigarettes and handrolling tobacco hidden behind a mirror in the bathroom at the back of one local shop.

02 At a shop in Huddersfield, West Yorkshire Trading Standards and West Yorkshire Police found 144 packets of cigarettes, 231 vapes and large quantities of hand-rolling tobacco within a ‘spy film-style’ false wall that could only be accessed via an electronically controlled hatch.

03 Derby City Council Trading Standards found one retailer had gone to extraordinary lengths to conceal illicit tobacco, installing a kitchen counter on hydraulic legs that could be raised and lowered at the push of a button. Beneath it Officers found more than £10,000 worth of illicit cigarettes and vapes.

04 When sniffer dog Griff found illicit cigarettes and vapes hidden behind a concealed wall in one store, Officers from Walsall Trading Standards had to use electric power tools to get them out. 04

05 Nottinghamshire Trading Standards, ably assisted by a tobacco detection dog, seized 1,437 illegal vapes with an estimated value of £18,861 from two shops in Newark in October.

06 Worcestershire Trading Standards found illicit cigarettes and tobacco behind a hinged mirror operated by an electromagnet. The shopkeeper initially claimed he was unaware of the illicit goods, saying they must have been there for more than four years. However, one pack of cigarettes had been manufactured only three months before the raid.

07 Tameside Trading Standards found illicit cigarettes and tobacco hidden in the ceiling of one shop whose owner was subsequently fined more than £1,000.

08 Darlington Borough Council Trading Standards found a bumper stash of illicit cigarettes, hand-rolling tobacco and vapes hidden inside a working drain. The discovery prompted the service to urge consumers to consider the hygiene implications of buying illicit goods.

09 Tobacco detection dog Billy helped Leicestershire Trading Standards find 107 packs of illicit cigarettes beneath a concealed shelf under the counter of a shop in Coalville.

By Edward Skinner

CPPD Module 27:

Financial investigations

Financial investigations are an important part of Trading Standards toolkit, and understanding how they work is vital to successful prosecutions and disruption work

The Proceeds of Crime Act (POCA) is a vital piece of UK legislation that allows Trading Standards authorities (and other law enforcement agencies) to tackle criminal activity by recovering money and assets obtained through illegal means. The Act has been in place since 2002 and local authorities have had powers under it since 2006. In 2023-24, local authorities collectively recovered £12.5m of criminal finances and imposed confiscation and forfeiture orders totalling £33m.

The diverse work of Trading Standards provides rich opportunities to apply financial investigation powers and techniques. Whether in relation to doorstep crime, intellectual property, illicit tobacco or even weights and measures investigations, POCA can be applied.

Given the evidential importance of a suspect or defendant’s finances in proving offences in court, it’s never been more important for a modern Trading Standards service to have financial investigation capabilities. Accredited Financial Investigators (AFIs) and intelligence officers (AFIOs) can bring a lot to the table when developing an investigation; for example, they are entitled to obtain Suspicious Activity Reports from regulated organisations such as banks and building societies, which are compelled to submit them under POCA rules. These reports can assist investigators with identifying victims of crime, discovering previously unknown suspects and new offending, and finding accounts, money and other assets that may be seized to pay compensation later.

Furthermore, other tools include the ability to obtain financial material from a plethora of organisations using various court orders. For example, obtaining a

suspect’s bank statements, conveyancing files and accountants’ records can be extremely useful when trying to prove the predicate Trading Standards offence. It can also identify money laundering which can be charged concurrently to the index offences. The value of charging these offences is that the penalties are often far greater than summary-only or even either-way regulatory offences. In addition to this, a conviction for money laundering is an automatic qualifying offence for criminal lifestyle provisions when it comes to Confiscation proceedings.

