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Frequently Asked Questions

Basics of C25

Why was Challenge 25 created?

RASG created Challenge 25 to eradicate underage sales of alcohol by resetting consumer expectations so that those who look under 25 would expect to be asked for proof of age when buying alcohol, seeing this as the norm rather than the exception.

We commissioned research into why underage sales were taking place and to look for policies that could be implemented to prevent this. Challenge 21 (now Challenge 25) provides staff with a buffer zone, should they not be able to accurately guess the age of a customer.

The scheme isn’t just about displaying posters. It signifies an important cultural change for businesses. Staff are given detailed training on the scheme and supported with additional training such as conflict resolution. Managers are trained to support staff and not overrule them when a challenge has been made.

Challenge 25 is a retailing strategy that encourages anyone who is over 18 but looks under 25 to carry acceptable ID if they want to buy age restricted products.

It is a widely recognised scheme that is voluntarily adopted by many retailers. Although originally created to tackle underage sales of alcohol, the simplicity of the scheme means that it can be applied to any age restricted product.

Challenge 25 is not a legal requirement in England or Wales; however, all licensed premises are required to have a proof of age policy for the sale of alcohol on their premises. This policy, as a minimum, require people to provide proof of age if they appear to the person serving the alcohol to be under 18 Challenge 25 is an effective way for retailers to satisfy this legal requirement. Retailers that adopt Challenge 25 have, on a voluntary basis, agreed to extend this age level to 25, which the regulations allow.

Licensed premises may also have a condition placed on their premises license that requires them to follow this. In this case, if a business does not adopt Challenge 25, they would be in breach of their license conditions and their alcohol license could be revoked.

The application of Challenge 25 is mandatory in Scotland.

Challenge 25 was created nearly 20 years ago after Government asked retailers to implement measures to reduce the number of underage sales of alcohol that were taking place. The scheme has been a huge success and is now widely adopted and applied beyond the alcohol industry.

Challenge 25 helps to protect minors from consuming and/or purchasing items that they are deemed too young for. For alcohol, the scheme also protects checkout staff who, if sold alcohol to a minor, may be prosecuted as an individual along with the business that employs them. Under licensing legislation, staff members making sales commit a criminal offence is alcohol is sold to a minor, hence the reason that asking for proof of age and having this buffer zone of 25 is so important.

The implementation of the scheme is the responsibility of each retailer that has adopted it. Given its highly successful track record, I doubt that either the government or the retail sector will have any appetite to change it.

Adopting C25

The operation of Challenge 25 needs to be determined by each individual retailer, based on their unique business model.

Challenge 25 training does not have to be a cost burden on businesses. The important things to note are:

  • C25 materials should be displayed in your premises.
  • Staff should be made aware of the different age requirements for the age restricted products you sell. A list of the most common is provided below.
  • Staff should be clear on what proof of age you accept. We recommend keeping this simple for staff and so restrict our list to a valid UK Driver’s Licence, Passport, PASS card or Military ID. For alcohol, the ID must include a photo, date of birth and hologram/ultraviolet feature, which all the ID mentioned does.
  • The scheme is simple and staff should ask for ID from any person they believe to be under 25 – this age should be applied to all age restricted items, even those with a restriction as low as 12 and 16. This helps to keep things simple for staff – if they are aware of what products are age restricted, the 25 rule is applied to all.
  • Once a challenge in made a sale cannot go ahead unless ID is presented. Managers must not overrule their staff.
  • Refusals should be recorded – whether on paper or in digital form.
  • It might be worth doing some mystery customer exercises yourself, although as it is an offence for an under 18 to buy alcohol, you should only use people over 18 for alcohol. This way the law has not been broken but you can assess compliance with the C25 scheme. Staff that fail to ask for ID should be reminded of the legal age restrictions on products and the need to ask for ID. This re-training should also be recorded.

Online sales of alcohol in the UK are governed by the same rules as face-to-face sales of alcohol, the basic rule being that you cannot sell alcohol to any person under the age of 18. This means that an age verification check should be done at some stage within the sale and/or delivery process.

Here is a link to our online sale guidance. This guidance was produced by all members of the Retail of Alcohol Standards Group (RASG) and advises businesses on the steps taken by the different businesses and business models we have in our membership. In general, our members that sell mainly online will carry out robust age verification checks at the time that a customer sets up an account or places an order. There are businesses that can do this for you and we urge you to contact the Age Verification Providers Association for more details on the options available.

C25 posters

All RASG Challenge 25 materials can be accessed and downloaded for free from our website. The materials are available in print quality format and can be produced at a local printer. RASG do not sell or supply printed materials, nor do we work with or endorse businesses that do.  

We have created UK nation specific posters that include the correct penalties for England, Wales and Scotland. We also have Welsh language materials. All materials can be accessed here.

If you are an on-trade premises you are more than welcome to use our posters. Our posters are not premises specific.

RASG posters are the industry approved materials and are free for businesses to download via the Retail of Alcohol Standards Group (RASG) website. A lot of other businesses will charge for the posters. None of these are linked to RASG.

