TOBACCO WHERE YOU LIVE: 

Retail Strategiesto Promote Health Equity
ACKNOWLEDGEMENTS

This brief was produced for the Centers for Disease Control and Prevention by 

the Center for Public Health Systems Science at the Brown School at Washington 

University in St. Louis. 

Primary contributors:

Stephanie Andersen, Laura Brossart, Rebecca Ballard, Amy Endrizal, Rachel Hackett, Chase Bryer, Keishi 

Foecke, Zara Petković, River Chew, Douglas Luke

Input was provided by:

René Arrazola, Natasha Buchanan Lunsford, Todd Combs, Elizabeth Courtney-Long, Paul Cummings, 

Phillip Gardiner, Lisa Henriksen, Lorraine Lathen, Maggie Mahoney, Mark Meaney, Kurt Ribisl, Karla 

Sneegas, Luke Witkowski

Other contributions:

Photo on page 6 courtesy of Truth Initiative

Photos on page 7 courtesy of Stanford Research into the Impact of Tobacco Advertising and California 

Department of Public Health

Photo on page 8 courtesy of The Center for Black Health and Equity

Photos on page 12 and 26 courtesy of Tobacco Free Florida

Photos on page 15 and 19 courtesy of ASPiRE Center

Photo on page 16 courtesy of Association for Nonsmokers-Minnesota

Photo on page 17 courtesy of Mecklenburg County Public Health

Photo on page 19 courtesy of Philadelphia Department of Public Health

Photo on page 20 courtesy of Pennsylvania Tobacco Resistance Unit (TRU)

Photo on page 21 courtesy of Tennessee Department of Mental Health & Substance Abuse Services

Photo on page 22 courtesy of Campaign for Tobacco-Free Kids

Photo on page 23 courtesy of City of San Antonio Metropolitan Health District

Photo on page 24 courtesy of Wisconsin Department of Health Services

Photo on page 28 courtesy of Multnomah County Health Department, Oregon

Photo on page 29 courtesy of Alameda County Public Health Department

Photo on page 30 courtesy of African American Tobacco Prevention Network

Suggested citation:

Centers for Disease Control and Prevention. Tobacco Where You Live: Retail Strategies to Promote Health 

Equity. Atlanta, GA: U.S. Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Center for Chronic Disease Prevention and Health Promotion, Office on Smoking 

and Health, 2022.
TABLE OF CONTENTS

OVERVIEW........................................................................... 1

Read about the Tobacco Where You Live series, what you’ll find in this brief, and 

how it fits in with the Best Practices User Guides. 

MAKE THE CASE .................................................................... 2

Understand why reducing tobacco industry influence in the retail environment is 

important to reduce commercial tobacco use disparities. 

LEARN THE BASICS ................................................................ 3

Learn about the retail environment, the industry’s marketing tactics and their 

impact on health equity, and commercial tobacco control retail strategies. 

GET READY ........................................................................ 12

Prepare for retail strategies by assessing the retail environment and forming 

partnerships.

TAKE ACTION ..................................................................... 17

Choose retail strategies that fit your needs, raise awareness about your efforts, 

implement and enforce strategies equitably, and monitor and evaluate your work.

EXPLORE COMMUNITY EXAMPLES ........................................... 29

Read about how local communities implemented retail strategies to reduce 

tobacco-related disparities.

REFERENCES ...................................................................... 31
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 1

OVERVIEW

Tobacco Where You Live

Clear evidence exists about what works to reduce commercial tobacco use at 

the population level.1 Yet, many states and communities across the country have 

not implemented effective strategies.2,3,4 Groups disproportionately impacted 

by tobacco industry targeting and social determinants of health continue to 

experience high rates of tobacco-related disease and death.5 Understanding 

community needs and using community-driven solutions can inform how to 

move toward closing these gaps in commercial tobacco prevention and control. 

The goal of Tobacco Where You Live is to empower tobacco control program 

managers, staff, and partners to understand how commercial tobacco use varies 

within their communities, overcome challenges, and reduce disparities. Each 

Tobacco Where You Live brief will cover a topic important to reduce commercial 

tobacco use in communities with the highest prevalence.

When this guide references commercial tobacco or tobacco products, it refers 

to products that are mass-produced and sold for profit. This is separate from the 

sacred and traditional use of tobacco by some American Indian communities.

In This Resource

Retail Strategies to Promote Health Equity describes the tobacco industry’s 

tactics to promote its products in retail stores and how retail strategies can reduce 

the burdens of commercial tobacco use and promote health equity. This brief 

provides information to help you: 

 Understand the retail environment in your community

 Learn about retail strategies

 Implement strategies equitably

 Overcome potential opposition and enforcement challenges

 Monitor and evaluate retail strategies

About the Project

Tobacco Where You Live is a Best Practices User Guide resource. The Center for 

Public Health Systems Science at Washington University in St. Louis is developing 

a set of resources to translate research into practical guidance for states and 

communities. These resources expand on the evidence-based guidelines and 

funding recommendations in Centers for Disease Control and Prevention’s (CDC) 

Best Practices for Comprehensive Tobacco Control Programs—2014 (Best 

Practices 2014).6

The Best Practices User Guides project is funded 

by CDC contract 75D30120C09195. Its contents 

are solely the responsibility of the authors and 

do not necessarily represent the official views of 

CDC. References to non-CDC sites and the use 

of advertisements and images do not constitute 

or imply endorsement of these organizations or 

their programs by CDC or the U.S. Department 

of Health and Human Services. CDC is not 

responsible for the content of pages found at 

external sites. URL addresses listed were current 

as of the date of publication.
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 2

MAKE THE CASE

Commercial tobacco use, which includes 

products such as cigarettes, cigars, 

smokeless tobacco, and e-cigarettes, is 

still high in communities where tobacco 

retailers are concentrated. People who live 

in these communities, including people 

with lower incomes, youth, and people 

from historically marginalized racial and 

ethnic groups, are more likely to use 

commercial tobacco and struggle to quit.7

Focusing on the local retail environment 

helps to make sure that strategies to 

reduce commercial tobacco use are 

culturally relevant to communities. Retail 

strategies are crucial, and complement 

other commercial tobacco control 

strategies to reduce disparities and 

ultimately achieve health equity.

Retail strategies advance health equity by:

 Reducing access to commercial 

tobacco products

People who live in communities with 

many tobacco retailers have access to 

a wide variety of tobacco products. 

Restricting where retailers can sell tobacco products can reduce exposure to 

tobacco products and differences in retailer density between communities.7

 Reducing exposure to commercial tobacco marketing

Industry marketing is targeted to certain groups and more prevalent in certain 

communities.8 Reducing exposure to tobacco advertising can denormalize 

commercial tobacco use and promote cessation, especially in communities 

exposed to more targeted marketing.9

 Promoting commercial tobacco cessation

Population groups targeted by the tobacco industry, including people with 

low incomes and Black people, have lower quit rates than in other groups.10

Implementing equitable retail strategies can help people quit by reducing 

exposure to advertising, promoting commercial tobacco cessation resources, 

and limiting access to tobacco products. Retail strategies can also reduce the 

availability of flavored tobacco products. Banning flavors, including menthol, 

could make it easier for people in communities with high commercial tobacco 

use prevalence to quit commercial tobacco.11

Strategies to reduce commercial tobacco use. Adapted from Kong & King, 20217 and King & 

Graffunder, 201812
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 3

LEARN THE BASICS

Reducing the Impact of Tobacco Retailing, 1970-present

The retail environment is 

now the main channel for 

industry marketing.

