Producer:
Sip N Drip
Complainant:
Zenith Global Commercial Ltd (as part of the independent proactive audit of the Naming and Packaging of Alcoholic Drinks Code, Sixth Edition Amended)
Complaint:
“The illustration on the front of the pack features cartoon bubbles, pinky clouds and bubble text “SIP N DRIP” logo reminiscent of the Goosebumps children’s books/TV show series which would provide a particular appeal to under-18s. The plastic bottle in 250ml is synonymous with fruit juices and smoothies, and so in a consumer fridge at home, this would be too easily confused by a child as a product intended for their consumption.”
Decision:
Under Code paragraph 3.2(h). A drink, its packaging and any promotional material or activity should not in any direct or indirect way have a particular appeal to under-18s. A producer must not allow the placement of brand names, logos or trademarks on merchandise which has a particular appeal to under-18s or is intended for use primarily by under-18s
UPHELD
Under Code paragraph 3.1. The alcoholic nature of a drink should be communicated on its packaging with absolute clarity
UPHELD
The company’s submission
The company welcomed the opportunity to respond to the complaint and explained that when designing the product, it aimed to ensure that the packaging and marketing of the drink was responsible, transparent and directed only at adult consumers. The company explained that it had taken action to address the concerns raised while maintaining the integrity of the brand.
The company explained that to ensure compliance it had made significant changes to the packaging which included:
• The flavour name amended to ‘Rumburst’;
• ‘Ready to drink cocktail’ was now displayed prominently on the front label as was the drink’s alcoholic strength by volume (ABV);
• The drink would only be stocked with alcoholic drinks in a retail setting with 18+ symbols on the label.
The company stated that prior to launch, it had conducted product testing and market research to gather consumer input. The company stated that it had never received a complaint regarding the drink’s logo from a consumer and that consumers had consistently recognised it as being an alcoholic drink. The company explained that consumer feedback had shown that clear alcoholic cues such as the drink’s ABV and a responsible drinking message were important and the company now included these elements across its entire range.
The company explained that the Sip N Drip logo had been in use for several years and was representative of the brand’s identity. The company stated that it was designed to reflect a fun, stylish lifestyle and was not targeted at under-18s. The company explained that the stylised text and dripping lips symbolised enjoyment and were an integral part of the brand. The company did not believe these elements would have particular appeal to under-18s when considered alongside a responsible drinking message and clear alcoholic cues.
The company explained that it had made substantial changes to address the concerns raised and the only element it had retained was the brand logo.
Company response to the provisional decision:
The company acknowledged that the Panel’s provisional decision was against the original packaging, rather than the revised version of the label it had submitted as part of its original response. However, the company stated that the revisions it had made to the packaging reflected its commitment to ensure the brand was directed solely at an adult market while retaining its brand identity.
The company stated that the intended meaning behind the logo and branding had been misunderstood. The company explained that the logo imagery symbolised enjoyment of a flavourful cocktail with the idea that a drink may drip from a person’s lip when savoured. The design was rooted in adult cocktail culture not youth trends and ‘drip’ was a reference to the liquid nature of the drink, rather than a connection to a slang phrase. The colour palette and bold style were consistent with other brands available on the market and used expressive, playful visual imagery to convey energy, nightlife and sociability. The company stated that the logo had been used for many years and had never been associated with, or targeted toward, under-18s.
The company further explained that it had a responsible approach to marketing across social media platforms and within retail premises. This included the requirement that retailer partners adopted a ‘Challenge 25’ policy to avoid underage sales. The company stated that while it respected the complaints process and Panel decision, it
requested that the Panel reconsider the meaning and intent behind the drink’s logo.
The Panel’s assessment
As part of the Panel’s consideration of the company’s first response to the complaint it clarified that its consideration would be solely focused on the packaging that had been subject to complaint, rather than the amended design that the company had described in its response as this was out of scope for the Panel.
3.2(h)
The Panel considered the overall impression conveyed by the product packaging and whether this would have a particular appeal to under-18s. The Panel discussed the company’s first response and noted that its intention was to reflect a fun lifestyle while targeting an adult market. The Panel considered the product and noted that the drink was packaged in a plastic bottle with a light blue screw lid reminiscent of a popular soft drink. The front label incorporated the prominent company logo ‘Sip n Drip’ in dripping, bubble font which was created from the effect of a jar pouring liquid. Behind the logo was a sky filled with pink bubblegum bubbles and below this, a field covered in different fruits including watermelon, blueberries, strawberries, pomegranate, cherries and dragon fruit. The Panel noted that in the centre of the front label was a mouth with full, red lips with further drips coming from the bottom lip and a bubble being blown. In the bottom right corner, the flavour ‘Bubble Yum’ and the product’s ABV appeared in smaller white text and the word ‘cocktails’ appeared on the opposite side in the same font.
The Panel discussed the flavour ‘Bubble Yum’ in the context of a similar case precedent, AU Vodka Bubblegum (2023) and noted that while bubblegum was popular with under-18s as a confectionary item, it was also a well-known product flavour used on products for all ages and did not have a particular appeal to under-18s in isolation. However, in this case, the Panel considered that the fruit imagery on the front of the label was the overwhelming message conveyed by the product and that this combined with the play on words of ‘Bubble Yum’ was likely to appeal to children with the emphasis on sweeter ‘yum’ flavours.
