What Does TPD E-Liquid Testing Involve?

May 13, 2017 4 min read

TPD E-Liquid Testing

What Does TPD E-Liquid Testing Involve?


By Tatyana Dyachenko

Here is our summary on TPD e-liquid testing in the UK and how it will impact on e-liquid flavourings, nicotine, base ingredients and e-liquid bottles and packaging. With the new TPD regulations introduced in 2016, there have been a lot of changes to what is deemed appropriate when it comes to selling E-Liquids. The new regulations are varied and they can be confusing to producers, retailers and consumers alike. As a consumer and avid vaper it is likely that you are wondering if your tried and true E-Liquid makes the cut when it comes to these new regulations but the rules in question can be difficult to navigate.

When the new regulations came into effect many producers believed that they were too stringent and complicated to understand. If producers find them convoluted it is likely that consumers will to so in order to help you as the consumer to navigate these changes here they are broken down for your convenience.


According to the new guidelines, E-Liquid will only be sold in 10ml bottles at a maximum strength of 20mg. It is important to note that these regulations only apply to E-Liquids that contain nicotine and not to ones that do not contain nicotine. Another rule is that all bottles containing E-Liquid must have a tamper proof cap in order to prevent children from injecting the substances. This was not a major problem as most responsible manufacturers have been making childproof bottles from the get go.

One of the more contentious issues that has come in part due to the new regulations the cost associated with the new compliance rules. For example each time a producer is creating a new product they are required to go through the process of having it approved by the MHRA, which incurs a cost. Overtime the costs compound which make it difficult for a small operation to sustain. This has the potential of limiting businesses that are on a lower scale but have the ability to offer customized services. Although it is important that there are regulations to govern distribution of these products it is important to balance this with the cost of compliance for small businesses. The MHRA stands to gain money in this situation but the question is whether it is at the cost of small business operations. The result of this issue is that many manufacturers will have to close their business because the profits do not account for these new compliance codes; the costs outweigh the money they are bringing in. When small to mid-size businesses close, this means that there are fewer available options for the consumer.

What may happen is that the few small to mid-range businesses that remain will have to rely on larger manufacturers to produce their products so they can be sure that they are meeting compliance regulations. Instead of managing their own production these businesses will remain focused on the retail side of their business and leave the manufacturing to the larger companies. This certainly has a bearing on the customization of products.

Another result of the new rules is that many producers may initially diminish the number of flavours they offer in order to readily manage the cost of compliance. Once they have the initial costs under control these companies may re-issue the flavours on a limited basis, which will allow them to spread out costs over a period of time. In order to provide the demands of their current customers and keep up with the strong reputations they have carefully developed with their loyal customers, smaller companies may draw on the stock of larger business that have already been approved through the TPD process.


Many consumers/vapers use flavour concentrated to make their own specific blends. Fortunately because the flavour concentrates they do not contain any nicotine, those who purchase these will not be impacted by the new regulations. There is a fear though within the E-Liquid community that there is a potential for the government to become over zealous int their regulation strategy would could eventually have an impact on flavour concentrates as they are sold in the same location as e-cigarettes and other products that contain tobacco. One strategy that manufacturers use to mitigate this risk is to separate their E-Liquid business from their flavour concentrate business so their sales will not be impacted if the government suddenly requires a high level of compliance amongst non-nicotine containing products that are sold in tandem with nicotine containing ones. The same issue applies to vegetable glycerine and propylene glycol which are never vaped by themselves but are sold to those who like to create customized vaping concoctions.


As of right now when it comes to nicotine that is sold on its own for mixing purposes regulations remain in limbo. The regulations around how much can be sold for E-Liquid mixing have not been clarified under the new TPD guidelines. Some believe that because nicotine is not vaped on its own and it is generally mixed into E-Liquids it should be able to be purchased in larger quantities and not limited to the 10ml/20mg limit.


So with all of these new regulations this must have a bearing on the consumer. What do the new guidelines mean for the common vaper and E-Liquid consumer? For one, consumers can be confident in knowing that the E-Liquids they vape are all highly regulated and compliant to the TPD guidelines. It is likely that the flavour of most of your favourite E-Liquids will not change drastically depending on the modifications the producer had to make to meet compliance codes.

As with any industry that stands to make a profit, particularly ones that have the ability to impact public health, the government must have a stake or a claim in determining what is legitimate business. While this is challenging for manufacturers especially those who are on the smaller scale end of production it means that there will be higher standards of product that goes to market. This potentially saves the consumer from becoming ill or ingesting something that make impact their health. The challenge for producers though is the maintain the high level of service while paying the compliance fee for each of their products; this has the potential to result in high product costs for the consumer down the line.

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