NATIONAL

Congress bans TV and radio ads for cigarettes 1971

Congress expands ad restriction to smokeless tobacco 1986

The Master Settlement Agreement (MSA) prohibits most 1998

outdoor billboards and sponsorships

Industry spending more than doubles following the 2003

MSA, making retail environment the main channel for 

industry promotion

2009 The Family Smoking Prevention and Tobacco Control Act

gives FDA authority to regulate the manufacturing, 

marketing, and sale of tobacco products

The Deeming Rule 2016 expands FDA authority over all 

tobacco products, including e-cigarettes

Congress raises the federal minimum legal sales age to 21 2019

Tobacco control retail goal added to Healthy People 2030 2020

health objectives

FDA proposes tobacco product standards to ban 2021

menthol as a characterizing flavor in cigarettes and ban 

all flavors in cigars

STATE & LOCAL

2005 Needham, MA becomes the first locality to raise sales 

age to 21

2009 New York, NY becomes first city to ban the sale of flavored 

tobacco products, except menthol and e-cigarettes

2012 Providence, RI bans flavored e-cigarettes and becomes the 

first city to prohibit coupons and multi-pack promotions

2013 New York, NY prohibits coupons and multi-pack promotions

2014 San Francisco, CA passes a retailer density law to cut the 

number of tobacco retailers in the city by half

2015 Hawaii becomes the first state to raise the age of sale to 21

2017 San Francisco, CA passes a city-wide, comprehensive flavor 

restriction

2019 Beverly Hills, CA bans the sales of tobacco from most 

retailers, except cigar lounges and hotels

Massachusetts becomes the first state to prohibit the sale of 

all flavored tobacco products

2020 At least 110 localities have flavor bans that include menthol

Brookline, MA passes “tobacco-free generation” policy, 

banning the sale of tobacco to anyone born after 1/1/2000

2021 As of July 2021, 39 states and over 570 municipalities have 

set the minimum legal sales age to 21

1970

present
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 4

What Is Health Equity in Commercial 

Tobacco Control?

Health equity is the opportunity for all people to live a healthy life free of 

commercial tobacco, regardless of who they are, where they live, or what they 

do.13 Reducing industry influence in the tobacco retail environment is a big step 

toward achieving health equity in commercial tobacco control. Retail strategies 

that are equitably implemented advance health equity. They limit access to and 

availability of commercial tobacco products, raise prices, and reduce exposure to 

tobacco advertising for all people.

W H AT A R E 

TO B ACCO - R E L AT E D 

D I S PA R I T I E S ? 

Tobacco-related disparities are 

differences among population 

groups in commercial tobacco 

use, prevention, and cessation.13 

Disparities can also exist in 

secondhand smoke exposure, access 

to commercial tobacco cessation 

resources, and health outcomes.13

These groups have systematically 

faced greater obstacles to health 

based on characteristics, such as:13

• Age 

• Criminal justice involvement

• Disability 

• Education

• Gender identity 

• Geographic region 

• Health insurance status

• Home insecurity

• Income level and occupation

• Military status

• Race and ethnicity

• Sex 

• Sexual orientation

What Is the Retail Environment?

The retail environment refers to stores where commercial tobacco products are 

sold. This is also sometimes called the point of sale or the built environment. 

The industry markets its products through: 

 Ads posted inside and outside of stores, such as storefronts and parking lots

 Prominent product placement

 Promotions such as price discounts, coupons, free or low-cost products 

In 2018, an estimated 326,000 retailers sold tobacco products.14 Research from 

2016 estimated that 5,000 to 10,000 retailers sold only e-cigarettes.15 Many types 

of retailers sell tobacco products, but convenience stores are the most common.16

Tobacco retailers are:17

 Widespread and accessible to most people

 Often located near schools

 Clustered together, often in urban, minority, or lower-income neighborhoods

Examples of tobacco industry price promotions, advertising, and product placement in the retail environment. Source: CounterTobacco.org

LEARN THE BASICS 
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 5

Tobacco products sold in retail stores include combustible products like cigarettes, 

cigars, cigarillos, and hookah. Retail stores also sell non-combustible products like 

e-cigarettes, chew, dip, snus, heated tobacco products, products with nicotine not 

derived from tobacco, and nicotine pouches. 

Simply living near a tobacco retailer can increase the risk of commercial tobacco use 

and make it harder to quit.18,19 One study found that nearly 50 percent of youth visit 

a convenience store once a week.

20 It also found that Black youth are twice as likely 

as their non-Black peers to visit a convenience store every week.20 Youth who buy 

items from convenience stores are unavoidably exposed to retail marketing. 

In one study, the number of tobacco retailers per person was up to three times higher 

in low-income neighborhoods than in higher-income areas.21 Reducing proximity 

to tobacco product retailers for all people can help to reduce exposure to targeted 

marketing and change behaviors toward buying and using tobacco products.18

T H E T R I B A L R E TA I L 

E N V I R O N M E N T 

Commercial tobacco products are sold on tribal lands. Because tribal lands are 

sovereign, they have the authority to make their own tobacco retail 

regulations.22,23 For example, tribes may raise their commercial tobacco taxes 

higher than state taxes. But tribal tobacco control measures are likely to come 

with some important considerations, like exemptions for traditional tobacco.24

Traditional tobacco is used for ceremonial or medicinal purposes.24 When 

working in the tribal retail environment, collaborate closely with tribal partners 

to understand their local environment and challenges.25

Indian outpost on the Shinnecock Indian Reservation, Southampton, Long Island, New York

W H E R E TO B ACCO 

I S S O L D 

Many types of stores sell commercial 

tobacco products: 

• Convenience stores

• Pharmacies

• Grocery stores

• Dollar stores

• Liquor stores

• Tobacco shops

• Vape shops

LEARN THE BASICS 
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 6

Industry Tactics in the Retail 

Environment

The tobacco industry spends nearly one million dollars per hour advertising and 

promoting its products.26,27 The industry uses different marketing tactics to target 

certain groups.28 These strategies encourage customers to make impulse 

purchases, create environmental cues to smoke, and normalize commercial 

tobacco use.29,30 They also encourage young people to start using commercial 

tobacco and make it harder to quit.31,32 The populations targeted by the industry 

are also a primary focus for commercial tobacco control retail interventions.

Tobacco industry retail spending infographic. Source: Truth Initiative

Price Promotion and Tobacco-Related 

Disparities

In some places, like communities with higher proportions of low-income, Black, 

and young people, commercial tobacco products are often sold at lower prices 

than in other neighborhoods.33-35 To do this, tobacco companies enter into 

contracts with retailers to display advertising and offer price discounts, rebates, 

and gifts in exchange for retailers promoting their products in prime retail space.36

These contracts allow retailers to sell tobacco products at low prices, some for less 

than a dollar.33

These promotions have also led to greater burdens of tobacco-related 

disease in certain communities. For example, historical documents show that 

the industry targeted Asian Americans because of their high rates of store 

ownership.37 The industry has made financial contributions to Asian American 

community organizations and business associations.37 Korean Americans and 

Vietnamese Americans have a higher cigarette smoking prevalence than many 

other ethnic groups.38

KEY RESOURCES

Counter Tobacco

Resources and tools to understand 

and counter tobacco industry tactics 

at the point of sale

Point-of-Sale Report to the Nation 

(Center for Public Health Systems 

Science)

Description of retail disparities with 

tools and resources for states and 

communities to counter industry 

influence 

Tobacco Disparities: Evidence 

Supports Policy Change (Tobacco 

Policy Center)

Fact sheet summarizing the evidence 

on tobacco-related disparities in the 

retail environment

Tobacco Retail Policy Trends in 

2019: Insights from the Field 

(ASPiRE Center)

Series of fact sheets discussing state 

and local perspectives on the barriers 

and facilitators to implementing retail 

strategies

Tobacco Retailers (ASPiRE Center)

Background information on tobacco 

retailers and retail disparities

LEARN THE BASICS 
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 7

Retail Advertising and Tobacco-Related 

Disparities

The industry uses appealing packaging, targeted messages, and strategic product 

placement to encourage customers to buy specific products. For example: 

 Menthol cigarettes are predominantly marketed in communities with a 

higher proportion of Black people and use images and messages that evoke 

Black culture.39

 The industry uses culturally representative imagery and brand names to 

appeal to Alaska Native, Hispanic/Latino, and American Indian people.39

 The industry advertises heavily in communities with higher proportion of 

Asian American people.37 Before the Master Settlement Agreement, the 

industry sponsored cultural festivals for Asian American communities.37

 The industry advertises heavily in retailers that accept Supplemental Nutrition 

Assistance Program (SNAP) and Special Supplemental Nutrition Program for 

Women, Infants, and Children (WIC), exposing people with low incomes to 

more tobacco marketing.40

 The industry places ads in publications that market to LGBTQ+ people and 

sponsors cigarette and merchandise giveaways.41

 Tobacco ads in rural communities link commercial tobacco use to rural values 

and ideals, such as ads that reinforce gender norms by featuring “manly” or 

“rugged” cowboys, race car drivers, and hunters.42

 The industry creates and markets products designed for women with ads that 

promote feminine beauty ideals with slim, attractive, and athletic models.43

 Tobacco products are often placed at eye level of children and have appealing 

candy-like flavors and colorful packaging.44

Ad from California Tobacco Control Program 

(CTCP)’s “The Tobacco Industry Has a 

Kids Menu” campaign. ©2018 California 

Department of Public Health. Source: CTCP

Examples of targeted tobacco industry advertising (from left to right: Black communities, young women, rural communities). 

