Background In January 2019, electronic nicotine delivery systems (ENDS) market leader Juul Labs (JUUL) launched an advertising campaign encouraging adult smokers to ‘make the switch’ from combustible cigarettes to JUUL. Our primary aim was to describe consumer perceptions of JUUL as communicated by members of JUUL’s online social community via testimonials promoted on JUUL’s website.
Methods User testimonials that were displayed on the JUUL website in December 2019 and January 2020 were collected and coded by three reviewers. A total of 220 testimonials were coded for primary and secondary themes (eight codes within four broader themes).
Results Testimonial writers were, on average, 43.0 years old (range 28 to 74) and reported using JUUL for an average of 21.8 months (range 9 to 59 months). The most prominent theme, present in nearly half of the testimonials, was a description of how to use JUUL, with a mention of JUUL’s benefits and tips on how to use the product. Nearly four in 10 statements encouraged smokers to give JUUL a try or noted that JUUL is a better product compared with cigarettes. About one in 10 statements focused on switching from smoking cigarettes to using JUUL.
Conclusion This study presents a foundation for understanding how adult users describe JUUL, including their experiences using JUUL to ‘switch’ or stop smoking. Currently, the effectiveness of ENDS for smoking cessation is not supported by substantial evidence; however, if cessation is defined as ‘quitting combustible tobacco products’, then regulators should be aware that switch and cessation messages may not be distinct.
- electronic nicotine delivery devices
- advertising and promotion
- public policy
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In the USA, smoking cessation products are regulated by the US Food and Drug Administration (FDA) as drugs or drug delivery devices and can only be legally sold if the FDA determines, after reviewing clinical trials, that they are safe and effective for that purpose. To date, no electronic nicotine delivery systems (ENDS) have sought nor received FDA approval for smoking cessation. Accordingly, no ENDS products can be marketed, implicitly or explicitly, as a tool to help smokers quit. By contrast, ENDS that are not intended for smoking cessation are regulated as tobacco products and, at the time this study was conducted, could be marketed without premarket review.1
In January 2019, ENDS market leader Juul Labs (JUUL) launched an advertising campaign encouraging adult smokers to ‘make the switch’ from combustible cigarettes to JUUL. In the wake of a vicious outbreak of lung injury associated with vaping,2 and the FDA’s criticism of its advertising activities, JUUL suspended the print, broadcast and digital product advertising in the USA in September 2019.3 Yet, the company’s website, direct email marketing and online store remained live and continued its ‘Make the Switch’ campaign (https://www.juul.com/).
JUUL argues that ‘switching’ does not constitute ‘quitting’ (ie, smoking cessation)4 and thus its products are tobacco products, not drug delivery devices that require FDA approval.5 For example, JUUL spokesman Ted Kwong has defended JUUL as a ‘switching product’ noting, “Switching involves continuing to consume nicotine but from a different device, while cessation is about getting users to eliminate their nicotine consumption altogether.”4 To date, the FDA has not publicly disagreed with that position. In a September 2019 warning letter, the FDA stated that the company’s ‘safer alternative’ claims constituted unsubstantiated risk reduction claims.6 The FDA did not address the possibility that switch statements are smoking cessation claims.
JUUL use is substantially higher among adolescents and young adults compared with older adults;7–9 however, adults do report using JUUL to help them quit smoking.8 10 Consistent with this, in his testimony before the US House of Representatives, JUUL co-founder James Monsees, noted, “The product we developed holds the promise to do what no previous technology has ever done on a consistent basis: help adult smokers stop smoking combustible cigarettes.”11 It is possible that JUUL’s ‘switch’ marketing is influencing consumer decisions to use JUUL for smoking cessation. Yet, to date, no scientific evidence describes whether consumers discern between ‘switching’ and cessation, or if consumers consider JUUL to be a smoking cessation product. Understanding how consumers interpret JUUL’s marketing claims is important for regulators. Whether a product is a drug (or device) typically depends on the product’s ‘intended use’, and the FDA often looks at a company’s promotional claims about its product, including consumer testimonials on the company’s website, to determine intended use. If consumers do not perceive JUUL’s ‘switch’ claims as distinct from ‘smoking cessation’ claims, then JUUL may be subject to regulation as a drug delivery device.
