Age-restricted sales & Challenge 25 policy

What you need to know

The plain-English guidance that comes with this document.

• This policy is the backbone of the whole pack — and your legal defence. If you're ever prosecuted for an underage sale, the law gives you a "due diligence" defence: you can show you did everything reasonable to prevent it. A written Challenge 25 policy, staff trained and signed up to it, and a refusals log are exactly what that defence is built from. Without them, you're exposed; with them, you have a real answer.
• Challenge 25 is the retail standard — 25, not 21. The Retail of Alcohol Standards Group promotes Challenge 25 precisely because judging whether someone is over 18 is hard, but spotting whether they might be under 25 is easy — it builds in a safety margin. In Scotland, checking under-25s for alcohol, tobacco and vapes is a legal requirement, not just good practice.
• The vape rules changed twice recently — get them right. Single-use disposables have been illegal to sell since 1 June 2025 (a legal vape is refillable and rechargeable). And the Tobacco and Vapes Act now pulls nicotine pouches into the under-18 regime from 29 October 2026, alongside a ban on vape vending machines and free samples. A lot of generic templates are out of date on this — yours isn't.
• The generational tobacco ban is the big one coming. From 1 January 2027 it's an offence to sell tobacco to anyone born on or after 1 January 2009. Practically, your staff will need to start checking date of birth, not just "are they 18". Diarise a staff briefing for late 2026 so nobody gets caught out on day one.
• Only accept proper ID, and know the PASS hologram. Passport, UK photocard licence, military ID, and PASS-accredited proof-of-age cards are the safe list. The PASS hologram is the thing to look for on proof-of-age cards. Don't accept a photo of an ID on a phone — it's trivially faked.
• Proxy sales catch people out. The adult buying booze for the teenagers outside is committing an offence, and so are you if you knowingly sell. Train staff to spot it and to refuse confidently.
• Display it, sign it, keep it. Keep a signed copy for every member of staff (that's your training evidence), display a Challenge 25 notice at the till, and revisit the policy whenever the law moves — which, right now, it is. Adapt the product list and ages to what you actually sell and to your nation.