Over the years the Portman Group has worked with a huge number of alcohol producers and most of the time those interactions are positive and constructive.

Like many growing brands, Tiny Rebel’s early interactions weren’t without challenge. But through open conversation and a better understanding of the landscape, that relationship has evolved into a more collaborative and proactive one.

Understanding that compliance and regulation are there to protect consumers rather than intentionally punish producers. We sat down with Brad Cummings, Founder of Tiny Rebel, to understand where they’ve come from as a business, where they are now and where they want to be in the future.

How did you feel when you first heard from the PG?

“At the time, we were a young, fast-growing business and Cwtch was a huge brand for us, so naturally it got our attention straight away. Like most founders, your instinct is to protect what you’ve built, so we were probably a bit defensive early on. But pretty quickly we realised there was an opportunity to take a step back and better understand the landscape we were operating in.

“Since then, our approach has evolved. We now build compliance into our process from idea concept stage. It means we can still push creativity but do it in a way that works for everyone. The relationship with the Portman Group today is very different to where we started, it’s collaborative, it’s proactive, and it helps us move our brands forward with more confidence.”

Can you tell us more about your B Corp status and what that means to you?

“Becoming a B Corp was a big milestone for us, but it wasn’t something we chased overnight. It came out of a wider piece of work we did post-Covid through our ‘Fit for the Future’ strategy, where we really challenged ourselves on what kind of business we wanted to be long term.

“What we found was that a lot of the principles of CSR (Corporate Social Responsibility) – people, community and planet were already part of how we were working. B Corp gave us a clear framework to measure, improve and hold ourselves accountable – it’s not about being perfect, it’s about continuous improvement.”

What does it mean to you to be a part of the community here in Newport?

“It means everything to us. Newport is where we started, it’s where we grew up, and it’s still at the heart of everything we do.

“We’ve always believed that if you’re building a business in a community, you’ve got a responsibility to contribute to it as well. Whether that’s creating jobs, supporting local causes, or just building places where people can come together and have a great time.

“As we’ve grown, that’s only become more important. We’re really proud to represent Newport on a bigger stage, but equally proud of what we can give back locally.”

Matt Lambert, CEO of the Portman Group, adds, “Tiny Rebel is a great example of a company that faced several complaints but by working cooperatively with the Portman Group’s free Advisory Service has been able to retain their distinctive style and character whilst remaining compliant with the Codes. Our Advisory service is a free and confidential service available to the whole industry.”

When Lewes-based Beak Brewery, founded by Danny Tapper in 2019, received a complaint about ten of its product range, it was a stressful moment. Following a ruling by the Independent Complaints Panel, six of those products were found to breach Code Rule 3.2(h). which states that a drink, its packaging or promotion should not have a particular appeal to under-18s. For a small brewery, this raised fears of a costly rebrand, reputational damage and major disruption.

Instead of panicking, Danny chose to engage openly with the Portman Group’s Advisory Service in the aftermath of the upheld decisions. Working with us to address the areas of concern identified by the Panel and taking the necessary steps to ensure that the brand’s identity was retained while being mindful of the Code. What could have been a punitive process turned into a collaborative and educational experience.

Danny Tapper, Founder of Beak Brewery, “Without being overly dramatic, when we received that first letter from the Portman Group, it was one of the worst days of my life. It was just the fear of not knowing how this would affect the business we’d worked so hard to build. The complaint was against pretty much our whole product line and so it felt devastating.

“However, when we spoke to the team at the Portman Group, we realised very quickly that they were trying to help us and the whole process felt a lot more balanced and collaborative. We had imagined that in the worst case we would need to change our whole logo and every product but, in the end, it was an amend not a complete overhaul.

“In fact, it was a beneficial process for the brand, it gave us a chance to distil what our brand was about and the complaint was against the products that perhaps weren’t the most reflective of the wider Beak brand and so we had the opportunity to change those and as a result we’ve developed really strong brand guidelines.”

As part of the process, Beak Brewery also used the Portman Group’s free, confidential Advisory Service to help guide future product development and potentially avoid similar issues down the line.

The outcome was positive for Beak Brewery. The necessary changes were made without a complete rebranding, which ultimately benefited the brand. The process allowed the brewery to refine their brand guidelines and distil their brand story. The customer base reacted supportively, and the brewery’s relationship with the Portman Group was strengthened.

