Background
Summary of Council decision:
Three issues were investigated, of which one was Upheld and two were Not upheld.Ad description
Four national press ads and a TV ad for Tesco:
a. The press ad, published on 4, 5 and 6 October 2018, had a headline stating "If you're looking for great value on these baskets, look no further than Tesco". It featured three baskets of goods one each for Aldi, Lidl and Tesco. Text stated, "£12.30 at Aldi", "£11.87 at Lidl", and "Exclusively at TESCO. £11.56 at Tesco". Text underneath stated "Small print: Saving based on products shown only. Comparison on Tesco products & comparable products at Aldi & Lidl. Prices checked at Aldi & Lidl on 01/10/2018. Pro rata Aldi and Lidl price used considering size. Products may vary by region. Details at Tesco.com/basketcomparison".
b. The press ad, published on 15 October 2018, had a headline stating, "To help you spot the cheapest trolley, we've circled it". It featured three trolleys filled with products. Text stated "£39.90 at Aldi", "£40.02 at Lidl" and "Exclusively at TESCO £38.62 at Tesco". The Tesco trolley was circled. Text underneath stated, "Small print: Saving based on products shown only. Comparison on Tesco products & comparable products at Aldi & Lidl. Prices checked in store and online at Aldi and Lidl on 12th or 13th October 2018. Pro rata Aldi and Lidl price used considering size. Products may vary by region. Details at Tesco.com/basketcomparison. Selected Stores excluding Express. Delivery charges may apply".
c. & d. The press ads, published on 17 October 2018 (ad (c)) and 20 October 2018 (ads (d)) were very similar to ad (b), but included different prices for the trolleys and referred in the small print to different dates on which the price comparisons had been carried out. Both ads showed the Tesco trolley to be the cheapest.
e. The TV ad, seen on 2 November 2018, also featured three trolleys filled with products and showed Tesco's trolley to be cheaper than Aldi's or Lidl's. A voice-over stated, "It's easy to spot the Tesco trolley here. It's the one with the lowest price. Our best value is exclusively at Tesco. Every little helps." On-screen text stated "Checked 31/10 @tesco.com/basketcomparison. Selected English stores. Tesco own brand versus competitor own brands".
Issue
Aldi Stores Ltd challenged whether ads (a) ‒ (e) were misleading, because:
1. they believed the ads implied the Tesco baskets/trolleys of goods were representative of typical shops at Tesco, and therefore representative of the prices and savings that could be typically achieved when shopping at Tesco rather than Aldi or Lidl. They understood they were entirely comprised of Tesco own-brand products and did not therefore constitute typical shops. They also understood, from the on-screen text in ad (e), that the products shown were only available in selected English Tesco stores and did not therefore constitute typical shops for consumers living in other parts of the UK;
2. there was a delay between the prices being checked and the publication dates. In some cases prices were checked over several days rather than on a single day (and in such cases, it was not clear which prices were checked on which days); and
3. in some cases, Aldi had cheaper comparable products than those used in the comparison.
Response
1. Tesco Stores Ltd said the basket and trolleys in the ads did not explicitly or implicitly represent typical shops and did not contain general savings claims. They believed they should be able to highlight a specific range of own brand products against comparable competitor products, as they had done in the campaign, without an additional requirement that the examples must represent a typical regular shop. Tesco believed none of the ads included messages about savings on typical regular shops, or any other general savings claims. The headline claim was "To help you spot the cheapest trolley, we've circled it". That heading was sufficiently clear to communicate that the savings claimed in the ads were achieved by purchasing the particular trolley of products featured, which was "circled" by the 'Exclusively At Tesco' roundel. They pointed out that the TV ad (ad (e)) included an additional word to clarify that the comparison was restricted to the products in the trolley: "To help you spot the cheapest trolley here we've circled it".
In relation to ad (a), Tesco believed the ad made a very clear, specific savings claim in respect of a specific group of own brand products, which was verifiable and otherwise complied with the Code. They said ad (a) featured just 12 products and so it was easy for consumers to identify the products compared, particularly because it was a half-page press advert split over two pages and all products were easily identifiable from the product images and/or product names on the packs. They also asserted the ad did not make any claims about savings on regular shops, or any other general savings claims. They pointed out the small print which directed consumers to a web page which set out verification for the price comparisons, including product descriptions and information, and they believed the claims were therefore verifiable. In relation to the trolley ads (ads (b), (c), (d) and (e)), Tesco said the prominent 'Exclusively At Tesco' roundel clearly communicated that consumers could purchase a competitively priced trolley of products at Tesco should they choose to purchase the relevant products from their 'Exclusively At Tesco' range. They believed the products in the trolleys were sufficiently clear for consumers to identify them as belonging to own brand product ranges at each of the three retailers and, as with ad (a), the ads directed consumers to a web page where they could find out more information about the specific products compared.
