Background
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
Two paid-for Facebook posts by BrewDog, seen in July 2026:
a. The first post included text which stated, “BOTTOMLESS BEER ALERT! Celebrate with 90 minutes of unlimited fresh beer for just £19.95 in England this weekend! Who’s in?” The post included a video featuring two men drinking one beer each with a caption above them stating, “When bottomless beers start to hit you”, followed by rapid images of 12 other alcoholic beverages appearing on screen.
b. The second post included text which stated, “BOTTOMLESS BEER ALERT! Celebrate with 90 minutes of unlimited fresh beer for just £19.95 in England this weekend! Who’s in?” The post included a video featuring a woman, with the caption “you” next to her, running towards a glass of beer which included text on top of it stating, “Unlimited beers for 90 mins under £20”.
Issue
The ASA challenged whether:
- ad (a) implied that alcohol had therapeutic qualities and was capable of changing mood, and therefore breached the Code; and
- ads (a) and (b) were socially irresponsible because they implied, condoned, or encouraged excessive consumption of alcohol.
Response
1. Tilray Brands UK Ltd t/a BrewDog stated that ad (a) did not portray alcohol as capable of changing mood, behaviour or physical condition. They said the wording “When bottomless beers start to hit you” was intended as an informal and humorous social media reference associated with a bottomless beer promotion rather than a claim that alcohol caused a desirable change and improved confidence, popularity, wellbeing, social success, physical or mental ability, or had therapeutic benefits.
2. Brewdog stated that ads (a) and (b) did not imply, condone or encourage excessive alcohol consumption. They said the references to “bottomless”, “unlimited” and “90 minutes” simply described a fixed-price, time-limited hospitality offer rather than encouraging consumers to maximise their alcohol consumption.
In relation to ad (a), they said the sequence of beers highlighted the range of beer styles included in the offer rather than suggesting the quantity consumers should drink. The ad did not tell consumers to maximise their consumption or present heavy drinking as desirable.
In relation to ad (b), they said the woman labelled “you” shown running towards the pint alongside the text “Unlimited beers for 90 mins under £20”, was a humorous expression of enthusiasm for the promotion rather than encouragement to drink excessively. They further said it did not depict alcohol consumption, rapid drinking, intoxication or behaviour indicative of excessive consumption.
Whilst maintaining that the ads did not breach the CAP Code, BrewDog said they had reviewed their processes. They planned to introduce stronger review procedures, involve their legal team before publication, review live alcohol-related advertising, give further CAP Code guidance and training, refresh guidance for local marketing teams and strengthen oversight of local social media activity.
Assessment
1. Upheld
The CAP Code said marketing communications must not imply that alcohol has therapeutic qualities. Alcohol must not be portrayed as capable of changing mood, physical condition or behaviour or as a source of nourishment.
The ASA noted that ad (a) included the text “When bottomless beers start to hit you”, appearing while two men were drinking and before the rapid sequence of further alcoholic drinks. We considered consumers were likely to understand the phrase “start to hit you”, in the context of alcohol, as referring to the point at which its intoxicating effects began to become noticeable. We noted before drinking, the two men were shown with relatively neutral expressions. Immediately after taking a drink, however, their expressions became noticeably more satisfied and positive. We considered that visual change, together with the phrase, suggested that after consuming alcohol, a person would begin to feel a change in their mood.
In that context, we concluded that ad (a) portrayed alcohol as capable of changing a person’s mood, physical condition or behaviour.
On that point, ad (a) breached CAP Code (Edition 12) rule 18.7 (Alcohol).
2. Upheld
The CAP Code stated that marketing communications must be socially responsible and must contain nothing that was likely to lead people to adopt styles of drinking that were unwise. The CAP Code also stated that marketing communications which included a promotion must not imply, condone or encourage excessive consumption of alcohol.
Ads (a) and (b) both promoted 90 minutes of “bottomless” and “unlimited” beer for £19.95. We considered that consumers were likely to understand those claims to mean that they could drink as much beer as they wished during the limited duration of the 90-minute offer.
In ad (a), two men were shown drinking beer before a rapid sequence of 12 further alcoholic drinks appeared on screen. Whilst BrewDog said the sequence was intended to show the range of beers available, we considered that was not made clear. Instead, in the context of the claims “bottomless beers” and “90 minutes of unlimited fresh beer”, we considered consumers were likely to interpret the sequence as representing the quantity of alcohol that could be consumed during the 90-minute promotion period.
In ad (b), a woman labelled with the text “you” in the video was shown running towards a glass of beer alongside the claim “Unlimited beers for 90 mins under £20”. Whilst we acknowledged BrewDog's view that the scene was intended to show enthusiasm for the promotion rather than for drinking the beer itself, we considered that, in the context in which it appeared, enthusiasm for the offer was inseparable from enthusiasm for consuming unlimited alcohol. We also considered that depicting the woman running towards the beer, in the context of an offer available for a limited 90-minute period, suggested an eagerness to begin drinking as quickly as possible to maximise the amount that could be consumed within that time. The woman’s broad smile, exaggerated slow-motion run and the accompanying dramatic build-up in the soundtrack heightened that impression.
For the reasons given, we considered that both ads (a) and (b) presented excessive consumption of alcohol as a desirable way to use the promotion. We therefore concluded that the ads were socially irresponsible, suggested styles of drinking that were unwise, and implied, condoned and encouraged excessive consumption of alcohol.
On that point, the ads breached CAP Code (Edition 12) rules 18.1 and 18.10 (Alcohol).
Action
Ads (a) and (b) must not appear again in the form investigated. We told Tilray Brands UK Ltd t/a BrewDog to ensure that future ads were socially responsible, contained nothing that was likely to lead people to adopt styles of drinking that were unwise, and did not imply, condone or encourage excessive consumption of alcohol. We also told them to ensure their future ads did not portray alcohol as capable of changing mood, physical condition or behaviour.