Laura Demorais, Director of Regulatory Affairs said, “Complaints don’t need to be a disaster, being on the receiving end of a complaint letter from the Portman Group is not necessarily an indication that a product is in breach of the Code, at that point it’s just the view of the complainant and the start of an investigative process. I’d encourage all producers in this situation to engage with the process in a transparent way and to take the opportunity to explain their brand identity and creative marketing choices in the context of the Code. The Panel will always look at the whole picture which will include the product, the complaint and the producer’s response.

“If a product is found in breach of the Code, our free, confidential Advisory Service is on hand to offer guidance and it’s great to see how this helped Beak Brewery”.

Matt Lambert, Portman Group CEO, “The experience that Beak Brewery had with the Portman Group highlights that our complaints process is fair, transparent, and supportive. As a proactive and pro-growth regulator, the Portman Group always focuses on proportionate regulation to protect consumers and support responsible businesses; and engaging with us in an open and productive way can turn challenges into opportunities. We’re grateful to Beak Brewery for working with us to fully address the issues raised in the complaint and to bring their marketing in line with the rules in the Code of Practice.”

Danny’s final advice to fellow producers: “My advice to others if they get a letter from the Portman Group is not to panic, keep the relationship and the communications positive, it’s very easy to be defensive but being open and transparent is the best way forward.”

For over 25 years, the UK alcohol industry has worked proactively to ensure that alcohol labelling is both socially responsible and informative for consumers. As a direct result of the Portman Group’s Alcohol Labelling Guidelines, consumers now have access to more product and health information than ever before on packaging.

This includes:

•  Chief Medical Officer Low Risk Drinking Guidelines
• Pregnancy warning
• Unit information
• Signposting to the independent alcohol education charity Drinkaware.

We recently published our latest review of alcohol labelling which covers 500 products from the top brands on the UK market and is the largest and most comprehensive survey of its kind.

The results encouragingly show near universal adherence to  our voluntary best practice standards covering pregnancy warnings and unit labelling, as well as a a significant increase in the number of products carrying the Chief Medical Officers’ Low Risk Drinking Guidelines since our last review in 2021.

We have already begun engaging with the small number of producers identified in this review to close the remaining gaps in the market and to ensure further take up of the guidelines. It’s reassuring that many producers have  already confirmed that labelling changes are underway.

We are also clear that this information should not be hidden away on labels, so it is welcome to see the vast majority of producers enhancing the visibility of information, such as through separate boxes on labels. We will be further clarifying our advice to producers that this is our recommended method for presenting Portman Group best practice.

It is particularly positive to see so many brands also going above and beyond to showcase additional elements such as calorie information, drink driving warnings and age restriction – further demonstrating a serious and widespread commitment to responsible marketing and tackling harm.

It’s important to note that all of this has been achieved without any need for government legislation and at no cost to the UK taxpayer. It highlights the ongoing success of voluntary partnerships within the industry to achieve our shared objective of informing consumers and preventing alcohol misuse.

We intend to keep a close eye on the market and continue to work in partnership across the sector and government, to ensure that health information is present on products and is accessible and easy-to-read for consumers.

Another British summertime is upon us which means we can look forward to a season filled with sports, festivals and if we’re lucky, maybe even some sunshine. It’s an ideal time for marketers to target consumers with engaging brand activations, but it is vital that care is taken to ensure these activities are conducted responsibly. Avoid a blunder with our hat trick of top tips.

Competitions for the off-trade

Many alcohol brands choose to engage with their customers by running promotions where the public have the chance to win tickets to an activity – like a sporting event, festival or even a holiday. While off-trade drinks are designed to be taken home to consume, care must still be taken that the mechanism for participating doesn’t inadvertently encourage immoderate consumption.

For example, if a brand is running a promotion or competition then a consumer may purchase several bottles or cans of a drink in order to maximise their chance of winning. Now, providing the drink has a reasonable shelf life, this would not necessarily be an issue under the Code because the consumer can then choose to drink the products at their leisure over a longer period of time. However, if the promotion or competition requires a drink to be opened in order to enter the competition (for example to get a unique entry number on the lid of the drink), and there was no limit to the amount of times a consumer could enter the competition, then a person could open and therefore potentially consume multiple drinks in order to maximize their chance of winning.