Source: Stanford Research into the Impact of Tobacco Advertising

LEARN THE BASICS 
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 8

Flavored Products and Menthol

Flavors mask the harsh taste of tobacco products, making it easier to start using 

commercial tobacco and harder to quit.2 Flavors are especially attractive to 

youth.45 The FDA banned the sale of flavored cartridge and pod-based products in 

February 2020, except for tobacco and menthol flavors. 

The FDA also prohibits the sale of flavored cigarettes, except menthol.46

Menthol cigarettes are more addictive than non-menthol cigarettes, particularly 

for youth.47 Menthol influences nicotine receptors in the brain, increasing 

addiction.48 Beginning in the 1960s, the industry began aggressively marketing 

menthol cigarettes to young Black people.49 The industry has also formed 

strategic partnerships with Black community organizations and made financial 

contributions to Black groups and political leaders.49 The impact of these tactics 

is clear: by 1971, 38 percent 

of Black people who smoked 

cigarettes used menthols.50 In 

2016, 85 percent of Black people 

who smoked cigarettes preferred 

menthols.51

The industry has also targeted 

other population groups with 

menthol ads, including the 

LGBTQ+ community.52

In 2022, FDA proposed tobacco 

product standards to ban 

menthol as a characterizing 

flavor in cigarettes and ban all 

characterizing flavors other than 

tobacco in cigars. Although the 

FDA has not yet banned all flavors 

including menthol, some states 

and localities have taken the lead 

in doing so, like Massachusetts.

The industry has found ways to 

evade measures to restrict flavors 

by using names that are not 

explicit flavors but imply that the 

product is flavored, such as 

“Island Madness.”33 These “concept 

flavors” can complicate 

enforcement and make products 

appear less harmful.53

Digital ad from No Menthol Sunday 2022 Campaign. Source: The Center for Black Health and Equity

Inequitable 

practices, including 

targeted marketing 

of menthol products, 

help to explain why 

85 percent of Black 

Americans who 

smoke cigarettes use 

menthols.

LEARN THE BASICS 
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 9

What Are Retail Strategies to Reduce Commercial Tobacco Use? 

 Product Availability

Reducing types of commercial tobacco products sold by retailers

Strategies

• Restricting sales of certain product types, such as flavored tobacco products

• Prohibiting sale of all tobacco products

Health Equity Impact

• Flavor restrictions may reduce youth initiation and menthol-related 

disparities7

• Restricting product sales limits the industry’s retail presence by reducing 

exposure to related ads and promotions7,54

Community Examples

• In 2019, Massachusetts became the first state to prohibit the sale of all flavored tobacco products.55

• Also in 2019, Beverly Hills, CA prohibited most tobacco product sales within city limits.56

KEY RESOURCES

Restricting Product Availability 

(Counter Tobacco)

Policy Options for Restricting the Sale of 

Menthol Cigarettes and Other Flavored 

Tobacco Products (ChangeLab Solutions)

 Pricing & Promotion

Non-tax approaches to reduce the industry’s ability to lower product prices

Strategies

• Setting the minimum price above market price for certain pack sizes

• Restricting coupon redemption (including mobile coupons)

Health Equity Impact

• Selling products in larger quantities makes them more expensive57

• Restricting coupon redemption may reduce the receipt of coupons among 

certain populations that use discounts more often than others, such as Black 

people, youth, and women58

• Higher prices help prevent youth initiation and motivate people with low 

incomes to quit commercial tobacco59

• Non-tax approaches help reduce disparities and complement taxes60

Community Examples

• In 2018, Alameda, CA set a minimum price for tobacco products.61

• In 2020, New Jersey prohibited coupons and price promotions for tobacco products.62

KEY RESOURCES

Increasing Tobacco Prices through Non-Tax 

Approaches (Counter Tobacco)

Point-of-Sale Tobacco Pricing Policies 

(Counter Tobacco)

Scientific Evidence Brief: Flavored Tobacco 

Products, Including Menthol (CDC)

LEARN THE BASICS
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 10

 Advertising

Reducing exposure to promotional items and ads based on the time, place, or manner, 

but not the content, of advertising

Strategies

• Content-neutral ad restrictions that limit all signage regardless of content

• Before considering any advertising restrictions, speak with a public health 

attorney with experience in this area

Health Equity Impact

• May reduce tobacco advertising in communities where it is often 

concentrated, such as low-income and minority communities28

• Decreased exposure to marketing can decrease cravings and impulse 

purchases9

• Removing marketing can help youth avoid initiation and help people who use commercial tobacco quit7

Community Examples

• In 2010, Henderson, NV restricted the size of storefront signs.63

• In 2016, Sacramento, CA restricted the size and number of outdoor signs.64

KEY RESOURCES

Restricting Tobacco Advertising (Counter 

Tobacco)

How Companies Control Where You See 

Tobacco Products and What Policy Can Do 

About It (Truth Initiative)

 Age of Sale

Raising the minimum age of sale for tobacco products

Strategies

• Restricting sales to people over the age of 21 to support enforcement of the 

federal Tobacco 21 law

• Prohibiting sales to those born after a certain year

• Prohibiting internet sales of tobacco products

Health Equity Impact

• May reduce underage sales in low-income and minority neighborhoods, 

where they are more common65

• Raising the minimum age may prevent young people from purchasing for 

themselves or others66

• Prohibiting sales to people born after a certain date may prevent future 

initiation and nicotine dependence in communities67

Community Examples

• In 2015, Hawaii became the first state to raise the minimum legal sales age to 21.68

• In 2021, Brookline, MA prohibited sales to anyone born after January 1, 2000.69

KEY RESOURCES

Scientific Evidence Brief: Raising the 

Minimum Legal Sales Age for Tobacco 

Products (CDC)

Tobacco 21 Model Policy (ChangeLab 

Solutions)

Policy Options for Restricting the Sale 

of Menthol Cigarettes & Other Flavored 

Tobacco Products (ChangeLab Solutions)

LEARN THE BASICS
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 11

 Retail Licensure

Implementing, evaluating, and enforcing retail strategies through licensing or zoning 

policies, including lowering retailer density

Strategies

• Capping: Limiting the number of retailers to balance their distribution across 

neighborhoods

• De-clustering: Restricting retailers from operating near each other

• Proximity: Restricting where retailers can be located, such as away from 

schools or at adult-only retailers

• Store-specific: Prohibiting sales at specific types of retailers

Health Equity Impact

• May reduce retailer concentration in low-income and minority communities17

• Decreasing retail density may reduce exposure to marketing that targets 

certain populations7

• Capping the number of retailers, especially around schools, can more 

equitably reduce density than focusing on specific types of retailers70,71

• Proximity-based strategies are more effective in lower income areas and show promise for reducing disparities71

• Making people travel farther to buy tobacco could decrease use18

Community Examples

• In 2016, Philadelphia, PA set a cap on the total number of tobacco retailer permits and restricted new retailers 

from being located within 500 feet of schools.72

• In 2020, Idaho required licensure for retailers selling tobacco and e-cigarettes, regardless of which substances 

they contain.73

KEY RESOURCES

Licensing, Zoning, and Retailer Density 

(Counter Tobacco)

Tobacco Retailer Licensing Playbook 

(ChangeLab Solutions)

Retail Sales, Internet Sales, and Licensure 

(Public Health Law Center)

Scientific Evidence Brief: Tobacco Retail 

Density, Location, and Licensure (CDC)

LEARN THE BASICS
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 12

GET READY

The retail strategies you choose will depend on your local retail environment. 

What works in one city may not work in others. Understanding the environment 

and forming community partnerships are essential first steps when planning a 

retail strategy.

