Instruction No. 011 on New Restrictions on Promotional Prize Schemes for Alcohol and Sugary Beverages

(Instruction No. 011, dated 29 June 2026)

A new Instruction has been issued establishing guiding principles for manufacturers, importers, and distributors of alcoholic products and sugary beverages in Cambodia, specifically addressing the use of promotional prizes and trade discounts. The measures are intended to curb aggressive marketing practices while allowing continued, regulated promotional flexibility for businesses in the sector.

Below is a summary of the key provisions.

1. Prohibition on Prize-Based Promotions

Businesses are no longer permitted to offer or exchange prizes through bottle caps, ring-pulls, or any other mechanism attached to product packaging — including raffles, scratch cards, coupons, prize-exchange cards, QR code-based promotions, or similar digital schemes.

  • Effective 29 June 2026: Affected enterprises must cease ordering, importing, or producing new ring-pulls, bottle caps, or packaging that contain or reference embedded prizes.
  • Effective 30 September 2026: All such prize-based promotional activity must be fully discontinued.
  • The free distribution or giveaway of alcoholic products and sugary beverages at no charge is also prohibited.

2. Trade Discount Limits

Trade discounts intended to promote or encourage sales are permitted, subject to the following limits:

  • Standard trade discounts must not exceed 15% of the invoiced selling price.
  • For products approaching expiration (within 60 days of their expiration date), trade discounts may be increased to a maximum of 25% of the invoiced selling price. In such cases, the taxpayer is required to notify the General Department of Taxation (GDT).

3. Alternative Prizes and Benefits

In place of alcoholic products or sugary beverages, businesses may offer alternative non-monetary benefits — such as glassware, umbrellas, ice buckets, water bottles, apparel, or tour packages — provided the value of these items does not exceed 5% of the invoiced selling price.

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