Alternative enforcement options

The POCA contains a suite of civil recovery powers. Therefore it has a useful part to play when considering disruption strategies as an alternative to criminal prosecution. One example is cash seizure/ forfeiture powers can be used when conducting inspections or executing warrants where cash is found and it is thought that the cash has derived from an unlawful act, or there is suspicion it will be used to commit an unlawful act. The scenario of finding a bundle of cash in a draw when Trading Standards seizes illicit tobacco and vapes would be sufficient to form a reasonable suspicion that the money has derived from the sale of illicit tobacco, rendering it liable to seizure, as long as it is over £1,000.

Once assets are seized, the AFI will seek and obtain a Detention Order from the magistrates’ court for up to two years. This is to allow for an investigation into the derivation of the cash to take place. The major advantage of this route, compared to traditional enforcement is the lower (civil) standard of proof and the fact the burden is on the ‘interested party’ (i.e. the person from whom you seized

the cash) to prove it is legitimate. Orders for forfeiture are subsequently made to the courts and 50% of funds flow back to Trading Standards.

Another noteworthy civil recovery power is Account Freezing Orders (AFOs). A useful Trading Standards scenario is a doorstep crime complaint is picked up. Following a review it’s a single complaint; the trader (or criminal) took the £2,500 deposit for roof repairs but then never returned to conduct the work. This is a scenario that will be familiar to most if not all Trading Standards Officers. It most likely won’t cross your departmental threshold for criminal investigation and prosecution so the victim may be left with a county court route to redress. The use of AFOs provides an alternative; the AFI can make enquiries with the victim’s bank if a cheque or transfer was used, and trace the payment to the bank account of the suspect. If it was a cash payment, then the suspect’s bank can be identified through other means.

The AFI can very quicky, often over the phone or email, identify whether the victim’s money – or any other money –exists in the suspect’s bank account. This is all done covertly and if funds are identified, similar to cash detention above, an application can be made to the magistrates’ court to freeze that money in the suspect’s bank account to allow further investigation. If it is confirmed, then a Forfeiture Order is made, and provisions are available to reunite the victim with their lost funds.

Similar civil recovery powers exist for ‘listed assets’ which include precious metals and precious stones, watches, artistic works, face-value vouchers and postage stamps, and cryptocurrency and crypto assets.

Top tips

• Always engage a financial investigator at the earliest opportunity. Too often investigation teams and prosecutors wait until the investigation is advanced or even after proceedings have concluded before they think to engage an AFI. Delays can mean fewer opportunities exist for the AFI to have an impact. Once the suspect is aware of your investigation, they may dissipate or hide their assets; an AFI who has been engaged early will be able to trace and quantify assets, and seek Restraint Orders to prevent dissipation. This can be done at the pre- and post-charge phase.

• To maximise the benefits of having an AFI, include their objectives in the charging decision. It is not uncommon for this to be overlooked when it comes to drafting summons. For instance, in scenarios where there isn’t a qualifying offence ( POCA schedule 2), ensure that a charge sheet has sufficient charges (facts allowing of course) to trigger criminal lifestyle provisions (s.75). Commonly this is achieved by including a continuing offence of a minimum of six months and minimum value of £5,000, or four or more ‘single day’

offences with a minimum aggregate value of £5,000. After a conviction and POCA confiscation, with criminal lifestyle condition met, the AFI can include assets obtained or transferred for a period of six years prior to the date summons were issued – not just the benefit associated with the offences the criminal was convicted of.

• Sometimes you will convict a defendant who has benefited hugely from their criminal conduct but doesn’t have any assets to show for it. In the current climate you could be forgiven for declining to spend more departmental resource in the courts pursuing a £1.00 Nominal Order. However, the advantage of sticking to the road and obtaining the £1.00 Order is that in doing so the court will also certify the defendant’s ‘benefit from crime’. If in the future the defendant comes into new assets, they are liable to have their Nominal Order increased to reflect this. ●

About the author

Edward Skinner is an Accredited Financial Investigator and CTSI Lead Officer for the Proceeds of Crime Act (POCA).