Assess the Retail Environment

Gathering information about the retail environment gives you a baseline for 

reducing tobacco-related disparities. Store assessments and opinion polling 

are two ways to assess the retail environment. States can also conduct a health 

impact assessment to assess the potential impact of a retail strategy.74

You can use assessment results to:

 Plan feasible retail strategies that meet the needs of your community and 

reduce disparities

 Build support for strategies by providing local data on tobacco retail disparities

 Support monitoring and evaluation efforts by getting baseline data and 

documenting changes

Connect with other communities and organizations to hear about their 

experiences assessing the tobacco retail environment. Some groups may assess 

other aspects of the retail environment, such as nutrition or alcohol. Learning 

about other retail efforts can help you see opportunities to work with other 

organizations promoting health in the retail environment. Partners who may be 

doing similar work include: 

 Youth organizations

 Nutrition professionals

 Substance use prevention coalitions

 Crime prevention programs

A youth volunteer collects data for a retail store 

assessment in DeSoto County, Florida. Source: 

Tobacco Free Florida

Conduct Store Assessments

Store assessments collect information about how and where tobacco marketing 

happens. This helps expose retail disparities in the community. Assessments can 

include questions about the types of stores that sell tobacco and their locations, 

and especially their proximity to communities targeted by the industry. Some 

assessments also involve collecting data about what products are available, where 

they are placed in the store, how much they cost, and how they are advertised 

inside and outside stores. 

Assessments look at patterns across areas and demographics to find out who 

is most affected by industry influence. For example, they can examine product 

availability and price in relation to median income. 

KEY RESOURCES

STARS (Counter Tobacco)

Store assessment for tobacco retailers 

(can be modified)

vSTARS (Counter Tobacco)

Store assessment for vape shops (can 

be modified)

fSTARS (Counter Tobacco)

Store assessment specifically focused 

on menthol and other flavored 

commercial tobacco products (can be 

modified)
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 13

How to Complete a Store Assessment

STEP 1 Define the assessment’s geographic area of interest and goals

Involve coalition members and other partners in planning where and what to assess to best meet community 

needs. Connect with other health promotion groups and communities working in the retail environment to 

streamline efforts and resources. 

STEP 2 List and locate all tobacco retailers in your community

The easiest way to find retailers is to use a tobacco retail license list. Your state may already have a list of 

authorized retailers. If not, check your state’s Synar report (a list of retailer violations for selling products to 

youth).75 You can also use downloadable business lists, online business review and mapping services, local 

partner knowledge, or street surveys. 

STEP 3 Find or design a data collection tool 

Your state may require you to use a particular assessment tool. If not, you can design a survey or use a publicly 

available tool. You can change existing surveys to ask about new policies, emerging products, and community 

needs and goals. For example, Vermont modified the STARS tool to ask about the state’s required “no sales to 

minors” sign.76 They also added questions about food and alcohol sales.77

STEP 4 Choose a mode of data collection

You can collect data by hand or electronically. Mobile apps can be faster and more discreet but often have 

fees. Photographs help illustrate industry activity. Compare different methods by assessing their fit with your 

goals, the training needed, the time it would take to enter data, and the cost. 

STEP 5 Recruit and train data collectors

Data collectors from the community can help put retailers at ease. Partners, students, program staff, and 

external researchers or evaluators can also collect data. Do a pilot test in at least 5–10 stores (different types 

and locations), experimenting with store interaction and noting store cooperation. Instruct data collectors to 

be respectful and to avoid disrupting the flow of business.

STEP 6 Collect data 

Create a letter or script describing the project. Consider scheduling visits with retailers in advance. If 

store employees ask, be honest and clear about how the data will be shared and whether stores will stay 

anonymous. For safety, group data collectors in pairs and have an adult go with youth. Inform data collectors 

that they can decline a store observation if they feel unsafe. Have staff on call to help with questions or issues 

that come up in the field. 

STEP 7 Analyze data to identify industry marketing and disparity patterns

If you don’t have a data analyst on staff, consider asking other departments working in retail (like nutrition 

and alcohol) for help. Ask community members to help review data and decide on key findings. Maps can 

help visualize data across neighborhoods and demographics to identify disparities, like in the California 

Tobacco Health Assessment Tool.

78

STEP 8 Share and use results

Share results with the community, program staff, and decision makers to raise awareness and plan retail 

efforts. Include visual aids like maps or photos. Use dissemination channels that your audience already uses.

Adapted from Feld et al.79

GET READY
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 14

POLL COMMUNITY OPINION

Many communities already have strong public support for retail strategies.80

Understanding how the public feels about retail work can help you plan for 

community engagement and potential opposition.

Use a survey to help answer the following questions:81

 How strong are pro-commercial tobacco attitudes?

 How strong are pro-health attitudes?

 What is current public awareness and opinion on industry influence in the 

retail environment?

 What is current public awareness and opinion on the proposed strategy?

Results can help:60

 Reveal retail issues most important to community members 

 Plan education efforts by assessing public awareness and attitudes 

 Show public support for retail strategies

CONDUCT A HEALTH EQUITY IMPACT ASSESSMENT

A health equity impact assessment examines the potential effects of a retail 

strategy on your community. For example, Oregon used a Health Equity Impact 

Assessment in 2015 to better understand the potential impact of tobacco retail 

licensing in Multnomah County.82 Results showed that retailers in the county 

were concentrated in racial minority communities.83 As a result, Multnomah 

County educated communities about the problem and passed a retailer 

licensing ordinance.

A S S E S S I N G T H E TO B ACCO R E TA I L 

E N V I R O N M E N T: CO V I D - 19 

CONSIDERATIONS

Health risks and public health measures related to COVID-19 pose new challenges for 

retail data collection. As a safety precaution, many states have halted data collection 

until community transmission is lower. Others have shifted to virtual retailer 

inspections and trainings.

84 When local health officials decide it is safe to resume, data 

collectors may need to be trained on safety measures, such as following local mask 

wearing and social distancing rules. COVID-19 restrictions may also impact where 

multiple data collectors can go together, as sharing vehicles may not be possible. Work 

with local health departments to decide the best approach to data collection based on 

your community’s restrictions. 

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 15

USE ASSESSMENT RESULTS

Analyzing assessment results with community partners can help you identify 

disparities and possible retail strategy solutions. In particular: 

 Location data can show how close retailers are to each other or to other places, 

such as schools or parks, and help you set appropriate distance restrictions 

 Product data can show where different products are being sold and how 

restrictions on different product types might affect disparities

 Price and promotion data can reveal which neighborhoods have lower prices 

and more advertising, and how density policies could affect these differences

Disparities can become clear when you add demographics and compare your 

data across neighborhoods and populations. For example, mapping data 

showed that retailers were concentrated in low-income districts in San Francisco.85

They also showed that residents of color lived in areas with higher retail density.85

So, San Francisco passed an ordinance to reduce tobacco retailer density 

throughout the city.85

Maps can also help you compare the potential impact of different retail strategies. 

For example, the Tobacco Swamps Dashboard maps retailer data for 30 large U.S. 

cities and allows the user to overlay different retail strategies to compare impacts.86

Work with a data analyst and your community to review data and identify the key 

retail issues in your community. 

Screenshot of interactive Tobacco Swamps 

Dashboard. Source: ASPiRE Center

KEY RESOURCES

Counter Tobacco

Tools and resources for assessing 

the retail setting, including the 

Standardized Assessment for Retail 

Settings (STARS)

How to Conduct Store Observations 

of Tobacco Marketing and Products 

(Feld, 2016)

Steps to conduct a store assessment 

of tobacco marketing and products

Form Partnerships

Community partners are especially vital for health equity strategies. Look for 

community partners early, including ones connected to groups targeted by the 

tobacco industry, and involve them from the beginning of your retail efforts. 

Trusted community members and organizations can give valuable insight into 

the community’s values, priorities, and readiness to adopt retail strategies. They 

can raise awareness and build community support. They can also share existing 

resources and act as trusted messengers.

Other partners can also use their skills and knowledge to support retail strategies. 

