Retailers have been asked by the Portman Group to stop placing orders for Sip N Drip’s Bubble Yum after 14 April 2026. This comes after the Independent Complaints Panel (Panel) found that the product had a particular appeal to under-18s and that the alcoholic nature of the product was not communicated with absolute clarity.
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 3.2(h), which states that a drink, its packaging and promotional activity should not have a particular appeal to under-18s. During the Panel’s consideration of the case it also raised Code Rule 3.1 which requires the alcoholic nature of a drink to be communicated on its packaging with absolute clarity.
A copy of the full decision is available here.
The Panel considered the imagery on the label, which included the Sip n Drip brand logo which featured brightly coloured lips, a bubble font with drip effect and a thick black outline, all design elements that can be used in marketing to appeal to under-18s as highlighted by research from the children’s marketing agency, Kids Industries[2] . This, alongside the overall impression of the packaging; a bright, colourful background, fruit imagery, fruit language and confectionary flavour, Bubble Yum, led the Panel to conclude that the product was in breach of Code Rule 3.2(h).
When considering Code Rule 3.1, 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 well-known soft drinks. 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 generally resembled a soft drink. Therefore, the Panel also found the product in breach of Code Rule 3.1.
As the producer, Sip n Drip, did not agree to make the required changes to the product to bring it in line with the Code, a Retailer Alert Bulletin (RAB) has been issued requesting that retailers do not place further orders for stock after 14 April 2026.
Chair of the Independent Complaints Panel, Rachel Childs, said: “This product has real potential to cause confusion as to its alcoholic nature. This, combined with its particular appeal to under-18s means it is essential this product is redesigned. We welcomed the company’s initial commitment to make changes to its product design; however, the Panel can only base its decision on the original packaging, which was very much in breach of the Code of Practice. The subsequent lack of engagement from the producer since is deeply disappointing and inevitably led to a RAB being issued.”
Matt Lambert, Chief Executive of the Portman Group, said: “It is especially disappointing that the producer has failed to reach a satisfactory agreement with us regarding amends to the product after sharing a redesigned label with the Panel. Every company has access to free advice to assist in complying with the Code and in this case the company did not agree to make the required changes to the product, leaving us with no choice but to issue a Retailer Alert Bulletin, only the second one since 2023. We now request that all responsible retailers across the UK stop placing orders for Sip N Drip’s Bubble Yum after 14 April 2026. If any retailer is unsure about the RAB’s application, please contact the Complaints Team for further information.”
A Retailer Alert Bulletin is only issued by the Portman Group following an upheld complaint by the Panel where the producer chooses not to comply with the decision. A RAB requests that retailers cease placing orders for the product three months after the publication date, in this case after the 14 April 2026. For further information please contact complaints@portmangroup.org.uk.
Sip N Drip Retailer Alert Bulletin
[1] Part of the independent proactive audit of the Naming and Packaging of Alcoholic Drinks Code, Sixth Edition Amended
[2] Marketing that appeals to under-18s, Kids Industries, 2023
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
- Nearly a quarter (24%) of alcohol drinkers who have tried low and no alcohol alternatives said that these products have reduced their alcohol consumption.
- More than a third (35%) of UK adults consume up to 5 units of alcohol per week.
- UK adults are more worried about British teenagers vaping, use of illicit drugs and social media than about alcohol and alcohol alternatives.
The Portman Group’s eighth annual survey on low and no alcohol in partnership with YouGov shows that 86% of UK adults either abstain from alcohol or drink within Chief Medical Officer low risk drinking guidelines (up to 14 units per week), with a significant portion of the population embracing low and no alcohol alternatives.
The survey found that 53% of UK adults consume 14 units of alcohol or less per week which includes 35% of adults who are drinking 5 units or less per week. A third of adults (33%) do not drink alcohol at all. Only 11% of adults exceed the Chief Medical Officer’s low risk guidelines.
Among UK adults who drink alcohol, 36% consume low and no alcohol products either regularly or occasionally (i.e. ‘semi-regularly’ which encompasses both regular and occasional drinkers). Alcohol alternatives continue to be more popular with younger adults, with 43% of 18-24 year olds and 40% of 35-44 year olds consuming them semi-regularly, but there is an upward trend in those aged 55+, with 35% also drinking alcohol alternatives semi-regularly, compared to 25% in 2022*
The results tell us that – for the eighth year in a row – driving home safely from social events remains the top reason for choosing low and no alcohol products (35%), followed by taking part in social activities without drinking excessively (24%) – highlighting how these products support responsible drinking behaviours and help avoid harms such as drink driving and binge drinking.
