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This Juul Labs Authorized Reseller Policy (“Reseller Policy”) contains the terms and conditions applicable to all customers that purchase portable vaporization products and accessories manufactured by Juul Labs, Inc. (the “Company”) for resale in the United States. Please read it carefully, because it impacts your relationship with the Company.
Capitalized terms shall have the meaning described herein. The following definitions shall apply in this Reseller Policy:
“Age Verification” means the process of confirming that an individual is of Legal Age to purchase JUUL Products.
“Authorized Retailer” means any Retailer of Company Products that purchases Company Products from a Direct Distributor or reporting Authorized Sub-Distributor, unless and until the Company has instructed Direct Distributors and reporting Authorized Sub-Distributors not to sell Company Products to that Retailer.
“Authorized Sub-Distributors” means any Reseller, other than a Retailer or Direct Distributor, to which Direct Distributors are authorized to sell Company Products for resale to Retailers.
“Direct Distributor” means any Reseller that has entered into a written domestic wholesale distribution agreement with the Company to buy Company Products directly from the Company for resale to Retailers and Authorized Sub-Distributors.
“Company Products” means any product sold, distributed, or merchandised by the Company that: (a) is made or derived, in whole or in part, from tobacco; (b) contains or delivers nicotine from any source, including tobacco-derived, synthetic, or botanical nicotine; or (c) is a component, part, or accessory of such a product.
“Delivery Service Sales” means the sale of Company Products to consumers in a transaction in which (1) the seller is not in the physical presence of the buyer when the request for purchase or order is made and (2) the Company Products are physically transported to a location other than a Physical Retail Store and delivered only to an individual who, at the time of the delivery, is verified in person to be of Legal Age and, where required by law, who signs for the acceptance of delivery.
“In Person Sales” means transactions at a Physical Retail Store in which the customer requests to purchase Company Products directly from the Retail Store and completes the purchase on site.
“Legal Age” means of or above the minimum age to purchase tobacco products, that is of or above 21 years of age.
“Reseller” means any Direct Distributor, Authorized Sub-Distributor, or Authorized Retailer that purchases Company Products for resale.
“Retailer” means any Reseller that sells Company Products directly to end-user consumers.
“Physical Retail Store” means an individual brick-and-mortar retail location situated at a commercial or industrial address; residential properties are strictly excluded.
All Resellers must comply with the applicable terms of this Reseller Policy. Failure to do so may result in escalation of penalties up to and including suspension or termination of your business relationship with the Company and/or a notification sent to our Direct Distributors and reporting Authorized Sub-Distributors of the revocation of your authorized Reseller status. This Reseller Policy is subject to change by the Company at its sole discretion.
An Authorized Retailer may buy Company Products only from the Company directly or from Direct Distributors and Authorized Sub-Distributors. For a list of Direct Distributors and Authorized Sub-Distributors serving your area, please contact your Company representative.
An Authorized Sub-Distributor may buy Company Products only from a Direct Distributor.
A Reseller is in violation of this Reseller Policy if it buys Company Products from the Company’s consumer eCommerce website (“Company Websites”) for resale.
Authorized Retailers may sell Company Products only to end user consumers (i.e., no wholesale transactions). These sales must either take place in a Physical Retail Store or via Delivery Service Sales.
Direct Distributors may not sell Company Products to end-user consumers.
Authorized Sub-Distributors may sell Company Products only to Authorized Retailers.
Without the prior written consent of the Company, a Reseller shall not (i) ship or sell Company Product outside of the U.S., (ii) sell Company Product that it knows (or, in the exercise of reasonable diligence, should know) will be sold or shipped for resale outside of the U.S., or (iii) sell in the U.S. Company Product that is intended for sale in another country regardless of whether it has been repackaged.
A Reseller may not buy, market, or sell counterfeit versions of Company Products. You risk purchasing counterfeit products if you source Company Products from an unauthorized Reseller.
Resellers may not alter Company Product packaging in any way. Resellers shall not remove Company Products from original packaging without authorization from the Company.
Unless otherwise agreed, Direct Distributors and Authorized Sub-Distributors must provide accurate, timely sell-through data for each customer by SKU, and inventory data by SKU, for the entire nicotine, tobacco, and vapor products categories to the Company either directly or through Management Science Associates (“MSA”).
The JUUL brand and related trademarks (“Company Marks”) are among Company‘s most valuable assets, and the Company takes the necessary steps to protect its rights in its various trademarks. We require Resellers to comply with the Juul Labs, Inc. Brand Usage and Trademark Usage Guide (the “TM Guidelines”), which are available at https://www.juullabs.com/trademark-guide/ and may be updated from time to time.
Our commitment to combatting underage use of our products requires that we direct any promotional communications to our intended audience of adult smokers and consumers of nicotine products, while guarding against the reach of our communications to underage individuals. We expect our Reseller partners to join us in this commitment and to ensure that all advertising and promotional materials are displayed in a manner that is consistent with applicable law and the guidelines set forth below.
Resellers may only use Company-approved advertising materials to advertise Company Products. Any use of independently-developed advertising materials using Company Marks is prohibited without prior authorization and a valid license to use our Company Marks.
With respect to advertising at Physical Retail Stores, unless directed otherwise by the Company in writing, Authorized Retailers may place approved advertising materials for Company Products only at storefronts, interior space and the point of sale, as specified below.
