In a general notice, the Dutch Advertising Code Commission (Reclame Code Commissie) shares its opinion that in order claim the characteristic “whole wheat” a product should contain flour which is exclusively made from whole wheat grains.
After receiving a number of complaints for a diverse number of products, the body decided to share its view on the website. The body’s opinion refers to the European Court of Justice-case Teekanne (C-195/14) where the image of vanilla and raspberry-blossoms on front of pack were considered to be misleading because the tea only contained artificial flavourings. The Dutch Commission elaborates that a front of pack or other explicit label indication of “whole wheat” creates the impression the product’s flour constituents comprise entirely of whole grain. The fact the list of ingredients indicates the actual -none whole wheat- characteristics of the other flour components would not lift that impression.
Reclame Code Commissie (20 September 2019) - link