We share Attorney General Josh Stein’s concerns about youth vaping, which is why we have been cooperating with his office and why we have taken the most aggressive actions of anyone in the industry. We strongly advocate for Tobacco 21 legislation.

We stopped the sale of non-tobacco and non-menthol based flavored JuulPods to our traditional retail store partners over six months ago, enhanced our online age-verification, strengthened our retailer compliance and shut down our Facebook and Instagram accounts while working constantly to remove inappropriate social media content generated by others. We also continue to develop technologies to further restrict underage access with our distributors, at retail establishments and as features of potential new products.

Combatting youth use is critical for the success of our business. Our market is the over one million smokers in North Carolina and one billion worldwide who should have the opportunity to switch to vapor products if they so desire. We are seeing tremendous success so far as we believe our product is driving historic change in the consumption of combustible cigarettes.

According to U.S. Nielsen data, cigarette sales that declined at an average rate of approximately 2.7% from 2011 to 2016 had historic declines of over 5% last year, increasing to over 10% recently. In North Carolina, recent data shows volume declines reaching almost 10%. These unprecedented trends represent a drop of over 13 billion fewer cigarettes smoked nationwide over the past year and over 400 million fewer cigarettes smoked in North Carolina alone.

But we know that underage use endangers this incredible opportunity. That is why we have taken aggressive action and support the FDA’s recent draft guidance. And it is why we urge government agencies across the country to act against counterfeit, knockoff and other illegal vapor products, which are often made with unknown ingredients, with unknown quality standards, and with youth-appealing flavors and packaging.

As we take these measures, we actively listen to our critics to learn from them. It is important that we also address some basic factual misconceptions and inaccurate statements.

First, we have never marketed to anyone underage. We fully recognize that while some of our earliest marketing did not accurately represent our goal (the often cited 2015 campaign that ran for only five months and did not meaningfully impact sales), our current marketing leaves no doubt about what our company was founded to do -- improve the lives of the world’s one billion adult smokers and eliminate combustible cigarettes. Our current advertising features testimonials from former adult smokers who made the switch off combustible tobacco with the JUUL device, and this campaign is targeted at adult smokers age 35 and up.

Second, some have inaccurately claimed that our website does not meaningfully age verify potential purchasers when, in fact, it features industry-leading third-party age-verification that puts every purchase through a rigorous, multi-step process, including two-factor authentication, to ensure every buyer is 21 or older. The site also restricts bulk purchasing, blocking a common strategy used by those seeking to illegally distribute the products.

Third, there are many inaccurate statements about the nicotine strength in our pods. We selected the nicotine strength in our pods for one reason only -- to give adult smokers an attractive option to switch off of combustible cigarettes. We knew a product should generally mimic the experience of a cigarette (the amount of nicotine delivered and the rate at which the nicotine enters the bloodstream), but assertions that our nicotine strength are 2-3 times that of traditional combustible cigarettes are false. In fact, in numerous controlled human clinical studies of our 5% strength products, nicotine absorption is always lower than a cigarette -- sometimes as low as 50%. In addition, adult smokers have the option to choose different JuulPod nicotine strengths.

Finally, contrary to common belief, far higher nicotine concentrations in products other than Juul were available when we launched in 2015 and they are still widely available today.

We appreciate the opportunity to clarify these inaccurate assertions and misconceptions surrounding our company and this category. But most importantly, we will continue to be a transparent partner and will work with all stakeholders, including Attorney General Stein, to combat youth use while preserving the opportunity for adult smokers to switch off of combustible cigarettes.

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Kevin Burns is the CEO of Juul Labs.

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