The most valuable brand on the estate cannot appear in the game.
Hawkstone turned over £21.3 million in the year to March 2025 and it is the obvious thing to put in a game about this farm. It cannot go in, and the rule that stops it is four sentences long.
The rule, stated plainly.
The CAP Code — the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing, enforced by the Advertising Standards Authority — provides at rule 18.15 that marketing communications for alcoholic drinks must not be directed at people under eighteen through the selection of media or context, and must not appear in a medium where more than twenty-five per cent of the audience is under eighteen.
A farming game attached to a family television programme would not clear that threshold. It might not clear it on day one and it would be extremely unlikely to clear it after a native mobile launch, which is precisely the point at which the exposure becomes largest.
So there is no Hawkstone in the game. No branded product, no brewery livery, no bottle on a shelf, no tap on a bar, and no commerce bridge to anything alcoholic. The in-game brewery at level sixteen produces an unbranded generic product behind an age gate, and even that is a decision worth arguing about.
The rules that apply, and what each one means here.
| Rule | What it says | What it means for the game |
|---|---|---|
| CAP 18.15 | No alcohol marketing in a medium where more than 25% of the audience is under 18 | No Hawkstone branding anywhere in the game, in any form |
| CAP 18.15, on context | Nor directed at under-18s through the selection of media or context | A game about a farm from a family programme is the context, whatever the audience data says |
| CAP 18.18–18.24 | Added May 2024. The same restrictions apply to alcohol-alternative products at or below 0.5% ABV | A "0% Hawkstone" is caught by exactly the same 25% threshold. It is not a workaround |
| CAP 18.14 | Alcohol marketing must not be likely to appeal particularly to under-18s | Which a cartoon farm with animals in it plainly would |
| The Children’s Code | High privacy by default, data minimisation, restricted nudge techniques | Compounds all of the above, because it assumes children are present rather than asking whether they are |
Why the zero per cent route does not work.
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The threshold is the same.
CAP rules 18.18 to 18.24, introduced in May 2024, extend the alcohol rules to alcohol-alternative products at or below 0.5 per cent ABV. The twenty-five per cent audience threshold applies to them in the same terms.
So a zero per cent Hawkstone in a game whose audience is more than a quarter under eighteen is in exactly the same position as the lager. The alcohol-free line does not create a door.
The rules were extended in May 2024 precisely because everybody was going to try this.
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And the brand is the problem, not the alcohol.
The reason the restriction exists is that a child who becomes familiar with a drinks brand becomes a customer for it later. A zero per cent version of the same brand, in the same livery, with the same name, does that job at least as well.
That is not a technicality being enforced pedantically. It is the entire purpose of the rule, and a design that tries to satisfy the letter of it while defeating the point is a design that will be written about.
The rule is about the brand becoming familiar. Removing the alcohol does not remove the brand.
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So the brewery in the game is unbranded and generic.
At level sixteen there is a small brewery. It takes barley and produces beer. The beer has no brand, no livery, no name and no connection to any real product, and the building sits behind an age gate.
It exists because brewing is genuinely what happens to a large share of the barley grown on this farm, and a farming game that ends at the field gate teaches the wrong lesson about where the value goes. It is the smallest possible version of that idea.
Barley becomes beer here. The game can say that without selling anybody a lager.
What can be in it, and what cannot.
Permitted
- A generic, unbranded brewery building at level sixteen, behind an age gate
- The barley-to-beer value-add lesson, stated as arithmetic
- A commerce bridge to non-alcohol products only — preserves, flour, clothing, homeware
- A link from the game to this site, where the age gates already exist
Absent, not merely gated
- Hawkstone branding, in any form, anywhere in the game
- A zero per cent or low-alcohol branded product, which is caught by CAP 18.18–18.24
- Any alcohol product in the commerce bridge, at any ABV
- A brewery livery, tap badge, bottle, can or label resembling a real product
- Any in-game reward redeemable against an alcoholic purchase
- Age-gated content that is merely gated rather than absent
The commercial cost of this, stated honestly.
Hawkstone is the most valuable thing on the estate. It turned over £21.3 million in the year to March 2025, almost tripling from £7.8 million, and took twenty-third place on the Sunday Times 100. A game that could carry it would be a substantially more valuable game.
It cannot carry it. That is not a preference, a caution or a legal team being difficult; it is a rule with a numeric threshold that a game of this kind would fail. The correct response is to build the game without it rather than to build a version that argues about the threshold.
The consolation is that the commerce bridge to everything else remains open. Preserves, flour, clothing, homeware and the shop’s hundred and thirty-odd non-alcohol lines are all reachable, and they are the products a game audience is more likely to buy anyway.
This is not legal advice
It is a plain-English account of published advertising rules, written by somebody with no standing to advise anybody about them. Any real version of this would take proper advice from a solicitor before a single asset was drawn, and the advice might well be more restrictive than this page.
No beer in it, questioned.
An age gate on the whole game would destroy the audience the game exists for. And an alcohol brand behind an age gate inside a family-brand game is still an alcohol brand inside a family-brand game.
CAP rules 18.18 to 18.24, added in May 2024, apply the same twenty-five per cent audience threshold to products at or below 0.5 per cent ABV. It is not a workaround and it was not meant to be one.
It can bridge to every non-alcohol product the shop sells, which is most of them. It cannot bridge to anything alcoholic at any ABV.
And the code that assumes children are present.
A mandatory DPIA, high privacy by default, and £17.5m or four per cent of global turnover.
