The complaint alleged that the beer’s packaging (in a 330ml can) and design, which features a cartoon bear and a graffiti typeface, appealed to under-18s and encouraged immoderate consumption.
The complainant, a member of the public, said that the beer looked like “a can of fizzy pop” and argued that the drink “appears to be aimed at kids”.
In response, Tiny Rebel said that that its marketing was aimed at no one group in particular, and argued that there were several clues on the packaging to clearly indicate that the product was alcoholic.
The brewery pointed out the words 'Welsh Red Ale' featured prominently on the can, and the alcoholic strength of the drink was clearly conveyed. It also emphasised the use of 330ml cans was not a new innovation in the beer industry, and that that the Tiny Rebel bear was a manifestation of the two co-founders’ personalities and a broader reflection of the industrial, urban city of Newport where the beer hailed from, and not designed to appeal to under-18s.
Social responsibility work
However, the Independent Complaints Panel found in favour of the complainant, and agreed that the packaging indirectly encouraged immoderate consumption. The panel also considered the prominence of the bear above the wording ‘Tiny Rebel’, in combination with the graffiti and swirling primary colours, caused the product to have a particular appeal to under-18s.
While considering the ruling, the panel recognised Tiny Rebel’s social responsibility work in its local community and highlighted that it had not deliberately sought to create product packaging that had an appeal to under-18s.
The Portman Group also acknowledged the positive way in which Tiny Rebel had engaged with the advisory service throughout the complaint process and welcomed its early commitment to respect the panel’s ruling.
Companies must be vigilant
Independent Complaints Panel secretary John Timothy said: ‘‘I welcome the way in which Tiny Rebel Brewing Company has engaged with the advisory service throughout this process and its commitment to ensure the panel ruling is incorporated into wider work to evolve the brand.
“While it was clearly not the intention of the producer to promote immoderate consumption, even indirectly, companies have to be extremely vigilant around themes that could be attractive to young people, particularly when designing 330ml cans which, in the UK, are traditionally associated with soft drinks.”
Tiny Rebel co-founder Bradley Cummings told The Morning Advertiser the brewery was working with the Portman Group to make appropriate changes to the product packaging.
“We’ve worked with the Portman Group and the result of our chats is a minor change to our Cwtch can product by making our logo less dominant on the front of the can,” he said.