| 1 | Check FDA authorization for each exact product. | Search the FDA’s tobacco-product resources and confirm the specific product appears among products with a marketing granted order. Match the product identity and applicable order details. | An FDA marketing order applies to the specific product identified in the order; it is not a blanket authorization for every product from a seller or manufacturer. |
| 2 | Match the product details, not just a similar name. | Compare the listed product name and relevant device and e-liquid details with the FDA record and order. Ask the seller to clarify any mismatch before purchase. | A similar-looking product or a different variant should not be assumed to be covered by another product’s order. |
| 3 | Use FDA sources rather than seller claims alone. | Independently consult FDA’s Searchable Tobacco Products Database and its lists of products with marketing granted orders. Keep a dated record of the search and relevant order information. | A certificate, invoice, or seller statement is not a substitute for confirming the product’s status in FDA records. |
| 4 | Understand what a marketing order means. | Confirm that the product has a marketing granted order and review any stated conditions or limitations. | A marketing order permits marketing under its terms; it is not the same as FDA approval or a finding that the product is safe. |
| 5 | Request product-level documentation. | Ask for the FDA order reference and documentation identifying the exact products offered. Reconcile those details with the FDA record before approving the purchase order. | Clear records help distinguish authorized products from products that are merely described as compliant. |
| 6 | Check every item in a mixed or multi-variant order. | Create an itemized list of all device and e-liquid variants in the shipment and verify each one individually against FDA records. | Authorization for one variant does not establish authorization for other variants included in the same bulk order. |
| 7 | Check federal, state, and local requirements. | Review the rules that apply where the products will be sold, stored, and delivered, including product restrictions, licensing, taxes, and any required reporting. | FDA marketing authorization does not by itself satisfy every other federal, state, or local requirement. |
| 8 | Confirm age-verification obligations. | Ensure sales procedures comply with applicable age restrictions. Federal law prohibits selling tobacco products, including e-cigarettes, to anyone under 21. | Bulk purchasing does not remove retailers’ obligations to prevent sales to underage customers. |
| 9 | Plan for traceability and receiving checks. | Record the ordered product identifiers, quantities, supplier details, and shipment information. Check that received goods match the verified order. | Accurate records make it easier to identify discrepancies and respond to regulatory or supply-chain questions. |
| 10 | Recheck status before repeat orders. | Repeat the FDA and applicable-law checks before each reorder, and review FDA updates or changes to the relevant order. | Product listings, order conditions, and other regulatory requirements can change over time. |