Nearly a quarter (24%) ** of current alcohol drinkers who have tried low/no alcohol alternatives report that these products have helped reduce their alcohol consumption – once again highlighting how consumers are actively using alcohol alternatives as tools for moderation.
For the first time, the survey asked UK adults at what age they first tried a low or no alcohol alternative. The results showed that only 7% of adults who have tried low and no alcohol alternatives first tried them before the age of 18 – 4% between 16-17 and 3% aged 15 and under. Whilst the Government is considering a ban on the sale of alcohol alternatives to under-18s, the industry has been proactive in ensuring the Challenge 25 is implemented across shops and bars to prevent sales to minors. Portman Group guidance also ensures these products are marketed responsibly and only to adults.
The results also show that concerns around teenage alcohol drinking (40%) are much lower compared to concern about teenage use of illicit drugs or vaping (64%), social media use (62%), self-harm (49%), energy drinks (46%), whilst just 9% of adults are concerned about teenagers drinking low and no alcohol alternatives.
This year’s findings underscore a continued shift towards moderate drinking and positive attitudes to low and no alcohol alternatives across all age groups.
Matt Lambert, CEO of the Portman Group, said: “These results serve to demonstrate that a large proportion of UK consumers continue to drink moderately and that low and no products help them to do this. It is for this reason we at the Portman Group continue to champion and support this important and growing sector.
“These figures also help us to understand underage drinking of low and no alcohol products and demonstrate that the industry is proactive in ensuring these products are marketed and sold as alcohol alternatives for adults only.
“It’s good news that UK adults are embracing moderate drinking and low and no alcohol options like never before, showing these products are now a mainstream choice helping people to drink responsibly while still enjoying social occasions.”
* Wording in the survey has changed since 2022, previously worded as ‘often’ and ‘sometimes’ rather than ‘regularly’ and ‘occasionally’.
** Based on removing those who did not drink alcohol before first trying a low/no alternative.
All figures, unless otherwise stated, are from YouGov Plc. Total sample size was 2138 adults. Fieldwork was undertaken between 24th – 25th November 2025. The survey was carried out online. The figures have been weighted and are representative of all UK adults (aged 18+).
Producer:
Lervig
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 can design features a colourful graphical illustration style representation of a house party, which is funny and quirky, and is likely to have strong appeal to older children and teens. The name “House Party” is also provocatively appealing to under 18’s and is likely a popular activity with many teens to socialise and consume alcohol before they can legally drink in pubs and bars. This is culturally entrenched in youth culture in the UK and would instantly create an appeal and association with this age group”.
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.
NOT UPHELD
The company’s submission
The company explained it was a craft beer producer based in Stavanger, Norway and therefore operated under some of the most restrictive alcohol laws globally. Since establishing its visual branding in 2016, it had not received any complaints regarding its artwork, product names, or related matters. The company stated that its beers, including “House Party”, were considered long-standing classics, sold domestically and exported to approximately 30 countries, all without any reported issues.
The company stated that over 90% of the product was sold in pubs in the UK, where under-18s were not permitted. The company explained that the beer had been on the market for years without receiving any complaints. Additionally, it noted that the higher price point of its craft beer typically attracted an adult audience as the flavour was bitter, unlike sweeter drinks that could appeal to under-18s.
The company explained that it operated in Norway, exported its beer to numerous countries and had not encountered any concerns regarding the artwork or name. In Norway, the legal age for purchasing alcohol was 18 for beverages up to 22% alcoholic strength by volume (ABV) and 20 for those exceeding an ABV of 22% to ensure there was no risk of under-18s purchasing alcoholic products. However, the company noted that UK law was less restrictive in that regard and questioned whether changing the beer’s name would address the purported issue or if the focus of regulation should be on the alcohol purchasing laws themselves as it doubted that the beer’s name was the root of underage drinking.
The company’s response to the provisional decision
The company respectfully disagreed with the Panel’s provisional decision and stated that it did not believe the application of Code rule 3.2(h) had been applied consistently by the Panel as it had been in previous decisions.
The company acknowledged that House Party may resonate with teenagers but agreed with the Panel’s finding that the name did not inherently appeal to under-18s in isolation. The company agreed that this aligned with how ‘house party’ was used in popular culture and the phrase did not create an automatic association with underage activity. The company explained that the name did not include slang, abbreviations, emoji or youth coded language, nor did it romanticise illegal drinking or underage rebellion. The company stated that it was an overgeneralisation to relate ‘house party’ with only under-18s as the phrase appeared in countless adult contexts including in films and podcasts. The product did not include memes, irony or rebellion which the company stated were touchstones of youth marketing. Furthermore, the company noted that many alcoholic drinks on the market referenced party culture, but the packaging of House Party was not paired with any literal illustrations of a party in any case.
