JUUL Labs

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JUUL Labs Inc. is a San Francisco-based e-cigarette company whose product JUUL has been the focus of considerable media attention and critical commentary, mainly around its popularity among young consumers.123

Until 2023 tobacco company Altria owned a minority stake in JUUL Labs.4 After several years of controversy, the US Food and Drug Administration (FDA) banned JUUL e-cigarettes from the US market in 2022.56 In May 2023, Altria announced that it had ended its investment in JUUL e-cigarettes, exchanging its shares for an interest in JUUL’s heated tobacco intellectual property.78

This page gives detailed background on JUUL, its products, and earlier FDA interventions.

Background

JUUL Devices

JUUL is a flat e-cigarette (also known as electronic nicotine delivery systems, or ENDS) which is designed to look like a USB key and is rechargeable in a USB port (Image 1). It has two components: the battery system, and a prefilled, single use nicotine liquid cartridge that serves as the mouthpiece and is called a ‘JUUL pod’.

The JUUL device was first launched in the US in 2015. With an exceptionally high nicotine content of 59mg/ml (the limit in the UK is 20mg/ml), JUUL cartridges containing e-liquid were initially available in various fruity flavours, including ‘mango nectar’, ‘royal crème’, ‘apple orchard’, and ‘alpine berry’.9 Due to a US ban on fruit and sweet flavoured e-liquids, JUUL cartridges have been available only in tobacco and menthol flavours since September 2019.10

Image 1. Juul e-cigarette (taken from juul.co.uk, April 2019) and JUUL2 e-cigarette (taken from juul.co.uk, October 2021)

In September 2021, JUUL launched the JUUL2 device, with a similar design and ‘pod’ system. JUUL2 pods contain less than 20mg/ml of nicotine, making them suitable for the European market where higher concentrations of nicotine are banned. Despite using liquids with lower nicotine concentration, however, JUUL2 devices deliver significantly more nicotine than the original JUUL e-cigarette. According to the company’s own research, after 10 minutes of using both devices, participants using the JUUL2 devices aerosolized more e-liquid and showed more plasma nicotine concentrations in the 90 minutes after use, compared to those using the original JUUL device.1112

At the time of writing, JUUL2 has not been submitted for market authorisation by the United States Food and Drug Administration (FDA).13 JUUL2 cartridges are only available in tobacco and menthol flavours.14

Ploom, Pax Labs, and JUUL Labs

The e-cigarette company was founded in 2007 by entrepreneurs Adam Bowen and James Monsees and was previously known as PAX Labs Inc. (2015-2017) and Ploom Inc. (2007-2015).1516 On 13 June 2017 the company became known as JUUL Labs Inc.17

In contrast to claims that JUUL Labs was an independent company spun off from PAX Labs,1819 official documents filed with the Secretary of States for California and Delaware show that the company changed name only.2021

Staff: Past & Present

A list of the company’s leadership team can be accessed from JUUL Labs’ website. A significant number of staff previously worked for industry regulators (see the section below ‘Revolving Doors’).

Prior to September 2019, none of the senior executives appointed had worked for tobacco companies in the past. This included Kevin Burns who was the company’s Chief Executive Officer (CEO) from December 2017 to September 2019.22

This changed with the appointment of K.C. Crosthwaite, Altria’s Chief Growth Officer, who succeeded Burns as JUUL Lab’s CEO in September 2019.2324 A few weeks later, the company announced that it had also appointed Joe Murillo as its Chief Regulatory Officer.25 Murillo was previously Altria’s Head of Regulatory Affairs.25 JUUL’s Chief Legal Officer, Tyler Mace, worked for Philip Morris International (PMI) before joining JUUL in October 2019.26

Memberships

  • UK Vaping Industry Association (UKVIA) (from March 2019).27
  • Independent European Vape Alliance (IEVA).28. As of December 2021, JUUL Labs is no longer listed as member on the IEVA website.29
  • The American Chamber of Commerce to the European Union.2830
  • Kangaroo Group.28
  • Asociatia Industriei De Vaping (AIV), the Romanian vaping industry association28
  • Up until August 2019, JUUL was also a member of the US-based Vapor Technology Association (VTA). JUUL reportedly left because of “policy differences” and the VTA filing a lawsuit against the FDA. This lawsuit sought to prevent the FDA from enforcing the May 2020 deadline for e-cigarette manufacturers to submit a premarket tobacco product application (PMTA) if they wanted to keep their e-cigarettes on the US market.31

