Dragon Soop Peach & Raspberry 500ml, Case of 8

Product Information

Heavy - Active for much of the day, walking non-stop and carrying objects. Typical jobs: hospital/ward nurse, waitressing in a busy restaurant, cleaner, porter, labourer/construction worker, gardener, farm worker. Leisure Activity Level The company then highlighted that in the interim, with the future of Dragon Soop in limbo, SHS Drinks had declared in the trade press that in May 2022 it was launching WKD X, which closely mirrored Dragon Soop with an almost identical offering. The company highlighted a quote from the article that stated that WKD X “was developed in conjunction with guidance from industry watchdog the Portman Group.” The company stated that it understood it was against Portman Group rules for SHS Drinks to suggest that the Portman Group had endorsed its brand in this way, even when a producer had consulted with the Portman Group’s Advisory Service prior to launch. The company stated that it understood that Portman Group Code rules prevented disclosure of advice given by the Advisory Service. However, given the commented printed in the article that the “onus on getting the responsibility right” had been noted by WKD, the company stated that it was hard to imagine that SHS Drinks would have gone ahead with launching WKD X in its current form if the Advisory Service had advised that it breached any aspect of the Code.

The company explained that at the time the complaint was made, Dragon Soop had 13 flavours, not 12 as stated by the complainant in the first paragraph under the header “Appeal to under 18s.” The company stated that at the time of its formal submission to the complaint, Dragon Soop now had 14 flavours. The company then examined the second paragraph under the heading entitled ‘strength’ which stated that “the high caffeine intake along with the high alcohol intake masks the effect of drunkenness”, which the company stated NIADA had not provided proof of. The company stated that the formulation did not break any of the Portman Group’s rules and that the Portman Group must agree with this because according to an SHS Drinks’ press statement, the Advisory Service had been consulted by the company prior to the launch of WKD X, which was a drink that closely mirrored Dragon Soop, and was destined for major grocery outlets in May 2022. Moderate - On your feet for much of the day, either standing or occasional slow paced walking. Typical jobs: shop assistant, teacher, chef/cook, bar worker, engineer. Taurine: Taurine is an amino acid, naturally occurring in the human body and present in the daily diet. It is involved in a wide range of biological processes. To help producers of caffeinated alcohol beverages ensure their marketing is on the right side of the Code, the Advisory Service has pulled together its top tips in its latest blog here.

FREE diet profile

The caffeine content of the products was clearly stated and there was no indication the products were linked to potential therapeutic qualities, mood or behaviour changing capabilities or benefits (3.2(j) – link with therapeutic qualities). The company stated that it recognised that while each element of the marketing and design of Dragon Soop was important, the overall impression was the most important element to avoid direct or indirect particular appeal to under-18s. Alcohol can cause abnormal heart rhythms in the body, high blood pressure and can damage the heart muscle and cause other diseases such as strokes, liver problems and some cancers. Alcohol is also high in calories and can lead to weight gain and health-related issues in that sense (British Heart Foundation). Caffeine in large amounts can also have effects on the body and health, such as increased breathing and heart rate as well as increased mental activity and physical energy. The body can also become dependent on caffeine physically and psychologically and then feel withdrawal symptoms from it (Better Health Channel). Hence, excess levels of both can have adverse effects on health, especially young people. It may be necessary to inform consumers that a product contains certain ingredients, for example high caffeine content, but this must be done in a factual and ‘non emotive’ way.” In the complaint headed paragraph ‘strength’, the company stated that NIADA had cited an unsubstantiated figure to make a subjective and misleading statement where it read “One day of drinking 3 and a half cans exceeds this limit for adults.” The company stated that the statement did not withstand rigorous scrutiny. The company explained that the same assertion could be used for any alcoholic drink which was abused by people with alcohol or substance abuse difficulties. The company highlighted that NIADA had not presented any evidence that people abused Dragon Soop more than they would abuse vodka, cider, wine or any other alcoholic beverage. The company stated that this information could not be relied upon, nor was indicative of the wider market, since the participants in the sample group were unable to limit their intake of alcohol.