To begin answering the question of whether consumers perceive switch claims as distinct from cessation claims, we turned to JUUL’s website (juul.com). ENDS products are predominantly marketed online, via company-sponsored websites, social media and email.12 Similarly, JUUL’s website presents switch language throughout its site, including in their mission statement and company values, and on their get started (ie, how to use JUUL) and consumer referral pages. Because our primary aim was to describe consumer perceptions of JUUL as communicated by members of JUUL’s online social community, we focused on testimonials promoted publicly on JUUL’s website. Via the JUUL community, consumers can share their ‘story’, which may include a ‘selfie’ style photograph and a personal testimonial. At any time, consumer stories could be featured on JUUL’s community page (juul.com/community) or elsewhere, as a representation of the consumer narrative, or perceptions that users have about JUUL.
Late in 2019, JUUL’s website displayed testimonials from JUUL users on multiple public-facing web pages. Website visitors did not need to create a special account to see these testimonials (in contrast, other features in JUUL’s ‘community’ required visitors to create a login profile). This research focused exclusively on testimonials presented on public-facing web pages that could be easily accessed by every visitor to JUUL.com.
We collected user testimonials publicly displayed on juul.com in December 2019 and January 2020 (n=220). Data (ie, text) from all 220 testimonials was coded by three individuals (JGP, DTL and ARM) for primary and secondary themes, identifying eight codes encapsulated by four broader themes (1) using JUUL, (2) comparing JUUL to other tobacco/nicotine products, (3) general statements and (4) JUUL and switching/cessation (table 1). Most testimonials (n=170, 77.3%) comprised only one theme. Results discussed here are based on primary themes only.
Descriptive statistics were performed on the coded qualitative data. Means, ranges and percentages were calculated to characterise the user demographics, smoking history and the themes portrayed by their comments.
Of all testimonials, consumers were, on average, 43.0 years old (range 28 to 74) and reported using JUUL for an average of 21.8 months (range 9 to 59 months). In approximately one in three testimonials (n=63; 28.6%), JUUL users referred to their smoking history. Of these, only 11% (n=7) explicitly referenced their smoking history or described themselves as a smoker (eg, “For someone who has smoked for the better part of 30 years…”) while 89% (n=56) implicitly described a combustible smoking history (eg, “It actually does feel just like smoking, but now I don’t stink”).
As indicated in table 1, the most prominent theme, present in nearly half of the testimonials, was a description of how to use JUUL. These included mentions of the unique benefits of using JUUL and tips on how to use the product. Combined, nearly one in five statements compared JUUL more favourably to other tobacco products and presented the benefits of using JUUL over smoking cigarettes. Nearly one in five testimonials were motivational in nature, encouraging individuals to give ‘it’ (ie, JUUL) a try. About one in 10 statements were focused on switching from smoking cigarettes to using JUUL.
To discern consumer perceptions of JUUL, we analysed user testimonials presented on JUUL’s website as part of their online ‘Make the Switch’ marketing campaign. Of all testimonials, the youngest contributor was 28 years old, suggesting that JUUL has curated the testimonials to advance the company’s narrative that (1) JUUL is a product for ‘adult smokers’ and (2) its marketing strategy targets older smokers (ie, not adolescents nor young adults). The overarching narrative depicted by users presented JUUL as easy-to-use, similar to smoking, worth trying and an effective means to stop smoking. JUUL’s marketing strategy is reminiscent of the Centers for Disease Control and Prevention’s Tips From Former Smokers campaign, which uses Real People, Real Stories in the messaging to encourage smokers to quit.13 Additionally, Chantix, an FDA-approved smoking cessation drug, uses online user testimonials—described as ‘Real People, REAL INSPIRATION’—to promote smoking cessation with varenicline.14
Prior studies indicate the JUUL is not the only company to make explicit or implicit smoking cessation claims in its advertising. Reports have suggested that 23% to 56% of online ENDS marketing contained potential cessation claims.15 16 Most of these claims were implicit and used somewhat ambiguous language (eg, ‘switching works’), but when directed toward smokers, these claims could be interpreted as implicitly promoting ENDS as a smoking-cessation tool. Data from these studies were gathered either prior to or right as the newest generation of ENDS was gaining popularity. Future studies should assess whether JUUL’s switch marketing is unique, or if ‘switching’ constitutes a ubiquitous marketing strategy across companies/brands selling novel ENDS.
