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:

Põhjala Brewing AS

Complainant:

Zenith Global Commercial Ltd (2025 Independent Proactive Audit of the Naming and Packaging of Alcoholic Drinks Code, Sixth Edition (Amended)

Complaint:

“Product is in a 330ml soft drinks can and the front design has minimal text with product name only. It is in only when the back of the can is read it’s clear it is alcoholic with very small wording for ‘Beer’ and the vol % slightly larger”.

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 appreciated the opportunity to address the concerns about the packaging of the drink and explained that Heli Imperial Gose was a small-batch, barrel-aged specialty craft beer targeted at enthusiasts within the premium beer segment. It was distributed through specialty alcoholic product channels like bottle shops, bars, and curated online platforms and was not available in mainstream soft drink contexts or UK supermarkets. The company acknowledged concerns about the minimal text on the front of the can but emphasised that the back of the can clearly included the word ‘Beer’ and the product’s alcoholic strength by volume (8%). The company also highlighted that the can included all legally required alcohol labelling as per Estonian and EU regulations and met export compliance criteria. The company explained that in Estonia, all alcoholic beverages were required to be registered on the Estonian Alcohol Register which involved a review of packaging and labelling elements by national authorities to ensure compliance with local laws on alcohol visibility and responsible presentation. The company confirmed that Heli Imperial Gose had been reviewed and approved by the Estonian Alcohol Register, validating that the packaging clearly communicated its alcoholic nature under national standards.

The company explained that the front-facing design of the product was minimal, reflecting a common aesthetic in the craft beer segment, particularly for specialty or barrel-aged releases. The intention of which was to communicate a refined, artisanal product rather than resemble a soft drink. The company stated that the product’s alcoholic nature was clarified through several elements: the high ABV (8%), which was uncommon for soft drinks; the inclusion of “Imperial Gose” in the name, a recognised beer style; and the 330ml can format, which was typical for craft beer and did not suggest a soft drink in the market context. Furthermore, the label prominently displayed the drink’s alcoholic strength of 8% in large, legible text on the upper-left corner. Beneath this, the word ‘BEER’ was clearly written in multiple languages. Additionally, the term ‘Imperial Gose,’ as both the product name and a recognised beer style, appeared in the description, contributing to clear communication of the product’s alcoholic nature. The company reviewed the similar cases of Yonder Pink Lemonade, Blossom Hill Spritz and Hello Kitty Pinot Noir and stated that Heli Imperial Gose differed significantly in intent and execution. The company explained that the drink’s muted, artistic design and labelling targeted an adult audience and did not include imagery or language which would appeal to children or mimic soft drink branding. The company highlighted that only 72 cans of the product had been sent to the UK as part of a one-off small batch release for specialist outlets and it was not distributed through mainstream retail as it was intended for a niche audience of craft beer enthusiasts. The company articulated its commitment to responsible marketing and expressed willingness to make minor adjustments to the front-can design in future print runs to better clarify the product’s alcoholic nature, while preserving its brand identity and design integrity.

The Panel’s assessment

The Panel discussed whether the packaging communicated the drink’s alcoholic nature with absolute clarity as raised by the complainant. The Panel first assessed the packaging, which incorporated a minimalist stylised design of a predominantly black background superimposed with green shapes that stretched around the majority of the can. 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) but did have the company name ‘Põhjala’ presented clearly in white text within a white outlined box. The Panel considered that a company name would not be considered a positive alcoholic cue because consumers might be unfamiliar with the fact that the company was an alcoholic drinks producer and therefore may not associate the drink with alcohol. Given that the front label of the drink did not contain any references to alcohol, the Panel considered that it was difficult to determine what type of drink it was, particularly as the artwork was abstract and did not relate to beer in any overt or obvious way. However, the Panel also noted that mandatory legal information was not required to be presented on the front label either by law or under the Code and therefore it was important to assess the label in its entirety to determine compliance under Code rule 3.1. The Panel considered the back label of the drink and noted that there were some

positive alcohol cues such as the drink’s ABV, the word ‘beer’ in a number of 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 Panel noted that while these points were not required under the Code, they were positive alcohol cues that UK consumers would be familiar with on alcohol packaging and therefore would help the drink to communicate its alcoholic nature. The Panel discussed the font size on the back of the can which was particularly small and noted that it was particularly difficult to read white text which had been overlayed on an iridescent pattern. The Panel noted that the largest font on the product, after the company name, was ‘Heli Imperial Gose’ on the side of the product which appeared above text describing the tasting notes of ‘sloe berries and lemon thyme’. The Panel considered that ‘gose’ was not a particularly well-known beer descriptor and would not necessarily be understood as a reference to alcohol in and of itself. The Panel noted that this was also compounded by the fruit flavour descriptors directly underneath it which would be more understood as flavours associated with a soft drink. The Panel discussed the producer’s response that only 72 cans had been sent to the UK and were intended for a niche audience of craft beer enthusiasts. The Panel sought to remind producers that the remit of the Code and its application applied solely to the product packaging as opposed to an assessment of how a product was retailed. Whilst the Panel acknowledged that some products could have a limited distribution, all products and companies were treated equally under the Code for regulatory consistency and fairness. The Panel therefore carefully considered whether the drink’s packaging had the capacity to cause consumer confusion taking the above points into account. When assessing the overall impression conveyed by the drink’s packaging, the Panel concluded that the minimalist front label, which was absent of any alcohol descriptors, combined with the fruit flavour descriptors, comparatively minimal references to alcohol, the drink name ‘Heli Imperial Gose’ which was not a well-known reference to beer in the UK and the difficult to read small white text overlayed on an iridescent label meant that, on balance, the drink did not communicate its alcoholic nature with absolute clarity. Accordingly, the complaint was upheld under Code rule 3.1.

Action by Company:

Was limited edition.