Are Your Products TPD Compliant?

Posted by Isabella Brown on

If you’re interested in or are already importing e-liquids and hardware to Europe you’ve likely heard of the Tobacco Product Directive, otherwise known as TPD, which is an updated version of an EU directive that was implemented in May 2016. There is, however, a grace period which allows registered previously produced non-TPD products to be sold in shops until May 20th 2017. After that point all vaping products must be compliant with the EU TPD to be imported and sold and must have been notified 6 months prior to selling. We have compiled the following information addressing all requirements that must be met from this point forward.

Bottles/Hardware:

Under the changes refill containers and e-liquid bottles must not exceed a quantity of 10ml. Prefilled atomizers are also restricted to 2ml maximum capacity. Bottles containing e-liquid must have a 1cm long nozzle, and emit no more than 20 drops of refill liquid per minute when placed vertically OR has a docking mechanism. Dripper bottles are banned under the TPD changes. All tanks/clearomizers must undergo emissions testing. Manufacturers and importers will need to submit them to the MHRA 6 months before being put on the market.

Nicotine:

E-liquid must be made with EU or USA pharma grade nicotine and must not have levels higher than 2%.

Testing/submission:

E-liquids need to undergo testing, including emissions testing with a submission being made 6 months before sale is allowed. The responsibility for testing and submission falls on the manufacturer and the importer. If you are importing devices/e-liquids, you will need to conduct these tests and submit notifications. Note that submissions should be made 6 months before going to market. If you are not importing or manufacturing, you will not have to conduct these tests or notify of these products.

Packaging:

All e-liquids packaging - this includes boxes and labels - must now carry the health warning "This product contains nicotine which is a highly addictive substance". The warnings must appear on both front and back surfaces and cover at least 30% of its surface area as the text itself must be on a white background in black Helvetica type, centered, and in a font size that ensures the text occupies the largest possible proportion of the warning label space. As well as all ingredients and nicotine content displayed on the front of the packaging. A leaflet must be also included containing information on addictiveness, toxicity and storage.


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