The competition would then become the catalyst for them drinking more alcohol, so the Advisory Service would suggest that the entry mechanic should not require the drink to be opened or that a limit is placed on the amount of times someone could enter per week.

On-trade promotions

Unlike the off-trade, promotions in the on-trade usually involve a consumer drinking at the point of purchase. For that reason, producers need to take extra care that they are not encouraging a person to drink immoderately or irresponsibly. The Advisory Service recommends that a person should not be encouraged to drink more than four units of alcohol in one sitting and should not drink more than 14 units of alcohol in a week in line with the Chief Medical Officer’s’ low risk drinking guidelines.

It can be tricky to run a promotion or competition in the on-trade, but it is the view of the Advisory Service that this sort of marketing can still be done in a socially responsible manner. We would recommend that if a producer is running a competition to win a prize, where purchase of a drink is required for entry, then entries should be capped at a limited number per consumer.

For example, if entry to a competition required the purchase of a drink which contained 1.5 units of alcohol, we’d suggest capping the number of times a consumer could enter at two drinks (three units of alcohol). This would help to avoid indirectly encouraging immoderate consumption.

Experiential Marketing

Lots of people will be out and about over the summer and for a lot of producers, promotional events or experiential marketing will be on the cards. However, one of the biggest concerns we see in the Advisory Service is this sort of marketing potentially having a particular appeal to under-18s.

While a lot of summer events are family friendly, even events which are restricted to over-18s should ensure that marketing does not have a particular appeal to under-18s. The test of this Code rule is not one of quantity but the way in which something appeals. It is important to remember that the Code applies to experiential marketing and so including items or themes as part of the experience which could have a particular appeal to under-18s is unlikely to be acceptable.

It is hard to say if any one element is likely to cause an experience to have a particular appeal to under-18s, but producers can reduce this risk by including elements which are likely to have a more adult appeal. Games such as tag, swing ball, water fights or slip and slides are all more likely to resonate with children than they are adults so we would suggest avoiding them. Instead, activities which are more adult focused like darts, badminton or tennis are likely to be okay as these are likely to have broad appeal to all age groups.

Similarly, incorporating items or themes which do not have a particular appeal to under-18s is also really important. For instance, balloon animals, teddies or clowns are all likely to have a particular appeal to children and should be avoided.

There are a lot of elements to consider but whatever your marketing plans are for the summer, the Advisory Service is here to help. Our full guidance can be found online here or you can contact us for a free, confidential and non-binding view at advice@portmangroup.org.uk.

The Portman Group’s latest survey, conducted by YouGov in 2023, marks a pivotal shift towards low and no alcohol consumption across the UK. As the market for these alternatives expands, understanding consumer motivations, behaviours, and preferences becomes crucial for stakeholders across the spectrum.

Key Findings

• Widespread adoption: 64% of UK adults have now tried low or no alcohol products, up from 59% in our 2020 survey, indicating a broadening consumer base. This includes 75% of alcohol drinkers, compared to only 33% of non-drinkers.

• Increased consumption: There’s a notable increase in semi-regular consumption, up to 35% of UK drinkers from 25% in 2020, highlighting growing consumer acceptance and regular inclusion in lifestyle choices.

Aiding moderation: 23% of current alcohol drinkers in the UK report reducing their alcohol consumption due to low and no alcohol alternatives.

Important tools for harm reduction

For the sixth year in a row, the most cited reasons for why customers choose low and no alcohol are being able to drive home and not drinking excessively at social events – highlighting how these products are important tools to tackle harms such as drink driving and binge drinking. Collectively minimising health concerns or current medical reasons was also cited by a large proportion of respondents, highlighting a move towards a more health-conscious society. The desire for social inclusion without the effects of alcohol, coupled with an increasing focus on responsible drinking and moderation are also fuelling the drive towards products which facilitate low-alcohol or alcohol-free drinking.

Generation Sober-Curious

Young adults lead the charge in embracing low and no alcohol options, an inclination that suggests a generational shift in attitudes towards alcohol – a phenomenon that has been dubbed as ‘Generation sober-curious’. Almost half of respondents ages 18-24 said they drank semi-regularly (44%), up 91% from 2020 (23%). However, our results also show a significant increase in regular or occasional use across all age groups since 2020.

