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1st September 2023

Complaint against Carbon Crush upheld for particular appeal to children

London, 1 September 2023: A complaint made against Docks Beers’ Carbon Crush has been upheld by the alcohol industry’s Independent Complaints Panel (Panel). A copy of the full decision is available here.

A complaint was made under two Code rules which raised concerns that the packaging did not clearly communicate the drinks alcoholic nature (Code rule 3.1), which was not upheld and that it had a particular appeal to under-18s (Code rule3.2(h)) which was upheld .

The predominant theme of the product’s label was a comic book strip style story which featured a caped crusader. Whilst comic books were popular across all ages, in some contexts including this case, they could have particular appeal to under-18s.  In coming to this view the Panel considered the packaging as a whole, and noted the contrasting primary colours, a fantastical narrative and the depiction of a superhero style figure, which all collectively enhanced the level of appeal to under-18s.

Regarding Code rule 3.1 which was not upheld, despite a busy design. This was due to the number of positive cues on the front and back of the label which includes the descriptor ‘low carbon IPA’ and the product’s alcoholic strength by volume (ABV) of 5%, unit content and a pregnancy warning logo.

The company said Carbon Crush was intended as a limited-edition product designed to spread awareness of Carbon Capture and Storage and is no longer in production.

Commenting on the decision, the Chair of the Independent Complaints Panel, Nicola Williams, said: “Comic books in some forms can be a popular source of entertainment for children. Producers need to take care when, in including such elements in marketing, that they do not particularly appeal to under-18s. Overall, in this case the packaging was found to have a particular appeal to children and I welcome the company’s response that the product is no longer in production.”

Will Douglas Director of Docks Beers & Docks Academy said:

“This beer was all about helping spread the message about carbon capture and storage.  We even used low carbon hops in the brew.  We felt a graphic novel character simplified a complex narrative and helped people understand the importance of this renewables endeavour in our area. The story told in the sequence of images on the can label is one that is eye catching and helped convey the message.  We certainly did not mean to create a product that appeals to children, but we can appreciate how the complainant and subsequently the Independent Complaints Panel might have reached that conclusion.”


For more information contact: / 07709 525971

Notes to editors

  1. Images provided
  2. A spokesperson is available for interviews upon request.
  3. The Portman Group was formed in 1989. It is the alcohol industry regulator and social responsibility body. It has over 160 Code signatories from producers, retailers and membership bodies.
  4. The Portman Group is funded by 19 member and associate member companies: Asahi UK Ltd; Aston Manor Cider; Bacardi; Beam Suntory; Brown-Forman; Budweiser Brewing Group UK&I; Campari; C&C; Diageo GB; Edrington UK; Heineken UK; Mark Anthony Brands International; Mast-Jäegermeister UK; Molson Coors Beverage Company; Pernod Ricard UK; Punch Pubs & Co; SHS Drinks; Thatchers’; and Treasury Wine Estates.
  5. The Code of Practice for the Naming, Packaging and Promotion of Alcoholic Drinks was first published in 1996. In 2021, we celebrated the 25th anniversary of the Code. The Code seeks to ensure that alcohol is promoted in a socially responsible way, only to those aged 18 and over, and in a way that does not appeal particularly to those who are vulnerable. The Code has helped create an industry that works effectively within the context of a self-regulatory model, while encouraging design, innovation and creativity. This has been done in an effective, responsive and inexpensive way.
  • Effectively – over 170 products have been amended or removed from the market. Many hundreds more have been helped to adhere to the Code before appearing on shelves through the support of the Advisory Service;
  • Responsively – there have been five updates to the Code over 25 years responding to changes in public attitudes and expanding its reach; all without recourse to Government or Parliamentary time;
  • Inexpensively – the leading members of the industry are currently funding the model for all to be protected at no cost to the public purse.

For more information contact: / 07709 525971

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