In 2019 the Portman Group published the sixth edition of the industry’s ‘Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks’. In order to ensure that the industry understands and is living up to the rules we commissioned the independent auditor Zenith Global to gauge compliance across the sector.
The audit showed that 95% of products were adhering to the code, and all of those that raised concerns have now been addressed.

Background to the audit

The sixth edition to the Code saw significant changes to the rules. It was updated in response to changes in society and expectations of the industry. The update introduced a new principle to protect the vulnerable and a rule on serious or widespread offence. Other new requirements are to avoid encouraging illegal behaviour or implying that alcohol can change mood or behaviour. The new Code was supported with guidance, including updated guidance on immoderate consumption.

The independent auditors reviewed the industry to flag products which were potentially problematic under the new Code.

Audit Results

Zenith Global took a random sample of 500 products from across the country and from a variety of alcohol categories. The audit found the industry was 95% compliant. This is not only a great sign of industry wide compliance and adherence to the Code, but it is a reassuring increase from our 2012 audit which found 92% compliance.

29 products were flagged as potentially problematic by the independent auditors. We contacted the producers and gave them the option of working with us to resolve the issue or remove the product from sale. Alternatively, they could challenge the auditors’ findings and go before the Independent Complaints Panel (ICP).

Of the 29 products flagged during the audit:

• 6 related to food labelling law and were referred to Trading Standards;
• 14 were altered or withdrawn before the new Code came into force;
• 9 went forward to the ICP for review.
6 of the products which went to the ICP were found to breach the Code.

One of the key decisions made by the ICP was about Lucky Buddha, a lager flagged under the new ‘serious and widespread offence’ rule. There was a concern that the bottle would cause serious or widespread offence on religious grounds. After carefully considering the producer’s arguments, the ICP did not uphold the complaint and to this day the ICP have yet to uphold complaints on the basis of offence. An encouraging sign of the responsible way most producers choose to market their products, and the positive work of the Advisory Service who help to prevent more questionable packaging from reaching the market by working with producers directly.

Other significant decisions were against Karpackie 9% and Oranjeboom 8.5%, both strong lagers which progressed to the ICP. These were important for us because the ICP referred to the new principle that alcohol must not appeal particularly to the vulnerable. Both products were found to give undue emphasis to their higher than average strength, in a way that was likely to appeal particularly to those who were vulnerable because of heavy drinking. This demonstrates the positive impact we can have in shaping the industry approach.

All of the decisions by the ICP are published so that producers can understand the rationale of the Panel and apply this when crafting of their packaging. If you would like to find out more about the ICP’s decisions, they are all available here.


The audit has shown not only the positive impact of the Portman Group and ICP, but the strength of industry self-regulation more widely and the commitment shown by UK producers to play by the rules. We are hugely encouraged by the results.

The audit also demonstrates the value of our Advisory Service, who offer advice and training completely free of charge to any producer. The free, fast and confidential advice has ensured that many potentially problematic products have been changed before they reached the market. The service has helped producers to design better packaging and deepen their understanding the Code. We will continue to help the industry to market responsibly, so if you are a producer who would like advice, or perhaps a more detailed training session on how the Code is applied, then please contact us.

This audit has shown that our rules are widely accepted, and we are pleased the industry has continued to hold itself to a high standard through effective self-regulation. It is great news that there has been a noticeable increase in compliance since the last audit. We will keep working with producers to ensure this continues and evolve our approach to meet the changes of the future.

Read more about the audit here.