Brand-share as the key entry point

As the market matures, the diversity and availability of low and no alcohol alternative products are expected to grow, further embedding these choices into mainstream consumption habits. Most notably, brand-shared low and no alcohol versions of popular alcoholic beverages serve as a significant entry point, underscoring the importance of brand familiarity in consumer choices, and signifying how the evolution of consumer preferences is being both reflected by the industry.

When and where the public drink alcohol alternatives

Pubs and bars remain the most popular locale for low and no drinking habits, with over a third of respondents choosing to opt for alcohol alternatives when visiting these establishments.

Alcohol alternatives also appear to be popular within social contexts, with 31% of alcohol alternative drinkers saying they drink them at home socially with friends or family, followed by 23% drinking them out at a friend or family member’s house.

Low and no drinkers are also most likely to favour these products when alternating with alcoholic drinks. The second most cited response was on ‘drink free’ days during the week – highlighting that these products are not just for periods of abstinence such as Dry January but all year round.

Facilitating a move to mindful consumption?

The findings here suggest that low and no alcohol alternatives are facilitating a distinct movement towards mindful consumption within the UK’s drinking culture.

Our survey illustrates that increasingly health-conscious consumers are saying that these products have helped them cut back their alcohol consumption as well as avoid harms such as binge drinking and drink driving when out – feeding into the Government and industry’s shared goal to promote a moderate and responsible relationship with alcohol across the UK.

Our research also suggests that low and no drinkers continue to favour drinking these products socially and in hospitality settings such as pubs and bars emphasising the importance of increasing the availability of low and no options wherever an alcoholic product appears on sale.

We welcome producers, retailers, pubs and the wider hospitality industry continuing to work together to increase choice, availability and visibility of alternatives, as well as initiatives such as instore tastings to help consumers overcome outdated taste prejudices.

Tis the season of festivity, and most people are looking forward to enjoying time with family and friends getting in the holiday spirit. The winter season can be a great way to engage with consumers and has become a focal point in the marketing calendar. It is important to remember though, that even during the holiday season, alcohol marketing needs to be compliant with our Codes.

The Advisory Service often sees winter holiday specific marketing and promotions which fall on the wrong side of the line – so we’ve compiled a list of the main issues that tend to arise.

Particular Appeal to under-18s

It is the view of the Advisory Service that Christmas and other winter holiday celebrations have a ubiquitous appeal to all ages. However, some familiar characters are likely to resonate with children, in a way they won’t with adults, so including them in alcohol marketing can mean that it crosses the line of acceptability. Festive elements such as Christmas trees, baubles, presents and food all tend to be acceptable (depending on depiction of course) because these are elements of the season which resonate with consumers of all ages.

However, character such as Santa Claus or Rudolph for example, are riskier inclusions in marketing because both characters feature prominently in media targeted at children. Films, stories and Christmas carols all consumed by children tend to have these characters as a main focus, and for many children a visit from Santa and his sleigh are a highlight of the season. While adults may enjoy this media, the test of Code rule 3.2(h) is not one of quantity but rather whether an element is likely to have a particular appeal to children. It is the view of the Advisory Service therefore that such characters are likely to have a particular appeal to under-18s and should be avoided.

It is not just inclusion of characters which can cause issues, as the overall impression conveyed by marketing will ultimately determine compliance. Artwork, colours, and flavours can all inadvertently cause a drink to have a particular appeal to under-18s and that is something that should be considered when creating a festive drink, particularly for the on-trade. Our guidance has recently been updated to help the industry comply with Code rule 3.2(h) and can be read here.

Irresponsible or immoderate consumption

The Code does not only apply to the naming and packaging of alcohol drinks, but to promotional materials and activities as well – in both the off-trade and the on-trade. While many consumers will be thankful for a bargain this year, it’s important to consider whether a promotional offer could encourage immoderate or irresponsible consumption. For example, discounted time-sensitive promotions are unlikely to be acceptable under the Code. This is because the nature of the promotion indirectly encourages immoderate consumption as a consumer may buy, and therefore consume, more than they otherwise would have done to maximise savings.