Consultancies, think tanks, front groups and other third parties

JUUL is known to have worked with the following:

  • United States (US) law firm Foley Hoag32 (which led Uruguay’s legal defence in the lawsuit Philip Morris vs the Government of Uruguay), S-3 Group, Empire Consulting and Sims Strategies.33 Chaka Burgess, of Empire Consulting Group, has in the past worked as a consultant with APCO Worldwide (which has a long history of working with the tobacco industry).34
  • UK-based PR firm, Freuds35 (which has been responsible for Public Health England’s Stoptober campaign since 2012),36 and Hanover Communications.373839
  • Pinney Associates and the Centre for Substance Use Research (CSUR), both of which co-authored papers in a JUUL-sponsored issue of the American Journal of Health Behaviour.4041 For more information, see the section below.
  • UK think tank Demos received funding from JUUL in 2019.42 This appeared to be to run an event at the UK Labour Party Conference in September that year, titled “New approaches to tackling health inequalities”.43 Labour MP Helen Goodman was listed as a speaker along with Max Chambers, Director, Government and Public Affairs for JUUL, as well as a representative of a UK charity working on digital exclusion.43 In 2022, Demos received further funding from JUUL for a “new research project” and in March published a report on the future regulation of e-cigarettes in the UK.4445 The MP Adam Afriyie referred to Demos’ work in a parliamentary debate, but did not mention the involvement of JUUL.46. See also Swedish Match and the APPG for Vaping (e-cigarettes).

Relationship with the Tobacco Industry

Was 35% Altria-Owned

In December 2018 tobacco giant Altria acquired a 35% non-voting stake in JUUL Labs.47 JUUL Lab’s press statement alluded to the controversy and scepticism that the acquisition was expected to cause, but stated that it believed that Altria’s investment would help the company to accelerate its “success switching adult smokers”.48

  • Read JUUL Lab’s statement about the acquisition here.

Despite claiming that “JUUL will remain fully independent”, in April 2019 Altria requested, , Federal Trade Commission (FTC) approval to convert its non-voting shares to “voting securities”.49 This was approved by the FTC in November 2020, giving Altria significant control in JUUL, including the right to appoint two representatives to JUUL Lab’s Board of Directors.50

However, Altria also declared it would not exercise these rights until the outcome of a FTC antitrust investigation into the acquisition, launched by the FTC in April 2020, was clear.50 JUUL is alleged to have forced Altria to withdraw its own e-cigarettes from the market when negotiating the deal.51 The FTC case, which aims to terminate the agreement, states that:

“Altria Group, Inc. and JUUL Labs, Inc. entered a series of agreements, including Altria’s acquisition of a 35% stake in JUUL, that eliminated competition in violation of federal antitrust laws. According to the complaint, this series of agreements involved Altria ceasing to compete in the U.S. market for closed-system electronic cigarettes (“the relevant market”) in return for a substantial ownership interest in JUUL, by far the dominant player in that market.”52

In February 2022, an initial decision by an FTC Judge dismissed the charges.53

In relation to its investment in JUUL Labs, Altria has also confirmed that:

  • JUUL e-cigarettes will be sold alongside Marlboro and other Altria cigarette brands;
  • JUUL pack inserts will be added to Altria cigarette products;
  • the distribution of JUUL will widen as it will be supported by Altria’s logistics services; and
  • Altria will support JUUL Labs in its engagement with the FDA and other authorities.47

Criticism of Altria Connection

In April 2019 eleven US senators signed a letter addressed to JUUL Lab’s CEO Burns, expressing their indignation that JUUL Labs had teamed up with Altria.54 In the letter, the senators accused Altria of “a long and sordid history of spending billions to entice children to smoke through targeted campaigns that intentionally life about the science and health effects from cigarettes”. They added:

“The corporate marriage between two companies that have been the most prolific at marketing highly addictive nicotine products to children is alarming from a public health standpoint and demonstrates, yet again, that JUUL is more interested in padding its profit margins than protecting our nation’s children”.54

The tobacco investment in JUUL Labs was widely condemned by public health experts and advocates.55

The New York Times reported that Washington-based public relations company Precision Strategies had ended its contract with JUUL Labs following Altria’s investment, although the PR firm declined to comment.56

27% Owned by Japan Tobacco International (2010 – 2015)

Altria was not the first tobacco company to own shares in the e-cigarette company.

