TPD / TRPR compliance on vape kits and e-liquids (short guide)

What is TPD / TRPR?

TPD – Tobacco Products Directive

TRPR – Tobacco and Related Products Regulations

The Tobacco and Related Products Regulations came into force in 2016, making the TPD (Tobacco Products Directive 2014/40/EU) a priority for manufacturers in the electronic cigarette industry. Basically, any e-cig device containing nicotine has to comply with this new set of rules and regulations to survive on the European electronic cigarette market after 20 May 2017.

The competent authority that implements the TPD in the UK, MHRA is responsible for implementing the majority of rules for nicotine-containing electronic cigarettes and refill containers and for creating the guidelines addressed to both producers and consumers.

Producers/manufacturers of e-cigarettes and refill containers that were available on the market before 20 May 2016 had until 20 November 2016 to submit a notification to MHRA for the products intended to sell after 20 May 2017. So, long story short, the e-cig producers or retailers are able to sell any kind of products designated for vaping until this date, and only TPD compliant vape products notified by MHRA after 20 May 2017.

How will the TPD changes affect the consumer?

The TPD compliant liquids will suffer a few changes in terms of labelling, packaging, and features.

The TPD requirements on nicotine concentration will set the 20mg/ml as maximum, compared to the current nicotine strengths that go up to 24mg/ml. Not only the nicotine level will be adjusted, but the size of a nicotine-containing e-juice bottle as well, as 10ml gets to be the maximum capacity accepted.

In terms of vaping devices, the tank/clearomizer/ cartridge capacity must not exceed 2ml for any type of refillable or disposable electronic cigarettes, and any electronic cigarette or refillable vaping device must be child-resistant, tamper-evident, and protected against breakage and leakage.

In addition, the TPD compliant eliquids cannot contain vitamins, colourings or prohibited additives in tobacco products must be manufactured using only ingredients of high purity, and cannot include ingredients (except for nicotine) which pose a health risk either in heated or unheated form.

What to look for on the new labels

The labelling on the 10ml bottles will look a lot different than they used to.

All the TPD compliant e-liquids with nicotine strengths up to 20mg/ml will display the following details on the label:

1. 1. Brand/ E-juice Name;
   2. Ingredients listed in descending order by weight: vegetable glycerin, propylene glycol, flavouring, nicotine;
   3. Nicotine content specified in mg/ml;
   4. Nicotine content in ingested dose specified in percent (%);
   5. Batch number, Best before;
   6. Warnings – Product not to be sold to people under the age of 18. Keep out of reach of children and animals. This product contains nicotine which is a highly addictive substance. It is not recommended for use by non-smokers;
   7. “Not to be used during pregnancy”, “Product not to be sold to people under the age of 18” and “Recycling” pictograms;
   8. Distributor/ Manufacturer information: name, address, phone number, website.