Notwithstanding the fact that Tesco believed the ads did not represent typical shops, or make any claims about general savings that could typically be achieved when shopping at Tesco, they did ensure that ads (b) to (e) included products that were commonly purchased by price conscious consumers to whom the ads were targeted. In particular, they used Kantar WorldPanel data to identify key categories of staple grocery products for a group of price conscious consumers who were under the greatest financial pressure and who spent more on food as a percentage of income than other segments of society, so were most likely to purchase entry tier own brand products. They then identified their own-brand, 'Exclusively At Tesco', products that fell into the relevant categories and (i) had a comparable product at Aldi and Lidl against which a fair comparison could be made, (ii) were available in a significant number of Tesco stores, and (iii) were in the top 33% of products sold by volume at Tesco (out of all available products, not just in the top 33% of Exclusively At Tesco products). From that group, they chose a spread of 41 products across fresh meat, produce, dairy, packaged and frozen foods, including two dairy, five fresh meat and seven fruit and vegetable products. They considered that was sufficient to meet the requirement that they had included a fair and representative selection of products in their price comparisons.
They believed the "fair and representative" test was not so narrow that it required a trolley of goods to be based very specifically on data alone and that basing a "typical" shop purely on data was unlikely to accurately identify an average UK consumer and their typical basket or trolley of goods because of the thousands of products available to the millions of diverse customers which UK supermarkets served every year. Furthermore, they believed a solely data based approach would be inaccurate because while retailers had information about their own customers, they did not have access to each other's data in order to be able to identify a market-wide average consumer.
Tesco did not agree with Aldi that consumers did not recognise the 'Exclusively At Tesco' range as a range of own brand products. They explained that back in 2016 they began replacing their 'Everyday Value' entry tier range, which exceeded 300 products, with 'Exclusively At Tesco' brands. That was part of a wider Tesco own brand refresh which consisted of around 5,000 entry tier own brands being rebranded over the past few years. In March 2016, Tesco launched the first six 'Exclusively At Tesco' brands across their entry tier range of fresh meat and produce lines. Those had since been followed by an additional ten 'Exclusively At Tesco' brands across all other grocery categories.
The own brand refresh was almost complete, with just 24 'Everyday Value' products remaining. They understood that Aldi referred to their own brand products as “exclusive brands” and considered that the ads would be understood by price conscious consumers to be comparing entry tier exclusive brands at Tesco with entry tier exclusive brands at Aldi. Tesco said they had actively educated customers about the change from 'Everyday Value' to 'Exclusively At Tesco' including through extensive advertising. That was in addition to significant promotion of the products in-store, including point of sale and product sampling, in the Tesco Magazine and through their digital channels, for example, social media and the Tesco website. They confirmed the 'Exclusively At Tesco' roundel appeared on all product packaging in the range.
Tesco stated that, although their corporate website quoted 3,400 stores, consumers would not expect to shop 'Exclusively At Tesco' products in their petrol, staff stores and depots, which were included in that number. They believed the number of stores where consumers would expect to shop Tesco products was therefore 2,641. That number included 1,758 Express stores, but Tesco considered it was unlikely consumers would complete their typical weekly shop in a convenience format store, so they would not expect Express stores to be included in the comparison and pointed out the average basket size in an Express store was four products. As a result of that exclusion, the number of stores applicable for the purpose of the ads was 883, where they maintained the 'Exclusively At Tesco' products were ranged in a significant proportion.