In 2010, when JUUL Labs was still known as Ploom Inc, the company signed an agreement with Japan Tobacco International (JTI) which resulted in JTI owning a minority stake and obtaining exclusive rights to commercialise Ploom’s hybrid heated tobacco products outside the US.57 In February 2015 Ploom Inc and JTI ended their partnership; JTI acquired the intellectual property related to the Ploom products, and Ploom bought back JTI’s minority stake and rebranded to PAX Labs.5859

Sales Strategy: From US to Global

Challenging US Operating Environment

The JUUL e- cigarette, with a nicotine content of 59mg/ml, was first launched nationally in the US in 2015, and experienced an explosive growth from September 2017.60 Nielsen data show that JUUL grew from holding 32% of the US e-cigarette market in late 2017 to 70% by July 2018.61

However, in April 2018 the FDA launched an investigation into JUUL Labs’ marketing practices. This culminated in JUUL Lab’s offices in San Francisco being raided by the FDA in September 2018, and the seizure of documents related to Juul’s sales and marketing activities.62

The FDA investigation was followed by multiple other similar investigations by state and federal authorities.636465 This included investigations by the US Senate (April 2019) and the US House of Representatives’ Subcommittee on Economic and Consumer Policy (June 2019).66

In June 2021, North Carolina became the first of eleven US States to reach a settlement with JUUL over accusations of marketing its products to youth. JUUL agreed to pay $US 40 million to settle the case, stating it would not sell its flavoured cartridges unless authorised by the FDA.67 In November 2021, a $US 14.5 million settlement was reached with the State of Arizona .68 As of November 2021, the FDA is yet to grant  JUUL’s pre-market authorisation.

In addition, numerous lawsuits have been filed by customers who claimed they had become addicted to JUUL, and in some cases, experienced severe health problems.6970

Market  share and valuation history

The US market was the driver of JUUL’s initial explosive growth: by July 2018, JUUL held 70% of the US e-cigarette market and was valued at $US16 billion.617172 Atria’s acquisition and $US 12.8 billion investment in the company boosted JUUL’s valuation to 38 billion USD by December 2018.71

However, the challenging US operating environment quickly brought JUUL’s rapid growth to a halt. By the end of 2019, the company’s valuation had gone down to $US 24 billion, amid regulatory challenges, proposed bans on e-cigarette flavours, litigation relating to its marketing practices, and health scares.71 At this time, the company began to scale back its operations, halting the in-store sale of flavoured cartridges (excluding menthol and tobacco), laying off staff and restructuring its leadership.7374

International expansion – followed by rapid scaling back

The increasing challenges of US regulation made international expansion an attractive option for JUUL Labs. Between 2018 and 2019, JUUL aggressively expanded its operations internationally, to Europe, the Middle East, Africa, South America and Asia, and spent millions of dollars on lobbying.75

However, perhaps due to over-reaching, the company soon began scaling back its overseas efforts in early 2020.76 77 By late 2020, JUUL’s market valuation had gone down drastically to around $US 4.5 billion, with investor Altria citing the company “downsizing international expansion” as a reason for the devaluation.78

A search of the D&B Hoovers database found that, by July 2019, JUUL Labs had set up at least 19 international subsidiaries and holding companies in Europe, Canada, Israel, South Korea, and Switzerland.79 The table below details where and when JUUL Labs launched its e-cigarette (where known), and when it exited the market.

Country  
United States On sale since June 2015, but awaiting a FDA decision on whether they can remain on the market.72
Israel On sale from March 2018 to August 2018.
United Kingdom On sale since July 2018.
Canada On sale since August 2018. JUUL Canada stopped selling flavoured cartridges in early 2020.80
Russia On sale since late 2018.
Ireland On sale from May 2019 until Late 202081
South Korea On sale from May 2019 until May 2020 82
Philippines On sale since June 2019.
Ukraine On sale since June 2019.
Indonesia On sale from July 2019 until February 2020.83
China (online only) Stopped selling in September 2019.84
Germany Stopped selling end of 2020 8586
Austria Stopped selling in July 2020.8586
Belgium Stopped selling in July 2020.86
Portugal Stopped selling in July 2020.86
France On sale, but intends to withdraw.86
Spain Stopped selling in July 2020.86
Italy On sale, but intends to withdraw.87
Poland On sale.
Switzerland On sale.
New Zealand On sale since 201888

