A complaint about the packaging of 5 x 20ml bottles of Mmwah (mixed flavour alcoholic drinks) produced by Harwood Drinks Ltd has been upheld by the Independent Complaints Panel (ICP) for particularly appealing to under-18s. The ICP did not uphold a further aspect of the complaint which suggested the packaging encouraged immoderate consumption. A copy of the full decision can be read here.

The complaint was initiated by a member of the public who, believed that the ‘cute size’ of the small bottles could lead to immoderate consumption by encouraging ‘snacking on alcohol’.  The complaint also highlighted the style of writing, flavours and size of the product packaging as appealing to a younger age group.

The ICP considered the packaging under paragraph 3.2(f) (encouraging illegal, irresponsible or immoderate consumption) and 3.2(h) (having a particular appeal to under-18s) of the Portman Group’s Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks.

In considering whether the packaging encouraged immoderate consumption, the Panel noted that the total alcohol content of all five 20ml bottles was 1.5 units. Accordingly the packaging was not considered to encourage immoderate consumption and was not upheld under Code rule 3.2(f).

The Panel then considered whether the product had a particular appeal to under-18s. The Panel discussed the style of font, product name, colour and imagery used on both the primary and secondary packaging. They considered each aspect individually and also the overall impression conveyed by the packaging. The Panel concluded that the style of font, bright colours, language and miniature size combined would have particular appeal to under-18s, particularly young girls. Accordingly, the Panel upheld the complaint under code paragraph 3.2(h).

Secretary to the Independent Complaints Panel, Henry Ashworth said:

‘‘When creating packaging and design for an alcoholic product, it is important to consider how all the elements combine so that, however inadvertently, the packaging does not end up having a particular appeal to under-18s.  The Portman Group Advisory Service is on hand to provide free and confidential advice regarding the marketing and packaging of alcoholic products.”