They confirmed that there were around 400 products in their 'Exclusively At Tesco' own brand entry tier range. In comparison, their core tier own brand range included approximately 9,000 products and their Tesco Finest premium tier own brand range included approximately 1,000 products. They said a typical Tesco Extra or Superstore stocked around 19,000 products, including a mixture of own brand and branded products. By contrast, they understood that Aldi stores stocked around 3,200 products in their permanent range, including approximately 70 entry tier own brand 'Everyday Essentials' products, and Lidl stores stocked around 3,000 products in their permanent range, including approximately 50 entry tier own brand 'Simply' products. They explained that in some product categories, for example fresh bakery, meat and produce, Aldi and Lidl did not always brand their entry level product as 'Everyday Essentials' (Aldi) or 'Simply' (Lidl) so it was not the case that ads (b) to (e) compared 41 out of 70 of Aldi's entry tier range. However, it was the case that when comparing 'Exclusively At Tesco' products with entry tier Aldi and Lidl products, the number of products that could be fairly compared was limited. They stated that 80% of the products featured in ad (a) ‒ the ad showing a basket of goods ‒ were available in at least 50% of Superstores and Extras, and 75% of the products featured in ad (a) were available in at least 75% of Superstores and Extras. They stated that more than 75% of the products featured in ads (b) to (e) ‒ the ads featuring trolleys ‒ were available in at least 50% of Superstores and Extras; and more than two-thirds of the products featured in ads (b) to (e) were available in at least 75% of Superstores and Extras.
They considered there were no significant limitations on the availability of EAT products across the Tesco Superstore and Extra estate, and they pointed out that their advertising had included “Selected Stores” in the small print. Tesco explained that all products in the ads were available in each of England, Wales and Scotland. However, three of the products were not available in their stores in Northern Ireland: Eastmans wafer thin ham; white potatoes; and apple juice. They explained that Clearcast had required them to include "Selected English Stores" in on-screen text in ad (e), which they were willing to do even though they considered it was not necessary given the ad was only broadcast in England. They acknowledged that ads (a) to (d) had not included information about geographical exclusions and said they would make that clear in future price comparison ads, should that issue arise again. In relation to ad (e).
Clearcast believed the trolley of goods was fair, representative and typical for shoppers whose main concern was price, and contained various staples that a budget conscious shopper would buy. They re-iterated Tesco's explanation for how the products used in the comparison were chosen, and added that Tesco had told them that, with a handful of exceptions, in each case the 'Exclusively At Tesco' product was available in at least 400 of Tesco's 799 larger stores (Extras and Superstores) and was in the top 33% of products sold by volume at Tesco between 1 and 11 October 2018. The three exceptions were sold in fewer stores but none represented less than 11% of products they sold by volume. They also provided a series of questions they had put to Tesco regarding the ad and Tesco's responses. 2. Tesco understood that Aldi's complaint was based on a view that advertisers ought to check prices on the same day that they supplied price comparison ads for publication or broadcast (which was typically the day before publication in press and two days before first broadcast on television). They believed that requirement was unreasonable in circumstances where comparisons were being made with products and prices that were not available online, as was the case here. They explained that they had appointed an independent agency to manually check prices in at least three different Aldi and Lidl stores to ensure accuracy. They pointed out that such an exercise took more time than checking prices on a website, and in most cases it would not be possible to conduct price checks on the day of supply, in particular if any of the price checks resulted in changes needing to be made to ads before supply. They pointed out that there was a maximum of four working days between the price check date and the date of publication and price check dates were included in the small print in ads (a) to (d), and on-screen text in ad (e). They said that, with the exception of ad (d), all prices for all 41 products in each of the three retailers' baskets/trolleys were accurate on the date of supply and publication, or date of broadcast in the case of ad (e), and the prices for the vast majority of the products were stable at all three retailers throughout the campaign.
The price check date included in the small print of ad (d) was 16 October and prices quoted in the ad were accurate on that date. Those prices were re-confirmed by Tesco's agency on 18 October (and were still accurate), ahead of supply on 19 October. On 19 October (the date of publication of ad (d)) their agency's price check identified that the price of strawberries at Aldi had dropped slightly from £1.34 to £1.26 overnight. However, that information was provided too late on the afternoon of that date for Tesco to be able to update the prices in ad (d) ahead of supplying the ad for publication on 20 October. Nevertheless, the price check date stated in ad (d) was 16 October and the price of strawberries at Aldi was accurate on that date. Tesco explained that ads (b) and (c) contained two price check dates (12 and 13 October) because on 12 October their agency discovered that a handful of products in the comparison were available in at least one, but less than three, Aldi and Lidl stores. In order to be cautious, prices for those products were checked again in three Aldi and Lidl stores on 13 October and none of those prices had changed. For those reasons, they believed the prices had been checked within a reasonable period prior to the date of publication, and that price check dates had been clearly included in the small print in the ads.
