Mystery Shop

We conduct compliance checks through our Mystery Shop program to assess retailer compliance with both federal age-verification requirements and our own internal policy restrictions on product quantity purchase limits. We take appropriate actions against retailers that fail compliance checks under this program, including up to a potential product sales ban. In addition to random mystery shop inspections, specific retailers may be targeted based on potential Juul product sales to underage individuals identified through our Track + Trace system.

Three Strikes Enforcement Policy

Juul Labs maintains a Three Strikes enforcement policy that penalizes retailers that fail a Juul Labs and/or FDA mystery shop compliance inspection. The inspection failures are tracked collectively. The Three Strikes enforcement policy is designed to administer remedial measures for non-compliant retailers that fail a mystery shop inspection.  Non-compliant retailers can incur a one-year suspension from selling Juul products.

• Strike 1 (first inspection failure): Retailer receives a “warning letter” and educational materials to improve compliance;
• Strike 2: Retailer is suspended for one Juul promotional cycle (an estimated loss of $1,500 in profits) following the second inspection failure and is reported to FDA; and
• Strike 3: Retailer is suspended as an authorized Reseller of JUUL products for one year following the third inspection failure and is reported to FDA. Suspended Retailers are prevented from ordering Juul products from Juul Labs authorized distributors and receiving Juul Labs commercial support.