The company explained that the visual stye of the packaging was intentionally abstract and artistic; it did not incorporate a narrative or cartoonish or child-like imagery. The design did not include characters or faces, animals, mascots, toys or pop culture references. It also did not include simplified shapes, bold outlines, relatable human figures or humorous juvenile content. The company explained that the limb shapes and distorted structure were symbolic of energy and chaos intended to be an artistic expression typical of the surreal and postmodern visual tradition. The company stated that this genre of art was commonly associated with adult oriented design rather than children’s media. The company explained that ‘visual noise’ was not a trait that was indicative of youth appeal and colourful packaging was common within the craft beer sector. The company stated that the artistic techniques employed intended to reflect a deliberate detachment from realism unlike other character driven packaging designs which had previously been upheld by the Panel. The company compared House Party’s abstract design to other alcohol products that featured clear youth-style imagery, such as cartoon characters, anthropomorphic animals and whimsical scenes. The company stated that House Party’s surrealist artwork was far removed from juvenile cues and was more likely to appeal to adults interested in alternative art. Furthermore, the company stated that ‘House Party’ contrasted sharply with other drinks on the market and expressed concern that an abstract design could be penalised while cartoon imagery had been found to be compliant with the Code. The company stated that the shift toward viewing abstract, artistic designs as appealing to youth risked setting an uncertain precedent which could potentially create disproportionate challenges for producers who use creative designs with no intention to target under-18s.
The company stated that there was no evidence that the packaging would have particular appeal to under-18s as the complaint had been raised as part of the 2025 independent proactive audit of the market, commissioned by the Portman Group. The company explained that in nearly a decade of international distribution it had never received a complaint about House Party regarding underage appeal. The company stated that the drink was stocked by licensed retailers and on-trade venues with age-gating policies and was at the mandatory regulatory standard in other markets with highly restrictive requirements. The company stated that it was therefore disproportionate to remove the product based on speculative appeal with no evidence of real-world appeal to under-18s or misuse. The company stated that in practice, House Party would not appeal to under-18s given its premium price point, its bitter and hoppy taste, its 4% ABV and that it was mainly sold through licensed on-trade venues which did not sell alcohol to under-18s.
The company requested that the Panel reconsider the provisionally upheld decision and dismiss the complaint based on the above points. The company maintained that House Party was clearly intended for adult consumers and did not pose a practical risk of appealing to under-18s.
The Panel’s assessment
During the Panel’s first consideration of the case, it discussed the name ‘House Party’ at length to determine what age demographic the reference would appeal to. The Panel noted that ‘house parties’ were an enduring tradition amongst young people which included those that were under the age of 18. The Panel considered that house parties would strongly resonate with under-18s because there were a limited number of nighttime establishments that would allow them entry which meant that house parties were invariably a popular alternative for those under the legal drinking age. However, as part of this discussion, and its consideration of the provisional decision, the Panel also noted that house parties would strongly resonate with those in an 18-25 age bracket and would have a level of appeal with an older age demographic who would still use the term to describe social gatherings. The Panel discussed the cultural shift that had occurred in recent years whereby house parties were not exclusively drinking occasions for under-18s and considered that it was not possible to state that a house party would particularly resonate with under-18s given their broad appeal to all age groups. Whilst broad appeal was acknowledged, the Panel expressed concern that the term would strongly resonate with those in the 15-25 age bracket which included some under-18s. However, when considering the name alone and the wording of Code rule 3.2(h), it did not consider that the name in isolation would have a particular appeal to under-18s. Therefore, the Panel noted that it was important to consider the name in the wider context of the rest of the packaging.
