Alcohol Marketing to Students in the UK: The Rules, Age Checks and What Works

The short answer

Yes, brands can sample alcohol to university students in the UK. Every person who receives a sample must be 18 or over, the activity must not appeal particularly to under-18s, and the marketing around it must follow the CAP Code and the Portman Group’s Code of Practice. The hard part is proving it. First-year halls mix 18-year-olds with students who are still 17, so the age check has to be designed into the activation from the start.

This is a practical summary for marketers, not legal advice: check specifics with your legal team and the relevant licensing authority. The licensing points cover England and Wales; Scotland and Northern Ireland have their own regimes.

Which rules apply to alcohol sampling to students

Three overlapping layers of rules apply, and a sampling programme has to satisfy all three.

CAP Code section 18

The principle of section 18 is that alcohol marketing “should not be targeted at people under 18”. The rules that matter most for student work:

• Rule 18.14: marketing “must not be likely to appeal particularly to people under 18, especially by reflecting or being associated with youth culture”.

• Rule 18.15: marketing must not be directed at under-18s through the choice of media or context, and “No medium should be used to advertise alcoholic drinks if more than 25% of its audience is under 18 years of age.”

• Rule 18.16: “People shown drinking or playing a significant role must neither be nor seem to be under 25.”

• Rules 18.2 and 18.3: marketing must not imply that alcohol “can enhance confidence or popularity”, or that it is “a key component of the success of a personal relationship or social event”.

• Rule 18.10: a promotion “must not imply, condone or encourage excessive consumption of alcohol.”

Freshers is, almost by definition, youth culture and social success. Creative that leans on the first week of university, making friends or a big night out can drift towards rules 18.3 and 18.14.

The 25% rule is the one to evidence. In a 2023 ruling on a student money website, the ASA noted that Scottish students often start university at 17 and required the advertiser to show that under-18s made up less than 25% of its audience. CAP’s current advice is to use “any and all available age-gating tools and technology, along with any available data” to support targeting.

The Portman Group Code and its sampling guidance

The Portman Group Code applies to the activity itself. Rule 3.2(h) says a drink, its packaging and any promotional material or activity should not have a particular appeal to under-18s, and since November 2023 that explicitly covers branded merchandise. Rule 3.2(f) rules out encouraging illegal, irresponsible or immoderate consumption.

The Portman Group’s Product Sampling guidance note (March 2019) defines sampling as “the unconditional giving away of alcohol to the general public in a public place” and sets out what good practice looks like:

• Offer samples only to people over 18. If in doubt, ask for proof such as a driving licence, passport or PASS-accredited card, and if doubt remains, “politely refuse to offer them a sample.”

• Keep each sample to no more than 1.5 units on-trade or 0.5 units off-trade. Units are volume in ml multiplied by ABV, divided by 1,000.

• Do not provide samples to anyone who appears intoxicated, and make sure the sample is drunk by the person who received it.

• Use sampling staff who are, and look, over 18, and who can give ABV and unit information.

• Display responsible drinking messages, including a reference to Drinkaware.

• Avoid areas that attract or appeal predominantly to children and young people.

Challenge 25 and licensing basics

Challenge 25 was created by the Retail of Alcohol Standards Group in 2009. Its rule is simple: if a person looks under 25, ask for proof of age, and if they cannot provide it, the alcohol does not change hands. In Scotland it is compulsory for licensed premises.

On licensed premises in England and Wales, the mandatory licensing conditions require an age verification policy. Anyone who appears under 18, or an older age the policy sets, must produce identification bearing their photograph, date of birth and either a holographic mark or an ultraviolet feature. Selling alcohol to children is an offence under section 146 of the Licensing Act 2003, and buying it on their behalf is an offence under section 149.

Free samples need care. It is the sale by retail of alcohol that is licensable. Barnsley Council’s licensing guidance puts it plainly: giving alcohol away for free is not a licensable activity, but free alcohol offered only to paying customers involves a financial transaction and needs a licence. The same guidance adds that alcohol must still not be given to children or vulnerable people. If a sample is tied to a purchase, a ticket or an entry fee, treat it as a sale and check the licensing position before you brief anyone.

Why halls run alcohol as a separate activation

A first-year hall of residence is a mixed-age audience. Most residents are adults, but some are still 17 when they arrive; the ASA has noted that Scottish students often start university at 17. That has two consequences.

First, the hall and the university decide. Each accommodation provider and university chooses whether to accept alcohol samples at all. Where they do, they take the delivery and take responsibility for distributing the samples responsibly, to residents aged 18 and over. That is why Dig In runs alcohol as a separate activation in halls rather than as part of the general Welcome Bag, with a Challenge 25 brief for hall teams. See how that works on our alcohol sampling page.