Israel

In March 2018, Israel was the first international country that JUUL Labs expanded to, offering the same high nicotine strength ‘pods’ as those available on the US market (59mg of nicotine each).899091 Concerned that the product posed a danger to health, Prime Minister and Minister of Health Benjamin Netanyahu issued a special bill in August 2018 that banned the sale and marketing of e-cigarettes with a nicotine content of 20mg, similar to EU restrictions on e-cigarette nicotine strength.92 In December 2018 the Israeli Parliament passed a further law which extended existing tobacco regulations to e-cigarettes.91

Law firm Eitan Haezrachy & Co, on behalf of JUUL Labs, filed two petitions with the Supreme Court of Israel against the Prime Minister’s special decree and the full law, which included opinions from Professors Moti Ravid and Yehuda Adler (HaYeshua Medical Center) that “Juul-like devices” did not have the same risks as cigarettes regarding cancerous substances.92 JUUL Labs Israel CEO Assaf Snir commented to the The Jerusalem Post that “JUUL will be sold in Israel- whether sooner or later”.9293

As of October 2021, however, JUUL was not for sale in Israel.94FINAL JUUL Letter 4.8.19

Europe

Image 2. JUUL campaign billboard in UK (source: conveniencestore.co.uk95)

JUUL’s main European market is the UK, which the company considers an attractive market because “it has the world’s ‘most supportive government’ when it comes to encouraging smokers to vape”.89

The company followed a similar sales strategy in the UK as it had in the US:96 first make the product available online and in e-cigarette retail stores, next start supplying the supermarket sector, then break into the convenience store market and petrol station stores.9798 The gradual roll-out was supported with a 12-week national marketing campaign, which consisted of billboards showing testimonials of smokers that had switched to JUUL (see Image 2), and “local brand ambassador activity”.95

To comply with nicotine strength restrictions set out by the EU Tobacco Products Directive (TPD), JUUL Labs was forced to reduce its e-cigarette nicotine strength from 59mg/ml to 20mg/ml (the maximum strength allowed under the TPD). The company has said that the reduced nicotine strength will make it “less effective as an alternative to cigarettes for heavy smokers”.93 This claim is not supported by European evidence which shows that e-cigarettes with a strength of 20mg/ml and lower were shown “…to be effective for the majority of smokers in their cessation efforts”99 and that most British e-cigarette users “use less nicotine than the limit set in the new EU regulations”.100

Asia & Pacific

The company courted the Indian market from late 2018, when it created an India country team ahead of its plans to create an Indian subsidiary.101 In December 2018 former Uber Head of Policy North India & Federal Affairs, Rachit Ranjan, was recruited to be JUUL Labs’ Senior Public Policy Strategist, and in January 2019 former Mastercard executive Rohan Mishra joined as Head of Government Relations.101 Juul also partnered with Indian Journal of Clinical Practice Group (IJCP), to help JUUL Labs “better understand the India market”.102 The editor in chief, Dr. K.K. Agarwal, was previously a member of the ethics committee of the Medical Council of India and national president of the Indian Medical Association.102

JUUL was unofficially available online, in tobacco retailers and some convenience stores in India.103 In August 2019 the Indian Health Ministry announced a ban on the production and import of e-cigarettes, saying that it was necessary to prevent “an ‘epidemic’ among children and young adults”.104 Under the proposed legislation, those that breach the law would face severe penalties ranging from a fine to gaol terms.