Our posters for England and Wales have been endorsed by the National Police Chiefs Council (NPCC). All our materials (England, Wales and Scotland) have the support of our Primary Authority trading standards partners at Salford City Council, on behalf of the Greater Manchester Regulatory Centre of Excellence, and the Shared Regulatory Services of Bridgend, Cardiff and the Vale of Glamorgan.

The benefits of using RASG Challenge 25 posters are that they:

  • are industry approved, clear and consistent designs.
  • are an instantly recognisable message that a premises operates Challenge 25.
  • are suitable for all age restricted products, not only alcohol.
  • provide staff with the confidence to make challenges.
  • are free for anyone to download.

On being challenged

In general terms, off trade retailers (supermarkets, convenience stores) follow Challenge 25 while on trade premises (pubs, restaurants) follow Challenge 21.

The scheme was originally launched as Challenge 21 and voluntarily adopted by both the on and off trade in 2006. However, in 2009 retailers decided in increase the challenge requirement up to 25 as, while the results were impressive following the implementation of Challenge 21, it was felt that a greater buffer above 21 could produce an even greater impact. The national retailers – co-ordinated by RASG – therefore voluntarily moved up to 25, while the on trade continued to operate Challenge 21.

It is incredibly difficult for shop staff to guess the exact age of customer and therefore occasionally people that are over 25 are challenged.

Some people that are clearly older than 25 may be challenged. This could be for several reasons:

  • Challenge 25 may be included as a licensing condition on a premises license.
  • Staff may be adopting an overly cautious approach due to recent issues and/or training on the scheme.

No matter your age, once a challenge has been made a sale will not go ahead unless proof of age can be provided which shows that you are over 18. The decision to age check will always be backed up by management to ensure that staff are not undermined and continue to have the confidence to challenge people.

Retailers are required to be vigilant not just for direct underage sales, but for proxy sales too.

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. They therefore train staff to make challenges if they believe there is a chance that 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 and any other information that has been picked up, for example if there has been underage drinking problem in the area.

If staff believe a proxy sale is taking place, all people within a group will be asked to prove their age.

While Challenge 25 was initially adopted by retailers to prevent underage alcohol sales, many have now extended the scheme to cover all age-restricted products. This means that you could be challenged under the scheme when buying any age-restricted products such as lottery, tobacco, knives, DVDs or video games. Each retailer’s policy in relation to challenge 25 may be different, so questions around the application of the scheme should be taken up directly with the individual retailer in question.

Challenge 25 is a versatile age verification scheme that can be applied to any age restricted product. Although this was created initially for alcohol, it is now being applied more widely – whether age verification is required by legislation or applied as part of a voluntary initiative, such as that for energy drinks. 

Although energy drinks are not currently age restricted by law, major retailers have voluntarily decided to age restrict these, to people over 16 years, as part of their social responsibility duties. This means that those retailers will include these drinks in their age restriction policies and subject them to age restriction checks. Proof of age will be requested by those they believe to be under 16 years of age. Please note that this activity is not prohibited by legislation and is a choice for individual retailers to make.

Retailers in the UK take their legal and social responsibilities very seriously and it is up to each individual retailer to decide whether to include alcohol free beverages within their age restricted sales policy.

Drinks that have an alcohol content above 0.5% abv are defined as an alcoholic beverage. Retailers cannot legally be sold to anyone under 18 and need a license to sell these. These will always be subject to the Challenge 25 scheme.

Drinks that have an alcohol content of 0.5% abv or below are not defined as alcohol and retailers do not require a license to sell these. However, retailers strive be both legally compliance and socially responsible and so as part of their commitment to be socially responsible they may subject the sale of these drinks to the same policies and restrictions as alcoholic ones. This means the voluntarily application of their age restrictions policy and challenges to any person who looks under 25.

ID

Currently only physical documents that contain a photograph, a date of birth and a holographic mark or ultraviolet feature can be accepted when buying alcohol

It is up to individual retailers to decide what forms of ID they accept; however, the most accepted forms of ID include:

  • a valid UK Driver’s Licence,
  • a valid Passport
  • a PASS card.

For more details on the PASS cards please visit: http://www.pass-scheme.org.uk/

It is up to individual retailers to decide what forms of ID they accept.

Any ID that contains a photograph, date of birth and either a holographic mark or ultraviolet feature is legally acceptable, however, some retailers may restrict the forms of ID they will accept. This could be for several reasons:

  • to keep things as simple as possible for checkout staff, so that they don’t become confused over whether a piece of ID is genuine or not.
  • The restriction may have been imposed by the local council as part of the premises license.

Anyone can purchase a Proof of Age Standard Scheme Card to enable them to be able to provide proof of age. More details can be found at: http://www.pass-scheme.org.uk/

No, currently digital proof of age is not legally accepted when buying alcohol.

The Home Office has announced that legislation will be amended to permit the use of digital proof of age, although we have no timelines as to when this will happen.

Making a complaint

Challenge 25 is administered by each individual retailer and so if you have any questions or concerns over the adoption of the scheme you should contact the retailer in question, either through the specific store or through their customer service teams.

Retailers welcome feedback on how the scheme is operating. If you believe that this is being enforced unreasonably at a particular store, you should report this to the store in question so that they can consider whether the operation and training is being delivered as it should be.