Similarly, encouraging consumers to indulge in excess drinking because it is the holiday season is unlikely to be okay, even if the promotion is intended to be humorous or tongue in cheek. Phrases like ‘get drinking – its Christmas’ or ‘tis the season to get wasted’ are both unlikely to be okay under the Code. Producers should be mindful that marketing should not encourage consumers to drink immoderately or irresponsibly.

Social Success and change in mood or behaviour

We see a lot of alcohol marketing over the holiday period which can highlight a drink’s premium qualities thereby making it an ideal choice for a special occasion. While there is nothing wrong with suggesting that a premium drink is ideal for a special occasion, or presenting alcohol as a legitimate accompaniment to socialising, care needs to be taken that it does not suggest it is integral to social success.

Phrases such as ‘get the party started with X’ or ‘Take your holiday season to the next level with X’ are unlikely to be acceptable because of the suggestion that the alcohol is elevating a social occasion or making it more fun than it would have been otherwise.

Equally, suggestions that alcohol can relax a consumer, help them to forget the stress that the holiday season can bring or generally put them in a festive mood are all likely to be unacceptable. Again, this is because there is a suggestion that a consumer’s mood or behaviour has changed on the basis of consuming alcohol.

We know that there is a lot to think about during the holiday season, so the Advisory Service as always is on hand to help. Contact us for a free, quick, confidential view here.

The Advisory Service recently attended the 2023 Brewers Congress where we were able to meet and chat with various producers and distributors. A common question that came up was in regard to the on-trade and how exactly our Code applies.

Pump Clips

While the majority of the advice requests we receive are in relation to packaging, its worth remembering that pump clips are covered by our Code. Pump clips can be a great way to stand out in the on-trade, and in recent years novelty, bright and colourful designs have become more common place. Some pump clips can now incorporate specific shape designs which can also place greater emphasis on artwork or a product’s brand heritage. It’s worth bearing in mind that the Code will apply in full and while the purchase of alcohol is age-restricted in this environment, entry to the venue is not always age-restricted and pump clips can still be seen by all age groups. The Code is designed to protect those aged under-18 and regardless of whether they can purchase the alcohol, the pump clip design still cannot have a particular appeal to under-18s.  Similarly, the sixth edition of the Code introduced Code rule 3.3 which prevents alcohol marketing from causing serious or widespread offence. It’s therefore important that pump clips do not include anything which could be deemed derogatory, demeaning or discriminatory. For example, gratuitous nudity or objectification of a person is unlikely to be acceptable, even if this is intended to be ‘humorous’ or a reference to brand heritage.

On-Trade Promotion

We often get asked about navigating promotions run for the on-trade, from loyalty cards, to buy one get one free offers.  If such marketing is led by, or run in collaboration with, an alcohol producer, then it’s likely our Code will apply. One of the most common issues we see with on-trade promotions in the Advisory Service fall under Code rule 3.2(f) (encouraging immoderate/irresponsible/illegal consumption). For instance, happy hours can encourage consumers to drink excessively in a short period of time to make the most of a limited time discount and are likely to be problematic under this rule. Any promotion which encourages consumers to drink more than they otherwise would have done in an irresponsible way or encourages them to drink to excess are likely to breach the Code.

Co-promotional marketing

While exclusively retailer-led activity is not covered by our Code of Practice, if a producer is involved in a co-promotional marketing activity, then this will be captured in our remit. For instance, co-promotional point of sale posters, promotions or drink offers, competitions and even menus can be captured by the Code.

It’s worth remembering that co-promotional activity refers to marketing activity between a producer and retailer, which has taken place with the approval or support of a producer, even if that activity is predominantly retailer-led. As an example, if you are providing branded empty belly posters where a retailer can fill in the middle of the poster, we would recommend providing a set of guidelines as to what material would and would not be acceptable in terms of alcohol marketing.

There are a lot of different things to think about in the on-trade, so why not get some clarity by reaching out to the Advisory Service for free, confidential, and non-binding advice.

Year on year, we are drinking less and moderating our alcohol intake. According to Government tracked date, 79% of UK adults either do not drink or stick within the Chief Medical Officer lower risk guidelines – 79% in England, 77% in Scotland, 83% in Wales and 80% in Northern Ireland¹. Since 2004, annual alcohol consumption in the UK has fallen by 15%, declining from 11.55 litres of pure alcohol in 2004 to 9.8 litres in 2019². The effect can be seen through the generations with younger generations drinking less and more moderately – learn more here.

