The PACT Act Monthly Reporting Checklist: What Every Vape Retailer Must File by June 10, 2026

The PACT Act (15 U.S.C. § 376a) requires online vape retailers to file monthly delivery reports.

They must file reports with each state where they ship vapor products. For May 2026 sales, those reports are due June 10. Filing late, filing incomplete, or missing a state triggers per-day penalties, per state. This checklist explains what you need to file.

It lists which states require separate submissions.

It tells you what data to include in each report.

It also explains which documents to keep on file before you submit.

What the PACT Act Requires from Online Vape Retailers

The PACT Act governs how tobacco and vapor products can be sold and delivered across state lines. For online vape retailers, it creates three core compliance obligations.

ATF Registration

Before your first delivery sale, you must register with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). You must register as a delivery seller. Registration is a prerequisite — not a step you can skip or complete retroactively without risk.

Monthly State Delivery Reports

You must file a delivery report each month with every state’s tax authority. Do this for each state where you shipped vapor products last month.

Each report covers buyer details, product information, and shipment data. Most states set a filing window around the 10th of the following month. There is no single federal filing that satisfies state requirements.

Carrier Compliance

USPS is prohibited from delivering vapor products under the PACT Act. You must use a certified private carrier, like UPS or FedEx.

You must have a signed agreement with the carrier.

The agreement must confirm the shipping restrictions.

You must require an adult signature at delivery.

Which States Require Separate PACT Act Filings?

Nearly every state that taxes tobacco or vapor products requires a separate monthly delivery report. The number of states you ship to determines how many reports you file.

States with active delivery reporting rules include California, New York, and New Jersey. They also include Massachusetts, Illinois, Pennsylvania, Washington, Colorado, Virginia, North Carolina, Georgia, Texas, Florida, and others. [INTERNAL LINK: PACT Act state-by-state compliance guide]

If you ship to 20 states, you file 20 separate reports. Each report must meet the specific format and data requirements of that state’s tax authority.

Operational takeaway: Pull your shipping records by state before June 10. If you have gaps in buyer documentation for any state, address them before submitting. An incomplete report carries the same penalty risk as a late one.

Required Data Fields for Every PACT Act Delivery Report

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Most delivery reports require the following data fields for each shipment. Confirm each state’s specific format with that state’s tax authority, as requirements vary.

Purchaser Information

  • Full name
  • Age (with verification documentation if the under-30 rule was triggered)
  • Verified residential address

Product Information

  • Product name and type (vapor product, smokeless tobacco, cigarettes, etc.)
  • Brand
  • Quantity (number of units)
  • Weight or volume

Transaction Information

  • Date of sale
  • Date of delivery
  • Carrier name and tracking number
  • Total purchase price (some states require excise tax breakdown separately)

Delivery Confirmation

  • Proof of adult signature at delivery (required by PACT Act)
  • Carrier-stamped delivery confirmation

Missing any required field can result in a submission being rejected or flagged for penalty review.

Under-30 ID Verification: What to Collect and What to Keep on File

The PACT Act requires identity verification for any purchaser who appears under 30 at the point of sale. For online retailers, this check happens at checkout, not at the door.

What “under-30 verification” means in practice.

Check the buyer’s government-issued ID before you complete the sale. Do this if the buyer looks like they may be under 30. For online sales, this usually means an age check tool that confirms the buyer’s age before processing the order.

What to keep on file for each verified transaction:

  • Type of verification performed (government ID check, data verification, etc.)
  • Date and time of verification
  • Verification result (verified or not verified)
  • Method used

These records support your monthly report filings and your carrier documentation. If an auditor ever audits a shipment, your verification logs serve as your primary evidence. Legal counsel should confirm documentation requirements for any specific jurisdiction.

What Triggers Per-Day Penalties Under the PACT Act

Penalties under the PACT Act are calculated per day, per state. For multi-state sellers, exposure compounds quickly.

Common triggers include:

  • Late filings: Missing a state’s monthly deadline
  • Incomplete filings: Missing required data fields in a state submission
  • Missing ATF registration: Filing without being registered as a delivery seller
  • Carrier non-compliance: Shipping via USPS or using a carrier without a certified agreement
  • No adult signature: Failing to require and document adult signature on delivery
  • Missing verification records: No on-file documentation for buyers checked at checkout

There is no standard cure period for most violations. The penalty clock typically starts when officials identify the violation. Consult legal counsel for guidance specific to your situation.

How to Build a Submission-Ready Monthly PACT Act Workflow

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A consistent monthly close process is the most reliable way to reduce penalty exposure.

Ongoing throughout the month:

  • Log all shipping records by state in real time
  • Confirm buyer documentation is complete for each transaction
  • Verify adult signature delivery records are captured by order

First business days of the following month:

  • Close out your delivery log by state
  • Confirm ATF registration is current
  • Confirm your certified carrier agreement is active and on file

By the 10th of the following month:

  • Submit each state’s delivery report with all required data fields
  • File excise tax documentation where required by the state
  • Archive copies of all submitted reports and supporting records for audit readiness

How Token of Trust Supports PACT Act Compliance for Vape Retailers

Token of Trust helps vape retailers meet PACT Act age verification requirements and automate excise tax reporting.

Age Verification at Checkout: The government ID verification tool checks the buyer’s age at checkout. It automatically starts the under-30 verification workflow when needed. Every verification generates a timestamped, exportable log designed to support monthly report filings and carrier documentation.

PACT Act Compliance Module: Built for tobacco and vapor product retailers, this tool automates delivery reporting. It reduces manual data entry and lowers the risk of incomplete or late submissions.

Excise Tax Integration: Through vapetaxes.com, Token of Trust supports automated excise tax reporting for ENDS products. It helps retailers manage state tax duties with their PACT Act filings.

Audit-Ready Record Keeping: Each verification and transaction record is saved and exportable. It supports audit-ready workflows if a state authority requests documents.

External authority reference: ATF PACT Act delivery seller requirements — ATF.gov

A semi-realistic digital editorial illustration set against a clean teal background. On the left, a large golden shield glows warmly, featuring a prominent teal shield emblem with an integrated checkmark and circle motif inside. A curved, dotted black arrow leads from the shield toward a compliance document on the right. The document features the word "COMPLIANCE" at the top, a stylized signature at the bottom, and a scalloped amber badge on its top-right corner reading "June 10". A single pen rests vertically beside the document.

The June 10 filing deadline is close. If your monthly reporting workflow has gaps, now is the time to close them.

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Frequently Asked Questions

When is the PACT Act filing deadline for May 2026 sales? Monthly delivery reports for May 2026 sales are due by June 10, 2026. Each state where you shipped vapor products requires a separate report filed with that state’s tax authority.

What happens if I miss a PACT Act monthly filing deadline? Late or incomplete filings can trigger per-day penalties that apply per state. Authorities typically calculate penalties from the date they identify the violation, not the date they correct it. Consult legal counsel for guidance specific to your situation.

Does PACT Act age verification apply to all online vape sales? The PACT Act requires identity verification for buyers who appear under 30 at point of sale. For online retailers, you must meet this requirement at checkout and document it in your monthly delivery records. Definitions and applicability can vary, and we recommend a legal review.

Can I ship vapor products through USPS? No.

The PACT Act prohibits USPS from delivering vapor products to consumers. You must use a certified private carrier with a signed carrier agreement. You must also require an adult signature when the order is delivered.