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
Related Articles: - [FDA Inspection: What to Expect] - [Smoke Shop Licensing in 2026] - Disposable Vape Ban 2026