These trends are the result of lifestyle and behavioural changes in UK society as many of us seek to make healthier choices. This has been supported by industry actions, which have had a significant part to play in helping educate consumers, ensuring information is displayed on labelling, and promoting responsible alcohol practices through industry campaigns and in partnership with Government. In this blog we take a deep dive into some of these industry-funded initiatives that are helping drive this moderate drinking trend.

Drinkaware

Founded in 2006, Drinkaware is an independent alcohol education charity. It’s aim is to provide impartial, evidence-based information, advice and practical resources; raising awareness of alcohol and its harms and working collaboratively with partners. It is funded by unrestricted voluntary donations from more than 120 organisations, including UK alcohol producers, retailers, supermarkets, venues, restaurant groups and sports associations.

One way in which Drinkaware helps consumers cut down is through its free MyDrinkaware App. It helps track a person’s alcohol consumption, calculate units and calories and set goals to help them moderate their drinking. By tracking units, calories and sleep quality, side-by-side, MyDrinkaware can guide the user towards a healthier lifestyle that works for them. To learn more and to download the app, click here.

Following an incredibly successful joint campaign with Public Health England in 2018 to incorporate ‘drink-free days’ into our week, many of us still follow this plan to help us moderate or cut down our consumption of alcohol.

And finally, another useful tool Drinkaware provides is its Unit and Calorie Calculator, which can calculate unit and calories for one or more drinks and across the week. Learn more and try it out here.

These are just a few examples of the abundance of support Drinkaware provides in helping to educate consumers and encourage moderate drinking. More information of the rest of its work and campaigns can be found on its website here.

Alcohol labelling

Since the Public Health Responsibility Deal, the Portman Group has been responsible for the for the best practice guidance for communicating alcohol and health-related information. The Alcohol Labelling Guidelines set the minimum recommended best practice elements for product labelling, which includes the 2016 CMO Low Risk Drinking Guidelines, provision of unit information, a pregnancy message or symbol, and a direction to Drinkaware so consumers can learn more about the facts about alcohol and make more informed choices.

The Guidance builds on over a decade of success in improving access to information, resulting in more than 99% of products containing a pregnancy warning message or logo, 94% demonstrating unit content, 93% displaying a Drinkaware or responsibility message, and almost four in five (79%) carrying the latest UK Chief Medical Officer low risk drinking guidelines³. These figures are expected to be improved upon and no doubt we will see this in our next Market Review in 2024.

More information on the updated guidance can be found here.

SWA’s Made to be Measured campaign

Launched in March 2023 by the Scotch Whisky Association (SWA), Made to be Measured aims to raise awareness of the alcohol content of drinks and the recommended weekly guidelines (units). As Scotland’s national drink, carefully crafted and only released after many years of maturation in warehouses across the country, Scotch Whisky is there to be savoured and enjoyed responsibly. The campaign, aimed at adults in Scotland, will run across a range of digital and consumer platforms, all using creative advertising to help convey and clarify the units within Scotch Whisky and other alcoholic drinks.

In September 2023, the Scottish Government pledged its support for the campaign ahead of the festive period, as the First Minister met the SWA’s governing Council to discuss how the industry and government can work in partnership.

To learn more about the campaign, visit the SWA’s website here.

Low and no alcohol alternatives

Availability and consumption of low and no alcohol alternatives has grown significantly in recent years. For five years now, the Portman Group has run a survey with YouGov to look at UK public attitudes to low and no alcohol alternatives.

In our most recent survey in January 2023, we found 29% of UK drinkers now ‘semiregularly’* consume low and no alcohol products (29%), with 21% saying that their weekly consumption had decreased since first trying a low and no alcohol alternative**. For the fifth year in a row, the most cited reasons (57% of respondents) for why consumers choose low and no alcohol are to drive home and not drink excessively at social events.

Our research continues to tell a positive story of how low and no products have become part of UK consumer buying habits. Five years of polling have given us a substantial data set to reflect and build conclusions. It shows how these products are by and large bought by current alcohol drinkers across all age groups, as a key tool for moderation and responsible drinking.

To learn more about our survey and read about the findings from our latest edition, visit our website here.

The Future

It is important that we keep driving forward approaches which help people to moderate their drinking. In working with Governments and partners, we can anticipate that the trend to moderate will continue as more people join an ever more responsible drinking environment.