Examples of potential partners include: 

 Decision makers, such as city council or board of health members, who adopt 

laws and regulations and act as champions for retail strategies80,87

 Legal experts, who give technical advice and support, such as reviewing 

drafts of policies and regulations87

 Communications experts, who create messages and campaigns to raise 

awareness about the importance of retail strategies87

 National organization representatives, who can speak at committee 

meetings or share evidence for strategies87

 Retailers, who can make voluntary changes in their stores, speak in support of 

strategies, and dispel myths about retail strategies harming businesses87,88

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 16

 Business leaders and chambers of commerce not connected with the 

tobacco industry, who bring a unique perspective on the health and economic 

benefits of retail strategies80,87

 Youth partners, who can speak in support of strategies and organize 

community support88,89

 Community coalition members, who can share efforts with the public, 

enhance community involvement, and shape retail policy60

 Social justice organizations, which can provide insights into health 

disparities and advocate for retail strategies90

Local and national retailers can be important partners. Local retailers in Vermont 

wanted to protect children and community members from the harmful effects 

of commercial tobacco, so they voluntarily stopped selling commercial tobacco 

products.91 Local retailers in California have also said that ending tobacco sales 

would promote a good image for their store.92 Some major chains, including CVS, 

have also voluntarily stopped selling commercial tobacco products.93

IDENTIFY PARTNERS

Effective partners are trusted by the community and knowledgeable about the 

area, including its commercial tobacco landscape. Choose partners who:87

 Share identities and experiences with the community

 Bring something valuable to the partnership, like skills or access to networks

 Are invested in the outcome

 Have no real or perceived conflicts of interest, including tobacco industry 

interests or investments

M I N N E S OTA PA R T N E R S H I P 

AGAINST MENTHOL

In 2015, the Minnesota Department of Health funded the Hennepin County 

Department of Health to address the high prevalence of menthol cigarette use 

in Black communities. Hennepin County partnered with the African American 

Leadership Foundation (AALF) to conduct community engagement activities.

94

As a trusted organization, AALF brought insight, connections, and expertise to the 

project, while the local public health partners provided technical support.94

In the first year of the grant, with support from staff, members of the AALF surveyed 

407 Black Minnesotans to assess support for tobacco retail work and use of tobacco 

products, including menthol. In the next year, AALF and other community leaders 

shared the results with community members. They also worked with the 

Association for Nonsmokers-Minnesota to present to community members on the 

use and harms of menthol in the Black community. Based on community feedback, 

AALF and Hennepin County developed recommendations to further reduce 

menthol use in the community.94

Member of the AALF providing testimony about assessment data. Source: Association for Nonsmokers-Minnesota

KEY RESOURCES

Best Practices User Guide: 

Partnerships in Tobacco Prevention 

and Control (CDC)

Action steps for states to form 

partnerships that support commercial 

tobacco control work

Networking2Save National 

Networks (CDC)

Consortium of eight national 

networks that represent different 

populations and can serve as partners 

to enhance commercial tobacco 

control work

Self-Assessments (National Center 

for Cultural Competence)

How to use self-assessments to build 

cultural competence

Identity, Bias, and Cultural Humility 

(The Community Technical 

Assistance Center of New York)

Presentation on self-reflection and 

building cultural humility

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 17

TAKE ACTION

Equipped with your assessment data and supported by your partners, you are 

ready to put retail strategies into action. A well-planned implementation process is 

important to increase both acceptance of new retail strategies and their potential 

to advance health equity. You can work with community partners to:

 Choose a retail strategy that’s right for the community

 Raise awareness about the importance of reducing industry influence in the 

retail environment

 Overcome potential challenges 

 Make sure new regulations are enforced equitably across all neighborhoods

 Monitor the retail environment and evaluate the effect of retail strategies

Choose a Strategy

There are no one-size-fits-all solutions when it comes to retail strategies to promote 

health equity. The most effective strategies are tailored to the unique needs of your 

community and have support from community members.95 Focus on retail strategies 

that match your community’s needs and incorporate equitable approaches. 

Look for strategies with these features:

 Fit with community needs96

 Evidence of effectiveness97

 Potential to reduce health disparities97

 Strong public support96

 Practical and equitable implementation97

 Legal feasibility60

 Cost effectiveness97

CONSIDER COMMUNITY NEEDS

Think about the community’s unique needs when choosing retail strategies. Ask 

yourself the following questions:13

 Which parts of my community have high commercial tobacco use prevalence? 

How does the retail environment vary across my community?

 What are the health priorities of the community? Are there competing issues 

that would make retail strategies difficult?

 What action has been taken before? What challenges did the community face?

Store assessments and health impact assessments can help you understand the 

commercial tobacco landscape. The STARS Policy Crosswalk matches data from 

STARS store assessments to specific retail strategies.98 Share data with partners 

and have a discussion about which strategies would meet their needs.

Staff from Mecklenburg County Public 

Health Office of Policy & Prevention replacing 

tobacco ads with prevention signage. Source: 

Mecklenburg County Public Health

Focus on retail 

strategies that match 

the community’s 

needs.
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 18

Reviewing outcomes of previous retail strategies in the community and activities 

of other, similar communities can help you plan for potential challenges. 

Subscribe to email lists of organizations that track retail activity and share the 

latest evidence, such as the Public Health Law Center and the ASPiRE Center.

99,100

COMBINE STRATEGIES

Combining multiple strategies is generally more effective than just using one.7

This could include:

 Combining multiple retail strategies, such as setting a minimum distance 

between retailers and restricting commercial tobacco sales near schools101

 Combining retail strategies with other commercial tobacco control 

strategies, such as combining retail strategies with increased access to 

commercial tobacco cessation resources102

 Implementing strategies at multiple levels (local, state, and national), like 

passing local Tobacco 21 laws to make compliance with the federal Tobacco 21 

law clearer and more efficient103

 Including other health priorities, such as providing low-interest loans to small 

businesses if they agree to sell fewer tobacco products and more vegetables104

Certain strategies may not have enough evidence to support their use yet. Check 

with legal experts or researchers to help you understand the potential benefits and 

challenges of strategies. You can also look for case studies from other jurisdictions.

PLAN EQUITABLE STRATEGIES

Strategies may not have the same effect for all groups in a community.15 When 

planning retail strategies, think proactively about avoiding potential unintended 

consequences that could lead some groups to benefit more than others and 

increase existing disparities. 

The following questions can help you plan for equitable retail strategies:

 Who will benefit from the strategy? Who might be negatively affected? Will 

anyone be left out?

 Will the strategy reduce access and exposure to tobacco products for those 

who are most harmed by them?

 Will the strategy align with the community’s values, culture, and needs?

 What culturally appropriate commercial tobacco cessation resources might 

accompany the strategy?

 What will be helpful for the community to know about targeted marketing 

tactics and limiting industry influence in the retail environment?

 Who will implement and enforce the strategy? Will they have the resources to 

do so equitably?

KEY RESOURCES

Boosting the Tobacco Control 

Vaccine (Kong and King)

How retail strategies support 

other commercial tobacco control 

strategies and reduce disparities

Point-of-Sale Strategies (Center for 

Public Health Systems Science)

Guidance on choosing strategies 

that fit local context, including 

rating strategies based on their legal 

feasibility

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 19

Raise Awareness

Educating the public helps build awareness about and support for retail strategy 

efforts.105 Media campaigns can raise awareness about:

 Tobacco industry influence in the retail environment

 The connection between the retail environment and health disparities

 New laws and regulations affecting the retail environment

 Available cessation resources

MAKE MESSAGES RELEVANT

Work closely with your partners to build your messaging. Different messages 

resonate with different audiences. Framing messages is the process of matching 

what you’re saying with what the audience cares about to encourage them to 

act.106 Partners can share community goals and values to better inform framing.

For example, community members care about the health and well-being of 

others in their community.107 Work with community partners to develop relevant 

messages centering on justice, highlighting health disparities, and explaining the 

reasons behind disparities.108 Using local data is also important to show how the 

community is affected and why the audience should care.109

Decision makers are responsible for allocating public funds, so they particularly 

care about costs and public opinion.109 Share results from community opinion 

polls and evidence about the positive effects of retail strategies, like cost savings

and decreased commercial tobacco initiation.110 Youth, who can testify at hearings 

and share information, are particularly influential among decision makers.109

Smoke Free Philly web ad promoting the 

National Quitline portal. Source: Philadelphia 

Department of Public Health

CO M M U N I C AT I N G A B O U T 

DENSITY DISPARITIES

A recent campaign led by the Campaign for Tobacco-Free Kids 

and the Advancing Science and Practice in the Retail Environment 

(ASPiRE) Center shared with the public just how prevalent tobacco 

retailers are in communities. Campaign messages shared ASPiRE 

research from 30 U.S. cities that found tobacco retailers are just a 

short walk away for many people, often located by schools, and 

concentrated in lower-income areas.

