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Preventing Underage Sales

Understanding how to manage underage sales is probably the main compliance challenge a convenience store retailer faces. This guide explains what you are legally obligated to do; what you should consider doing as best practice; and how you put in place the policies and procedures that will help you to manage this difficult area successfully.

Age Restricted Sales Guide (Updated April 2019)

ACS recommends the use of Challenge 25 policies for all underage sales.

Challenge 25 is a store policy based on two simple principles:

1. All staff serving customers should be trained to ‘think 25’. This means if a customer is seeking to buy an age restricted product (of any kind), the staff member should ask themselves the question – ‘does the person in front of me look like they might be under the age of 25 years?’ If the answer is yes, then they should ask the person for a valid proof of age. If the identification confirms they are over the legal age of purchase for that product, then it can be sold to them.

2. The store policy is clearly communicated to customers, usually through the use of visible in-store signage.

Additional advice on preventing underage sales is also available on the Business Companion website here

DIGITAL ID VERIFICATION

For age restricted products excluding alcohol, there are additional ways that customers can provide proof of their ID digitally. You can accept digital forms of ID under the following circumstances:

  • The purchase does not include alcohol
  • The method of digital identification that is used is one that you understand how to use and is part of an age verification system that has been implemented in your business
  • The operator of the digital verification scheme can demonstrate compliance with BSI PAS 1296 – Online Age Checking: Provision and Use of Online Age Check Services

More information about digital ID verification providers that have demonstrated their compliance procedures are below: 

PSYCHOACTIVE SUBSTANCES ACT

The Psychoactive Substances Act (2016) came into force on the 26 May 2016, replacing previous legislation on intoxicating substances. The primary purpose of the legislation is to stop the sale of items that are commonly known as ‘legal highs’. However, the Act will also have implications for legitimate retailers, which in many cases will sell psychoactive substances such as butane and solvents entirely legitimately.

The ACS guidance document on Psychoactive Substances can be downloaded here.

Supporting materials for this advice guide are available for ACS members. For more information about these materials, please email Chloe Heyde at chloe.heyde@acs.org.uk

Preventing Underage Sales - Extra Materials

Printable Version - Preventing Underage Sales