1. Health Survey for England, December 2022 / Scottish Health Survey, November 2022/ National Survey for Wales, July 2023 / Health Survey Northern Ireland, December 2020
2. WHO, May 2021
3. Portman Group, Market Review, September 2021– research of June/July 2021)

* Incorporating those who responded drinking low and no alcohol either ‘often’ or ‘sometimes’).

** Removing those who did not drink alcohol before first trying a low/no alternative.

The Portman Group has created a ‘quick read’ document which highlights the main elements that producers should be mindful of to ensure that alcohol marketing does not encourage immoderate, irresponsible, or illegal consumption. Read on for the key points that you should bear in mind to stay compliant with Code rule 3.2(f).

Immoderate consumption

The quick read looks at how on-trade promotions, words, phrases, imagery and other factors could fall foul of the Code. For example, using phrases like ‘wasted’ or ‘smashed’ are likely to be an issue because of the connotation they have with intoxication. ‘Having a session’ is also likely to be an issue because it infers drinking for a long period of time is acceptable. However, it is the view of the Advisory Service that ‘session’ when used as ‘session IPA’ for example, may be acceptable where it is clearly communicating a lower strength IPA. If ‘session IPA’ were used alongside other elements though, which inferred intoxication, it may be found to be a contributing factor in a breach of the Code. Finally, using an image or depicting drunkenness in your marketing is likely to be found in breach of this Code rule because it could encourage consumers to drink to the point of being drunk.

In addition to this, the quick read also explains the points to be mindful of when using packaging which is typically single-serve and non-resealable and contains four units or more.

Irresponsible Consumption

Alcohol marketing can be found to be in breach of Code rule 3.2(f) if it encourages irresponsible consumption and it’s worth bearing in mind that it does not need to simultaneously encourage immoderate consumption to be problematic.

For example, serving ‘shared’ drinks in large containers, such as a fishbowl, without providing a way for the consumer to decant the drink (and therefore gauge how much alcohol they are consuming) is likely to be considered as encouraging irresponsible consumption. Additionally, encouraging consumers to drink at a time which would be socially irresponsible, before an exam for ‘luck’ for example, or before going to work, are likely to be seen as encouraging irresponsible consumption.

It is not just direct encouragement to drink alcohol irresponsibly that can breach this Code rule, as indirect claims will also be captured. For example, if a drink purports to have a therapeutic benefit, then a consumer may be encouraged to drink based on the implied effect gained from the drink, rather than basing consumption on alcohol content. This would indirectly encourage irresponsible consumption and is therefore unacceptable.

Illegal consumption

There are only a few scenarios when consuming alcohol is actually illegal. For example, driving whilst over the alcohol limit; or for an unaccompanied under-18 to drink alcohol in a licensed premise. There may also be scenarios where there are local policies prohibiting consumption or carrying open alcohol containers in local areas or transport networks. Any encouragement of such behaviour should be avoided.

We recommend checking out our new quick read for a brief overview and referring to our full guidance document for the full detail. As always, the Advisory Service is on hand to provide a quick, free, and confidential view under our Codes, and you can reach them here or send an email to advice@portmangroup.org.uk.

Binge drinking and alcohol related crime across the UK has fallen significantly in recent years. Alcohol-related violent crime has fallen by almost half (47%) in Britain since 2009/10 (ONS, September 2020 / Scottish Government, March 2021). Whilst binge drinking* among UK drinkers has fallen by over a quarter (29%) in the last decade (Health Survey for England, December 2022 / Scottish Health Survey, January 2021; *drinking over 6-8 units in a single session).

This is partly due to a growing number of moderate drinkers and consumers wishing to pursue healthier lifestyles, which is  to be celebrated. However, the industry has also played a key role, by funding and leading a series of initiatives devoted to helping ensure our night-time spaces are safer and that alcohol is enjoyed responsibly. In this blog, we take a deep dive look at some of these initiatives.

Best Bar None

First piloted in Manchester in 2003, Best Bar None is an awards and accreditation scheme supported by the Home Office and drinks industry. It was developed to recognise and reward responsible premises which demonstrate progress in the four areas covered the UK Licensing Act:

• The prevention of crime and disorder.
• Public safety.
• Prevention of public nuisance.
• And protection of children from harm.

