- 02/05/2026
- Posted by: Marta
- Category: Questions and answers
Dear Dario,
I was struck by the prime-time TV commercial for Camatti Amaro on La 7: "useful for sea voyages" and "suitable for athletes," "reviving," "heartening," and "giving a sense of pleasant relief." The ad is accompanied by the slogan "Drink responsibly – but drink."
Is everything in order?
Thank you very much, Elena
The lawyer Dario Dongo, Ph.D. in international food law, answers
Dear Elena,
Amaro Camatti has a century-old history (Great Italian Food Trade, 2017), little known outside of Genoa and Liguria until the advertisement in question. This advertisement, however, is "over the top" in several respects.
Amaro Camatti, analysis of the commercial
'Suitable for athletes'
Regulation (EU) No. 609/2013, in reforming the rules governing 'Food for Specific Groups', removed from its scope sports foods, which were previously subject to it. These products are now subject to the general rules established for commonly consumed foods (Dongo, 2026).
Regulation (EU) No. 1169/11 on commercial information relating to foods establishes some general criteria for transparency and fairness of commercial practices which are expressed in certain prohibitions, including those of:
⁃ mislead the consumer regarding the essential characteristics of the product;
⁃ attribute to the product effects or properties that it does not possess (Article 7.1, letters 'a' and 'b'; Article 36.2).
The claim 'suitable for athletes' in a food advertisement implies that the food, as may be the case with an isotonic drink, has been formulated with this target in mind, meaning that it has certain nutritional characteristics consistent with the needs of those who practice physical exercise.
However, this claim is not permitted in the advertising of any alcoholic beverage. This is even more true since Regulation (EC) No. 1924/06 expressly prohibits the use of 'nutrition' and 'health' claims on beverages with an alcohol content exceeding 1,2%, except for nutritional claims regarding:
– a low alcohol content or a reduction in alcohol content, or
– the reduction in energy content (Article 4.3).
'It revives, it cheers up, it gives a sense of relief'
The suggestion that Amaro Camatti can 'revive', 'hearten' and offer 'a sense of relief' – although suggestive, with a reference to advertisements from the early 20th century – can be classified as a health claim referring to psychological and behavioural functions, pursuant to Regulation (EU) No. 1924/2006, Article 13.1.b.
Furthermore, such indications – in addition to being subject to a prior authorization regime at the European level, based on scientific evidence that must be validated by EFSA (European Food Safety Authority) – are prohibited a priori on all alcoholic beverages, as mentioned in the previous paragraph.
'Useful on sea voyages'
Liqueurs often appear in the galleys of boats, both in real life and in television commercials. However, even in this case, explicitly referring to the "usefulness" of Amaro Camatti on sea voyages can be ambiguous and therefore reprehensible.
To give you a point of comparison, let's recall the memorable commercials for Bocchino grappa with Mike Buongiorno as testimonial, in the 80s and 90s:
⁃ beyond the incipit 'Cheer up!', which today could perhaps be classified as a psychological 'health claim' and therefore prohibited
⁃ grappa was presented on the occasion of consumption ('after a good meal'), referring to only
⁃ organoleptic (e.g. 'soft') and qualitative attributes, with
⁃ endorsement from the famous presenter.
Even when the great Mike carried Bocchino grappa to a snowy Alpine peak (reached by helicopter), the slogan was 'Always higher!', without any prompting that, in any case, would have added nothing.
'Drink responsibly – but drink'
The phrase "Drink responsibly – but drink" is definitive confirmation that neither the owner of the Amaro Camatti trademark nor the operators in the communications chain subjected the ad to a preliminary compliance check.
Consumer Code
The message in question may constitute an unfair commercial practice pursuant to the Consumer Code (Legislative Decree 206/2005), in particular:
⁃ a commercial practice is unfair if it is contrary to professional diligence and is likely to significantly distort the economic behaviour of the average consumer (Article 20.2);
⁃ the message 'Drink responsibly – but drink' can appear to be such, presenting a reminder to consume the alcoholic beverage as 'responsible';
⁃ This message may at the same time be considered misleading due to the contradiction between the formal reminder of responsibility and the actual command to drink 'in such a way as to induce consumers to neglect the normal rules of prudence and vigilance' (Article 21).
Advertising Self-Regulatory Code
The Advertising Self-Regulation Code, in turn, establishes that "commercial communications relating to alcoholic beverages must not conflict with the need to promote consumption patterns inspired by moderation, fairness, and responsibility. This is to protect the primary interest of individuals, especially children and adolescents, in a family, social, and working life protected from the consequences associated with alcohol abuse" (IAP, Article 22).
The slogan in question, while mentioning responsibility, immediately subordinates it to the imperative "but drink," thus nullifying any call for moderation. The adversarial "but" transforms the reference to responsibility into a simple ritual formula, while the command "drink" constitutes the substantive (and illicit) message.
Conclusions
Significant investments in an advertising campaign should always be preceded by a thorough prior check to ensure that the content and methods of expression comply with applicable legislation and self-regulation codes.
Compliance verification is essential both for the advertising client – who is primarily responsible – and for marketing agencies and audiovisual service providers, who in turn may be held accountable for the most serious violations.
Our FARE (Food and Agriculture Requirements) team is available to all operators who intend to manage their advertising investments responsibly, without running the unnecessary risk of financial penalties and reputational damage.
Cordially
Dario
Bibliography
Legislative Decree no. 206 of September 6, 2005. Consumer Code. Normattiva (last updated on April 18, 2026). https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2005-09-06;206
⁃ Legislative Decree 8 November 2021, no. 208. Implementation of Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending Directive 2010/13/EU on the coordination of certain provisions laid down by law, regulation, or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual Media Services Directive), in light of evolving market realities. (Last updated on 17/04/2024). https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2021-11-08;208
⁃ Dongo, D. (2026, January 5). Functional foods and specialized nutrition in Italy. GIFT (Great Italian Food Trade). https://www.greatitalianfoodtrade.it/nutrizione-specializzata/alimenti-funzionali-nutrizione-specializzata-italia/
⁃ GIFT, Editorial Staff (2017, August 1). Amaro Camatti, a typical Genoese liqueur. GIFT (Great Italian Food Trade). https://www.greatitalianfoodtrade.it/liquori-e-cocktail/amaro-camatti-liquore-tipico-genovese/
⁃ Institute for Advertising Self-Regulation (IAP). Advertising Self-Regulation Code, 71st edition, effective October 30, 2024
⁃ Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market For Digital Services and amending Directive 2000/31/EC (Digital Services Act). http://data.europa.eu/eli/reg/2022/2065/oj
