TPD Compliant E-Liquids

April 01, 2017 4 min read

TPD Compliant E-Liquids

TPD Compliant E-Liquids

By Elena Ognivtseva

If you are just learning about vaping and getting into the whole vaping scene, then you are probably also wondering if your E-Liquid provider is TPD compliant with all of their E-Liquids. 

The new regulations, which many sellers of E-Liquids complain are simply too harsh and too confusing have now been in effect since 2016, with a 12 month grace period which will end in May. The changes they have brought about are many and even consumers are puzzled over what is right and what is wrong. Well, here are some of the effects the new rules are having on E-Liquids in general:

Effects on E-Liquids

Henceforth, E-Liquid will only be obtainable in10ml bottles, at a maximum strength of 20mg.  Since it is unrealistic to expect manufacturers of E-Liquids to produce liquids which are more than 18mg in strength, you need to permit some room for error).  None of these rules apply to E-Liquid which doesn't have nicotine, and it remains untouched by the TPD.

  1. All E-Liquid bottles need to have a childproof cap -- which shouldn't be a problem because all responsible makers are currently using them anyhow.
  1. MHRA's notification costs might not seem like much on the surface, but you need to think it through. Probably they will be no more than a couple hundred pounds per flavor, per strength, the expense of testing could rise to several thousand pounds for each.  What this boils down to is that a small manufacturer with perhaps twenty flavors in four different strengths could find themselves hit with compliance costs that amount to about a quarter of a million pounds.  You can't earn a decent living like that.
  1. The results of the above problem are that many manufacturers will simply be driven out of business. This means that the number of manufacturers, and thus the types of E-Liquids available will be severely reduced.
  1. The small to medium sized companies remaining, and that want their own label product will wind up outsourcing their manufacturing to other manufacturers who are presently in compliance with the new rules and concentrate their energies on retail sales (like supermarkets do with their own brand products).
  1. Many E-Liquid manufacturers will likely cut the number of flavors under their own brand, and then gradually add them back. That way they will be able to spread out the expense of complying with TPD over time.  For the present, they will likely stock more E-Liquid brands from the larger, manufacturers who have either already reached the point of full compliance, or will soon do so.  Thus they will be able to keep offering their customers an array of choices together with the prices and quality of service that they have built their reputations on.

Flavor Concentrates

The sales of flavor concentrate used by those individuals who prefer to make their own blends of E-Liquids really won't see very much change.  Why should they?  The actual flavors have no nicotine and are multi-purpose.

Unfortunately, this new wave of regulations has some E-Liquid marketers concerned, that in its exhausting zeal to protect the public, the government may go overboard and one day Trading Standards might declare that, because they are selling flavor concentrates in the same place as e-cigarettes, they will be required to treat all these products as vaping products.  If this were ever to happen, it could be disastrous for some manufacturers, as it could ultimately lead to a cost of millions of pounds.

This is why some manufacturers are already separate businesses with their own websites that only sell multi-purpose flavor concentrates.

Vegetable Glycerine and Propylene Glycol

The same story as with flavorings.  These are multi-purpose, are never vaped by themselves and the TPD doesn't specifically refer to them.  So most manufacturers should continue selling them a before.


For now what can be determined is that the sale of nicotine in PG or VG for DIY E-Liquid mixing has not been clarified, so the subject is more or less in limbo.

One claim is that since nicotine isn't an E-Liquid and isn't vapid alone, so it shouldn't be held to the 10ml/20mg limits.  Plus, there is the fact that nicotine does have other uses.  For these reasons, some vendors believe they will be able to sell 72mg nicotine after May.  Time will tell.


What the above means for the consumer:

  • You can now vape with the confidence that you are vamping 100% TPD compliant E-Liquids.
  • For the most part, your favorite E-Liquids will taste just as they did previously, providing the company didn't need to make any changes to comply with the new rules.
  • Flavor concentrates remain the same as they are not affected by the TPD and you can purchase them as usual in 50 and 100ml bottles.
  • Once a company complies with the new rules, everything else remains the same.

The consensus seems to be that higher-concentrate E-Liquids will likely remain available through word of mouth channels, instead of overt channels such as eBay, or in the e-cigarette shop itself.  Also, the cost per batch for testing, which covers all concentrations in a batch, along with the registration fee will hopefully not be as dramatic as had been the worry previously.

This is practically the only good news, however, because have no doubt that every section of the e-cigarette supply chain is going to feel the winds of change in some manner.  New E-Liquids and hardware now necessitate a six-month wait for approval and approval costs.  The maximum tank size is a measly 2ml, less than half of the normal tank size which existed prior at 5ml.  The maximum nicotine concentration in an E-Liquid is 20mg/ml -- not the 24mg/ml that today's smokers seek when first beginning to vape.  Those who currently use high voltage ("sub ohm") vaping hardware won't be affected, as they actually use very low nicotine concentration liquids -- but the law will prove a major inconvenience, as they go through a lot more E-Liquid.  They'll also be carrying more bottles since the maximum capacity of a refill container size is set to 10ml.

However, vaping fans should prepare themselves for the ultimate reality.  That is that while there are loopholes in the new law, and it will probably see modification down the road, the casual, vape as you please atmosphere which has prevailed since the practice first began are most likely at an end.

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