The Panel considered the imagery used on the packaging which included an abstract depiction of a character that had a large building placed on its head, with a body protruding underneath and wavy arms flailed at its side. The Panel also noted that on one side of the can a pair of wavy hairy legs were also included at an angle which reinforced the perception that the artwork was intentionally fantastical and abstract. The Panel discussed the splashes of coloured patches around the central artwork and considered that the design represented visual noise and gave the impression that the party was uncontrolled which was compounded by the streaks of colour emanating from the property, suggestive of loud music. The Panel discussed that an unrestrained house party would resonate with under-18s as youth culture often glamourised wild and loud house parties. As part of its consideration of the provisional decision, the Panel debated the depiction of a chaotic and visually loud party at length in terms of its appeal to a younger age group. The Panel also discussed the company’s response to the provisional decision and acknowledged that while chaotic and wild house parties would resonate with a younger age group, this appeal spanned an age demographic which included adults as well. The Panel discussed Code rule 3.2(h) and its accompanying guidance alongside the company’s response to the provisional decision. The Panel acknowledged the difficulty in applying the test of particular appeal to a chaotic house party concept that would appeal to a younger demographic but not to the extent where it would resonate with under-18s more than it would with young adults. The Panel considered research that it had commissioned from the children’s marketing agency Kids Industries[1] and discussed how early adolescence was often a period where appeal for under-18s became more adult-like in nature. As part of this change, the Panel noted that teenage appeal was often based on seeking to emulate the interests of older age groups which made it difficult to apply the test of particular appeal. On this basis, the Panel determined that in such cases assessing the product packaging in its entirety was key to determine whether it could resonate with under-18s in a particular way.
The Panel considered the overall impression conveyed by the product packaging and noted that it employed a muted colour palette overlaid on a silver metallic background. The Panel considered that the font for the company and product name only appeared in black and was simplistic in its design. When considering the artwork, colour palette and font in combination, the Panel noted that the design was intentionally abstract and stylised in a manner which conveyed a loud and chaotic house party. However, typical design features that would normally be associated with a younger age group, such as identifiable characters, contrasting colours, thick black key lines and youth culture references were notably absent.
The Panel noted the producer’s response that the product was primarily sold in age-restricted pubs in the UK but noted that this still did not represent all sales which meant the product could still be taken into the home environment and that this remained outside of the producer’s control. In addition to this, the Panel noted that the remit of the Code and its application applied solely to the product packaging as opposed to an assessment of how the product was retailed, how it tasted and how it was priced.
After careful consideration, the Panel acknowledged that the name ‘House Party’, alongside an abstract depiction of a chaotic and wild house party, would have a level of appeal to a teenage age group. However, the Panel considered that the concept would also strongly resonate with a younger adult demographic. Whilst the Panel noted that this appeal was likely to be particularly strong in the 15-25 age bracket and would therefore capture a level of appeal to some under-18s, the Panel did not consider that this appeal would particularly resonate above and beyond the likely adult appeal. Furthermore, in the context of an abstract, stylised design which used a limited colour palette on a metallic background with black simplistic font, the Panel concluded that the packaging did not have a particular appeal to under-18s. Accordingly, the Panel did not uphold the complaint under Code rule 3.2(h).
Action by Company:
None required.
[1] Marketing that appeals to under-18s, Kids Industries, 2023
A complaint against Lervig’s House Party IPA has not 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 3.2(h), whereby 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.
After a provisional decision by the Panel to uphold the complaint, the producer appealed on the grounds that the name House Party did not create an automatic association with under-18s, that the packaging did not include the normal touchstones of youth marketing, and that the phrase ‘house party’ appeared in countless adult contexts. The design was intentionally abstract and did not include any of the fonts or imagery that would normally appeal to under-18s.
The Panel acknowledged that the name ‘House Party’, alongside an abstract depiction of a chaotic and wild house party, would have a certain amount of appeal to a teenage age group but agreed that the concept would also strongly resonate with a younger adult demographic. This, alongside an abstract, stylised design with a limited colour palette with a simplistic font, meant the Panel concluded that the packaging did not have a particular appeal to under-18s. Accordingly, the Panel did not uphold the complaint under Code rule 3.2(h).
Chair of the Independent Complaints Panel, Rachel Childs, said: “It is very unusual that the Panel overturn a provisional decision, however, this case shows the benefits of producers engaging with the complaints process and with the Panel. This also shows the importance of our two-step process in ensuring we have considered and fully discussed all factors before making a full and final decision.”
[1] Part of the independent proactive audit of the Naming and Packaging of Alcoholic Drinks Code, Sixth Edition Amended
Retailers have been asked by The Portman Group to stop placing orders for Liquor Zaar’s O.J Premium Strong Beer after the 15 December 2025, after the Independent Complaints Panel (Panel) found that the product placed undue emphasis on its higher alcoholic strength, and that that the packaging, which contained more than 4 units of alcohol, indirectly encouraged immoderate consumption.
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 about potential Code breaches of Code Rule 3.2 (a), which states that a drink should not give higher alcoholic strength, or intoxicating effect, undue emphasis, and Code Rule 3.2 (f), whereby a drink should not encourage illegal, irresponsible or immoderate consumption.
