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Juul Labs’ Mystery Shop Program

Juul Labs conducts retailer compliance checks through its Mystery Shop program to assess compliance with federal age-verification requirements and Juul Labs’ internal restrictions for product-quantity limits. Initially launched in 2017, Juul Labs, through a third party, now conducts a minimum of 2,000 mystery shops per month across retailers nationwide.

The U.S. Food and Drug Administration (FDA) also conducts approximately 12,000 compliance checks per month using underage youth to attempt to purchase tobacco or vapor products.

Failing either an FDA compliance check or Juul Labs mystery shop comes with serious penalties.

Juul Labs enforces a Three Strikes Enforcement Policy for retailers that fail a compliance check.

Juul Labs’ Three Strikes Enforcement Policy

  • Strike 1: Retailers receive a “warning letter” and educational materials to improve compliance.
  • Strike 2: Retailers are suspended for one JUUL promotional cycle (an estimated loss of $1,500 in profits) following the second inspection failure. Retailers with two strikes are also reported to the FDA.
  • Strike 3: Retailers are suspended as an authorized Reseller of JUUL products for one year. They are placed on a “No Sale List” that is shared with distributors. Retailers with three strikes are also reported to the FDA.

The FDA also conducts approximately 12,000 compliance checks per month using underage youth to attempt to purchase tobacco or vapor products. The FDA also has penalties for failing a compliance check. After an FDA violation, the FDA applies penalties based on a store’s inspection record. These penalties may include:

  • Warning Letter Issued (FDA issues a warning letter on first violation)
  • Civil Money Penalty (for a 2nd or more violations)
  • No-Tobacco-Sale Order (if a store has had 5 or more repeated violations within 36 months)

To learn more about the FDA violation process, see FDA’s chart here.

To see FDA’s fine and penalty structure click here.

One of the top reasons cashiers fail compliance checks is because the store was busy, and they didn’t take the time to do the right thing.

Let technology do the guesswork for your staff, and have peace of mind that your cashiers will age-verify and comply with Juul Labs’ product-quantity limits.