This is a working checklist, not a legal guide. Print it, walk your store with it, and fix what you find. Update it annually — regulatory requirements change.

Age Verification — Register-Level Checklist

  • POS system prompts cashier for age verification on every tobacco/vape/hemp transaction
  • POS system logs verification timestamp per sale
  • ID scanner hardware is functional and calibrated
  • Acceptable ID list is posted at register (valid driver’s license, state ID, passport, military ID)
  • Staff know the cutoff birth date for 21+ sales (calculate: today minus 21 years)
  • No sale policy is posted and staff have practiced the refusal script
  • Manager has override code for any ID scanner — and knows when to use it

Required Signage — Walk Your Store

  • “No tobacco sale to persons under 21” sign posted at every register (federal requirement)
  • Sign is visible to customers, not obstructed by merchandise or displays
  • State-specific signage requirements checked and current (these vary — look up your state)
  • Kratom signage posted if required by your state’s KCPA regulations
  • Hemp/CBD product signage meets your state’s labeling and display requirements
  • No promotional signage visible from outside that features tobacco/vape products (restricted in some states)

Inventory Documentation

  • Purchase invoices retained for all tobacco and vape products (keep 2 years minimum)
  • Supplier information on file for every product category
  • PMTA authorization status documented or noted for e-cigarette/vape products
  • Kratom COAs (Certificates of Analysis) on file for each kratom product/batch
  • Hemp product lab test results on file showing THC content within legal limits
  • No products from unlicensed or unverified suppliers in inventory

Staff Training Documentation

  • Written age verification training policy exists
  • All current employees have signed the training acknowledgment
  • Training log maintained with dates and employee signatures
  • New hire training includes compliance module before solo register work
  • Annual refresher training scheduled and logged

Physical Store Compliance

  • No products accessible to customers without staff assistance if required by local ordinance
  • Tobacco products not visible from outside in jurisdictions where this is required
  • Store layout does not permit self-service tobacco access by minors
  • Cash register area is staffed at all times during operating hours
  • Security camera covers the point-of-sale area (compliance documentation benefit)

FDA-Specific Items

  • FDA tobacco retailer registration is current (renews every 2 years at FDA.gov)
  • Registration certificate is accessible if requested by inspector
  • Written response plan exists for what to do if an inspector arrives

Quarterly Review

  • Run your own mystery shop or have a trusted person do it
  • Check POS reports for any transactions without age verification logged
  • Review any incidents (refused sales, near-misses) and update training accordingly
  • Verify no new products have been added without documentation check

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