In addition the Panel considered whether the cartoon image of an athletically built man with large muscular biceps could suggest that the drink could enhance physical capabilities, which would have been a breach of Code Rule 3.2 (j) but concluded there was nothing on the packaging to sufficiently link the image to consumption of the drink and this part of the complaint was not upheld.
A copy of the full decision is available here.
The Panel noted that whilst it was important to ensure a drink’s strength was communicated factually, the higher strength should not be unduly emphasised. The Panel considered that the combination of multiple strength cues, including disproportionately large fonts and repeated overt presentation of the drink’s ABV, alongside imagery representing physical strength, placed undue emphasis on the drink’s higher alcoholic strength. In this case, the Panel noted that some consumers would be particularly vulnerable to marketing where the higher alcoholic strength of a drink was presented as a virtue and expressed significant concern regarding its presentation. Accordingly, the complaint was upheld under Code Rule 3.2(a).
Looking at whether the drink encouraged irresponsible or immoderate consumption, the Panel noted that as the product contained 4.4 units of alcohol in a single serve, non-resealable container, mitigating factors such as a ‘share’ message or per serve information should have been included on the packaging. In the absence of this information, the Panel considered that the packaging indirectly encouraged immoderate consumption, as such, the complaint was upheld under Code rule 3.2(f).
Chair of the Independent Complaints Panel, Rachel Childs, said: “Despite being given several opportunities to submit a response to the Panel about this complaint, the company did not respond to any correspondence relating to this matter. It is unacceptable for an alcoholic product to market its higher alcoholic strength as the primary reason for purchase, particularly when it was also found to encourage immoderate consumption. The Code is explicitly clear that alcohol marketing should not particularly appeal to those who are vulnerable. During consideration, the Panel expressed significant concern about the packaging of O.J Premium Strong Beer and concluded that it had not been marketed in a socially responsible manner.”
Matt Lambert, Chief Executive of the Portman Group, said: “This is the first Retailer Alert Bulletin (RAB) the Portman Group has issued since 2023. It is particularly disappointing that the producer refused to engage with the process or take advice from our free advisory service. The Portman Group will not hesitate to enforce the Panel’s decision and request that all responsible retailers across the UK stop placing orders for O.J Premium Strong Beer after the 15 December 2025. If any retailer is unsure about the RAB’s application, please contact the Complaints Team for further information.”
A Retailer Alert Bulletin is only issued by the Portman Group following an upheld complaint by the Panel where the producer chooses not to comply with the decision. A RAB requests that retailers cease placing orders for the product three months after the publication date, in this case after the 15 December 2025. For further information please contact complaints@portmangroup.org.uk.
You can see the Retailer Alert Bulletin here: OJ RAB pdf.
[1] Part of the independent proactive audit of the Naming and Packaging of Alcoholic Drinks Code, Sixth Edition Amended
Producer:
Vault City Brewing
Complainant:
Member of the public
Complaint:
“I am contacting you regarding the packaging of a Scottish brewery called Vault City. I purchased some of their products and left them in the fridge. When I was out my son picked radler out of the fridge thinking it was a soft drink. He opens it and tried it and fortunately didn’t like it. The packaging is immigrating san pelegrino soft drinks and that is what he thought it was”.
Decision:
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 emphasised its commitment to responsible marketing, compliance with regulations and highlighted that, in its view, the packaging was compliant. The company explained that the product was only sold through independent retailers but stated that it was open to constructive feedback from the Panel.
The company stated that it was confident that the alcoholic nature of Lemon Grapefruit & Pineapple Radler was clearly conveyed through several cues on the packaging. The company argued that the word “beer” appeared prominently on the front of the can, alongside the company name “Vault City Brewing” which reinforced the alcoholic nature of the drink. Additionally, the product’s alcoholic strength by volume (ABV) of 3.4% was displayed on the front, with the messaging “ALC 3.4% VOL”, unit content information and a pregnancy warning logo also present on the back label. The company stated that these elements adhered to legal labelling requirements and best practice guidelines for responsible alcohol communication, exceeding the standards observed in previous not upheld cases under Code rule 3.1.
The company referenced similar cases where the Panel had determined that the presence of an ABV and other alcohol cues were sufficient enough to avoid a breach, despite the absence of the word “beer” on the front of the pack. The company highlighted that the packaging of Radler Lemon Grapefruit & Pineapple Beer went beyond this by prominently displaying the ABV alongside explicit alcohol descriptors which included the words “beer” and “brewing” on the front of the packaging, ensuring even greater clarity regarding the drink’s alcoholic nature.