Juul was launched in New Zealand in 2018.88 Despite Australia banning the sale of e-cigarettes, the Australian Financial Review revealed that JUUL Labs had applied to secure several trademarks in Australia, including the company’s logo, JUUL ‘pods’, the word ‘juuling’, and the phrase ‘make the switch’.105 A JUUL Labs spokesperson denied that this move was related to a potential imminent launch in Australia: “The trademark applications associated with the company and brands of JUUL Labs are part of the normal business process to secure our brand identity and intellectual property rights”.105

From May 2019 JUUL was available in South Korea, Philippines, Indonesia and briefly China (online sales were halted one day after launch). Its launch in the Philippines was supported by a JUUL Lab’s organised stakeholder event at 20 June 2019. In Indonesia, JUUL Labs “sounded out government officials in Indonesia” months ahead of its launch, discussing e-cigarette tax with officials of the Ministry of Finance.106

As with the middle east, JUUL Labs indicated that it intended to further expand in the  region. Speaking to the Nikkei Asian Review, Ken Bishop, the company’s Asia Pacific Vice President International Growth, said that “we essentially want to be available wherever tobacco is sold”.107 It is not clear whether it still has ambitions to do so.

Africa and Eastern Mediterranean

JUUL Labs’ EMEA (Europe Middle East and Africa) President Grant Winterton had said, in 2019 that the company was hoping to launch its product in Africa in 2020 or 2021, adding that “There is no one who is not on our radar if you look forward next 4-5 years”.93 However, given overall trends in market expansion for JUUL, the company is likely to remain out of the African market. In 2019, JUUL indicated that it planned to launch in Middle Eastern countries in 2020.10893It is not clear whether that is still the case.

Controversial Marketing and Sales Strategies

JUUL Labs has repeatedly made headlines for targeting its product at young people. Matt Meyers, president of health advocacy group Campaign for Tobacco-Free Kids, said:

“The Juul playbook is identical to what the tobacco industry has done for decades. They claim to care about public health, then they engaged in media marketing whose primary appeal was to kids”.34

Image 3. Invitation to JUUL launch parties (source: R. Jackler, C. Chau, B.D. Getachew et al, 2019109

Early Marketing Practices: “Patently Youth-Oriented”

In 2017, reports emerged that JUUL was popular with young students in the US.110111112 Researchers from Stanford University published a study in January 2019 that examined JUUL’s marketing campaign from its launch in 2015 to autumn 2018, looking at the company’s ads, emails and social media content. The authors concluded that JUUL’s campaign, in its first six months, was “patently youth-oriented” and appeared to mirror well-known tobacco industry tactics.109 This included launch events targeted at young people (see Image 3) and free sampling at youth events such as rock concerts. Thereafter the campaign turned more “muted”, but was widely distributed on social media channels like Instagram, which is known to be popular amongst youth. The social media campaign was “amplified by hashtag extensions” (which effectively mixes JUUL advertisements with postings from a wider variety of Instagram users) and “catalysed by compensated influencers and affiliates”.109 The use of influencers by companies is a type of paid promotion, where a popular person with a large social media following gets paid to promote a product, in this case JUUL.

Voluntary Marketing and Social Media Code

Image 4. JUUL Lab’s Marketing & Social Media Code (source: Juul.com, accessed July 2019)

JUUL Labs has adopted a voluntary “Marketing and Social Media Code” (see Image 4). This strategy echoes tobacco companies’ past efforts to pre-empt formal regulation of its marketing activities.113
The first copy of JUUL Lab’s code dates back to July 2018. The code has evolved over time, with a few notable changes between July 2018114 and July 2019 (bold emphasis added by Tobacco Tactics editorial team):115

  • 2018: JUUL is a nicotine product intended for adults of legal purchase age
  • 2019: JUUL is a nicotine product intended for adult smokers of legal purchase age
  • 2018: JUUL is a switching product. JUUL products have not been approved by the Food and Drug Administration to diagnose, treat, cure, or prevent any disease.
  • 2019: JUUL is a switching product. JUUL products are not intended to be used as cessation products, including for the cure or treatment of nicotine addiction (e.g. smoking cessation), relapse prevention, or relief of nicotine withdrawal symptoms.
  • 2018: Product sampling complies with all federal and state regulations.
  • 2019: Paid product sampling complies with all federal and state regulations
  • 2018: We use social media responsibly to ensure content is targeted to adult smokers, while limiting engagement by youth. In the U.S. we do not use social media to advertise or promote JUUL products, and messaging is limited to non-promotional communications
  • 2019: We do not share social media content that promotes excess use or inappropriate us of our product. We only share user generated social media content that does not feature underaged users.

The July 2019 version included a new principle: We always include nicotine warning messaging with all social media posts.