Submit your answers at tradingstandards.uk/cppdtest

1. Are financial investigators permitted to obtain Suspicious Activity Reports?

2. Can money laundering offences be charged concurrently to index offences?

3. Is a conviction for money laundering an automatic qualifying offence for criminal lifestyle?

4. Does the POCA include civil recovery powers?

5. What percentage of funds flow back to Trading Standards from local authority forfeiture orders?

6. Should an AFI’s objectives be included in a charging decision?

7. What does ‘AFO’ stand for?

8. Can a Nominal Order later be increased if the defendant comes into new assets?

Applicants who complete the module will be given a certificate. The test must be taken by 7 June 2025. If you have any questions, please email kerryn@tsi.org.uk

Previous module answers are available on the Journal of Trading Standards website.

Spreading the word

As consumers of all ages face a rising tide of scams and other threats, arming them with information they can use to protect themselves should be a key priority for the public and private sectors alike

When the broadcaster Moira Stuart nearly lost money to a bank scam earlier this year, she felt the same as many other people who have found themselves in a similar position: “absolutely devastated, embarrassed and angry with myself”. Thankfully a sharp-eyed cashier prevented her from losing thousands of pounds, but Stuart still said that the intrusion into her personal life would stay with her (see more on page 9).

Authorised Push Payment (APP) fraud – in which someone is tricked into sending money to a criminal posing as a genuine payee – is frighteningly common. According to the banking body UK Finance, it resulted in losses of almost £460m in 2023. That amounted to 232,429 cases.

As fraudsters become ever more sophisticated, the consumer detriment continues to rise. But, like many things in life, when it comes to scams, prevention is better than cure. That is certainly the view of Trading Standards Officers working hard to educate the public. “People need different education on different

things throughout their lives but, early on, school-age children need to start off knowing what their consumer rights are, knowing where to go to complain, and giving them a little bit of literacy on what to do if something goes wrong,” says Alison Farrar, CTSI joint Lead Officer for Consumer Education and Chair of the Consumer Empowerment Alliance. “What are the processes? What can you do to protect yourself? What should you be doing as a consumer?”

Farrar believes that, from a relatively young age, people need something in their toolkit to help them recognise their rights but also identify potential scams. She says that it’s especially important for the younger generation when they are making decisions for the first time, such as opening a bank account or buying a car, because at that point, they are more vulnerable. “It’s really good for people to understand the very basics of how things work before they go on and do the more complex transactions that happen as they go through life,” she says.

Louise Baxter, also joint Lead Officer for

Consumer Advice and Education, agrees. She points to statistics revealing that only 17 per cent of people will admit that they are situationally vulnerable. Wearing one of her other hats, Baxter runs the Consumer Friend website, which aims to make consumer rights easy for everyone.

“What we try to do is provide the information in a way that is inclusive,” says Baxter. “It’s written for nine to 12-year-olds. Also, I don’t particularly think that campaigns for education purposes work if you target vulnerability. I think you need to have a campaign that is inclusive so it lands for everybody because if people are labelled as vulnerable, you lose them instantly. They won’t want to be in that particular cohort.”

She continues: “We need to rethink how we do it, and build all of our services inclusively to ensure that everybody can access them, which should scoop up all of that vulnerability.”

Limited resources

It’s no secret that dwindling resources and a lack of investment in Trading

We’re just firefighting in Trading Standards now... it’s heartbreaking to see younger people becoming victims earlier of crimes and scams and not knowing their consumer rights

scaling back of consumer education work. She points to fewer and fewer consumer education campaigns and a decline in the number of outreach programmes, not to mention an increased workload meaning that Trading Standards services can no longer devote as much time to things like over-50s clubs and school visits. She says: “You can do massive campaigns across social media. But unless you’re doing that kind of face-to-face and practical stuff with people, I don’t think it really sinks in in the same way because people don’t apply what they hear to what actually happens to them in real life.”

to be included in the school curriculum –which is also one of the recommendations in CTSI’s 2024 Manifesto.

