The Portman Group’s primary purpose as a self-regulator is to protect consumers from harm, particularly those who may be vulnerable and a fundamental part of this is protecting those who are under-18. In 2023 the Portman Group consulted to amend Code rule 3.2(h) to allow for further protection of under-18s, the rule reads:
3.2(h) A drink, it’s packaging or promotion should not have a particular appeal to under 18s.
In 2023, the Portman Group and the Independent Complaints Panel commissioned a children’s marketing agency, Kids Industries, to provide insights on marketing techniques used to appeal to children and teenagers outside of the alcohol industry, for instance, by analysing marketing used for children’s food products. This year, in the 30th year of the Code of Practice, the Portman Group and the Independent Complaints Panel asked Kids Industries to update the report to provide new insights into a constantly evolving area of marketing in order to support the application of Code rule 3.2(h).
The 2026 update to the report, which can be read in full here, featured four key areas:
Child Development
Each child develops at their own pace and the age at which children reach different developmental stages will differ from child to child. Broadly speaking, children will go through three broad shifts in their development and this can impact how they engage with marketing content. In the early years, for under sevens, it’s all about ‘me and my family’ with the focus on the key people in their life. This extends to ‘me and my peers’ around ages seven to twelve when children will become more impressionable, keen to fit in and begin to reject things that they consider babyish. In the teenage years, the focus becomes ‘me and the world’ where young people increasingly desire autonomy, social status and feel a stronger pull towards content that is culturally relevant and reflects real dynamics and aspirational lifestyles.
Trends in Marketing
Influence transforms as children age and parental impact on decision-making gradually diminishes. Children’s access to marketing is strongly influenced by their media habits with children having significant access to digital devices at a young age. In the UK 69% have access to a tablet at age three to five and by aged sixteen to seventeen 98% of young people have their own smartphone. Influencers are beginning to rival friends and family as trusted sources of information as well as having considerable influence over purchases including toys and groceries. Gaming is also an increasingly popular trend beginning at age three with interactive experience-based games graduating to a point where this becomes a significant social and cultural environment for mid to late teens. Part of the attraction in the gaming world is the ability to customise experiences and explore self-expression. By adolescence, self-identity becomes influenced by a broader mix of cultural and social factors and old-fashioned marketing stereotypes about gender don’t necessarily reflect the way that young people view themselves or want to be represented.
Appealing to Kids
Packaging specifically designed to appeal to young children often features bright colours, often with a key thick black outline, which helps children to distinguish items as they develop visual perception skills. Characters are a key feature too, those which resonate with young children are often cartoon-like and anthropomorphic, safe and funny. For older children, popular characters are less defined by how they look and more by what they symbolise, with humour and cultural references such as meme-like behaviour being represented.
Packaging which features a collectible element has long been popular with children, under sevens seek to collect by quantity whilst older children and teens are more motivated by quality, viewing their collections as a means of social connection and self-expression. Many adults also enjoy collecting, so there can be some overlap between what appeals to teenagers and adults. However, collectibles that encourage trading, sharing and being part of current trends or popular culture are more likely to appeal to teenagers. Collectibles that focus on history, tradition, expertise, or a deep interest in a subject are more likely to appeal to adults.
Flavour preferences will influence packaging appeal with under sevens enjoying classic flavours that are easy to understand like chocolate or strawberry. Eight to twelve-year-olds tend to prefer exciting tastes with unusual novelties such as pickles. In the teenage years, experimentation becomes more refined and likely expressed through premium flavours like mocha rather than purely playful elements.
Aspirational cues shape how children and young people engage with marketing too, under sevens are typically drawn to imitation and imagination. As children grow up their awareness of what is considered ‘cool’ increases and by late teens, the aspiration switches to adult brands and a mature aesthetic.
Cultural relevance is woven throughout the way that children and young people engage with marketing. For young children it is driven through familiarity, recognition and alignment with trusted characters such as Bluey. As children grow up, they become more aware of trends that travel via social media into peer environments with appeal driven by what is being talked about rather than brand messaging alone. By late teens, cultural relevance becomes more closely tied to social fluency with brands that feel current and ‘in the know’.
Considerations
The Kids Industries report culminated in a summary of factors that the Independent Complaints Panel might consider when making their evaluations of what constitutes particular appeal to under-18s with detailed indicators on; colour and clarity, characters, names and logos, collectability, licensing, flavour, aspirationalism and cultural relevance.
The report will be used to inform an updated version of particular appeal to under-18s guidance later in the year alongside new case precedents from the Independent Complaints Panel.
If you are an alcohol producer or marketing agency working with alcohol brands and you’d like free and confidential advice on whether packaging and marketing may particularly appeal to under-18s you can contact the Portman Group’s Advisory Service for a view using our or direct email address advice@portmangroup.org.uk.
Author: Laura Blackmore
Laura is responsible for providing tailored regulatory advice and training under the Portman Group’s Codes of Practice. Laura brings experience from a successful career in education, leadership and management. Laura utilises her educational background to deliver bespoke training and advice through the Portman Group’s advisory service.