We conduct retailer compliance checks through our Mystery Shop program to assess compliance with both federal age-verification requirements and our own internal restrictions on product-quantity limits. From there, we take appropriate actions against retailers that fail compliance checks under this program, including up to a potential sales ban. In addition to random checks, we may also target specific retailers that have been identified as having potentially sold a JUUL product to someone underage as reported within our Track + Trace system.
Three Strikes Enforcement Policy
Juul Labs has implemented a Three Strikes enforcement policy that penalizes retailers that fail our internally-run secret shops and/or FDA’s retailer compliance-check inspections. The compliance failures are tracked collectively across both metrics. The enforcement policy is designed to administer remedial measures for non-compliant retailers that fail secret shop inspections, including up to a one-year sales ban.