In August 2019, the FTC had reportedly begun an investigation into JUUL Lab’s use of social media influencers and other marketing tactics that might appeal to children.63

Pitched Inappropriately As Smoking Cessation Aid

Despite little independent evidence that JUUL is an effective smoking cessation aid, and in violation of JUUL Labs’ own marketing code which states that JUUL is not intended to be used as a smoking cessation product (see above), JUUL Labs reportedly pitched its product as a tool to quit smoking to US employers and insurers who want to help their staff quit smoking.116 According to CNBC News, JUUL Labs hired former Cardinal Health executive Douglas Roberts to head up a team of 17 staff to strike deals with “health plans, providers, self-insured employers and the public sector”.116 To date (September 2019) no announcements of such deals have been made.

In July 2019, retail magazine The Grocer reported that JUUL Labs had teamed up with a UK convenience store chain to offer smokers “a drop -in service to help them quit”.117 Rather than having a consultation with a trained health professional, smokers visiting the store are assisted by a JUUL Labs employee who “offers information and support on making the switch from smoking to vaping, and informs smokers about the range of alternative products available to them”.117 Customers are offered discounted JUUL products, in a bid “to help transition smokers away from tobacco”. According to the company, the initiative prompted “a four-fold increase in vape sales”.117 This initiative comes after years of UK Government spending cuts to stop smoking support services, with at least one other e-cigarette retailer launching new support services in its stores to fill the gap.118

Tracking its Users

In 2019 JUUL Labs launched a ‘pilot programme’ on the UK market for a JUUL product called C1. Using Bluetooth technology, the e-cigarette can be paired with an android phone via an app, and users can track their usage and lock and locate their JUUL C1 device.119 A similar technology was re-launched alongside the JUUL2 devicein 2021, available only in the UK. 11

JUUL Labs is not the first company to exploit Bluetooth technology to collect e-cigarette usage data. In 2019,  British American Tobacco (BAT) launched the Vype iSwitch Maxx which incorporates similar technology,120 as does IQOS from Philip Morris International (PMI).121

JUUL Labs has argued that the Bluetooth technology is used to help consumers ‘tailor their vaping experience’ and told the BBC News in August 2019 that it “would not sell or share the information without users’ explicit permission”.119 But concerns have been raised that the data collected could be used for entirely different purposes, in particular maintain nicotine addiction. A study by Lempert and Glantz showed PMI for example, using the same technology to remind consumers when to re-order IQOS tobacco sticks, or notify them that they haven’t used their IQOS device yet.122

Illegal Sale of High Strength JUUL

In July 2019 Dutch newspaper De Volkskrant reported on the illegal sale of JUUL e-cigarettes of the 59 mg/ml nicotine strength variety in Amsterdam.123 At the time, JUUL Labs had not officially launched its product on the Dutch market. Retailers selling the product told the newspaper they had either imported it directly from the States or from China (‘it’s probably a reproduction’), with one claiming that the product sells so well that it now represents a quarter of their revenue. JUUL Labs told the newspaper it was aware of the illegal sales in the Netherland but denied involvement.123 The National Institute for Public Health and the Environment (RVIM), the research arm of the Dutch Ministry of Health, said it was concerned about the illegal supply and sales of JUUL in the Netherlands, and would start an investigation.

Influencing E-Cigarette Regulations

Increased Spending on Lobbying

JUUL Labs lobbying budget is substantial and has significantly increased over time.34 In the US alone, the company spent US$1,640,000 on lobbying in 2018,124 including $870,000 to consultancies, such as Sims Strategies, W Strategies, KDCR Partners, S-3 Group, Insight Public Affairs, Empire Consulting Group, and Covington & Burling.124 In the first half of 2019, the company had already spent more than US$1,900,000 on lobbying.125126.