They provided some Assured Advice from their Primary Authority in respect of a price comparison campaign against another retailer. The Primary Authority had considered that including prices checked at least every seven days on shelf-edge labels was sufficient to avoid misleading consumers about how current prices were. They understood that Clearcast's approach was that including a price check date in on-screen text was sufficient to make clear to consumers the date on which prices were checked and an ad would not mislead so long as prices had not changed significantly in the interim. In relation to ad (e), Clearcast pointed out the ad stated, in on-screen text, that prices were checked on 31 October and they understood the ad was broadcast for three days over the weekend after 31 October. 3. Tesco believed all the products in the ads met the same need and purpose, and were interchangeable for the purposes of comparative advertising, as they were the most comparable products at each of Aldi and Tesco.
They explained that comparability of products had been assessed by their Food Technical Team and signed off by their Food Technical Director. All but one of the price comparisons in the ads compared the cheapest comparable product available at Aldi, and sat within the same own brand entry tier hierarchy. For bacon, they compared Tesco's Woodside Farms entry tier unsmoked back bacon rashers with Aldi's core tier Freshcure unsmoked back bacon rashers. Aldi and Tesco both sold cheaper, lower specification entry tier bacon products: Tesco's Woodside Farms Cooking bacon and Aldi's Everyday Essentials Back bacon. Tesco believed the comparison was fair, and that Aldi's Freshcure bacon and Tesco's Woodside Farms bacon were the most comparable products at each of the retailers. Tesco believed Aldi's cheaper Everyday Essentials Back bacon did not meet the same intended need and purpose as Tesco's Woodside Farms Back bacon because they understood the purpose of Aldi's Everyday Essentials Back bacon was as a cooking bacon, for use in recipes (after being diced, chopped or sliced), rather than as whole rashers, and therefore had the same purpose as Tesco's cheaper bacon product (Woodside Farms Cooking Bacon). Tesco stated that, although Aldi described their cheaper bacon product as back bacon, they were in line with the industry standard to describe their (cheaper) product as ‘cooking bacon’. They provided examples from other supermarkets, also called ‘cooking bacons’ which they considered were comparable bacons with Aldi's Everyday Essentials Back bacon and Tesco’s Woodside Farms Cooking Bacon. Tesco believed that even though Aldi's cheaper Essentials Bacon contained a similar pork content, it was typically a lower specification bacon comprised of off-cuts of unequal size. They provided images of Aldi's cheaper Essentials Bacon, together with images of the two bacon products used in the comparison.
Clearcast did not comment on that point in relation to ad (e).
Assessment
1. Upheld
The ASA noted that Tesco believed the ads contained price comparisons that were restricted to the particular selection of goods shown and that the ads did not contain any general savings claims or messages about savings on typical regular shops at the three retailers. The ads stated "If you're looking for great value on these baskets, look no further than Tesco" (ad (a)), "To help you spot the cheapest trolley, we've circled it" (ads (b), (c) and (d)) and "It's easy to spot the Tesco trolley here, it's the one with the lowest price" (ad (e)). In each ad the Tesco basket or trolley was encircled by the ‘Exclusively at Tesco’ roundel, which we understood also appeared on the packaging of each product in the ‘Exclusively at Tesco’ range – the range having started to appear in Tesco stores in 2016. We considered that the individual own-brand products included in each basket/trolley were not readily identifiable, particularly in ads (b) to (e) given the large number of products in the trolleys, but we also noted that there were no premium branded products visible (or included in the comparison), which consumers would expect to see in a typical weekly shop at Tesco.
We considered that for each ad even those consumers who were not already familiar with Tesco’s ‘Exclusively at Tesco’ range would understand the comparison was between entry tier exclusive brands at Tesco and entry tier exclusive brands at Aldi and Lidl, as opposed to typical shops at each retailer. In that context, we considered the overall impression was that by swapping from shopping at Aldi or Lidl to buying from the ‘Exclusively at Tesco’ range, consumers could make savings and that the level of savings highlighted in the ads were representative of the level of savings which could be achieved by price conscious shoppers. Because we considered that the ads were likely to be interpreted as comparisons between entry tier exclusive brands at Aldi, Lidl and Tesco, we considered that we would need to see evidence that the selection of goods from the comparator supermarkets were fair and representative of those entry tier ranges and did not skew the comparison to give Tesco an artificial advantage.
