Last modified date: 11 Mar 2026

Issue Description

Data from the Southeast Asia Public Policy Institute (SEAPPI) and the Asian Vision Institute (AVI) reveal a concerning trend in Cambodia’s public health landscape: 25.8% of youth aged 15–19 report engaging in Heavy Episodic Drinking (HED). This represents a significantly higher prevalence of binge drinking among minors compared to neighbouring ASEAN countries.

The high rate of consumption among minors is attributed to a combination of legislative gaps and cultural factors. Currently, it is note that there is no clear legal framework for alcohol control including no defined legal purchasing age, no time sale restriction, limited enforcement of blood alcohol limits for driving and no legal regulating alcohol sponsorship or sale promotion. Furthermore, the deep integration of alcohol into social traditions—ranging from religious festivals to wedding celebrations—further normalises early-onset consumption

As of date, in Cambodia, a major contributing concern is the widespread and largely unregulated practice of “under-the-lid” promotions, locally known as Winning Ring Pulls. These incentives, embedded beneath bottle caps or aluminium can tabs, offer instant rewards ranging from complimentary beverages to high-value prizes such as luxury motorcycles, cars, and substantial cash rewards.

Although industry stakeholders often present these prizes as a “lucky” perk for consumers, the reality is that they have become a strategic marketing tool that gamifies alcohol consumption. By diverting attention from the product itself to the excitement of winning, these promotions establish a psychological cycle that can drive purchases beyond genuine demand for the beverage.

We acknowledge and commend Samdech Moha Bovor Thipadei Prime Minister Hun Manet’s wise decision to consider banning all beer, alcoholic, and non-alcoholic beverage manufacturers from offering prize-based promotions with their products, as stated in the letter dated 22nd April 2025. The Royal Government has also proposed a transition period of six months to one year to allow companies sufficient time to comply before the restrictions are fully implemented.

Impact on business

The prevalence of ‘open lid’ promotions has led to multiple adverse effects on the Cambodian business environment.

One of the most significant impacts is the distortion of consumer demand. By linking purchases to the chance of winning high-value prizes, these promotions encourage excessive consumption, shifting consumer focus away from product quality, brand value, or genuine need. This poses potential health risks, as individuals may consume more than recommended.  When the volume of purchase is directly tied to the opportunity to win prizes such as motorcycles, cars, or cash, consumers are incentivised to prioritise winning over moderation. This undermines the “drink responsibly” messaging that many modern global brands strive to promote and can negatively affect the long-term reputation of the Cambodian beverage sector. Over time, such practices may erode public trust, damage brand credibility, and invite criticism from health advocates and regulatory authorities.

Market instability is another direct consequence. Smaller players face unfair competition because only businesses with substantial financial resources can afford large-scale promotions and high-value prize pools. This creates a barrier for local manufacturers who focus on product quality rather than extravagant marketing. As a result, smaller businesses may be pushed out of the market, reducing industry diversity and innovation. For larger companies, the “arms race” to offer bigger prizes increases marketing expenditure, potentially cutting into profit margins and creating pressure to continuously escalate promotions to maintain market share.

In addition, companies that adhere to ESG principles and responsible marketing, such as promoting moderation and product quality over gimmicks, may find their products appearing less appealing to consumers in the short term. Even when these products are superior in quality, the focus on flashy promotions by competitors can overshadow their value, undermining brand positioning, consumer perception, and long-term market trust.

Recommendation

  • Prohibit free beverage and prize promotion through an under-the-lid promotion mechanism.

EuroCham Fast-Moving Consumer Goods (FMCG) committee respectfully request the Royal Government of Cambodia (RGC) to:

Strongly support its full implementation of the bans on the ‘open lids’ promotion – of the ban on ‘open lids’ promotions across all beverage categories, ensuring that no product type is excluded and that the ban is applied consistently nationwide, and.

Clear guidance on implementation and procedures for businesses and enforcement agencies to follow including detailed procedures for businesses, distributors, and enforcement agencies to follow, to avoid ambiguity and ensure uniform compliance.

A comprehensive approach will not only help reduce harmful consumption and gambling-like behaviour associated with under-the-lid promotions but also promote responsible consumption, encourage innovation, and support the long-term growth and contribution of the FMCG sector to Cambodia’s economy.

Dialogue with

Royal government of Cambodia

Initiative from Eurocham: The issue has been raised by the Fast Moving Consumer Goods Committee within The White Book edition 2026.

No response from the Royal Government of Cambodia

National Counterparts

Ministry of Commerce

Ministry of Health