ASPiRE researchers and Campaign for Tobacco-Free Kids made 

tailored fact sheets and resources for each city, including 

customized social media posts for cities to reuse.111 They also 

teamed up for a 30-city radio tour to promote the campaign. The 

campaign reached over three million people and generated news 

coverage from many stations. 

Source: ASPiRE Center & Campaign for Tobacco-Free Kids

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 20

Audience research, such as surveys, polls, or interviews, can reveal information 

about the audience’s values and message preferences.112 Partners can also give 

insight on what specific messages may encourage action. 

CHOOSE A COMMUNICATION CHANNEL

Retail campaigns can be promoted in similar ways to those you may have run in 

the past (such as smokefree air or commercial tobacco cessation campaigns). 

Effective channels reach your audience where they spend time and are most 

attentive, such as in the car or at home. Community partners can help you choose 

which channels to use. Local news outlets, radio channels, podcasts, and social 

media platforms popular with the audience can be low-cost ways to reach them 

with information about the retail environment.

Other ways to raise awareness include holding community presentations, 

webinars, and press conferences. For example, youth in New York shared stories 

about commercial tobacco’s consequences in their own lives at a city council 

meeting and invited city leaders to join them on their walks to school to see how 

tobacco advertising impacts their daily commute.113 Parents, people harmed by 

tobacco-related illnesses, and healthcare providers can be influential messengers.109

Consider holding events or contests that directly engage your community, like a 

rally or a social media photo contest of tobacco marketing near schools.

Consider displaying commercial tobacco cessation information, such as health 

messages and quitline information, near point-of-sale displays of tobacco products.60

Pennsylvania youth show their support for raising the age to buy tobacco to 21. Source: 

Pennsylvania TRU

KEY RESOURCES

Best Practices: Health 

Communications User Guide (CDC)

Steps that state programs can take 

to develop effective messages and 

choose channels to share messages 

with different audiences

Equity (FrameWorks Institute)

Resources to support communicating 

about equity

Reframing the Issue (Community 

Tool Box)

Practical steps for framing an issue in 

a way that appeals to your community 

and helps you gain support

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 21

UNDERSTAND ANTI-LOBBYING RESTRICTIONS

Cities and states pass many retail strategies by adopting laws or local ordinances. 

The decision makers who pass these laws are an important audience. But 

programs receiving federal funding cannot use these funds to lobby for specific 

proposals. Federal funds can be used to educate on public health issues, potential 

policy solutions, and tobacco industry influence in the retail environment.114

Funds from other sources have different restrictions. An attorney can help you 

understand the activities you can do with federal and other funding.

Overcome Potential Challenges

Industry opposition and preemption are two common challenges that 

communities have described when implementing retail strategies.80 Dispelling 

myths spread by the tobacco industry and understanding preemption can help 

overcome these obstacles. 

DISPEL MYTHS ABOUT RETAIL STRATEGIES

The tobacco industry and convenience store associations often oppose retail 

restrictions, mostly on economic grounds. The evidence, though, doesn’t support 

these claims. Retail strategies can effectively reduce tobacco-related disparities 

and promote health equity, with little to no effect on retailers’ profits.115 Retail 

policies are unlikely to cause small retailers to go out of business, because 

customers who would otherwise buy commercial tobacco will spend money 

on other goods.115 Non-tobacco products, like snacks and beverages, are more 

profitable than tobacco products.116

The industry has also tried to encourage opposition by aligning itself with the 

communities they target. They claim that commercial tobacco control strategies 

are discriminatory to minorities.117 They sometimes use front groups to oppose 

strategies, such as retailer associations and other organizations. This tactic is 

known as “astroturfing.”118 For example, the National Association of Tobacco 

Outlets has partnered with the industry to lobby against regulations and 

encourage retailers not to support tobacco retail ordinances.119

Programs can play an important role in educating about industry influence in 

the retail environment. Participating in public hearings, holding press conferences, 

or giving presentations can be good ways to:

 Counter myths and share facts, especially with retailers120

 Raise awareness about industry tactics common in the community and their 

effect on tobacco-related disparities

 Share how retail strategies can improve community health and reduce disparities

 Share findings from store assessments and opinion polls

Despite best efforts, a retail strategy may face resistance. Keep debates 

constructive by speaking with opponents privately, listening to concerns, asking 

questions, and confirming your shared commitment to the community.109

CO M M O N I N D U S T RY 

M E S S AG E S A B O U T 

RETAIL STRATEGIES

The industry tends to focus its 

messages on retail strategies around 

these themes:

• Limits on the rights of consumers 

to use a legal product

• Costs of complying with new 

regulations, such as license fees, 

staff training, changes to inventory

• Loss of retail jobs, profits, and tax 

revenues

• Concerns about bans contributing 

to unjust criminalization

TAKE ACTION

Tennessee young adults handing out the 

Tennessee Tobacco Retailer Education 

Guide.

121 Source: Tennessee Department of 

Mental Health & Substance Abuse
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 22

UNDERSTAND PREEMPTION

Preemption occurs when a higher level of government limits a lower level 

of government’s authority.122 The tobacco industry uses preemption, mostly 

through legal challenges, as a way to create barriers for cities working in the retail 

environment.123

Preemption can discourage communities from introducing innovative measures 

to meet their specific needs.123

Understand and address preemption challenges by: 

 Knowing your state’s laws and which retail strategies are preempted124,125

 Monitoring efforts to restrict local action

 Educating community members and decision makers on the importance of 

local control and framing preemption as a lack of local control 

 Using assurances of voluntary compliance (AVCs) to implement retail 

strategies without risking preemption challenges

 Focusing on issues within local control

 Assessing support for overturning preemption and retaining local control 

Although state preemption laws can be difficult to repeal, several states have 

done so successfully.122,126 Other states have passed laws that allow local 

communities to enact their own ordinances.122 Consult an attorney to better 

understand local preemption and what actions you can take.

Campaign for Tobacco-Free Kids Rally. Source: Campaign for Tobacco-Free Kids

A S S U R A N C E S 

O F V O LU N TA RY 

COMPLIANCE

Due to industry-led legal challenges 

and state preemption laws, adopting 

tobacco retail laws sometimes 

isn’t possible. But an assurance of 

voluntary compliance (AVC) is a 

legally binding agreement between a 

state attorney general and a company 

in which the company agrees to 

follow proper sales and marketing 

practices.127 Many states have used 

AVCs to enforce tobacco advertising, 

marketing, and age restrictions.

128

AVCs can be strengthened by 

retailer education and routine 

enforcement.129

K E Y R E S O U R C E S 

STATE System Preemption Fact 

Sheet (CDC)

Maps with updated preemption 

status in each state for licensure, 

smokefree air, and youth access

Preemption: The Biggest Challenge 

to Tobacco Control (Public Health 

Law Center)

Background and information 

on preemption as a threat to 

commercial tobacco control with 

examples of preemption laws and 

anti-preemption provisions for 

commercial tobacco control laws

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 23

Support Equitable Enforcement 

Equitable enforcement means ensuring compliance with laws in a just and fair 

way that considers and reduces harm to priority communities. It is important 

to choose enforcement mechanisms that don’t make disparities worse. Equity 

can be considered in all aspects of enforcement, including when and how 

regulations are enforced.

PLAN FOR ENFORCEMENT

Limited budgets, not enough staff, and poor coordination across agencies tasked 

with enforcement are challenges to enforcing retail policies.80 Taking the time to 

secure adequate resources and plan for enforcement is important to make sure 

strategies are fully and consistently implemented. Steps to plan for enforcement 

include:

 Adopting a retailer licensing program, including collecting fees to fund 

enforcement efforts and creating retailer lists to monitor compliance and 

inform future efforts130

 Adding an enforcement mechanism to laws already in place80

 Using clear and comprehensive language to define commercial tobacco 

products, consider their interactions with legalized non-medicinal cannabis, 

identify which retailers are subject to regulations, and describe enforcement 

mechanisms and schedules131

 Setting a realistic date for implementation to start so retailers are ready132

 Avoiding purchase, use, and possession (PUP) laws that penalize underage 

people who buy and use tobacco products rather than the retailers that sell 

and market tobacco products to these customers133

 Tasking the public health department with enforcement when possible, or 

training other departments who may be responsible for enforcement on the 

types of tobacco products and specifics of retail laws, limiting law enforcement 

involvement if possible due to systemic inequities60

AV O I D I N G 

LOOPHOLES

Incomplete or vague regulations 

can make enforcement more 

difficult. Avoid creating enforcement 

loopholes by using definitions that 

are broad enough to include:

• E-cigarettes regardless of 

substance66

• Products that contain any type of 

tobacco131

• Any potential future tobacco 

products that may enter the 

market66

EDUCATE RETAILERS EARLY

Most retailers want to comply with new commercial tobacco restrictions.132

Retailers, especially employees who are responsible for implementing the 

strategies, can be important partners in encouraging compliance. Communicate 

with retailers even before the regulation goes into effect. 