“There should be a lot more around preparing people for life,” she says. “And it shouldn’t just be things like consumer rights. It should be more around the stuff we used to do about recognising fakes and safety of products and that kind of thing, so you’re protecting yourself physically as well as financially.” l

Key messages

Standards have had significant impacts across the board. One of the areas most affected has been consumer education, as Baxter explains. “There’s been a massive knock-on effect on base-level consumer information and education and what consumers are actually aware of. Businesses are making it more difficult to complain, and consumers don’t know what their rights are.

“We’re also moving into a world of litigious and vexatious consumers because they’re getting frustrated, and they’re thinking they’re entitled to a lot more than they actually are.”

Baxter also thinks it’s important to differentiate between consumer education and business education. “We need to simplify it for everybody. The problem we have with education is trying to make it relevant, accessible and easy to understand. It shouldn’t be reams and reams of words and information that consumers are then having to decipher when they have a problem. Because when you’ve got a problem, it’s really stressful.”

Farrar is likewise concerned about the

She adds: “We’re just firefighting in Trading Standards now... it’s heartbreaking to see younger people becoming victims earlier of crimes and scams and not knowing their consumer rights. But that translates into later life because everybody who’s at school now will end up in a profession. They will have a job. They will be consumers all of their lives.”

What next?

Looking to the future, both Farrar and Baxter hope that more can be done to boost the work of Trading Standards and therefore help consumers better protect themselves – but it will all cost money, and that money needs to come from new sources.

Baxter says: “I think that the new Government allows us an opportunity to have a real consumer focus. I also think that we can’t do it on our own. I think we need to do it in partnership with the private sector where, historically, it’s always been ‘us and them’. We’re not in competition with each other. We need to work together to ensure that we get effective messages to consumers.”

Farrar is

These resources can help consumers and businesses help themselves.

Consumer Friend provides simple, accessible information about consumer rights.

www.consumerfriend.org.uk

Friends Against Scams empowers consumers and helps support victims. www.friendsagainstscams.org.uk

Citizens Advice has useful consumer resources on a wide range of topics. www.citizensadvice.org.uk/consumer

Business Companion provides free, expert-written guidance to businesses. www.businesscompanion.info

CTSI has a dedicated section on its website which helps consumers find their local Trading Standards service –many of which provide locally-tailored consumer advice of their own – as well as links to further useful resources such as the Approved Code Scheme, the UK ICC and other relevant organisations. www.tradingstandards.uk/ consumer-help

keen for consumer education

Left Katey Anderson and Gavin Davies, Trading Standards Officers at Scottish Borders Council, took to the road with the ‘Scam Van’ initiative, which offers consumer protection advice on the front line

Above Finalists of the CTSI Young Consumer Influencer of the Year Award, which was set up to boost awareness of consumer issues among young people

A night to remember

The passion and dedication of some of consumer protection’s brightest stars were recognised at a ceremony in the Houses of Parliament

Despite the crisp and cold weather outside the Palace of Westminster, there was a warm reception waiting within for the recipients of the 2024 CTSI Hero Awards on the evening of 10 December.

Now in its nineteenth year, the event celebrates the best and brightest in consumer protection, honouring those whose hard work, enthusiasm and commitment have safeguarded communities, promoted fair play and changed lives for the better over the past 12 months.

Speaking to the Journal before proceedings got under way, CTSI Chair Nikki Pasek said: “For me, this event just captures the passion that the Trading Standards profession and our partners have for doing amazing things in our local communities and with local businesses.” Pasek, who was one of the award panel judges, added: “There were so many good entries, so many worthy pieces of work –the problem was picking the winners. It was a very difficult call.”

As the auspicious surroundings and the presence of several MPs and peers demonstrated, the hard work of Trading Standards has not gone unnoticed over the past year. One of those in attendance, Labour MP for Rochdale Paul Waugh, was there to support his local Trading Standards team, who received the Outstanding Trading Standards Project of the Year Award for their work on two initiatives: Operation Ghost and Operation Vigilant. The former was set up to tackle ‘ghost’ car registration plates which cannot

be read by traffic cameras and have been linked with wider acts of criminality, while the latter is a partnership project to detect and disrupt the links between child exploitation and youth vaping.

