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EU TPD (Art20)

Over the past 12 months or so I’ve been actively engaging with manufacturers in an attempt to establish their thoughts about the impending EU TPD (Art20). Many, but not all, as of 19/01/2016 still have no understanding of what the TPD implications are. So here are (4) links that should help manufacturers, importers and wholesalers, should they wish to continue supplying and operating within the UK & EU.

20151218_Draft Act_Technical standards for refill mechanism (1)

The current understanding of the TPD (as of the date of this post) is as follows.

* nicotine strength limited to 2mg/2.0%
* refill containers (bottles) limited to 10ml
* refill containers subject to specified refilling mechanism/design
* refill containers subject to specific labelling (wording/warnings)
* clearomisers/ tanks limited to contain no more than 2ml of E-Liquid
* E-Liquid subject to pre-market notifications that must include toxicology and emissions testing
* Hardware (clearomisers/tanks/atomisers/coils) subject to pre-market notifications that must include material and emissions testing
* pre-market notifications must be submitted to the UK Gov via the MHRA six (6) months in advance of bringing the product to the market

If you’re a manufacturer, importer or wholesaler and would like to discuss this situation with me, please contact me by email

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