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Waitrose and partners sell in their CHRISTMAS series of products an EXTRA THICK VANILLA CREAM which is described at the top of the back label as a

“Sweetened blend of pasteurised extra thick double cream, double cream from Jersey breed cows with [LUXARDO] Vanilla and Vanilla seeds,”

and lists in its ingredients:

Double cream (milk), jersey double cream (milk), sugar, Luxardo (R) Vanilla (5%), flavouring, exhausted vanilla seeds

The product package seems to make no mention in these two key information areas of any alcoholic content or percentage whatsoever, although Bob does wonder why vanilla ingredients may be so fancy that they have a trademarked brand. He notices at the bottom of the back label a note that

LUXARDO is a registered trademark of Girolamo Luxardo S.p.A. Waitrose is an authorised user thereof.

Which confirms his interpretation without making any indication of alcoholic content.

But after buying a cup on clearance, and not needing any staff approval of appropriate age for alcoholic product purchase, Bob notices that the product tastes of rum, and begins posting on stack exchange to find out whether the legal situation would suggest if there is possibly any liquor in the product at all, before then re-examining the usually less-interesting parts of the labelling as he picks the package up to transcribe the ingredients list and product description. He notices an inconspicuous note in small but CAPITAL print at the bottom right of the front label that states

CONTAINS ALCOHOL

Then he sees that the front centre product name in large print states EXTRA THICK VANILLA CREAM but has a very small printed note following it: “with LUXARDO Vanilla Liqueur”, though the more brightly coloured top of the package which Bob had read much more carefully before buying it simply read:

WAITROSE & PARTNERS CHRISTMAS

EXTRA THICK VANILLA CREAM Best before 8th Jan Keep Refrigerated

Nowhere does this product indicate an alcohol by volume percentage or anything similar. What is the legal status of this product and its packaging?

TylerDurden
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2 Answers2

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ABV labelling is only required where it is above 1.2%

Presumably, the amount of liqueur used doesn’t bring the alcohol content to that level.

Dale M
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4

An image from waitrose.com, described below.

From waitrose.com, here is an image (the best quality I could find online) of the 'front' of the container. To the right of "WAITROSE EXTRA THICK VANILLA CREAM" etc there is a column of data. The column is divided into two sections. In the second section, which indicates what is in each 30ml serving (about two tablespoons), there is a number I can't quite read. To the left of this reads "CONTAINS ALCOHOL" followed by one or two characters on the blue background.

Is it legal to sell Christmas themed products that taste of liqueur but have no clear/apparent indication of any alcoholic contents on the label?

Regardless of the time of year, drinks with more than 1.2% alcohol by volume (ABV) must show a warning.

The product package seems to make no mention in these two key information areas of any alcoholic content or percentage whatsoever

This particular package says "CONTAINS ALCOHOL".

What is the legal status of this product and its packaging?

It seems legal.

The mandatory information is within the field of vision. I assume the mandatory information has been printed with an x-height of 1.2 millimetres or more. Certainly the "CONTAINS ALCOHOL" is as legible in this poor quality image as the "Vanilla Liqueur".

Lag
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