Waugh said: “I’m here to celebrate the fantastic Rochdale Trading Standards team who are getting an award tonight for two reasons. One is their great work in tackling illegal vapes, which has real implications for child protection in Rochdale. It has its roots in organised crime, and they’re working with the police really closely.

“Our Trading Standards team has also had great success in seizing lots of ‘ghost’ plates. In Rochdale, sadly, we do have an organised crime problem, but this shows that we’ve got people who are tackling that and standing up for residents.”

On the issue of Trading Standards’ wider work and its importance to the Government’s agenda for strengthened consumer protection laws (see page 18), Waugh commented: “We think regulation empowers citizens and shows the connection across government with police and local councils working in tandem. If you can give them the tools, then you can help every citizen; you can help protect young kids from vaping, you can help protect them from county lines drug gangs. You can help them in the basic safety requirements that all families and parents expect from toys, for example.

“We’ve got an agenda as a government which is to enable people to get on with their lives, and safety and Trading Standards are a key part of that.”

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Another politician in attendance was Mark Sewards, Labour MP for Leeds South West and Morley. He was there to support the West Yorkshire Trading Standards team, who were being highly commended in the Outstanding Trading Standards Project category for their work on Operation Artemis, an initiative to gather key information and intelligence about complaints in the home improvement sector. The project, which has been running since 2022, has prevented approximately £35,000 in consumer detriment alongside further unquantifiable savings through improved compliance.

Sewards commented: “Several of my constituents from West Yorkshire Trading Standards are being honoured for their work, and I wanted to be here to celebrate with them.

“We won the election in July with a very clear mandate for the things set out in our manifesto. Things like renters rights

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are absolutely essential to protect people from the worst excesses of the market. It’s really important that we get these things done, and get them done quickly so that consumers are better protected.”

And the winners are...

The compere for the evening’s ceremony was broadcaster Jenni Falconer, who kicked things off by praising all of the worthy winners. “Tonight is a very special event to celebrate the incredible work that goes on day in, day out, by those working in Trading Standards and wider consumer protection across the UK,” she said.

“It is good to be in such great company this evening as we recognise the contribution that Trading Standards and others make. For me, you are unsung heroes who represent what is best in society, helping the community and the most vulnerable, and always putting others’ needs before your own.”

The first accolade of the evening was the Intellectual Property Award, presented by Rhys Hurley of the Intellectual Property Office. The award went to Project Firecrest, a partnership between Newport Trading Standards and Gwent Police which has resulted in the seizure of counterfeit and illegal tobacco, vapes, clothing and watches worth millions of pounds.

The Diversity and Inclusion Award went to the CTSI London Branch Race and Equalities Group, who were praised for their work at the REACH Conference in 2024 to promote Trading Standards careers to students and undergraduates from under-represented backgrounds.

The Best Product Safety Initiative Award was presented by category sponsor UKAS’s Richard Collins to the London Borough of Tower Hamlets Trading Standards team. They were recognised for their work to tackle unsafe e-bikes and e-scooters, the potential fire risks of

which are of real concern in a borough where 80% of homes are flats. The Tower Hamlets team, working with London Fire Brigade, developed the #ChargeSafe media campaign, which raised awareness of the risks associated with the devices and caught the attention of local and national media (for more on e-bike safety issues, see page 26).

The Outstanding Trading Standards Project Award was presented by Adam Carter from the National Trading Standards Scams Team to Rochdale Trading Standards, with West Yorkshire Trading Standards being highly commended in the category (see above). Also highly commended were the Barking & Dagenham Trading Standards team, whose projects over the past year have included work to remove unsafe vapes from the supply chain, tackling underage knife sales in the borough (see page 5) and conducting inspections of

1 CTSI Chair Nikki Pasek

2 The London Branch Race and Equalities Group with CTSI Chief Executive John Herriman (second left)

Awards presenter Jenni Falconer

Winners from the London Borough of Barking & Dagenham

5 The Tower Hamlets Trading Standards team

6 Rhys Hurley (left) presents the IP Award to Operation Firecrest

shisha venues through the multi-agency Operation Alice initiative.

