Evidence from FDA Compliance Check Inspections on the Effectiveness of Retail Access Controls on Tobacco Purchases

This study analyzes data from FDA’s compliance check inspections of tobacco product retailers to assess the effectiveness of Retail Access Control Standards™ (RACS). RACS is a standards-based technology solution at the point-of-sale that automatically prompts electronic ID scanning to verify the age of the purchaser of electronic nicotine delivery systems (ENDS) and imposes automated product-quantity purchase limits (to reduce the potential for social sourcing). Supported by JUUL Labs, Inc., RACS is being adopted for the sale of JUUL products, but has not uniformly been implemented for other tobacco products. This study assesses the incidence of FDA compliance check inspection failures across tobacco-product types at a regional chain of convenience stores that implemented RACS, and compares it to those observed at similar retail locations without RACS. At the chain that implemented RACS, in the 8 months after RACS was installed, there were a total of 10 inspection failures, of which none were ENDS-related. At the comparator sites, 28% of failures were ENDS-related. These findings provide real-world evidence that an automated, technologically-based solution for age-verification at the point-of-sale, such as RACS, may effectively restrict underage access and thus contribute to reducing underage use. This points to the potential benefit of adopting similar approaches across all tobacco products and potentially other age-restricted products. Keywords:    Retail Access Control Standards (RACS); FDA compliance check inspections; age verification; youth prevention; electronic nicotine delivery system (ENDS); enhanced access controls; tobacco.