Mystery Shop

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.

  • Strike 1: Retailer receives a “warning letter” and educational materials to improve compliance;
  • Strike 2: Retailer loses promotional funding for two cycles (an estimated loss of $3,000 in profits) from the date of the second failure and is reported to FDA; and
  • Strike 3: Retailer is suspended as an authorized seller of JUUL products and added to Juul Labs’ No-Sale List for one year from the date of the third failure and is reported to FDA. This prevents the Retailer from purchasing JUUL from Juul Labs authorized distributors and ends all commercial support.