Next up was the Brian Smith Hero Award, named in honour of the late Angus Council Trading Standards Officer whose tireless work to safeguard the vulnerable was an inspiration to many. The winner of the award was Yemisi Forrest from Southwark Trading Standards, who has gone above and beyond to support fraud victims and bring rogue traders to justice. The award was presented by Steve Smith from category sponsor trueCall, who praised Forrest’s “fantastic professionalism”, which has empowered victims and resulted in prison sentences for the worst offenders.

Highly commended in the same category was Walt Boydell from Barnsley Safer Neighbourhoods Service, whose fight against a local loan shark resulted in a seven-year conviction for a ruthless

criminal. He was praised for his diligence, persistence and empathy in his work alongside the England Illegal Money Lending Team.

One of the evening’s more emotional moments came with the next award, the CTSI Megan Lee Hero Award, named in tribute to the teenager who tragically lost her life after eating undeclared allergens in a takeaway meal. Megan’s parents Gemma and Adam have been unflagging in their support of Trading Standards’ work to promote allergen awareness, and they sent a heartfelt video message to the category winners, Lancashire County Council Trading Standards Food Team.

The Lancashire team were praised for their creation of business advice and training packages, as well as an educational awareness package to promote understanding of anaphylaxis. The team have also taken more than

300 samples for allergens across a range of food types, leading to seven successful prosecutions.

The Staffordshire County Council Trading Standards Food, Feed and Animal Health Team were highly commended in the category after spearheading outstanding collaborative work on food safety in Staffordshire and the surrounding local authorities.

The Business Award was presented by Lesley Crompton, Head of Resolution Services at CTSI, to ABC Warranty, who were praised for their work to support new homeowners.

David Pickering, the recently retired CTSI Lead Officer for Food Safety, was named the Institute’s Hero in recognition of his significant contribution to Trading Standards. A much-liked and highly respected member of the profession, Pickering was praised for his passion and

1 Mark Sewards MP (centre) with the West Yorkshire TS team

2 Yemisi Forrest collects the Brian Smith Hero Award from trueCall’s Steve Smith

3 Lancashire TS won the Megan Lee Hero Award

4 AJ Fleetcare won the Motor Ombudsman’s Star Garage Award

5 Pippa the detection dog

6 Walt Boydell was highly commended for the Brian Smith Hero Award

7 Business Award winners ABC Warranty

8 The Oxfordshire TS team 8 7

knowledge about food matters, and for his ‘phenomenal’ ability to provide guidance and best practice for colleagues at all stages of their careers.

Speaking to the Journal after the ceremony about his thoughts on the current state of the UK’s food safety landscape, Pickering said: “There is now an opportunity to really look at food safety and security in relation to economic growth. We need to look at regulation that works for businesses and consumers. If you want economic growth, you’ve got to have rules that businesses understand and can work with.”

Highly commended in the Institute’s Hero category was Newham Trading Standards’ Vincent Searle, who was praised for his drive and passion for his own career, as well as for his work to promote the success and sustainable future of the profession. Also highly commended were the Oxfordshire Trading Standards team, whose work to support vulnerable victims of scams showed “a commitment to restoring trust and dignity for those who have lost faith in themselves and others”.

Finally, two Special Recognition Awards were handed out, with Thomas Haslam, a former test purchasing volunteer, being praised for his remarkable work with Highland Council Trading Standards to promote the safe sale of goods to young people. During an 18-month period he took part in an incredible 70 test purchasing operations.

And last but by no means least, the second Special Recognition Award went

to Pippa, a specialist tobacco and vape detection dog from Wagtail UK. Pippa, who Falconer described as “the most popular guest this year”, took to the stage with her handler Brad Thomas and Wagtail UK Managing Director Collin Singer, and was praised for her sterling work over the past seven years, during which she has uncovered more than 12.6 million illicit cigarettes, 170,000 illegal vapes and 38.6 tonnes of illegal hand-rolling tobacco.