This study raises several regulatory questions related to switch claims, yet the arguments for and against permitting switch claims in ENDS marketing rest on two main concerns: (1) how smoking cessation is defined (ie, combustible tobacco product cessation only or total nicotine and tobacco product cessation) and, relatedly, (2) whether switching and cessation describe synonymous or distinct concepts. While further research is needed to fully understand how JUUL’s marketing affects consumer perceptions of JUUL as a smoking cessation product, this study presents a foundation for understanding how adult users describe JUUL, including their experiences using JUUL to ‘switch’ or stop smoking. At present, the effectiveness of ENDS for smoking cessation is not supported by substantial evidence.17–23 If cessation is defined as ‘quitting combustible tobacco products’, then switch and cessation messages may not be distinct (as implied by consumer testimonials) and, importantly, switch claims made in ENDS product advertising could be considered false or misleading.
In March 2020, JUUL applied for a patent to use artificial intelligence for a device to help users quit nicotine. The device would work with a vaporiser (like JUUL), but would limit daily use to help users reduce and, eventually, quit nicotine altogether.24 With this change, JUUL may be laying the groundwork for more explicitly marketing its products as adult-focused smoking cessation products, belying the company’s earlier assertions that “switching” and cessation are distinct.4 Such a change would be laudable if JUUL were shown to be a safe, effective smoking cessation product and was approved by the FDA. Prior to such approval, the FDA should carefully scrutinise JUUL’s product promotion—including user testimonials—to determine whether its messaging communicates the intent that JUUL be used for smoking cessation and, thus, could be subject to regulation as a drug or drug delivery device.
Regulatory questions related to switch claims
Should regulators consider stopping use of combustible tobacco products to be ‘smoking cessation’?
Should regulators consider switch claims to be smoking cessation claims, modified risk claims, both, or neither?
Should there be ways for ENDS manufacturers to market their products as smoking alternatives without regulators considering them to be making smoking cessation or modified risk claims?
If consumers do understand ‘switch’ messages to constitute smoking cessation messages, is public health best protected through regulating those ENDS as drugs or as tobacco products?
Should regulators’ approaches differ if switch claims are a widespread marketing strategy across the ENDS industry?
What this paper adds
JUUL’s ‘Make the Switch’ campaign uses testimonials from adult consumers who encourage others to try JUUL for various reasons, including its ability to help one switch from combustible tobacco products to ENDS. As a result of this study, we know the major themes that are promoted in these testimonials and that approximately 10% of them are messages about stopping combustible tobacco use and switching to ENDS, which could be construed as smoking cessation messages.
Patient consent for publication
Contributors JGP, AKF and PJZ substantially contributed to the conception and design of the study. JGP, DTL and ARM conducted all data analysis. All authors contributed to data interpretation, manuscript preparation and approved the final version of the manuscript.
Funding This study was funded by The Ohio State University Comprehensive Cancer Center internal grant and dupported by the National Cancer Institute of the National Institutes of Health under award number T32CA229114. The content is solely the responsibility of the authors and does not necessarily represent the official views of the National Institutes of Health.
Competing interests None declared.
Provenance and peer review Not commissioned; externally peer-reviewed.