The overall percentage of participating venues entering the scheme and receiving full accreditation is over 80%. Schemes have been set up in towns and cities across the UK and has proven its success by:

• Reducing the risk of alcohol-related harm, disorder and crime.
• Established benchmark of good practice.
• Recognising and rewarding responsible operators.
• Creating consistency of standards throughout the UK.
• Creating a positive vehicle for all sectors of the night-time economy to work together in partnership.

A recent survey by Stonegate Pub Company (85% of their around 5,000 pubs are involved with a regional BBN scheme or other community safety programme) found that:

The programme continues to innovate and in 2019 BBN launched a pilot with Manchester Airport Group (MAG), encompassing Manchester, London Stansted and East Midlands airports. MAG Group were looking to further improve standards of airside alcohol retailing  across the UK’s biggest airport group and improve the travel experience for its 60 million passengers.

Learn more about the work Best Bar None does here. For Best Bar None Scotland, click here.

Pubwatch

National Pubwatch (NPW) is an entirely voluntary organisation set up with the aim to achieve a safe, secure and responsibly led social drinking environment in all licensed premises throughout the UK, helping to reduce alcohol-related crime.

The scheme was evaluated in 2012 by Leeds Metropolitan University. They conducted  a UK wide study of Pubwatch to see what members and other stakeholders thought about the scheme’s effectiveness. The evaluation showed that the vast majority of responding local authorities (76%), police (70%) and licensees (70%) believed that Pubwatch contributed to a safer drinking environment in the areas in which they operate. Councils (71%) and police (67%) also pointed to a decrease in anti-social behaviour in the wider localities as a result of effective schemes and closer partnership working.

To learn more about the valuable work National Pubwatch does, visit its website here.

Purple Flag

Purple Flag is a UK, Ireland and now international accreditation process run by the Association of Town and City Management (ATCM) to raise standards and broaden the appeal of town and city centres in the evening and night-time. Similar to the Blue Flag scheme for beaches, areas awarded with a Purple Flag are recognised for providing a diverse and vibrant mix of dining, entertainment and culture while promoting the safety and well-being of visitors and local residents. This means not just for pubs and clubs but for a wide range of activities including arts and culture, leisure, eating out and events.

The accreditation process takes towns and cities through a comprehensive set of standards, management processes and good practice examples all designed to help transform the evening and night-time economy and provide a research, training and development programme. Those already accredited have reported positive feedback from local businesses.

Learn more about Purple Flag and the ATCM on its website here.

Local Alcohol Partnerships Group

Even though Best Bar None, Pubwatch and Purple Flag are separate organisations, they are all devoted to a common purpose – reducing alcohol harm and making our communities safer. Collaboration is key to helping achieve this. This is why all three are members of the Local Alcohol Partnerships Group (LAPG), alongside other representatives from local partnership schemes, industry partners, regulators, government departments and alcohol advisory/concern groups. Established in 2012 by the Portman Group who ran the scheme for six years before handing over to the Institute of Licensing, LAPG objectives include:

• Providing the basis for closer collaboration between the industry local partnership schemes, trade bodies and other stakeholders.
• Providing a source of practical and operational expertise in licensed economy issues for operators and regulators.
• Implementing and supporting schemes as appropriate.
• Facilitating the sharing of good practice through attendance at events, meetings and roundtable discussions as appropriate.
• And sharing good practice on evaluation and gather data that demonstrates the benefit of the schemes at local level.

Through the sharing of best practice, they have been able to enhance each scheme and aim to have a multiplier effect where they work in partnership in core areas of the country. It is through LAPG that the Portman Group worked with London City Hall to sign the Women’s Night Safety Charter, a voluntary initiative to improve the safety for all women in the night-time economy, that feeds into LAPG schemes.

You can learn more about LAPG here.

The Future

Since the pandemic, these schemes have had to look at how they support the night-time economy to bring people back to a safe entertainment environment. Working closely with the police they have been able to help reestablish safe practices and adapt to a new environment. Whether this is supporting the Stamping Out Spiking campaign or expanding the use of Ask for Angela (a scheme to help women who are concerned about their safety), collateral, we can anticipate that the multitude of on the ground bodies looking to reduce harms in the night-time economy will continue to adapt as society changes.