TPD Compliant Vape Rules in the EU


by Jeffrey Buckley

Updated: August 18, 2020

tpd compliant e-liquids

What is TPD compliant? TPD compliance is the new vocabulary in the vaping industry! The TPD is an updated version of a European Union directive, and it now appears on every vaping forum and website. It landed on the 20th of May, 2016, and has altered the vaping landscape in the European Union drastically as everyone has to ensure that their vapes are TPD compliant.

TPD as a Directive of the European Union

TPD stands fully for the Tobacco Products Directive. It is a directive of the European Union which sets limits on the merchandising and sales of tobacco and products related to tobacco in the EU. It was created initially in 2001 but was reviewed in 2014 also to include e-cigarettes.

After the passage of the regulation, each member state in the EU had to transfer the TPD requirements into their laws by the 20th of May, 2016. Simply put, the TPD is a regulatory act in the EU set on the sales of tobacco products, including vaping devices and e-liquids. The guidelines for TPD compliance are laid out in the TPD Article 20.

The Aim and Objectives of the TPD

Regulation is unavoidable in an emerging industry, and the Tobacco Products Directive is designed to improve the operations of the internal market for tobacco and its related products. Its primary objectives are to:

  • Protect children from nicotine products. It is designed to ensure that only individuals above the age of 18 can purchase and use e-cigarettes and products related to e-cigarettes.
  • Protect consumers of tobacco and its related products by creating upholdable standards for the quality and safety of all vaping devices and e-juices. It ensures that consumers are aware that their purchased products contain nicotine.
  • Protect consumers by compelling both manufacturers and retailers to provide valuable information on the packaging

The MHRA Registration as a Process of TPD Compliance

The Medicine and Healthcare Products Regulatory Agency (MHRA) is the competent authority responsible for the notification scheme for refill containers and e-cigarettes in the UK, and also for executing the majority of provisions under Article 20.

All vaping devices and e-liquids must alert and register under the MHRA; then, it can go up for sales after six months. This includes vape products existing before the 20th of May, 2016. However, once the producer’s notification has been published under the list of submitted products, they can place the product on the UK market even before the six-month duration elapses.

A product which has been modified to a substantial degree counts as a new product and must also follow this process.

TPD Compliant Restrictions

The Tobacco Product Directive (TPD) enforces restrictions of tobacco and its related products, new requirements which became effective from May 20, 2017.

Vape Tanks Restrictions

Aspire Revvo Sub-Ohm Tank

The stipulation for compliant tanks is that:

  • the maximum capacity for a single use cartridge, a disposable electronic cigarette or a tank should not exceed 2 ml
  • the TPD vape tank must have an ECID (European Community Identification Number) and must be registered on the MHRA website
  • Nicotine warning stickers should accompany vape tanks

E-liquids Restrictions

TPD Compliant E-liquid

The stipulation of compliance is that:

  • Emissions testing is compulsory for e-liquids with nicotine, and the testing must be done in a lab
  • Each e-liquid bottle which contains nicotine is restricted to a maximum of 10 ml per bottle
  • The nicotine strength in an e-liquid product must not exceed 2.0% nicotine or 20 mg/ml
  • E-liquids must not contain certain ingredients such as caffeine, taurine, and other stimulant compounds and additives that are associated with additives and stimulant compounds
  • Cannot contain additives which have coloring properties, and additives with CMR (carcinogenic, reprotoxic, mutagenic) properties in unburnt form
  • Cannot contain vitamins or related additives that give the impression that a tobacco product includes a health benefit or offers reduced health risks
  • E-liquid bottles must have nozzles at least 9 mm long and childproof caps that constrain liquid flow and emit no more than 20 drops per minute
  • Each e-liquid box must contain informational and warning leaflets. “This product contains nicotine which is a highly addictive substance” must be labeled on the TPD vape juice packaging, and it must encompass 30% of the package surface both on the front and back

The TPD-Consumer Relationship

As a Result of the TPD

  • consumers of e-cigarettes and vaping devices will benefit from improved quality and safety for products
  • there is now a tamper-evident and childproof policy, protecting e-liquids against leakage and minimizing the risk of consumer exposure to the dangers of ingestion or handling, particularly children. There is now a significant drop in the number of children who consume vape juices.
  • e-juice bottles are now made with an unbreakable material, preventing accidents such as animals or children getting to the bottle
  • consumers will be better informed through new labeling and packaging requirements: mandatory usage requirements, health warnings, information on toxicity and addictiveness information on nicotine content and the ingredients contained in the product, information on batch number and expiration date.
  • tobacco products are manufactured with only high purity ingredients.
  • no promotional element is allowed on packs

TPD Compliance in the EU: Conclusion

The TPD brought about some inevitable changes to the tobacco and vaping juices available in stores.

Some liquids and flavors ceased to exist as they were being manufactured by small companies with not enough funds to proceed with compliance and testing.

Now, e-liquids are available in 10 ml bottles with a strength of 18mg.

However, e-liquids with zero nicotine do not need to be tested and is unaffected by the TPD compliance. Only tanks with a 2 ml capacity are available, and the TPD compliant tanks must deliver a consistent nicotine dose and must be leakproof at refilling point.

Meanwhile, the TPD does not make the e-juice healthier, but the emissions testing offers confidence to consumers with the awareness of knowing the ingredients in the e-liquid.

Published: June 10, 2019Updated: August 18, 2020

Jeffrey Buckley

I was a smoker for over 25 years. In this time I also earned my medical degree with a specialization in addiction treatment and counseling. That period has led me to vaping, my interest started around 2011. I’m fighting the tide of hysteria and dis-information around vaping that emanates from various fronts legislative, cultural and scientific. Having scientific councils support, I’m happy to contribute my thoughts, articles, and expertise.


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