B-group vitamins: Vitamins are essential micronutrients that are required for maintaining normal body functions. The Panel considered Dragon Soop Rhubarb and Custard and noted that the flavour was based on a traditional sweet and that the colour scheme of the pastel pink and yellow closely resembled these sweets. The Panel considered that there was a risk that this could have an appeal to under-18s. The Panel discussed a previous complaint case about Mr Gladstone’s Curious Emporium Range from 2017 which had a rhubarb and custard flavour. The Panel noted that the decision reflected that rhubarb and custard had a wide appeal and was not particularly appealing to under-18s. The Panel also noted that the decision noted a difference between using a sweet name as a flavour and marketing a drink in the context of sweets which Dragon Soop did not do. When considering the Dragon Soop Rhubarb and Custard flavour, the Panel concluded that the flavour had wide appeal and did not have a particular appeal to under-18s. Red Bull Energy Drink is appreciated worldwide by top athletes, students, and in highly demanding professions as well as during long drives. The use of a dragon on all product artwork, along with the claw marks did not look aggressive and did not create an association with aggressive behaviour (3.2(b) – aggressive behaviour) And a drink must not suggest any link with therapeutic qualities, mood altering or enhanced mental or physical capabilities – 3.2(j).The company stated that a company, whether it be a Code Signatory or member of the Portman Group, should be able to trust that a ‘final’ decision was final. The company explained that should the same product be subject to complaints of the same nature on more than one occasion, businesses would find it impossible to make medium to long-term planning and investment decisions. There must be no undue emphasis on the drink’s higher alcoholic strength, or intoxicating effect – 3.2(a); Inactive - Do very little exercise, going for the occasional walk (moderate pace, low intensity). Spend majority of leisure time doing activities such as watching TV, playing computer games, on the internet, reading, cooking, driving, general household chores. The company then explained that since Dragon Soop had been launched in 2010 there had only been three complaints in the intervening 12 years (the complaint from 2015 which was considered against Dragon Soop Strawberry and Lime, which was found not to be in breach of the Code, and the other two which were currently subject to investigation.) The company stated that this was a remarkably low figure for a brand that sold 13.6 million cans per year.

The Panel then considered Dragon Soop Red Kola further under rule 3.2(h). The Panel noted that the name Red Kola sounded similar to the retro sweet ‘Cola Cubes’. However, the Panel considered that any reference to the sweet name was purely incidental, but that even if there was a link, the Panel concluded that ‘cola cubes’ as a flavour had a wide appeal and did not appeal particularly to under-18s. The company noted that there were specific cues which had been defined by the Panel as possibly having a particular appeal to under-18s. ‘Bright, high contrast colours’ were an example and the company highlighted that many alcoholic brands featured colour schemes which could be described in this way. In contrast, the company explained that Dragon Soop was specifically designed not to be garish or particularly bright and that the different colours used throughout the range were to denote the various flavours within the range, as was common practice for flavoured alcoholic beverages. Complaints against 11 Dragon Soop products were not upheld by the alcohol industry’s Independent Complaints Panel (ICP). A copy of the full decisions are available here and here.

The company stated that NIADA seemed to make the general case that high strength alcohol in and of itself caused anti-social behaviour. However, the company stated that if this was true, a well-known vodka brand with a 37.5% ABV would be far more likely to cause excess drinking and anti-social behaviour than Dragon Soop at 7.5% ABV. One 250ml can of Red Bull Energy Drink contains 80 mg of caffeine, about the same amount as in a cup of home-brewed coffee. The company stated that it had respect for the work of specialist organisations like the Northern Ireland Alcohol and Drugs Alliance (NIADA) and supported the work it did to aid and educate the often vulnerable, under-privileged young people who were addicted to immoderate and dangerous behaviour with regard to substances and alcohol. However, the company stated that NIADA’s focus was narrow and specialised and its evidence that had been taken solely from its work with this particular group was not impartial.

A factual statement that a product contains a particular ingredient, for example high caffeine content, is unlikely in itself to be problematic under the Code.” Light - Have a job that involves long periods of sitting (office-based / driving) or are home-based and sitting for much of the day. Typical jobs: office worker, sales rep, bus/taxi/lorry driver.The communication of the products’ alcoholic strength had been conveyed in a factual and proportionate way and there was nothing on the cans that placed undue emphasis on the products’ higher alcoholic strength or intoxicating effect(3.2(a) – emphasis of higher alcoholic strength). As a membership group that delivers alcohol and drug services daily to a large number of young clients, we feel the need to raise our concerns around this drink as It breaches numerous codes of conduct. Therefore, we are asking you to consider all points made above and take on board our recommendations to reduce both the alcohol and caffeine content and rethink the marketing strategies of this brand and particularly the impact it has on our young people and their health. The Panel considered each of the rules in relation to the products. In terms of the rules, they noted: Under the ‘Health effects concerns’ paragraph of the complaint, the company highlighted that NIADA had stated that “so many young people are consuming this drink usually in large quantities.” The company stated that this claim was based on shaky evidence of one small focus group made up of young, often under-age, substance and alcohol abusers. The company stated that there was no proof that Dragon Soop was consumed in greater excess than any other alcoholic drink. Additionally, the company stated that young people who did consume alcohol in great excess might reasonably be supposed to consume any popular alcoholic drink in large quantities. With regard to the research submitted by NIADA in support of its complaint, the company noted from previous Panel rulings the stringent standards that the Panel required when research was accepted. The company stated that it was confident that the Panel would agree that NIADA’s research did not meet these standards.