Dragon Soop Peach & Raspberry 500ml, Case of 8

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NIADA is the alliance which facilitates co-operation among voluntary and community sector organisations supporting those affected by alcohol and drug use, and their families. We as a collective membership group wish to submit a complaint about caffeinated alcoholic drinks. 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. Red Bull Energy Drink's special formula contains ingredients of high quality: Caffeine, Taurine, B-Group Vitamins, Sugars, Alpine Water. And a drink must not suggest any link with therapeutic qualities, mood altering or enhanced mental or physical capabilities – 3.2(j).

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. 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. The amount of sugars in a can of Red Bull Energy Drink is comparable to the level of sugars in an equivalent amount of apple or orange juice - 11 g per 100 ml.

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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. 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.

Moderately active - Do light to moderate intensity exercise 3-4 times a week. E.g. going to the gym / swimming / cycling / horse riding / dance classes / playing golf. Daily dog walking (brisk pace, twice a day). 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 NIADA had made a number of unreliable observations, incorrect contentions and factual mistakes that the company wished to comment on. 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. 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. The Panel then considered specific flavour variants that it believed warranted further discussion, as the Panel considered that some flavour variants carried additional connotations that had not been captured in the Strawberry and Lime 2015 precedent or discussion so far.

The company stated that NIADA could not claim to have knowledge of what ‘most young people’ did, as its day-to-day work and research was conducted with a very specific group of young people, all of whom had serious alcohol or substance abuse issues. The company explained that this research group could not in any way be seen to be representative of the population as a whole. The company argued that any extrapolations about the behaviour and attitudes of the wider population based on research carried out solely with this group would be skewed, misleading and far from impartial. There must be no undue emphasis on the drink’s higher alcoholic strength, or intoxicating effect – 3.2(a); Firstly, the company highlighted that NIADA had stated that it wished to submit “a complaint about caffeinated alcoholic drinks”, but that the organisation had only singled out Dragon Soop from a group of other caffeinated alcoholic drinks. The company stated that the organisation had done this based on the unscientific basis that Dragon Soop is what NIADA called “the more popular drink of choice.” 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). 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).

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 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. Red Bull Energy Drink is appreciated worldwide by top athletes, students, and in highly demanding professions as well as during long drives. 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.

The company agreed that four participants in the focus group had provided quotes that demonstrated they used Dragon Soop irresponsibly, and for one participant, immoderately. However, the company stated that the participants in this focus group were young people with known alcohol abuse problems and so whichever alcoholic drink they chose, it would be likely that they would consume it irresponsibly and immoderately. The company stated that whilst their responses were wholly regrettable, they were not surprising and could not be admissible because they constituted a skewed unrepresentative sample. The company explained that if NIADA had put together a similar small sample group of its clients who preferred other types of alcohol such as rum, vodka or cider, and were then asked about their abuse of that drink, they would likely give similar answers. 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 A drink should not suggest any association with bravado, violent, aggressive, dangerous, anti-social or illegal behaviour – 3.2(b);

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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. 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. 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. The company explained that in 2015, Dragon Soop was fully investigated by the Independent Complaints Panel (Panel) under Code rules 3.2(f) and 3.2(h) which it found to not be in breach. The company highlighted that it had received a letter from the Chair of the Panel that there had not been any breach of the Code and that the decision was final. 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.