A complaint against Heli Imperial Gose has been upheld by the alcohol industry’s Independent Complaints Panel (ICP), the full decision can be read here.
The complaint, made by Zenith Global Commercial Ltd, as part of the Portman Group’s independent proactive audit of the UK market[1], raised concerns under Code Rule 3.1, that the product did not communicate its alcoholic nature with absolute clarity.
The producer explained that the design was purposefully minimal and reflected a refined, artisanal product. Additionally, the term ‘Imperial Gose,’ as both the product name and a recognised beer style, appeared in the product description which communicated the product’s alcoholic nature. The producer expressed willingness to make minor adjustments in future print runs if deemed necessary by the Panel.
While not required by law or the Code, the Panel noted that the front label did not include any positive alcoholic cues such as the legal name of the drink, alcoholic drink descriptors or the alcoholic strength by volume (ABV), making it difficult to know what type of drink it was.
Considering the back label, the Panel noted there were positive alcohol cues such as the drink’s ABV, the word ‘beer’ in different languages and the pregnancy warning logo. However, the Panel noted there was no other best practice information such as unit content information, the Chief Medical Officer’s low risk drinking guidelines or responsibility messaging. The font size on the back of the can was particularly small and difficult to read and the term ‘Gose’ was not a particularly well-known beer descriptor and would not be understood as a reference to alcohol in and of itself. This combined with the fruit flavour descriptors underneath it meant that the Panel found that the drink did not communicate its alcoholic nature with absolute clarity. Accordingly, the complaint was upheld under Code rule 3.1.
Chair of the Independent Complaints Panel, Rachel Childs, said: “The Panel were mindful that this was part of a small batch of beers sent to the UK and intended for craft beer enthusiasts. However, it’s important for producers to remember that for regulatory consistency and fairness, all products are treated equally under the Code. Not all consumers will be familiar with specialist terms and producers should consider this when communicating a product’s alcoholic nature. We’re pleased to see that the producer is willing to make amends to the product and I’m confident this can be achieved while retaining its brand identity.”
[1] Part of the independent proactive audit of the Naming and Packaging of Alcoholic Drinks Code, Sixth Edition Amended