The company described itself as a fruit-forward craft brewery that used over 185,000kg of real fruit annually in its beers. The company stated that its packaging was designed to emphasise the real fruit ingredients in a modern and adult-appropriate manner. The design aligned with the broader Radler category, which was characterised by bright, citrus-forward artwork and lower alcoholic strength. The company highlighted that Radler was a well-established beer style, recognised by consumers in both mainstream and craft sectors as a low-strength, fruit-infused beer, citing other examples on the market which featured similarly vibrant, fruit-led packaging.
The company explained that its product was packaged in a 330ml sleek can, a format commonly used in the UK alcohol market for ready-to-drink cocktails and fruit-forward alcoholic beverages. The company highlighted that this packaging style was familiar to UK consumers as a standard choice for alcoholic drinks, not just soft drinks. To prevent consumer confusion, the company had included clear and visible alcohol indicators, such as the word “beer” on the front, multiple ABV statements and responsible drinking messaging.
The company expressed regret that a child had accessed the drink and suggested this may have been because the alcohol had been left unattended in a family fridge instead of in a locked beer fridge. The company stated that the alcoholic nature of the product had been clearly communicated and was consistent with both regulatory standards and previous Panel precedents. The company concluded that it remained committed to upholding best practice standards and would carefully consider any recommendations by the Panel.
The Panel’s assessment
The Panel considered whether the packaging of Radler Lemon Grapefruit & Pineapple Beer communicated its alcoholic nature with absolute clarity as raised by the complainant. The Panel noted that when determining whether the alcoholic nature of a drink had been communicated with absolute clarity, regard would be given to a drink’s compliance with Regulation (EU) No 1169/2011 on the provision of food information to consumers and the UK Food Information Regulations 2014. However, compliance with the law would not be the only determining factor in judging compliance with the Code under rule 3.1. The Panel noted that packaging could still be found in breach of the Code if it had the potential to mislead about its alcoholic nature or was likely to cause consumer confusion.
The Panel assessed the front label of the drink which included the word ‘Radler’ in a prominent large font. The Panel discussed that while the term ‘Radler’ may be recognised by some consumers as a citrus-based beer, this was not a universally recognised term to denote alcohol in the UK. The Panel acknowledged that the term was better known with a younger drinking demographic but noted that it had not been understood by the underage person who had accidentally consumed the drink. Therefore, the Panel considered that ‘Radler’ on its own did not sufficiently communicate the product’s alcoholic nature.
The Panel considered that the front label included the product’s alcoholic strength of 3.4% but noted that this was positioned at the bottom of the label in a relatively small font size which meant that it did not particularly stand out. Juxtaposed above this, there were prominent images of fruits with the words ‘lemon, grapefruit and pineapple’ set on a white background. The Panel noted that the rest of the label was fairly minimalistic with a yellow and blue background which meant that the fruit imagery and flavour references were the dominant theme on the front of the can. The Panel noted that fruit flavours were commonly found in soft drink beverages and that such soft drinks often employed a heavy use of fruit imagery on the front of pack to convey their fruit-based nature. Therefore, due to the label’s strong similarity to a soft drink, the Panel considered that it was incumbent on the packaging to make it absolutely clear that the product was alcoholic to avoid any potential consumer confusion.
The Panel considered the company’s response which highlighted that the words ‘brewing’ and ‘beer’ were included on the front label. However, the Panel considered the presentation of the word ‘beer’, which was written in a dark yellow fine line italicised font on a lighter yellow background, made the text particularly difficult to read. Furthermore, because the word blended into the edges of the line pattern on the label, it was not immediately obvious or clear that the text was there. Therefore, on balance, the Panel considered that while the front label included the word ‘beer’ and the product’s ABV, the word ‘beer’ was not clearly presented, nor was the ABV or beer descriptor given the prominence required on a label which was predominantly focused on fruit-flavours and bore resemblance to a soft drink.
The Panel then considered the side of the can and noted the inclusion of text which described the flavour of the drink. While the text included some references to the brewing process, the majority of the text described the drink’s fruity and floral flavour with no specific mention of beer or alcohol. The Panel assessed the back label and noted that there were some positive alcohol cues such as the drink’s ABV, a pregnancy warning logo, unit content and the word ‘beer’ written in multiple languages. However, these were not particularly prominent and further best practice information such as a responsible drinking message, the Chief Medical Officers’ Low Risk Drinking guidelines and signposting to Drinkaware were absent from the label.
When discussing the company’s response, the Panel noted that the company had highlighted the Yonder Pink Lemonade precedent a few times to emphasise the similarity in a case where a child had mistakenly consumed an alcoholic drink and which it believed the Panel had concluded that the labelling was sufficient regardless. The Panel sought to clarify that while Yonder Pink Lemonade had not been found in breach of Code rule 3.2(h), it had been found in breach of Code rule 3.1 for not communicating its alcoholic nature with absolute clarity.
