Further enhancing protection for under-18s – Code Review of rule 3.2(h): Particular appeal to under-18s

May 17th '23


The Portman Group’s primary purpose as a self-regulator is to protect consumers from harm, particularly those who are vulnerable, and a fundamental part of this is protecting those who are under-18. For over 30 years, they have responded to the challenges of alcohol harm and this includes periodically reviewing the Code of Practice on the Naming Packaging and Promotion (NPP) of Alcoholic Drinks to ensure it is fit for purpose.


The NPP Code was subject to an extensive public consultation in 2019 and the majority of the Code is working as intended. However, the Portman Group recognise that the Code must adapt to provide effective self-regulation to an industry, which at its heart, is creative and constantly evolving. This consultation is therefore a narrow one. It is designed to address an issue that has arisen in the daily application of the Code and to ensure alignment with the Alcohol Sponsorship Code. Self-regulation is at its most effective when it enables robust, proportionate action quickly and in a way that also allows the views of all interested parties to be heard.



After conducting an internal examination of the Code rules, the Portman Group has identified that Code rule 3.2(h) requires further clarification, to ensure that the protection for those under the age of 18 is delivered as intended. Code rule 3.2(h) currently reads:


A drink, its packaging and any promotional material or activity should not in any direct or indirect way have a particular appeal to under-18’.


The Portman Group has proposed changing the current wording of Code rule 3.2(h) to read:


‘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.’


The proposed rule amendment would therefore create consistency between the Naming, Packaging and Promotion of Alcoholic Drinks Code and the Alcohol Sponsorship Code, with the intention to prevent any link between alcohol and childhood.



The consultation will run for six weeks and encourage all interested parties to read the full consultation document here and respond to the questions outlined on page 10.


The Portman Group will consider all responses carefully and with an open mind. They are committed to maintaining a strong and effective Code of Practice for the responsible marketing of alcoholic drinks. If you share these aims, then please share your views.


The consultation will close at 5pm on 7 July. In light of the comments received, the Portman Group may prepare a revised Code of Practice.  If changes are agreed, it is hoped that the sixth edition (amended) of the Code will be published in autumn 2023 alongside revised accompanying guidance.


Whenever the new edition of the Code is published, there will be a grace period of at least six months before products and promotions are required to comply with the new Code.


If you have any questions about this consultation or need advice on the form of the response, please contact us consultation@portmangroup.org.uk.


Source: Portman Group


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