Three Pugs Gin Liqueur rapped for appealing to children

8th February, 2019 by Melita Kiely

Industry watchdog the Portman Group has upheld a complaint against Three Pugs Bubblegum Gin Liqueur that argued the product would appeal to children due to its cartoon label.


Three Pugs Gin Liqueur has until 1 June 2019 to overhaul its label design

The Portman Group’s independent complaints panel upheld the complaint under code rule 3.2(h), which states a drink, its packaging and any promotional material should not in any direct or indirect way have a particular appeal to under-18s.

A member of the public believed that “the pink liquid and label with the cartoon pictures of the pugs on is too appealing to children”.

The Portman Group took action in lieu of the member of the public. The complaints panel took the overall packaging into account and concluded the use of “pugalicious” as a description of the bubblegum flavour on the label, along with the fact the product was pink, were not problematic on their own.

However, combined with the cartoon pug illustration, which depicted the dogs in a hot air balloon overlooking a “Willy Wonka-like sweet land” across a pink liquid, the panel said the gin liqueur “was likely to have a particular appeal to under-18s”.

A spokesperson for the Portman Group said: “This decision once again highlights that producers should steer clear of references and imagery related to childhood and childhood memories.

“They should think carefully about what is conveyed by the overall impression of the product and speak to our advisory service if in any doubt.”

During the complaints process, Silverback Distillers, which makes Three Pugs Gin, explained to the panel that it had sought advice from the Wine and Spirits Trade Association (WSTA), Trading Standards and Business Growth Hub, and consulted various distributors and specialist retail outlets when designing the label.

The company highlighted it had ensured the words ‘gin liqueur’ were displayed prominently on the front of the bottle to stress it was aimed at adults.

Silverback Distillers also argued that the picture of the pugs on the front of the bottle was not a cartoon, but a caricature of the owner’s three pet pugs and “represented their true likeness without any embellishment to ensure that they did not appeal to under-18s”.

Furthermore, the bubblegum bubbles on the front of the bottle were “relevant to the flavour” of the liquid, which was also stated on the front of the label as required by EU law.

It also said the product was priced “relatively high” and therefore unaffordable to under-18s. The company also said it was currently “not willing” to commit to any labelling changes due to the uncertainty of Brexit, which could result in changes to labelling laws next year.

Three Pugs ‘fully supportive’ of Portman Group

Following the ruling, Three Pugs Gin has agreed to edit its label by 1 June 2019, and has said it is “fully supportive” of the Portman Group’s code.

Christine Ditchfield, director of Three Pugs Gin, said: “We had taken advice from many independent organisations prior to printing this label and had spent a considerable amount of time and resource and money to obtain certification to ensure we met EU regulations with regard to our label.

“When we received the complaint from the Portman Group we had in-depth conversations with them. Based on the independent panel’s decision, we are working to make relevant changes to the label for this product and have agreed with the Portman Group that this will be achieved no later than 1st June 2019.

“With this in mind, we would like to state that we are fully supportive of the Portman Group guidelines to ensure alcoholic products do not appeal to under-18s.

“We are passionate about what we do and feel that the industry as a whole, particularly craft distillers, need to be made aware sooner rather than later of the existence of the Portman Group and guidelines.”

A copy of the Portman Group’s Code of Practice on Naming, Packaging and Promotion of Alcoholic Drinks can be downloaded from the Portman Group’s website.

The trade body also offers free and confidential advice to alcohol producers, which can be accessed by contacting

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