Tesco had used data to identify key categories of staple grocery products for a group of price conscious consumers, and had then identified their 'Exclusively At Tesco' products (exclusive branded products that were only available at Tesco) that fell into the relevant categories, had a comparable product at Aldi and Lidl, were available in at least 400 of Tesco's larger stores (Extras and Superstores) and were in the top 33% of all products sold by volume at Tesco. We considered that Tesco had taken reasonable steps to identify products that would provide for a fair and representative comparison. While we were satisfied with the basis upon which the products to compare had been selected, we were concerned that the 'Exclusively At Tesco' products were not widely available throughout Tesco stores. We acknowledged, in relation to ad (a), that 80% of the basket’s products were available in at least half of Tesco’s Superstores and Extras stores and 75% were available in at least 75% of those stores.
In relation to ads (b) to (e), more than 75% of the products featured in the trolleys were available in at least half of those larger stores and more than two-thirds of the products were available in at least 75% of those stores. That meant that more than half of Tesco’s larger stores would not have been able to offer the combination of Tesco products used to calculate the savings it was claimed consumers could make by switching to Tesco. Moreover the products were not available in Tesco’s smaller stores; Tesco Express and Metro. We noted that the total number of Extras and Superstores was 883, out of a total of 2,641 Tesco stores. We did not agree with Tesco that consumers would assume Express and Metro stores were excluded from the comparison – even if they would not expect to buy as many products as shown in the trolleys when shopping in those stores, there was no reason for them to believe that no products in the range could be found in those stores, and that they could not therefore make any savings by shopping there.
We acknowledged that ads (b), (c) and (d) contained small print stating “Selected stores excluding Express”. We considered consumers would understand that to mean that not all products included in the comparison would be available in all Tesco stores, and they would not all be available in Express stores, but that otherwise they would be unaware of the extent or nature of the excluded stores. Ad (a) did not contain any such explanation and ad (e) only stated “Selected English stores”. Furthermore, three of the Tesco products used in the comparison (ham, white potatoes and apple juice) were not available in their Northern Ireland stores and whilst that was not an issue in relation to the TV ad (ad (e)) that was only broadcast in England, the press ads (ads (b) to (d)) were published throughout the UK. Consumers in Northern Ireland would not have been able to replicate the savings on the basket/trolleys of goods shown in the ads.
For the reasons given we considered that the ads made clear the comparison was between entry tier exclusive brands at Tesco and entry tier exclusive brands at Aldi and Lidl, as opposed to typical shops at each retailer, and we were satisfied that Tesco had included in the comparison products that would provide for a fair and representative comparison of the price of products in those entry tier ranges. By swapping from shopping at Aldi or Lidl to buying from the ‘Exclusively at Tesco’ range, price conscious consumers could therefore make savings at the level highlighted in the ads. However, there were limitations on the availability of products within the ‘Exclusively at Tesco’ range.
We therefore concluded that all of the ads were misleading because they did not make clear that noneof the products from the ‘Exclusively At Tesco” range were available in Tesco Express or Metro stores and that the specific combination of products upon which the savings were calculated were available in fewer than half of their larger stores.
We concluded that the press ads (a) to (d) were also misleading because they did not make clear that the specific combination of products upon which the savings were based were not available in any Tesco stores in Northern Ireland.
On that point, ads (a), (b), (c) and (d) breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising), 3.33 (Comparisons with identifiable competitors) and 3.39 (Price comparisons), and ad (e) breached BCAP Code rules 3.1 and 3.2 (Misleading advertising), 3.33 (Comparisons with identifiable competitors) and 3.39 (Price comparisons).
2. Not upheld
Tesco had checked the prices of the Aldi and Lidl products used in the comparison in at least three of their stores to ensure consistency and we acknowledged that checking prices in-store was more time consuming than checking prices on a website. We also noted that each of the ads contained information about the price check dates and that there was a maximum of four working days between the price check dates and dates of publication (or broadcast in the case of ad (e)). We understood that ads (a) to (d) were published on up to three consecutive days and that ad (e) was broadcast on three consecutive days. Tesco's agency had carried out a price re-checking exercise on the day the ads were supplied and the day of publication or broadcast, and with the exception of ad (d), prices for all 41 products remained the same across the three retailers. Although the price of strawberries at Aldi had dropped by eight pence in between the supply and publication date, we considered that did not make the ad misleading because the ad clearly stated the price check date and the price had been correct on that date.