Serious

purpose

Reflecting on the purpose of the Hero Awards and their importance to the wider consumer protection profession, CTSI President Lord Jamie Lindsay told the Journal: “I think it’s hugely fitting and very appropriate that these awards are taking place in the Palace of Westminster. Trading Standards is so important to everyone throughout Britain, and it’s important that this event is being held at the apex of British governance and democracy.

“Each of the winners’ stories is an amazing example of what is going on every day in the Trading Standards world. By highlighting the specific achievements of some of those amazing people, it’s spreading an awareness of what great work they’re doing. And the more people realise how important Trading Standards is to their everyday lives, the more recognition they get, and the more support I’m hoping they will also get from central government, from local government, and from their local communities.” l

The

winners in full

Intellectual Property Award

Project Firecrest

Highly commended: Andy Miles, Southwark TS

Diversity & Inclusion Award

London Branch Race & Equalities Group

Best Product Safety Initiative

London Borough of Tower Hamlets

Outstanding Trading Standards Project Rochdale TS

Highly commended: West Yorkshire TS; London Borough of Barking & Dagenham TS

CTSI Brian Smith Hero Award

Yemisi Forrest, Southwark TS

Highly commended: Walt Boydell

Megan Lee Hero Award

Lancashire TS

Highly commended: Staffordshire TS

Business Award

ABC Warranty

The Institute’s Hero 2024

David Pickering

Highly commended: Vincent Searle, Newham TS; Oxfordshire TS

Special Recognition Award

Thomas Haslam; Pippa, Wagtail UK vape detection dog

Motor Ombudsman Star Garage Award

AJ Fleetcare

Lindsay Chartered Trading Standards Practitioner and former Chair of CTSI

Words of power

Even those with the best of intentions can sometimes cause harm through their choice of words

We must remain open to learning and understanding how different cultures and communities define themselves

Language is a living entity, constantly evolving with societal changes and cultural shifts. It reflects our values, shapes our perceptions and, at times, can cause unintended harm. What is acceptable or respectful in one place may carry very different connotations elsewhere. A global shift towards inclusive language reflects a broader push for equality and respect in our daily lives, whether in the workplace when speaking with colleagues, visiting businesses to carry out enforcement work, or engaging with local communities.

Words carry the weight of history, and societal understanding of their impact changes over time. Just as outdated terms for sexuality or disability have been replaced with respectful alternatives, racial terminology must also reflect a commitment to dignity and inclusivity. Listening to how people identify themselves and adapting their language accordingly is essential for fostering understanding and mutual respect.

Across the globe, there has been a growing awareness of how language shapes racial identity and perpetuates discrimination. Anti-racism movements such as Black Lives Matter have catalysed this shift, encouraging people to discard outdated terminology.

Language is not just a reflection of reality; it shapes how we view the world and how we treat one another. When we use inclusive language, we acknowledge the humanity and dignity of those we speak about. Conversely, when we use outdated or harmful terms, we perpetuate stereotypes and reinforce systems of oppression.

We must remain open to learning and understanding how different cultures and communities define themselves. This will be vital in making Trading Standards more effective at engaging with different communities and addressing the issues which particularly affect them, whether through their religious practices or their use of certain products. It will also help the profession broaden its appeal to new recruits, injecting new ideas, fresh perspectives and a renewed sense of purpose.

As we navigate a world where racial and cultural contexts differ, it’s essential to learn, to listen, and to adapt. By fostering inclusive language, we take a small but meaningful step towards dismantling racism and building a world that respects and honours every person’s dignity. Each one of us can make a positive difference. Let us love one another. l

Tendy

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Read the definitive history of hallmarking and its enforcement

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This hardback book includes detailed coverage of specific prosecutions and a comprehensive index of more than 600 court cases, as well as a wealth of fascinating historical facts, illustrations and poems. Copies of the book can be ordered from CTSI, with proceeds donated to the College of Fellows. For your copy email institute@tsi.org.uk. (£35 per copy +

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