The Panel discussed accompanying guidance to Code rule 3.1 which stated that where there were multiple negative alcohol cues on a drink’s packaging, such as fruit flavours and imagery, it may need to work harder to communicate its alcoholic nature and to avoid consumer confusion. In this instance, the Panel was also mindful that there was evidence of consumer confusion where an under-age individual had mistakenly consumed the product due to its perceived similarity to a well-known soft drink. The Panel considered the above points and concluded that the emphasis on the drink’s fruit flavour, predominant use of fruit imagery and use of the word ‘Radler’, which also appeared on non-alcoholic drinks, meant that the product needed to work harder to communicate its alcoholic nature. The Panel acknowledged that while it was not the intention of the company to obscure the alcoholic nature of the drink, the positive alcohol cues that had been included needed to be enhanced and made clearer to mitigate the risk of consumer confusion. Accordingly, the Panel upheld the complaint under Code rule 3.1.
Action by Company:
Working with the Advisory Service.
Producer:
Sainsbury’s Supermarkets Ltd
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 product has no clear alcohol labelling and visually resembles an RTD tea, which could mislead consumers about its alcoholic nature. Additionally, if the label is removed after opening, it further reduces transparency regarding the alcohol content, raising additional concerns”.
Decision:
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 stated that it did not believe that the drink’s packaging was in breach of the Portman Group’s Code of Practice. The company explained that the product communicated its alcoholic nature through the product name, which prominently stated “Tiramisu Rum Liqueur”; a universally recognised indicator of alcohol. The alcoholic strength by volume (ABV) was clearly stated as “20% vol 50cl” on the swing tag and the cork was marked as alcoholic. In addition to this, the descriptive text on the rear tag described the product as “a delicious blend of Caribbean rum, dark chocolate and coffee… creating a decadent liqueur”. The company addressed the suggestion that the product resembled a Ready-To-Drink (RTD) tea and stated that this was unsubstantiated. The company highlighted that the packaging format featured a glass, faceted bottle with a cork-style stopper and gold foiling which was not typical of RTD teas. The company stated this premium styling reflected a high-quality liqueur rather than a casual soft drink. Furthermore, the product was exclusively merchandised within the alcohol section, both in-store and online, reinforcing its alcoholic nature.
The company addressed concerns about the removable swing tag and explained whilst the swing tag was removable, the cork was permanently labelled with the product name “Tiramisu”, the alcoholic descriptor “Rum Liqueur” and “20% ABV” which ensured that the alcoholic nature remained clear. The company stated that further required information was presented on the swing tag at the point of sale and ensured that the product complied with labelling regulations.
As part of its response, the company shared a view from Oxfordshire County Council, the Primary Authority for Sainsbury’s Supermarkets Ltd. Oxfordshire Trading Standards (OTS) stated that its relationship with Sainsbury’s was to provide advice regarding the interpretation of Trading Standards legislation, in particular in relation to this matter, areas that covered Food Standards and Fair Trading, including misleading products. OTS confirmed that it had reviewed the complaint and that in its view the product complied with the Food Information to Consumers Regulations (1169/2011) which permitted mandatory food information to appear on a swing tag. OTS highlighted that the product was correctly labelled with the name of the food and its ABV and that its presentation was not misleading in any way. Addressing the other element of the complaint, OTS explained that the bottle design, a high-quality glass with a cork lid, clearly indicated an alcoholic product, not an RTD tea. The view provided by OTS concluded that the product communicated its alcoholic nature with absolute clarity and did not breach the Portman Group’s Code.
The company concluded that the Tiramisu Rum Liqueur complied with the Portman Group’s Code by clearly communicating its alcoholic nature and did not resemble a non-alcoholic drink. The company requested the complaint be reconsidered and expressed confidence in its compliance while remaining open to constructive dialogue.
The Panel’s assessment
The Panel considered whether the packaging communicated the drink’s alcoholic nature with absolute clarity as raised by the complainant. The Panel discussed the Portman Group’s accompanying guidance to Code rule 3.1 which stated that when determining whether the alcoholic nature of a drink had been communicated with absolute clarity regard would be given to a drink’s compliance with Regulation (EU) No 1169/2011 on the provision of food information to consumers and the UK Food Information Regulations 2014. However, the Panel also noted that guidance stipulated that compliance with the law would not be the only determining factor in judging compliance with the Code under rule 3.1. The Panel noted that packaging could still be found in breach of the Code under the absolute clarity requirement if, in the Panel’s view, it had the potential to mislead about its alcoholic nature or was likely to cause consumer confusion.