Create educational materials that explain:

 What the new law will change

 When it will go into effect

 How to comply with the new law

 How the new law will impact health in their community

TAKE ACTION

Spanish-language outreach flyer from T21 

Community Education Toolkit.134 Source: City 

of San Antonio Metropolitan Health District
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 24

For example, Alachua County, Florida, took advantage of a nine-month roll-out 

period to educate retailers and develop best practices for conducting compliance 

checks.66 Working with their partners, they contacted other communities that 

already had licensing laws to learn how to support retailer compliance.135

Train retailers on implementing new strategies. Develop a training that is 

culturally responsive and available for all retailers. Trainings can be in-person or 

virtual, and can include role playing (like checking IDs and refusing sales), quizzes, 

and other interactive elements.136 For example, Multnomah County, Oregon, 

developed self-paced, online trainings as a safe, convenient way to continue 

educating retailers during the COVID-19 pandemic.84

Adapting enforcement materials to your audience helps make sure retailers can 

read and understand them. For example, if your community has a large non-Englishspeaking population, contract with individuals fluent in other languages. They can 

review materials and work with retailers to help make sure retailers are prepared to 

implement new regulations.137 San Antonio, Texas, developed a toolkit in English 

and Spanish to educate the community about its city-wide Tobacco 21 ordinance.134

Keeping communication with retailers open helps build relationships to support 

compliance. For example, use retailer compliance visits as an opportunity to educate 

and build relationships. One-on-one outreach visits, rather than town hall meetings, 

are more effective in sharing information and answering retailers’ questions.132

Web ad reminding tobacco retailers to not sell tobacco to anyone under 21. Source: Wisconsin 

Department of Health Services

KEY RESOURCES

Decriminalizing Commercial 

Tobacco (Center for Black Health 

and Equity)

Principles to support health equity 

goals and address systemic racism 

in commercial tobacco control 

enforcement

Identifying Best Practices in 

Adoption, Implementation and 

Enforcement of Flavoured Tobacco 

Product Restrictions and Bans: 

Lessons from Experts (Peck et al.) 

Recommendations for implementing 

and enforcing tobacco product 

restrictions

PUP LAWS

Purchase, use, and possession 

(PUP) laws penalize underage 

people who buy and use commercial 

tobacco, rather than the retailers 

that sell and market tobacco to 

these customers.133 The tobacco 

industry has a history of supporting 

PUP laws over other, more effective 

laws to reduce youth commercial 

tobacco use.133

Underlying social inequities and 

systemic racism have contributed 

to unjust enforcement of tobacco 

retail policies.138 PUP laws 

disproportionately penalize Black 

and Hispanic/Latino youth—the 

groups the tobacco industry most 

aggressively targets.139

These laws are also ineffective 

at reducing youth initiation and 

smoking prevalence.139 Most states 

still have PUP laws.139 Replacing 

these laws with licensing or other 

regulations directed at retailers, not 

consumers or clerks, is an important 

step toward equitable enforcement.

DEAL WITH NONCOMPLIANCE

Even with thoughtful planning ahead of a new retail law, some retailers may 

choose not to follow the regulations. What retailer noncompliance looks like 

depends on what restrictions are in place. For example, cities have described 

retailers avoiding compliance by:80

 Hiding restricted products from view

 Claiming that distance restrictions don’t apply 

TAKE ACTION
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 25

 Claiming they didn’t receive an inspection notice

 Failing to post age requirement signage

 Sectioning off parts of the store that sell commercial tobacco products to 

identify as an adult-only retailer

In most cases, simple education, either to retailers or enforcement agencies, can 

help resolve the issue.

Perform repeated compliance checks for retailers that continuously are in 

violation.140 Tiered penalties for compliance violations can support health 

equity goals.138 Tiered penalties phase in higher fees or consequences for 

repeated noncompliance, like suspending or revoking a license. For example, 

the suspension period or fines can increase based on the number of violations a 

business has. These fees can be used to fund future or ongoing retail strategies. 

Direct fees and penalties toward retailers, not individual clerks. Reserve criminal 

penalties only for businesses that repeatedly violate laws.138

Monitor and Evaluate the Retail 

Environment

Monitoring and evaluation can help you decide which strategies work best to 

reduce disparities in the retail environment. Compare new data you collect to 

baseline data from your community assessment to highlight changes. 

H O W E VA LUAT I O N S 

S U P P O R T H E A LT H 

EQUITY WORK

Evaluation results can help you:143

• Assess how retail strategies are 

implemented and enforced for 

different populations 

• Identify barriers to equitable 

implementation 

• Build support for health equity 

strategies

• Learn and improve future retail 

efforts to promote health equity

MONITOR THE RETAIL ENVIRONMENT

Monitoring activities helps keep track of commercial tobacco use trends, changes 

in the retail environment, and tobacco-related disparities. Monitoring can 

help you: 

 Keep a current list of all retailers

 Track changes in products and targeted industry marketing

 Keep up-to-date on what other communities are doing, including new 

regulations and proposed restrictions that failed141

 Know which products are most often the subject of violations and where they 

are happening

 Stay in the know about evidence by setting alerts for new journal articles or 

signing up for listservs like the Penn Rutgers TCORS Tobacco Industry Marketing 

Core Alert, and Counter Tobacco and ASPiRE Center monthly newsletters142,100

Monitoring can also help you spot and correct unintended consequences of retail 

efforts.13 You can take proactive steps to monitor for unintended consequences by:13

 Updating your monitoring systems to include tobacco-related disparity 

indicators, such as commercial tobacco use among population subgroups

 Conducting compliance checks in neighborhoods most affected by tobacco 

industry influence to make sure strategies are implemented consistently (for 

example, in low-income and higher-income neighborhoods)

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Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 26

 Monitoring changes in commercial tobacco use among subgroups to look for 

new or widening disparities

 Asking community members how they think implementation is going

 Reviewing enforcement as time goes on and making changes if policies are not 

having their intended effect144

Include community members and youth groups in monitoring activities, like 

collecting store assessment data.89 Community members may have more trust and 

credibility with retailers than outside researchers. They can help retailers feel 

comfortable participating in data collection.67 Involving community members also 

helps build awareness of industry tactics, as they can share what they learn with 

leaders and others in the community. If staff collect monitoring data, provide 

cultural competence training.145

Volunteers surveying local tobacco stores. Source: Tobacco Free Florida

KEY RESOURCES

A Practitioner’s Guide for Advancing 

Health Equity: Community 

Strategies for Preventing Chronic 

Disease (CDC)

Recommendations and reflection 

questions for integrating health 

equity considerations throughout the 

evaluation process

Best Practices User Guide: Health 

Equity (CDC)

Recommendations for state 

commercial tobacco control 

programs to promote health equity, 

including how to design evaluations

Tobacco 21: Policy Evaluation for 

Comprehensive Tobacco Control 

Programs (CDC)

Six steps for evaluating commercial 

tobacco control strategies and how 

the steps can apply to assessing the 

local impact of Tobacco 21 

Tobacco Where You Live: Mapping 

Techniques (CDC)

How to create, share, and use maps in 

commercial tobacco prevention and 

control, including evaluation

Evaluate Retail Strategies

Evaluations assess what works, for whom, and under what conditions. 

Integrating health equity into evaluations helps make sure you do not overlook 

unintended effects on specific communities. Results can help you make informed 

changes to retail strategies. For example, include evaluation questions that ask:143

 To what extent was the retail strategy enacted uniformly in all communities?

 Is the strategy consistent with evidence to reduce disparities in the retail 

environment?

 Were there efforts to educate community members about the strategy and 

address concerns?

TAKE ACTION
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 27

 Are there pockets of noncompliance that require extra effort to support 

compliance?

