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. The company also provided examples of the use of snake imagery for a diverse range of other products, including cars and other alcohol brands. 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 considered that this also contributed to the overall impression that the product was inherently linked to poison, danger and intimidation, and that it therefore created an association with bravado.

The muted colour scheme, the font and the imagery were not considered to have a particular appeal to under 18s (3.2(h) – particular appeal to under-18s); The company noted the Panel’s rationale that Dragon Soop Venom was significantly different to the rest of the Dragon Soop range as it considered that Venom did not indicate its flavour and was marketed mainly on the danger and intimidation associated with venom, alongside the aggressive snake imagery. The company also noted the Panel’s point that Dragon Soop Venom had a clear association with poison, which implied that the drink was dangerous to consume and therefore required bravado to do so. At NIADA we have serious concerns about these high caffeinated and alcoholic drinks, especially Dragon Soop, as so many young people are consuming this drink usually in large quantities. Our focus group concluded that while young people drink the cans, they also mix them with other substances. One 16-year-old female reported ‘they are sweet and fruity flavours they can be mixed with vodka’. Scheduled for self-release at the end of March, his Subtle As Dynamite album coincides with a big tour across Scotland throughout April and May, supported by Dragon Soop. We spoke to Graham about his upcoming tour, going viral, game shows and eating too many crisps.

For young people, both large quantities of caffeine and alcohol can be harmful and both of these together in one drink is very concerning. In addition to this, it is worth noting that one can contains more than double the daily recommended limit of caffeine and can exceed the limit of alcohol units daily. Throughout April and May this year you’re touring in support of your album, are there any places you particularly love performing?

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. Each can of Dragon Soop has caffeine equivalent to more than two shots of espresso and four units of alcohol A complaint against Corinthian Brand’s Dragon Soop Venom was upheld by the alcohol industry’s Independent Complaints Panel, which found that the product’s name and imagery suggested it “required bravado to drink it”.The company then explained that in terms of the overall impression of the product, there was no evidence of confusion about the offering, its marketing, or the can artwork amongst its target audience. The company reiterated that despite selling over 3 million cans of Dragon Soop Venom since its launch in October 2018, it had not received any complaints regarding the Venom name or branding, or any concerns that the brand was associated with bravado or was linked to boldness that was intended to impress or intimidate. In summary of the above, the Panel concluded that Dragon Soop Venom did breach Code rule 3.2(b), but did not breach Code rules 3.1, 3.2(a), 3.2(f), 3.2(h),3.2(j) or any other part of the Code. Action by company: The Panel considered that the product factually and neutrally explained the ingredients of the product and did not overemphasise the caffeine content or the effect that drinking caffeine and alcohol could have on consumers. A NIADA spokesperson commented: “NIADA are delighted that one of the complaints lodged against the drink Dragon Soop has been upheld.

The Panel considered the name Venom would be recognised by the majority of UK consumers to mean ‘poison’ in its day-to-day usage and noted this in the context of a beverage which had a relatively high alcohol and caffeine content. A previous complaint made by the NIADA against Dragon Soop in September 2022 was not upheld by the Independent Complaints Panel about its products being mistaken for an energy drink. Commenting on the decision, the chair of the Independent Complaints Panel, Nicola Williams, said: “Whilst creativity and brands expressing their identities through their products is to be encouraged, care must be taken to avoid associating alcohol with bravado, or suggesting a consumer must be daring to drink it. We are satisfied with the response to this concern and look forward to any amendments made to the marketing of the brand as a result.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 then discussed the word ‘venom’ and whether it had any other well-known connotations or meanings. The Panel noted that the company had provided a definition from Urban Dictionary that stated that the word was used by younger people to mean ‘cool’ or attention grabbing. The Panel discussed this online interpretation and considered that, while a minority demographic of the UK population may use the word to mean ‘cool’, the majority of UK consumers would recognise the word to mean ‘poison’ in its day-to-day usage. In addition to this, the Panel also considered it was unlikely that the company intended ‘venom’ to mean cool in the context of the product, particularly when viewed alongside the snake imagery. The Panel considered that the product factually and neutrally explained the ingredients of the product and did not overemphasise the caffeine content or the effect that drinking caffeine and alcohol could have on consumers. Furthermore, the ‘unique drinking experience’ stated on the product was in relation to how the product tasted and did not suggest the drink had therapeutic qualities (3.2(j) – therapeutic qualities). The NIADA made a complaint against 11 Dragon Soop products in September last year, which was not upheld by the Independent Complaints Panel.

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 said 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. 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. NIADA continue to have concerns over the promotion of caffeinated alcoholic drinks particularly for younger users where the risk of the caffeine masking the effects of the alcohol may lead to increased health harms and disinhibited risky behaviours.” The company then explained that Dragon Soop Venom had similar dominant flavour notes to its on-trade namesake which included orange, other fruit hints and a touch of the rich, round caramel associated with Bourbon.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. 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. 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. The high strength content encourages binge and excessive drinking and leads to irresponsible behaviour as most young people drink more than one can breaching the anti-social behaviour code of conduct. The high caffeine intake along with the high alcohol content masks the effects of drunkenness. Hence, young people don’t realise how intoxicated they are, which can lead to becoming unwell and engaging in risky behaviours.