We also considered that consumers were unlikely to be misled by the fact that in relation to ads (b) and (c) the price checking exercise had taken place over a two-day period (due to certain items not being located at three Aldi or Lidl stores on the first day of checking) as the ads made that clear. We considered that because the ads made clear the comparison date, there was only a delay of up to four working days between the price check dates and the ads being published or broadcast, and the ads were not published or broadcast for more than three consecutive dates, they were unlikely to mislead.
On that point, we investigated ads (a), (b), (c) and (d) under CAP Code rules 3.1 and 3.3 (Misleading advertising), 3.33 (Comparisons with identifiable competitors) and 3.39 (Price comparisons), and ad (e) under BCAP rules 3.1 and 3.2 (Misleading advertising), 3.33 (Comparisons with identifiable competitors) and 3.39 (Price comparisons), but did not find them in breach.
3. Not upheld
Because we considered that the ads were likely to be interpreted as comparisons between entry tier exclusive brands at Aldi, Lidl and Tesco, we considered that consumers would expect Tesco to have compared the Tesco products used as a basis for the comparison with the most similar product offered by Aldi and Lidl. Tesco had selected their Freshcure Unsmoked Back Bacon and compared it with Aldi’s Woodside Farms Unsmoked Back Bacon. We noted both bacons were produced in the EU using EU pork and contained the same pork content (87%). We also understood that Tesco and Aldi also sold cheaper bacons, namely, Tesco’s Woodside Farms Cooking Bacon and Aldi’s Everyday Essentials unsmoked back bacon. We understood those bacons were also produced in the EU using EU pork and contained the 87% pork content. We understood that Aldi objected to the Aldi bacon product Tesco had selected for the comparison because they sold that cheaper bacon product (Aldi's Everyday Essentials unsmoked back bacon) which that they believed was comparable with Tesco's product. In support of that, Aldi confirmed that their cheaper bacon, Everyday Essentials unsmoked back bacon, and the bacon Tesco had selected for the ad, Tesco’s Freshcure Unsmoked Back Bacon, were both produced in the EU using EU pork and contained the same pork content (87%). We also understood from Aldi that their cheaper bacon product (Everyday Essentials) retailed for 50p less than their more expensive product (Freshcure Back Bacon) throughout the relevant period. Tesco agreed that the two products contained a similar pork content, although they nevertheless believed the products were materially different. Tesco believed the cheaper bacon (Aldi Everyday Essential) was most similar to Tesco’s cheaper, lower tier bacon (Tesco’s Woodside Farms Cooking Bacon), namely to be diced, chopped or sliced and used in cooking recipes, rather than being cooked and eaten as whole rashers. We also understood that the cheaper Aldi bacon, the Everyday Essentials Back Bacon, had rashers more irregular in shape or size than the Tesco bacon used in the comparison (Woodside Farms Unsmoked Back Bacon). We also noted that if Aldi's cheaper bacon product had been used in the comparison, Tesco would have still had the cheapest basket/trolleys in the ads but the savings would have been reduced by 50p.
Although we acknowledged that the emphasis of the comparison in the ads was price rather than quality and they had been directed at the price conscious consumer at Aldi and Lidl, we nonetheless considered that the selection of the two bacons in the ad (Tesco’s Freshcure Unsmoked Back Bacon and Aldi’s Woodside Farms Unsmoked Back Bacon) would be in line with consumer expectation of the appropriate product comparison. Because of that we considered the ads were not misleading.
On that point, we investigated ads (a), (b), (c) and (d) under CAP Code (Edition 12) rule 3.33 (Comparisons with identifiable competitors) and ad (e) breached BCAP Code rule 3.33 (Comparisons with identifiable competitors), but did not find them in breach.Action
The ads must not appear again in their current form. We told Tesco Stores Ltd to make clear that no products from the ‘Exclusively At Tesco” range were available in Tesco Express or Metro stores, to make clear the limitations on availability at their larger stores of the specific combination of products upon which the savings were calculated, and to make clear if the specific combination of products upon which the savings were based were not available in any Tesco stores in Northern Ireland.