 How has reported access to tobacco products, social norms, or commercial 

tobacco use changed for priority populations as a result of the strategy?

 What is the economic impact on retailers?

 Were there any unintended consequences for specific groups?

Community members have firsthand knowledge of community priorities. They 

can help choose evaluation questions.

Many kinds of data can help answer questions about the tobacco retail 

environment, including store assessment or retail scanner data. If you gather 

data about people, such as commercial tobacco use patterns, make sure you 

understand and recognize the different subpopulations in a community.

Mapping retailer data before and after implementation can reveal enforcement 

inequities. Maps can also help retailers understand and follow the law.135 For 

example, maps can show retailers whether they are within distance restrictions.80

S I X S T E P S O F E VA LUAT I O N 

CDC outlines six steps that can be used to evaluate retail strategies:146

1. Engage community members, evaluators, retail tobacco control experts, 

enforcement officials, and coalition members.

2. Describe the strategy being evaluated to make sure all partners and 

community members have a clear understanding of tobacco-related 

disparities, health equity goals, and potential challenges.

3. Focus the evaluation by developing clear goals that consider what 

community members want to know and creating a plan for collecting and 

analyzing data.

4. Gather credible evidence using sources such as store assessments, 

retail scanner data, surveys, interviews with key partners, and 

compliance checks.

5. Justify conclusions by comparing to baseline data when possible and 

considering how the local environment may influence implementation.

6. Apply evaluation results to implementation, retailer education, compliance 

activities, and future planning. Ask community members to help review 

data and decide next steps.

R E TA I L 

SCANNER DATA

Retail scanner data gathers 

information from product codes 

about purchasing behavior 

of consumers in the U.S. Data 

include each product sold in a 

store on a given day, how many 

of the product are sold, and 

the sales price.147 The Nielsen 

retail scanner dataset can be 

downloaded online through 

some university libraries.148

TAKE ACTION
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 28

SHARE EVALUATION RESULTS

Share results with the community, decision makers, and other partners 

to improve and expand retail efforts to reduce disparities. Sharing evaluation 

results with communities most affected by tobacco-related disparities helps 

them understand the industry’s targeted marketing tactics and take action.87 It 

is important for community members to have the opportunity to review data, 

decide on key findings, and use results to help their communities.13

When sharing findings, consider your audience and highlight the results that are 

most relevant to them. For example:

 Educate retailers on economic impact, community support, and action steps 

they can take to implement strategies effectively

 Inform partners, retailers, and program staff of outcomes and lessons 

learned during implementation, including any errors or mistakes

 Give decision makers concise key points on costs and local impact

 Show community members how strategies impact health across different 

neighborhoods and populations

Map of tobacco retailers by census tract and percentage of population from communities of 

color. Source: Multnomah County Health Department, Oregon

TAKE ACTION

It is important 

for community 

members to have the 

opportunity to review 

data, decide on key 

findings, and use 

results to help their 

communities.
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 29

EXPLORE COMMUNITY EXAMPLES

Oakland, California

In 2017, the Oakland City Council became concerned about 

youth using flavored tobacco products. Commercial tobacco 

control partners wanted to prohibit all menthol and flavored 

tobacco sales in Oakland to reduce disparities in the tobacco 

retail environment. So, they adopted a menthol and flavored 

tobacco product restriction.

149

However, the city council exempted adult-only tobacco 

shops, creating a loophole. The tobacco industry exploited 

the loophole by increasing the number of tobacco shops in 

low-income Black and Latino neighborhoods shortly after the 

ordinance went into effect.

Retailers were now defining themselves as adult-only tobacco 

shops by converting all or part of their stores to sell primarily 

tobacco products. Oakland’s tobacco shops increased from 

about five in 2017 to over 56 in 2020. The ordinance was not 

working as intended.

The African American Tobacco Control Leadership Council (AATCLC) helped lead 

Oakland’s efforts with the Alameda County Tobacco Control Program, speaking 

out about the effects of commercial tobacco and the loophole on Oakland’s 

Black communities. “The industry hasn’t met a loophole they don’t like. They took 

full advantage of the exemption,” says Dr. Phillip Gardiner, AATCLC Co-Chair.

The Program and AATCLC approached the city council about the need for a 

comprehensive restriction. “We don’t think exemptions work. The benefit of a 

jurisdiction-wide policy is it can impact everybody,” says Tobacco Control Program 

Director Paul Cummings. 

To illustrate the problem, the Program created maps of menthol and flavored 

tobacco retailers in 2017 and 2020. The maps showed that menthol and 

flavored tobacco sales were increasingly concentrated in Black and Latino 

neighborhoods. AATCLC provided an essential voice to counter arguments 

that the restriction would hurt Black-owned businesses. Together, the maps 

and message were convincing. The City Council unanimously voted to end the 

exemption in 2020. The legislation passed with extra measures, including a 

minimum price of $8.00 for a pack of cigarettes or cigarillos.150

Although the FDA has announced plans to prohibit menthol cigarette sales 

nationally, Dr. Gardiner emphasizes the importance of continuing to fight on the 

local level. “Black lives are at stake,” he says, explaining the announcement is just a 

step in what will be a lengthy process of removing menthol from the market. 

“People cannot lift their foot off the gas. I want to encourage local work. The 

higher up the food chain you go, the more influence the industry has.”

Oakland convenience store with a separate ”adult-only” tobacco shop 

inside. Source: Alameda County Public Health Department

We don’t think 

exemptions work. 

The benefit of a 

jurisdiction-wide 

policy is it can 

impact everybody.

— Paul Cummings
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 30

Milwaukee, Wisconsin

In 2016, the heavily segregated city of Milwaukee was still 

experiencing tobacco-related disparities, despite having 

components of a strong state commercial tobacco control 

program. In collaboration with many local partners, including 

the Wisconsin African American Tobacco Prevention Network, 

the Wisconsin Department of Health Services decided to 

conduct store assessments throughout the Milwaukee area to 

learn about and address disparities in its retail environment.

With CDC funding, the Department piloted the Wisconsin 

Retail Assessment Project (WRAP). WRAP is a communitycentered effort to collect data and expose tobacco-related 

disparities with support from Counter Tools and their 

Standardized Tobacco Assessment for Retail Settings 

(STARS) assessment tool.76 The Department trained local 

coalitions to take the lead in conducting the assessment. 

They trained community members to collect data and build 

relationships with retailers. Local volunteers were more 

welcomed by retailers when they explained that they were 

collecting data for a project, not for enforcement, according 

to Luke Witkowski, WRAP co-coordinator.

Directly engaging the community was key to the project’s success. “Let your 

community do the heavy lifting,” said Lorraine Lathen, director of the Wisconsin 

African American Tobacco Prevention Network and the Wisconsin Tobacco 

Prevention and Poverty Network. “It gives credibility to the movement and will 

lead to sustainable programs.”

The assessment created opportunities to make meaningful partnerships, 

including with retailers. “We should not see tobacco retailers as the enemy. Magic 

can happen just sitting down with a retailer and having a conversation that can 

lead to collaborations that can benefit the community,” said Lathen. 

The assessment revealed that tobacco retailers are most concentrated in 

Milwaukee’s low-income communities of color and that menthol and flavored 

tobacco products are marketed most heavily to Black residents. Local coalition 

partners shared these findings with retailers, decision makers, and community 

members in easy-to-read fact sheets.

151

One year and 120 assessments later, the team scaled up the project to conduct 

assessments statewide, including rural areas, and observed the impact of different 

regional approaches. “Engaging the right people to carry out retail strategies, 

including enforcement, is key,” says Lathen. 

WRAP’s findings helped generate awareness and interest in tobacco retail 

disparities across the Milwaukee area and statewide. The team is creating a final 

report to the community and city council presenting the five-year results from the 

assessment. They hope that their findings can motivate future efforts to improve 

retail strategies and help overcome preemption challenges. 

A Milwaukee store owner explains how he keeps tobacco products out 

of the reach and sight of minors during a Wisconsin African American 

Tobacco Prevention Network retailer tour. Source: African American 

Tobacco Prevention Network

EXPLORE COMMUNITY EXAMPLES

Magic can happen 

just sitting down

with a retailer 

and having a 

conversation.

— Lorraine Lathen
Tobacco Where You Live I RETAIL STRATEGIES TO PROMOTE HEALTH EQUITY 31

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