The e-cigarette brand JUUL became the fastest growing e-cigarette brand in the U.S. in early 2017, surpassing other brands marketed by tobacco industry giants. JUUL was introduced in 2015 by PAX Labs, Inc., based in San Francisco, California, and is now manufactured by JUUL Labs, Inc., which spun off from PAX Labs in 2017. Knock-off products have entered the marketplace including a recent upscale entry, myblu, an offshoot of the e-cigarette brand, blu. Although JUUL is promoted as a product for adults looking for an alternative to smoking conventional cigarettes, it has developed a cult-like following among youth and young adults, fueled by a strong presence on social media sites like YouTube, where the term “JUULing” is used to describe use of the product.

The popularity of JUUL among youth and young adults is a matter of deep concern for the public health community, which has invested in efforts to prevent e-cigarette use by young people, based on evidence that most tobacco use starts in adolescence and that exposure to nicotine during adolescence can cause addiction and harm the developing brain. A 2016 Surgeon General’s Report speaks to numerous health concerns and is emblematic of the public health community’s long-standing commitment to doing all it can to prevent e-cigarette use by young people. E-cigarettes have become the most common type of tobacco product used by youth in the U.S., and many young people between the ages of 18 and 25 engage in dual use of e-cigarettes and conventional cigarettes. Reasons young people are drawn to e-cigarettes include curiosity, taste, and a persistent belief that e-cigarettes are less harmful than other tobacco products.

JUUL’s distinctive design features make it attractive to teens and young adults.  For instance, its small size and shape—it resembles a USB flash drive—enable young people to hide it from view and use it discreetly in regulated environments such as schools. The device’s battery is easy to recharge, taking only about an hour using a USB charger. Discreet use is also made possible because JUUL devices do not emit voluminous vapors, unlike many other brands of e-cigarettes.  Although JUUL is sold as a closed-end system, multiple social media sites feature easy, how-to instructions for opening JUUL devices and filling them with e-juice.

As with other e-cigarettes, an obvious attraction for young people is JUUL’s assortment of appealing flavors, including fruit medley, mango, cool mint, and crème brûlée. The public health community is concerned that many young people enticed by JUUL’s fruit and candy-like flavors may be unaware that JUUL e-juice contains nicotine, to which they can become easily addicted. The FDA has had the authority to regulate e-cigarettes since 2016, but has delayed implementation of key provisions for several years, including a regulation that would require all e-cigarette products, including flavors, to obtain FDA approval before entering the marketplace. In most jurisdictions, flavored e-cigarettes are readily available in convenience stores and gas stations, locations where youth can easily access them.  

Each JUUL pack of e-juice contains four “pods.” The e-juice in JUUL pods is formulated with nicotine salts from natural tobacco leaves, rather than free-base nicotine commonly used in e-juices formulated by other manufacturers. JUUL’s nicotine salts are said to emit a taste and sensation similar to conventional cigarettes and unlike other e-cigarettes. The advertised concentration of nicotine in each pod is marketed as being approximately equivalent to the amount of nicotine in a typical pack of cigarettes. Insufficient quality control regulations in the manufacture of e-cigarettes raises concerns, including the potential for nicotine poisoning, especially if nicotine concentrations significantly exceed advertised amounts. Even if labeled accurately, the concentration of nicotine in each JUUL pod is approximately twice that of many other e-juice nicotine concentrations, delivering a hefty nicotine hit; it is listed as 5 percent, whereas various other brands market e-juices with nicotine concentrations of 2.4 percent or less—raising concerns that JUUL may have a higher risk of addiction than other e-cigarettes..

Wrapped in prevention hype, JUUL appears to be following a (wolf-in-sheep’s-clothing) playbook used extensively by the tobacco industry. In California, JUUL’s outreach to school systems has been led by two retired school administrators, one of whom is a former superintendent. The California Department of Education recently asked schools to reject involvement with the JUUL Prevention Initiative and is collecting data on JUUL use and the number of devices confiscated in schools. Similar data have been collected in Arizona.

Public health materials to build public awareness about potential harms associated with use of JUUL are emerging, including educational toolkit materials for teens developed by the Stanford University Department of Medicine, a Truth Initiative fact sheet, and a Campaign for Tobacco-Free Kids fact sheet. The Public Health Law Center has also held a webinar on JUUL, and has released a resource that addresses policy considerations related to regulation of JUUL and similar types of e-cigarettes.

 

Updated April 30, 2018


Susan Weisman, J.D., is a Senior Staff Attorney at the Public Health Law Center.