Retail Access Control Standards.
To combat underage use of JUUL products, we are working with retailers across the U.S. to implement JUUL Labs’ Retail Access Control Standards (RACS) program. Under the program, every retail point-of-sale system immediately locks when a JUUL product is scanned until a retailer electronically scans a valid, of-age government-issued I.D. to verify age and I.D. validity. Additionally, RACS imposes automatic limits on the amount of product a legal-age customer can purchase. Through this technology, RACS directly combats two large drivers of underage access to JUUL products at retail:
Failure to check and verify I.D.
Legal-age individuals buying bulk quantities of products to resell to
Retail chains representing over 40,000 store locations, have already committed to becoming RACS-compliant. Many of these stores are currently in the process of implementing RACS. Retailer compliance with RACS will be certified by a third-party auditor during an in-person visit.
Track + Trace.
We announced the national rollout in the U.S. of our Track + Trace program, which aims to trace confiscated JUUL Devices through the distribution chain in order to identify the retail location where the product may have been sold. As of today, all JUUL Devices in the U.S. market are fully traceable. Our dedicated team will monitor these submissions and track confiscated products. Once identified, we will work with the retailer and take appropriate action.
Anyone who has confiscated a JUUL Device from a minor may access the Track + Trace portal to provide the serial number so that our team can take the appropriate corrective actions. Together, we will strive to keep JUUL products out of the hands of minors.
Visit the Track + Trace Portal.
Mystery shopper program enhancement.
On October 1, 2019, JUUL Labs implemented a new “3-Strikes” enforcement policy, further enhancing our robust mystery shopper program. The enforcement policy is designed to administer significant consequences for non-compliant retailers that fail multiple age-verification compliance mystery shop inspections. Retailers that fail multiple Age-Verification compliance mystery shop inspections are subject to a loss of promotional funding and/or a one-year ban on ordering and selling JUUL products.
First Inspection Failure: JUUL Labs will issue a letter notifying the retailer of its first violation. The letter will reiterate our youth prevention policies, 3-strike penalty escalation structure, and provide links to additional regulatory and policy training.
Second Inspection Failure: If there is a second violation within one year of the first violation, JUUL Labs will issue a letter notifying the retailer of its second violation. The retailer will lose the opportunity to participate in two JUUL promotional cycles following the date of the second failed inspection. JUUL Labs will communicate the JUUL Labs-sponsored second age-verification inspection failure to the FDA.
Third Inspection Failure: If there is a third violation within one year of the first violation, JUUL Labs will issue a letter notifying the retailer of its third violation. The retailer will lose the opportunity to order and sell JUUL products for one year from the date of the third failed inspection. JUUL Labs will notify wholesalers, distributors, and sub-distributors of the enforcement action. JUUL Labs will communicate the JUUL Labs-sponsored age-verification failure to the FDA.