Second, everything around the activation needs the same discipline: the QR code, the landing page, the follow-up email and any social content. Age-gate them, keep the audience data and be ready to show that under-18s are well below a quarter of the audience.

What works: a compliant student alcohol activation

Before the activation

• Define the audience as 18 and over and decide how you will prove it: an age-verified list, an ID check at hand-over, or both.

• Size the sample within the Portman guidance and work out the units.

• Check creative against CAP section 18 and Portman rule 3.2: no youth culture cues, nobody who looks under 25, no promise of confidence or social success.

• Brief every distributor on Challenge 25, acceptable ID, a refusal script and what to do if someone appears intoxicated.

• Confirm the licensing position with the venue or accommodation provider, especially if anything is sold or ticketed.

On the day

• Ask anyone who looks under 25 for photo ID, and refuse politely if there is none.

• One sample per person, drunk by that person.

• Give ABV and unit information and a responsible drinking message.

Afterwards

• Keep a record of ID checks and refusals.

• Survey recipients on taste, purchase intent and where they would buy. Dig In has collected over a million survey responses since 2016, and our measurement approach sets out how results are reported.

Choose the right occasion

Attach the product to a moderate, specific occasion, such as a meal with flatmates or a match on television. That keeps creative clear of rule 18.3 and gives students a reason to buy again.

Low and no alcohol

The Health Survey for England found that 75% of 16 to 24 year olds drank alcohol in the previous 12 months in 2022, which leaves a quarter who did not. Alcohol-free variants can reach that group under their own rules. CAP rule 18.23 applies the same 25% audience limit to alcohol alternatives at or under 0.5% ABV, rule 18.19 requires a prominent ABV statement, and references that share an alcohol brand’s name without naming the alternative are likely to be read as alcohol advertising under rule 18.18.

What this means for brands

• Students aged 18 and over are a legitimate audience, and the rules are workable if age assurance is built in from the start.

• A general Welcome Bag is the wrong vehicle for alcohol. Use a separate activation where every recipient is checked.

• Keep the evidence: audience data, ID records and creative sign-off.

• Survey recipients for purchase intent and taste, and compare them with other student sampling results.

Questions brands ask

Can you sample alcohol to university students in the UK?

Yes, provided every recipient is 18 or over, the activity does not appeal particularly to under-18s and the marketing complies with CAP Code section 18 and the Portman Group Code. Because first-year halls include some 17-year-olds, samples should be handed over only after an age check.

Do you need a licence to give away free alcohol samples?

In England and Wales the sale by retail of alcohol is the licensable activity, so a genuinely free sample is not usually licensable. If the sample depends on a purchase, ticket or entry fee, it may be treated as a sale. Check with the local licensing authority, and never give alcohol to under-18s.

What ID should be accepted for alcohol sampling?

The Portman Group’s sampling guidance names a driving licence, a passport or a PASS-accredited proof of age card. On licensed premises, the mandatory age verification condition requires photo ID showing a date of birth and either a holographic mark or an ultraviolet feature.

What is the 25% rule in alcohol advertising?

CAP Code rule 18.15 says no medium should be used to advertise alcoholic drinks if more than 25% of its audience is under 18. Rule 18.23 applies the same limit to alcohol alternatives at or under 0.5% ABV.

Can alcohol be included in a student welcome pack?

Not in a general welcome pack, because recipients cannot all be age-checked and some will be 17. Use a separate activation where each recipient’s age is verified first.

Planning a student alcohol activation for 2027? Talk to us about an age-checked brief.

Sources

• Committees of Advertising Practice / Advertising Standards Authority, CAP Code (Edition 12), Section 18: Alcohol (accessed 2026).

• CAP / ASA, Alcohol: Targeting and Appeal to Under 18s (Advice Online) (2025).

• Advertising Standards Authority, ASA Ruling on Grip Media Ltd (2023).

• Portman Group, Guidance Note: Product Sampling (2019).

• Portman Group, Portman Group revises Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks to enhance protection for under-18s (2023).

• Portman Group, Codes of Practice (accessed 2026).

• Retail of Alcohol Standards Group, Challenge 25 (2009).

• legislation.gov.uk, The Licensing Act 2003 (Mandatory Licensing Conditions) (Amendment) Order 2014, Schedule (2014).

• Home Office, Revised guidance issued under section 182 of the Licensing Act 2003 (September 2026) (2026).

• Barnsley Council, Frequently asked questions about premises licence applications (accessed 2026).

• NHS England Digital, Health Survey for England 2022, Part 1: Adult drinking (2024).