The Panel considered the Sip n Drip logo which was presented in brightly coloured bubble-like font with a drip effect on each letter outlined with a black and white keyline which provided a higher level of colour contrast. The Panel discussed the plain jar above the writing which was designed to appear as though liquid was spilling out of it to create the name Sip n Drip. The Panel considered that the drip effect presentation of the logo appeared horror-like in a cartoon style and the contrasting outlines on the brightly coloured font with cartoon pink clouds and bubble imagery in the background was likely to particularly appeal to under-18s. The Panel discussed the name Sip n Drip and also noted that the term ‘drip’ was used by a younger generation to mean stylish. Whilst the term was not problematic in and of itself, the Panel considered that in combination with the rest of the packaging artwork the name would also increase the level of appeal to an under-18 demographic.
The Panel discussed the presentation and prominence of the brightly coloured lips on the front of the label and noted that the lips were also presented in a thick black keyline with the red lips and white teeth providing a high contrast effect. The Panel considered the drips from the red of the lips and the pink bubble being blown from the mouth which reinforced the product’s focus on bubblegum.
The Panel considered research from the children’s marketing agency Kids Industries1 and discussed the section which highlighted that playful names and logos presented in bright colours, with chunky cartoon-like font, high contrasting colours and thick black outlines were features that were likely to be used in marketing which would appeal to under-18s. The Panel noted that all of these elements were incorporated on Bubble Yum and considered that the overall impression did have a particular appeal to under-18s.
As part of the Panel’s consideration of the company’s response to the provisional decision, the Panel reiterated that it would not consider any proposed revisions to the drink’s label as that was not its purpose as a Panel. The Panel clarified that its decision would only be in regard to the packaging that was subject to complaint but noted the willingness of the company to work with the Advisory Service to make amends to the label. The Panel also acknowledged the responsible retailing practices outlined in the company’s second response but explained that retailer placement and age verification policies did not inform whether packaging was in breach of the Code. The Panel reminded producers that a drink could be seen by a wider audience outside of a retail environment and therefore compliance with the Code was based on the merits of the case and how the packaging would be perceived by the average consumer.
With that in mind, the Panel discussed the company’s request in its provisional decision response for the Panel to reconsider its decision relating to the brand logo. The Panel discussed the detailed view it had provided in the provisional decision regarding the overall impression conveyed by the product’s design and concluded that the points in the provisional decision still applied regarding the overall packaging design, the flavour ‘Bubble Yum’ and the presentation of the Sip n Drip logo. While the Panel accepted the company’s explanation regarding its intention behind the logo, the Panel stated that its decision was based on the design appearance of the product and how this would be perceived by the average consumer, as opposed to the intent behind the design.
On that basis, the Panel reiterated that the brightly coloured lips, bubble-writing font, high contrast colours, drip effect presentation and thick black outline meant that the Sip n Drip logo had a particular appeal to under-18s. Therefore, the Panel concluded that the overall impression conveyed by the packaging design, which compromised of a bright colourful background, prominent fruit imagery, fruit language and a confectionary flavour presented as ‘Bubble Yum’ did have a particular appeal to under-18s alongside the Sip n Drip logo which also had a particular appeal to under-18s. Accordingly, the complaint was upheld under Code rule 3.2(h).
3.1
During the Panel’s discussion of whether the product had a particular appeal to under-18s, it also raised whether the product communicated its alcoholic nature with absolute clarity for consideration. The Panel considered the shape and size of the bottle which incorporated a light blue screw cap lid and noted that it was very similar to packaging used for fruit juice drinks. The Panel stated that any alcoholic drink which used packaging more commonly associated with a soft drink needed to work harder to communicate its alcoholic nature with absolute clarity to minimise the potential for consumer confusion.
The Panel then assessed the front label of Sip n Drip and noted that the flavour Bubble Yum and ABV of the product were present in the bottom right-hand corner of the label in small white text. However, the Panel also noted that the text was superimposed onto fruit imagery and in the case of the ABV was very difficult to read over the image of blueberries. In addition to this, the Panel considered that both the ABV and the word ‘cocktail’ were presented in the smallest font on the front label and in the context of a brightly coloured, high contrast label with a significant amount of fruit imagery, the alcoholic cues did not stand out.
The Panel discussed the presentation of the jar of liquid on the front of the label which was angled to pour liquid to form the Sip n Drip logo with drip-effect. The Panel considered that the choice of a jar, instead of glassware that was commonly associated with alcohol, increased the likelihood of potential consumer confusion as another negative cue that detracted from the product’s alcoholic nature.
The Panel considered the back label of the product and noted that the ingredient list included the words cocktail and rumpunch alongside other recognisable alcoholic descriptors including vodka, rum and cognac. However, the Panel noted that in the list of ingredients, the alcoholic descriptors were embedded further in the text with the fruit ingredients given the most prominence first. While not required, the Panel also noted that the back label did not include best practice labelling elements such as the product’s unit content or the Chief Medical Officers’ Low Risk Drinking Guidelines which would typically provide further positive alcohol cues on pack.
With the above points in mind, the Panel concluded that the predominant fruit imagery and brightly coloured, high contrast artwork on the packaging detracted from the alcoholic nature of the product, particularly when combined with the packaging style, which was reminiscent of a well-known soft drink. While the Panel noted that there were some positive alcohol cues on the packaging, these were presented in a relatively small font size and not given the prominence required on a product which resembled a soft drink. Therefore, on balance, the Panel also found the product in breach of rule 3.1.
The Panel welcomed the company’s intent to make changes to the product and encouraged the company to engage with the Portman Group’s Advisory Service.
Action by Company: Producer action – The producer did not agree to make the required changes to bring the product in line with the Code. A Retailer Alert Bulletin was therefore issued requesting retailers to stop placing orders for the product after 14 April 2026.
1 Marketing that appeals to under-18s, Kids Industries, 2023