The Panel considered the packaging and noted that the bottle employed a novel design, with textured clear glass and a geometric pattern vertically displayed on one side. The Panel noted that aside from the vertical geometric design, there was nothing else printed on the bottle and it was void of any alcohol-related information on the glass. Instead, the Panel noted that the product’s alcohol health-related information only appeared on a swing tag which included signposting to the Drinkaware website, unit content information, pregnancy warning, the Chief Medical Officers’ Low-Risk Drinking Guidelines and a responsible drinking message. The Panel assessed the swing tag in more detail and noted that it was attached to the bottle with string and displayed a “to” and “from” inside which gave the impression it was a gift tag. The Panel discussed that if the drink was given as a gift, it was likely that the tag would be removed and discarded so that a consumer could peel off the protective plastic wrapper to open the product and that this was also compounded by the cultural assumption that most people would remove a gift tag before using a gift. Furthermore, the elasticated string meant that the swing tag could be easily pulled over the drink’s neck and as it was not securely fastened could easily be removed, intentionally or accidentally, in a home or retail environment. The Panel discussed two comparable precedent cases, Spiced Sugar Plum Light Up Snow Globe Gin Liqueur and Clementine Light Up Snow Globe Gin Liqueur, and noted that in its previous decisions it had concluded that swing tag labels which were easily removable could cause confusion as to the alcoholic nature of the drink if that information was not clearly repeated on the primary packaging.
With that in mind, the Panel then assessed the overall impression conveyed by the packaging. The Panel noted that the drink was sealed with a large cork stopper which had the words “Rum Liqueur” and “20% vol” printed on it. The Panel discussed that the text was embossed onto the golden lid in a light gold text colour and noted that the lack of contrast in the colours meant that it was difficult to read, was not particularly prominent and was not contrasting enough to catch someone’s attention. The Panel further noted that the lid of a drink was not in a field of vison a consumer would normally expect to find alcoholic cues. The Panel discussed that consumers would turn a product around to look at a product in the round when assessing its alcoholic nature but considered that the top and bottom of a product were not typically places where a consumer would expect to find important information regarding a product’s alcoholic nature and that this became more pertinent when a removable swing tag contained the only clear, positive alcohol cues.
The Panel discussed the complainant’s view that the product appeared to be an RTD tea but considered that there was no additional language on the product which supported this assertion or any flavouring that referenced tea. The Panel noted that if the swing tag were removed the overall impression conveyed was not one of any specific drink.
The Panel discussed the producer’s response and noted the producer’s point that the product was exclusively merchandised within the alcohol section, both in-store and online, which in the producer’s view enforced the product’s alcoholic nature. The Panel noted that the remit of the Code applied solely to product packaging, irrespective of how a product was retailed and considered that ultimately the product would end up in the home-environment as most products in the off-trade would. The Panel also discussed the view provided from Oxfordshire Trading Standards which formed part of the producer’s response. The Panel sought to remind producers that compliance with the law was not always indicative of compliance with Code rule 3.1 and the wording requirement of ‘absolute clarity’. The Panel encouraged producers to carefully consider how a product’s alcoholic nature was communicated and that the minimum requirements in law were not always sufficient under the Code when there was the possibility that a consumer could be misled as to a product’s alcoholic nature if important information was provided on a removable gift tag and further mandatory information was not clearly visible in an unconventional place. The Panel further noted that this position was consistent with precedent that had been established in previous cases regarding Spiced Sugar Plum Light Up Snow Globe Gin Liqueur and Clementine Light Up Snow Globe Gin Liqueur.
Taking this into account, the Panel concluded that in its view, the drink’s packaging did have the capacity to mislead as to the product’s alcoholic nature. The Panel considered that it was not sufficient to include the only clearly presented, positive alcohol cues on a removable swing tag that was likely to be removed after purchase or could be accidentally removed even prior to purchase. As established in previous precedent, the Panel noted that if a product incorporated a removable swing tag it should repeat important alcohol-related information on primary packaging in a clear and legible manner. However, in this case, the Panel noted that this mandatory information had been embossed in gold lettering, on a gold-cork lid which it considered was an unconventional place where consumers would not typically seek such important information and that this was not particularly distinguishable or visible in its presentation. Therefore, the Panel concluded that the product did not communicate its alcoholic nature with absolute clarity and accordingly upheld the complaint under Code rule 3.1.
Action by Company:
The product has been discontinued