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.