Adopting Challenge 25
How to adopt C25
We are often asked how to adopt Challenge 25 and so to aid businesses we have included some points for consideration below.
Adopting Challenge 25 does not have to be a cost burden.
Adopting and following C25 is one way for a business to demonstrate that they took all reasonable precautions and exercised due diligence to avoid selling alcohol to minors.
To adopt Challenge 25, businesses should consider the following:
Staff training
It is important to have programmes in place to regularly train staff about the Challenge 25 scheme, including who to challenge and how. This will help to ensure that staff are confident in making challenges and that the policy is consistently applied in store.
All staff should be trained as part of their induction programme, which should be repeated every 6 months and after any event of an underage sale.
It’s useful to keep training records to ensure staff have their training refreshed regularly.
Staff training does not have to be a cost burden and so RASG have developed our own training programme, which you can access for free via this link or via the training tab on this website.
Age restricted products
Staff should be aware of the different age restricted products sold in store and the minimum age that a person needs to be to buy these.
Internal policies relating to age restricted products
When selling alcohol, you are legally required to have an age restricted sale policy for your business. As a minimum this requires staff members to ask for ID from any person they believe to be under 18, when buying alcohol. Retailers that adopt Challenge 25 voluntary extend this age level to 25, which the law allows.
All staff need to know that you have a policy in place. They should have read this policy and need to understand it.
What is acceptable ID
There are hundreds of forms of ID that are used in the UK. The standard Challenge 25 scheme suggests accepting Passports, Driver’s Licences and PASS approved cards. While individual premises can accept anything ID that includes the following features, when selling alcohol – a hologram or ultra-violet feature, name, date of birth and photo – it is important to make a decision about what you will accept and publicise this clearly.
We recommend keeping the list of ID you accept to a minimum, to keep things simple for staff and to minimise confusion over what ID they can and can’t rely on.
On how to spot fake ID
The Home Office has produced guidance for retailers to help them understand how to spot fake ID. It is important to ensure staff are trained about the types of ID that are acceptable and how to look out for fakes.
Managers must support staff
Challenge 25 only works if the staff have confidence that the decisions they make will not be undermined. It is therefore important to ensure that difficult decisions staff have made are not challenged and overturned by managers.
Identifying proxy sales
A proxy sale is where an adult attempts to buy alcohol on behalf of a minor. Retailers found to be supplying alcohol to minors, including via proxy sales, could face a fine and/or have their license removed. Staff should understand that a challenge should be made if they believe a proxy sale is taking place.
How retailers approach this varies and a range of factors are considered when deciding to make the challenge. This will include information like the relationship between the person buying alcohol and the person with them, the time of day, the products being purchased.
Selling to intoxicated people
It is a criminal offence to sell alcohol to a person who is drunk, whether they are over 18 or not. In all cases, a sale cannot be made.
Keeping records
Keeping records is the best way to demonstrate the policies and procedures you have in place to prevent underage sales.
We recommend that you have a document on file that sets out your company’s policy on preventing underage sales. This should be available to staff in every shop that you have.
1. Of staff training
Each member of staff should have their own training record. This should record the date of their initial induction training and subsequent refresher training.
2. Of failed purchases
Records of all failed purchases should be kept. This can be in writing or recorded digitally. All staff should understand that failed attempts need to be recorded and know how to record them. We advise that no personal information be recorded about the customer. The details recorded need only include:
- The date
- The time
- The item the person attempted to buy
- The reason for the refusal
- The staff member making the refusal
Keeping a record of failed purchases can help prove that you are taking positive steps to prevent underage purchases. These can also be used to identify any staff they may need additional training in this area.
Communicating the adoption of C25 to customers
Customers need to know that you have adopted C25. This is done by displaying C25 materials around your premises. All our Challenge 25 materials can be downloaded for free from our website.
Displaying materials near the entrance of the store will inform customers that the scheme is in operation and may also act as a deterrent to minors that may attempt to make an underage purchase.
Displaying materials at the checkout is an easy way to help staff avoid potential conflict. Having a poster that staff can point to can act as a back up to staff members who make challenges and help deflect any blame from the member of staff.
RASG C25 Training Portal
Adopting this training and the recommendations suggested in are a way to help demonstrate that ‘all reasonable precautions’ were taken and ‘all due diligence’ exercised to avoid committing an offence, if alcohol is sold to a minor.
While we encourage retailers to use this as part of your staff training, completing this does not confer immunity from enforcement action should offences be committed. Businesses must ensure that they are aware of all legal requirements expected of them when selling alcohol and other age restricted products.