Unless expressly authorized in writing by the Company, Resellers may not feature Company-approved advertisements through any of the following channels: broadcast, paid online digital advertisements on third-party websites or apps, billboards, social media, bloggers, events, or influencers, and in general through any means other than the permitted means specified above.
Resellers may not advertise, market, display, or demonstrate products that are not Company Products together with Company Products in a manner that could create the impression that such products are made by, endorsed by, sold by, or associated with the Company.
Combating underage access to Company Products is a central pillar of the Company’s mission, and Authorized Retailers are expected to be partners in this mission by adhering to the requirements outlined below. The Company strongly encourages Authorized Retailers to invest in technology solutions that automate age verification and product quantity limit controls, referred to as “Enhanced Access Controls.”
For more information on how you can implement Enhanced Access Controls, please visit our Retailer Resource Center at https://www.juullabsretailer.com/learn/.
Restrictions Applicable to In-Person Sales
Age-Verification. The Company requires Authorized Retailers to implement Age Verification processes in compliance with applicable law. For sales at Physical Retail Stores, federal regulation requires retailers, prior to completing a sale of Company Product to any person under the age of 30, to visually inspect the purchaser‘s government-issued photo ID to verify that the photo on the ID matches the person presenting the ID and that the individual is of Legal Age. Authorized Retailers must implement and have in place, prior to selling any Company Product, policies and procedures to comply with these requirements.
Product Quantity Limits. Authorized Retailers may not sell more than sixteen (16) JUULpods and one (1) JUUL Device to a consumer during a visit to a Physical Retail Store. This restriction is designed to reduce the potential for social sourcing (i.e., third-party resale or sharing by an of-age purchaser to or with an underage user). Authorized Retailers are prohibited from circumventing this requirement by processing multiple transactions with a single consumer. If applicable, Authorized Retailers will provide franchisees with direction regarding this restriction.
Restricted Access. Authorized Retailers offering Company Products for sale at Physical Retail Stores must keep displays of JUUL Products either (1) behind the counter or (2) in a secure location that effectively prevents consumers from accessing the Products without the assistance of an Authorized Retailer employee.
Restrictions Applicable to Delivery Service Sales
Age Verification. Authorized Retailers that sell Company Products via Delivery Service Sales must implement controls to ensure that: (1) prior to accepting an order, the purchaser’s identity and age are verified by a service that compares customer information against independent, competent, and reliable data sources (such as public records) to confirm the individual is of Legal Age; and (2) the individual accepting delivery of the order undergoes Age Verification at the point of delivery and, where required by applicable law, signs for acceptance of the delivery.
Product Quantity Limits. Authorized Retailers that sell Company Products via Delivery Service Sales must implement controls reasonably designed to prevent sales of Company products in excess of 16 pods or 1 device in a single transaction.
Reporting. Authorized Retailers engaging in Delivery Sales of Company Products must, upon request, provide the Company with information necessary to evaluate the adequacy of controls needed to comply with the terms of this Policy. Authorized Retailers that do not provide the requested information or that lack adequate controls will be ineligible for Company-paid marketing support and product promotions for their Delivery Service Sales and may face a suspension of their status as Authorized Retailers.
The Company reserves the right to monitor compliance with the Age-Verification and Product-Quantity Limit requirements set out in Paragraph 10 by engaging in mystery shops. The Company will notify Retailers of any “failed” mystery shop and of the consequences of any subsequent failed mystery shop.
The Company provides end-user consumers with the limited warranty described on its consumer website, JUUL.com. While Resellers are free to grant or promise any separate or additional warranties or return policies of their own, the Company disclaims any responsibility or liability for any such additional warranties or return policies. The Company will never reimburse Resellers for returns or warranty claims unless agreed in writing, in advance. If a Reseller receives any warranty claims, complaints, returns, or other inquiries from consumers, Resellers should direct consumers to contact the Company directly, following the directions provided in the customer support section of Company’s consumer website. Wholesale sales are not returnable, and Resellers bear full responsibility for any wholesale return policies they offer.
The Company maintains a list of Resellers and other entities that, due to one or more violations of this Reseller Policy, are not authorized to receive Company Products from Direct Distributors or Authorized Sub-Distributors (“No-Sale List”). Direct Distributors and Authorized Sub-Distributors shall familiarize themselves with the No-Sale List. It shall be a violation of this Reseller Policy to sell Company Product to any Reseller identified in the then-effective No-Sale List.
Direct Distributors making sales to entities on the No-Sale List may be subject to reductions to their rebates and incentives as described in their rebate and incentive terms. Such actions also risk denial of future purchase orders or termination of our business relationship.
We encourage Direct Distributors that sell Company Products to an Authorized Sub-Distributor to require in writing that Authorized Sub-Distributors make no sales of Company Products to entities on the No Sale List and implement controls reasonably designed to prevent and detect such sales. In the absence of the measures, a Direct Distributor that sells to an Authorized Sub-Distributor that makes sales in violation of the No-Sale List will be accountable for those sales and may lose incentives under their effective incentive programs.
Resellers must comply with all applicable federal, state, and local laws and regulations, including tax and reporting obligations, applicable to the advertising, sale, marketing, and delivery of Company Products. Resellers that fail to comply with applicable law and regulations pose a significant risk to the entire category and to the Company’s brand. Where required, and as it is deemed appropriate, the Company may report violations of the law to appropriate authorities.
Effective: May 1, 2026