Most on-pack promotions don’t break the law on purpose.

They just miss things: vague terms, hidden barriers, unreadable text. I offer independent audits to catch these issues before they become a ruling.

Running a promotion on your product packaging? Whether it’s a prize draw, instant win, or collect-to-win mechanic, there are rules, and plenty of ways to get it wrong.

This page gives you a practical guide to the rules that apply in the UK and beyond. You’ll learn what needs to be shown on pack, what risks to avoid, how different countries handle prize promotions, and what to do when space is limited, like on small cubes or lip balm.

This guide is for general information only. It is not legal advice and does not guarantee compliance. If your campaign is high-value or involves multiple countries, speak to a qualified legal professional.

Who is this for?

Brand managers planning on-pack campaigns
Creative and production teams responsible for pack messaging
Marketing and compliance leads in FMCG
Indie brands running their first giveaway
Anyone asking: “Can we say this on pack?”

UK rules: what you need to cover

Be honest and upfront. Under UK consumer protection law, you must not mislead buyers. That includes:

Saying someone has won when they haven’t
Hiding key terms in tiny or inaccessible places
Overstating the odds or number of prizes

You must show key info before purchase, not just inside the pack.

Follow the CAP Code (ASA Guidelines)

The ASA expects:

Clear entry instructions
Eligibility (age, residency) stated up front
A closing date
No unnecessary disappointment (e.g. only one real prize despite “hundreds to be won”)
Fair and auditable winner selection

Avoid running an illegal lottery

Under UK law, a lottery is any promotion that includes:

Payment to enter
Chance
A prize

You can avoid this by offering a free entry route (e.g. postal) or by making it a genuine skill-based competition.

If you collect personal info:

Say what you’re collecting and why
Link to a privacy policy
Get clear consent for any future marketing
Allow opt-outs and deletions

Special care for children

If your product or promo targets children:

Avoid pester-power messaging (“Get your mum to buy it!”)
Make rules simple and transparent
Disclose the need for parental permission if required

Tiny text: a big problem

Using small, faint, or hidden text to display key information is one of the most common ways brands get into trouble.

Don’t:

Hide terms in 5pt grey-on-foil
Print crucial conditions under a flap without signposting
Say “T&Cs apply” and nothing else

Do:

Use at least 6–7pt font in high contrast
Include a link to full terms (e.g. brand.com/win)
Make it obvious where and how customers can find the rules

If customers have to squint, that’s a red flag. Clarity builds trust and avoids complaints.

What about tiny packs?

Some products just don’t give you much real estate. But the rules don’t go away just because your label is small.

The Challenge:

Tiny packs still need to show what the promo is, who it’s for, and how to find the terms, in a way customers can actually see.

How to handle it

Keep it specific
- Avoid vague slogans. Say what’s actually being offered.
Link to the rules
- Include a short, memorable URL (e.g. brand.com/win).
- Use a URL shortener.
- QR codes are fine, but don’t rely on them alone.
Use surrounding materials
- If your pack is too small, reinforce key terms via:
  - Multipacks
  - Shelf POS
  - Social media
  - Retailer websites

Avoid vague headlines like “Win a Weekend”

This kind of messaging sounds catchy, but it’s unclear and risky.

The problem:

What kind of weekend? A spa? Travel? Food?
Could be seen as misleading or incomplete
Lacks legal clarity and invites customer confusion

Instead, use:

Win a 2-Night Break
Win a UK Getaway
Win a Gourmet Weekend
Dine & Stay Giveaway

And back it up in the full T&Cs.

Selling in Europe? Know the local rules

If your product might be sold or seen in Europe, especially online or via resale, you need to know that each country has its own promotional laws.

Ireland

Purchase-based prize draws can count as lotteries (licensable)
Safer to include a free entry route
Terms must be available before purchase

Italy

Extremely strict
Promotions must be pre-registered
You’ll need:
- A notary or official to oversee the draw
- Hosting on Italian servers
- All content in Italian
Legal help is essential

France

Chance-based prize draws with a purchase can be illegal
Safer to run skill-based competitions
May need to file terms with a bailiff (huissier)
All T&Cs and promo content must be in French

Germany

Must treat all participants equally
Terms must be in German
GDPR is strictly enforced. Be precise with data handling

Spain

High-value prizes must be declared to the tax office
Promo may need to be registered
All terms must be in Spanish
Winners may owe tax, which must be disclosed

Pro tip: If you’re not prepared to meet these requirements, exclude certain countries explicitly in your terms and pack copy.

Most common mistakes I see

“Everyone’s a winner!” but the reward is a 10p coupon
QR code is the only way to access terms
No mention of who can enter (e.g. age, country)
Promo appears on pack, but entry mechanic is unclear
Terms link doesn’t work or redirects to a blank page

A note for small brands

You don’t need a legal team to run a simple giveaway but you do need clarity.

If you’re working with limited budget and short print runs:

Keep copy honest, specific, and readable
Avoid flashy claims if the prize is modest
Use a simple hosted terms page (even a Google Doc is better than nothing)
Say what people are getting and how they can get it

Final pre-launch checklist

Before you go to print, make sure:

Key conditions (age, eligibility, entry) are visible
Closing date is shown or clearly linked
Entry mechanic is simple and transparent
Font size is readable in real lighting
GDPR rules are followed (with privacy policy linked)
Free entry route is included if needed
Countries like Italy and Ireland are covered or excluded
T&Cs are accessible, live, and tested on mobile

Want a second opinion?

I offer independent promo audits: practical reviews of your packaging, terms, and promo structure to highlight red flags and opportunities for improvement.

What I look for:

Clarity of message
Potential for customer confusion
Legal grey areas
Missed trust-building opportunities
Brand consistency

I don’t offer legal compliance certification but I can help you avoid the most common issues before it’s too late.

Get in touch if you’d like to book a review or ask a quick question.