On 29 June 2026, the Ministry of Economy and Finance (MEF) issued Instruction No. 011 (“Instruction 011”) on the Management of Alcoholic Products and Sugary Drinks. Instruction 011 gives effect to the Royal Government’s policy direction and follows MEF Letter No. 4528 dated 4 May 2026 (“MEF Letter 4528”), which introduced measures to control promotional prize schemes linked to alcoholic beverages and sugary drinks. The Instruction imposes mandatory restrictions on prize-based promotions, caps trade discounts, and regulates the provision of non-beverage benefits in sales promotions.
Background
MEF Letter 4528 introduced measures to prohibit prize-based promotions linked to the sale of alcoholic products and sugary beverages, covering mechanisms such as bottle cap prizes, can ring rewards, pull-tabs, and similar devices. Instruction 011 builds on this framework by establishing specific and enforceable compliance obligations applicable to producers, importers, and distributors operating in the sector.
Key Measures Under Instruction 011
| Section | Description |
|---|---|
| 1. Stopping the provision or exchange of prizes | All prize-based promotions must cease by 30 September 2026. This covers any mechanism — whether physically attached to or separate from a product — through which prizes are offered or redeemed, including can rings, bottle caps, raffles, scratch cards, coupons, prize exchange cards, QR codes, and digital prize programs. The free distribution or gifting of alcoholic products and sugary drinks is prohibited. With effect from the date of issuance, enterprises must immediately cease ordering, importing, or manufacturing cans, bottle caps, or packaging that incorporate any prize element. |
| 2. Trade Discount Permit | Trade promotions through discount sales are permitted, subject to the following limits: Standard discount: up to 15% of the invoiced selling price. Near-expiry discount (products with ≤ 60 days remaining shelf life): up to 25% of the invoiced selling price. Enterprises must notify the General Department of Taxation (“GDT”) before applying any trade discount. |
| 3. Other benefits | Enterprises may offer promotional benefits in the form of goods or services other than alcoholic products or sugary drinks (e.g., glasses, umbrellas, ice buckets, water bottles, apparel, hats, or tour packages). The aggregate value of such benefits must not exceed 5% of the invoiced sales price. |
While Instruction 011 does not specifically address tax treatment, businesses should monitor further guidance from the GDT regarding the tax implications of promotional expenses and rewards. Companies currently relying on prize-based marketing schemes may need to reassess the deductibility and compliance treatment of related expenditures following the prohibition.
DFDL Commentary
Instruction 011 marks a shift in the regulatory framework governing promotional activities in the alcoholic beverage, beer, energy drink and sugary drink sectors in Cambodia. Affected businesses should act without delay to reassess sales and marketing strategies, distribution arrangements and packaging designs in order to meet the 30 September 2026 compliance deadline. The lead time required for inventory management makes early action especially critical for businesses carrying significant stocks of prize-bearing packaging or products.
Recommended Compliance Steps
- Review all existing promotional campaigns that involve bottle caps, can tabs, QR codes, reward points, coupons or similar prize mechanisms and assess exposure to the prohibition.
- Review all existing permits or certificates for advertisement of beverage, beer, energy drink and sugary drink with prize or promotion to determine the impact on the existing promotional campaigns. For more detailed compliance requirements regarding advertisement, please refer to our client alert: Link.
- Develop and execute a plan to exhaust and phase out all existing prize-bearing inventory ahead of the 30 September 2026 deadline.
- Immediately halt the procurement, importation and manufacture of any new cans, bottle caps or packaging incorporating prize elements.
- Review all trade discount arrangements against the 15% standard cap and the 25% near-expiry cap, and remediate any non-compliant structures.
- Establish internal controls to monitor and ensure that the aggregate value of promotional goods and services does not exceed the 5% threshold of the invoiced sales price.
- Prepare and maintain documentation to support GDT pre-notification requirements for near-expiry product discounts.
Should you wish to discuss any of the matters addressed in this alert or explore how these developments may affect your business, please do not hesitate to contact us. DFDL’s multidisciplinary team stands ready to provide timely, practical, and commercially focused advice tailored to your specific circumstances and objectives.
Tax services required to be undertaken by a licensed tax agent in Cambodia are provided by Mekong Tax Services Co., Ltd, a member of DFDL and licensed as a Cambodian tax agent under license number – TA201701018.
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