In its early efforts to expand to global markets, the company reportedly spent “millions of dollars lobbying politicians in an  attempt to pre-empt or roll back relevant regulations on products”.75 In Europe, JUUL Labs’ UK subsidiary, JUUL Labs Ltd, has been registered with the European Lobbying Register since August 2018.28 Records submitted in July 2019 state that the company had two members of staff accredited to access the European Parliament, Peter Beckett (Managing Director of Beckett Associates) and Eva Chitul, and that its 2018 EU lobbying budget was between EUR€100,000 and EUR€200,000.127

Political Donations

In the US, JUUL Labs has donated money to members of Congress through its Employees Political Action Committee (PAC), which launched in March 2018.128 In the first half of 2019 the PAC donated nearly $100,000; $74,000 to Democrats and $22,500 to Republicans.129

Funding Allies to Oppose Bans

In addition to lobbying federal decision makers, JUUL Labs has lobbied at state level. According to Forbes, the company spent US$3 million in a July 2019 campaign against the proposed e-cigarette ban in the company’s home city San Francisco.130 Others reported that JUUL Labs spent closer to US$19 million to oppose the ban.131 The funds appear to have supported the establishment of the Coalition for Reasonable Vaping Regulation, a lobbying organisation which was set up in May 2019 to fight San Francisco’s proposed ban.130 In late September, shortly after K.C Crosthwaite was appointed as JUUL Labs’ CEO, the company announced that it would seize “active support” of the campaign to overturn the ban, as part of efforts “to responsibly lead the industry”.132

Image 5. JUUL Lab’s “Switch Network” (source: theswitchnetwork.com, accessed October 2019)

JUUL Labs (by proxy of consultancy Locust Street) has recruited consumers to join the so-called “The Switch Network”.133 The Switch Network is a website where JUUL consumers are invited to share their story about switching from cigarettes, invite friends, and importantly, “advocate for responsible policies” (see Image 5).134 To “protect” their “vapor access”, visitors of the site are urged to sign a petition, email, call or meet with elected officials, attend a public rally, or testify at a state or local hearing”.134 According to CNBC News, Locust Street has been calling and emailing JUUL consumers to get them to sign up to the website.133

Setting up a seemingly grassroot movement to support regulatory change is a well-used tobacco industry tactic. For more information see: Astroturfing.

Revolving Doors

Since July 2018, JUUL Labs has appointed or contracted key staff to strengthen its lobbying and legal team, many of whom have previously worked closely with US politicians and decision makers, or as political appointees:

  • Rebeccah Propp – appointed in June 2019 as the company’s Communications Director.135 Previously, she served as Vice President Mike Pence‘s Director Media Affairs.
  • Johnny DeStefano – contracted as an external consultant in May 2019.135 DeStefano previously oversaw staff recruitment for the Trump administration in 2017.
  • Martha Coakley – joined in April 2019. Coakley most recently worked as a lobbyist for Foley Hoag where she worked on the JUUL account.32 From 2007 to 2015 she was the State Attorney General of Massachusetts. Coakley’s appointment at JUUL Labs followed the announcement in July 2018 that her successor, Attorney General Maura Healey, had launched an investigation into JUUL Labs and online sellers of JUUL, over concerns about the marketing and sale to minors.136
  • Gerald (Jerry) F. Masoudi – appointed Chief Legal Officer in July 2018. From 2004 to 2009 Masoudi worked for the FDA, where he “supervised agency litigation and advised the FDA’s senior leadership on regulatory and enforcement matters”.137 Masoudi’s appointment came in the wake of a series of regulatory FDA interventions to curb teenage use of Juul and other e-cigarettes, with FDA Commissioner Gottlieb later stating that “youth use of JUUL represents a significant proportion of the overall use of e-cigarette products by children”.138 Also see: E-Cigarettes: Altria

The Revolving Door is often used by the tobacco industry as a tactic to exercise influence on its regulatory environment. Recruiting staff with useful connections and a network that they can use to manage those events, can be beneficial for companies and give them undue access and influence. However this is a clear conflict of interest.

For other (non-JUUL Labs) Revolving Door examples, see Johan Gabrielsson, Michel Petite, Kate Marley.

JUUL Labs and Science

Tobacco companies have a long history of manipulating science, often using industry-funded studies to create doubt about the scientific consensus of the health impacts of tobacco and nicotine products, and to promote their own positions.139 JUUL Labs appears to have adopted similar tactics.140

Promotional Corporate Science Website: JLIScience.com

Like BAT and PMI before it, JUUL Labs has set up an online portal to promote its scientific credentials and studies.141 Through JLI Science, JUUL Labs aims “to better understand the effects and impact vaping products have in the long term, while also discouraging new users, and to share those results with the scientific community”.142 The website contains a ‘research library’ and a section where third party researchers are invited to apply for funding for “studies with scientific and medical merit”.143

The ‘research library’ contained 19 studies in September 2019, with the majority being non-peer reviewed posters published at tobacco industry-accessible conferences like the Society for Research on Nicotine and Tobacco Annual Meeting and the Global Forum on Nicotine, and the Altria-organised Tobacco Science Research Conference.144 Many of the studies in the ‘library’ suggest that e-cigarettes have a positive impact on public health.

