Juul Labs was founded and is based in the United States, and its affiliates operate in countries across the globe in order to pursue our mission of transitioning the world’s billion adult smokers away from combustible cigarettes, eliminating their use, and combating underage usage of our products. To accomplish that mission, we are committed to working with governments, regulators, and other stakeholders in all of our markets to create a responsibly regulated and adequately safeguarded vapor category.
We will comply with the requirements set by any country or locality in which we are present. We work hard to ensure that all our products are manufactured to stringent quality standards and to behave as responsible members of the global marketplace. But we believe that, particularly in an emerging field such as vapor products, a set of principles must guide our approach to policy so that we can earn the trust of society and earn our license to operate.
Juul Labs believes robust and appropriate regulatory oversight is required for the category, and that it should be designed to be proportionate to the risk of these products relative to combustible cigarettes. Countries around the world have their own approaches to regulating the category, but we believe there are high-level principles that should be adopted by all countries in some form, regardless of the specific regulatory regime in place. At the highest level, all countries should adopt risk-proportionate frameworks that guard against access and appeal of all nicotine products to underage users, while facilitating adult smoker transition to less harmful products. Here, we set out our high-level principles for the category in order to be transparent about our current thinking on the vapor category and how it should operate.
We strongly believe that no underage person should use nicotine in any form, including our products. Our intent is to make our products available to adult smokers who want to transition away from combustible cigarettes, but this can only be accomplished responsibly if there are restrictions on access by underage persons.
- Minimum Purchase Age. We support a consistent minimum purchase age for all tobacco products, and support raising that age to a minimum of 18 years.
- Age and identity Verification at Purchase. Vapor products should be sold, at retail or online, only after effective age and identity verification (for example using a government or third-party verified identity card). We also support instituting mystery shop programs to monitor retailer compliance with age verification requirements.
- Illicit and Illegally Accessed Product. We support implementing policies and new technologies that prevent adults from buying vapor products with the intent to resell those products to underage people, including restrictions on purchase quantities. Policies and new technology should be explored to identify and remove illicit products from the market.
We believe, particularly because vapor continues to be an emerging category, that it is important that manufacturers be able to communicate accurate and truthful information about their products to adult smokers. But marketing that is targeted to underage people is unacceptable, and category-wide restrictions prohibiting it are necessary.
- Restrictions on Advertising. Advertising and promotion of products should never be intended for underage people. It should always be carefully designed to target and appeal to adults, while limiting reach and appeal to those who are underage. Products should not feature any of the following in the product’s advertising, promotion or sponsorship: products intended for children (e.g., toys); fictional characters (e.g., superheroes, cartoons); celebrities, athletes, sports, music, animals, or games; or, television shows, movies or similar media.
- Communication about Health Risks. Consumers have a right to information about vapor products that is truthful and not misleading. This information should be science and evidence-based, consistent with regulatory requirements, easily comprehensible, and presented in accordance with the “continuum of risk” for all tobacco products. Any claims of reduced-risk, reduced-exposure, and other potential health benefits of vapor products compared to other tobacco products should be substantiated with sound science and be subject to transparent and consistent regulatory oversight. Vapor products may appeal to smokers for cost, quality, convenience and other non-health related benefits (such as no ash or reduced odor), and manufacturers should be permitted to inform consumers on these topics.
- Packaging and Labeling. Packaging and labeling should be carefully designed to target and appeal to adults, while limiting reach and appeal to those who are underage. Vapor products should not feature any of the following in the product’s packaging and labeling: products intended for children (e.g., toys); fictional characters (e.g., superheroes, cartoons); celebrities, athletes, sports, music, animals, or games; or, television shows, movies or similar media.
One of our areas of focus is maintaining the quality of our products. We believe that the entire industry should be held to basic standards of production.
- Manufacturing Facilities and Processes for Pods and E-liquids. All manufacturing activities for the device or e-liquids should occur in ISO 13485 certified facilities. Similarly, all e-liquids and pods should be manufactured in ISO Class 8 clean rooms.
- Manufacturing Facilities and Processes for Devices. Vapor products should be developed to resist alteration, tampering, or unintended use. Devices should be designed and manufactured using quality standards that minimize potential risks or unintended consequences to users by controlling the introduction of contaminants. Device temperature control is an important safeguard to minimize the generation of harmful by-products in the aerosol produced because higher temperatures can generate harmful by-products. Device batteries should be designed and manufactured to internationally recognized safety standards to prevent overheating or ignition.
- Ingredients. Internationally recognized testing standards should be developed to screen e-liquids and aerosols for ingredients of potential concern. All ingredients in vapor products should be manufactured to appropriate purity standards. Ingredients should be produced in manufacturing facilities that can adequately exclude or control potential contaminants, aligned to international standards, such as ISO 9001. Any restrictions on ingredients should be based on sound science, realistic exposure levels, and consideration of their potential to promote adult transition from combustible cigarettes and of the relative risks to combustible cigarettes.
We believe that taxes on e-liquid are appropriate but must be considered on a risk-proportionate basis when compared with combustible cigarettes. Tax policy should be crafted to encourage adult smokers to adopt potentially lower-risk products.
- We believe that tax policy should reflect the continuum of risk for nicotine delivery, and should encourage smokers to transition toward potentially less harmful products. Taxes for this category should be levied on the volume of e-liquid, and should be less than, and certainly no more than, taxes levied on combustible cigarettes.