Ten of the 19 studies were undertaken by Neil McKeganey’s research consultancy, Centre for Substance Use Research (CSUR). The UK-based CSUR previously has undertaken work for British American Tobacco and its subsidiary Nicoventures, Philip Morris International, and Imperial Tobacco’s subsidiary Fontem Ventures.145 In 2018 CSUR was awarded nearly US$100,000 by the PMI-funded Foundation for a Smoke-Free World, to set up a ‘Centre of Excellence in Behaviour Research Related Smoking Cessation’. See: Foundation for a Smoke-Free World Centres of Excellence.

JUUL Labs also held research contracts with Enthalpy Analytical, Christchurch Clinical Studies Trust, Rose Research Center, Cliantha Research, Celerion Inc, and GfK Custom Research LLC.141

Lack of Scientific Credibility

A 2019 study published in The Lancet, led by first author Tan, evaluated JUUL Labs-funded studies against the eight criteria developed by Cohen and colleagues to evaluate the potential impacts of tobacco industry sponsored research.140146 Tan and colleagues found several weaknesses in the JUUL Labs studies which undermine their scientific credibility, including:140

  • Lack of transparency in the selection process of successful applications, with the selection criteria and expertise of reviewers not fully described;
  • Unclear to what extent the researcher owns the data or has freedom to publish (irrespective of the findings);
  • The research agenda is determined by the company;
  • Lack of information on the governance team providing oversight;
  • There are no stated conflicts of interest policies.

Based on the highlighted weaknesses, the authors urge caution and recommend scrutiny of studies funded by JUUL Labs, warning that the findings might be used for lobbying and PR gains, and promoting the company’s business interests.140

Findings of its Paid-For Research Used to Influence E-cigarette Policy

In response to US President Trump’s plans to ban e-cigarette flavours in September 2019,147 The Times revealed that JUUL Labs had cited evidence from one of its own studies to argue that e-cigarette flavours should not be banned in the UK.148 JUUL Labs had already ceased the sale of most of its e-cigarette flavours in U.S. retail stores in November 2018 due to increased scrutiny by the FDA.149 But the company has opposed any potential move to ban e-cigarette flavours in the UK.

Citing a paid-for study carried out by CSUR, JUUL Labs told The Times that the study found that “the use of non-tobacco flavours, such as mango and mint, increase the likelihood for smokers to move away from tobacco cigarettes by 30%”.148 A similar conclusion was reached by a non-peer reviewed study conducted by JUUL Labs own researchers, which was presented in poster-format at the Global Forum on Nicotine on 14 June 2019, and available at JLIscience.com.150

Attempted to Recruit Tobacco Control Experts

In February 2019, a senior member of the Scientific Affairs team at Juul Labs EMA Region contacted a member of the tobacco control community offering support:151

”As JUUL has an interest in the use of e-cigarettes, we are keen to build more scientific data around this particular use of smoking cessation & ENDS (electronic-nicotine delivery systems) especially within specific populations across different medical disciplines. This is an area that we believe needs more research & and is something that JUUL is committed to supporting. I am very interested in your research within tobacco control and we would be delighted to learn more about your work & possibly support any research ideas that you may have.”151

At the time of publication, Tobacco Tactics was not aware of any similar approaches made elsewhere by the company.

Paid-for issue of the American Journal of Health Behaviour

In June 2021, JUUL sponsored an entire issue of the American Journal of Health Behaviour, spending up to $US57,500 to publish eleven articles in the academic paper.72152 JUUL employees co-authored the articles alongside associates from the US health consultancy Pinney Associates, and from the Centre for Substance Use Research, a Scottish consultancy receiving funds from the PMI-funded Foundation for a Smoke Free World.153154 Some of the paid-for studies, which focus on the role of JUUL’s products in promoting smoking cessation, were submitted by the company as part of its application for market authorization to the American FDA.155 The special issue was widely criticised by academics, NGOs and public health organisations, leading to the resignation of three members of the Journal’s editorial board.156

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