Blog

TPD Explained

 

TPD explained

Find out about the changes to UK vaping regulations

WHAT IS TPD ALL ABOUT, AND WHY SHOULD YOU CARE?

Firstly, what do you know about the Tobacco Products Directive? 

The Tobacco Products Directive (TPD) or European Tobacco Products Directive (EUTPD) (2014/40/EU) is a directive of the European Union which legislates the sale and merchandising of tobacco and tobacco related products across the EU. The TPD aims to ensure a high level of health protection for European citizens. The Directive entered into force on 19th May 2014 and became applicable in the EU Member States on 20th May 2016.

This Directive covers the manufacture, presentation, and sale of all tobacco related products including cigarettes, roll your own tobacco, and electronic cigarettes. In order to address this situation, the European Union and its Member States have taken various tobacco control measures in the form of legislation, recommendations and information campaigns.

In summary, the policies for the Tobacco Products Directive cover; the regulation of tobacco products on the EU market (e.g. packaging, labelling, and ingredients), advertising restrictions for tobacco products, the creation of smoke-free environments, tax measures and activities against illegal trade, and acquiring anti-smoking campaigns.

With specific regard to e-cigarettes, the TPD introduced new rules which ensure:

 

minimum standards for safety and quality

information is provided to consumers of nicotine containing products

that protections are put into place to prevent children from starting to use the products



SO, WHAT ARE THESE NEW RULES?

As of May 2017, any nicotine containing product relating to e-cigarettes/vaping must:

RESTRICT THE MAXIMUM VOLUMEOF E-LIQUID IN A SINGLE CONTAINER TO 10ML

RESTRICT THE CAPACITY OF TANKS TO NO MORE THAN 2ML

RESTRICT THE NICOTINE STRENGTH OF E-LIQUIDS TO NO MORE THAN 20MG/ML

TPD compliant max nicotine strength

BE CHILD RESISTANT AND TAMPER EVIDENT

TPD compliant child resistant bottles

NOT CONTAIN CAFFEINE, TAURINE OR COLOURINGS

No caffeineNo taurineNo colourings

BE SUBMITTED TO THE MHRA BEFORE THEY CAN BE SOLD

INCLUDE RELEVANT WARNINGS AND INFORMATION

All packaging to include relevant warnings about nicotine


BETWEEN THE DIRECTIVE COMING INTO FORCE MAY 2016, AND THE CUT-OFF DATE OF MAY 2017, RETAILERS SHOULD HAVE SOLD ANY STOCKS OF PRODUCTS THAT DID NOT COMPLY WITH TPD. 

As of May 2017, you should not be able to purchase non-compliant products within the EU. For this reason, you may have seen certain brands that you were familiar with have disappeared. If this is the case for you, chances are the manufacturer was not able to comply with the new requirements.

What will change?

The changes to the law will affect the products that we can sell. All non-compliant products will be removed. 

You will notice that 30ml bottles of e-liquid will be taken off sale and replaced by 10ml bottles

You may also spot that our tank sizes reduce to a maximum of 2ml. For new and less experienced vapers, the chances are you won't notice the difference. However, for advanced vapers and sub-ohmers, this will likely cause a period of readjustment.

Necessity is the mother of invention, so the saying goes.  In this case, the invention is an eliquid approach known simply as shortfills, and the necessity… that came from the Tobacco Product Directive (TPD) way back in 2017.

After the legislation changed, all nicotine products required submission to the MHRA, approval and testing.  Vapers who were used to unlimited size bottles of eliquid had to get the same amount of eliquid but in 10ml bottles.

The tanks got smaller too and some flavours disappeared altogether as eliquid retailers and manufacturers did the maths.  Some flavours weren’t economically viable – they just weren’t selling well enough for manufacturers to justify the cost of analysis and submission.  Plus there was the additional costs of creating the properly labelled boxes the new rules demanded...

…SO ALONG CAME THE SHORTFILL 

 Zero-nicotine products don't require testing under the rules of the Tobacco Products Directive, so using this notion, manufacturers created a zero-nicotine eliquid product to which you could add an MHRA compliant nicotine concentrate.  It was all legal, the rules were preserved - just swerved slightly.

Take a 60ml bottle that is filled short with just 50ml of eliquid.  That leaves 10ml spare into which you add a 10ml pre-measured ‘shot’ of concentrated nicotine.   

The result is 60ml of your favourite flavour in one bottle, not 10ml times six bottles.

That is the basic way a shortfill works.  Everything is measured, you just top up the shortfill with nicotine. 

Vapers also get a bigger choice of eliquid flavours as it doesn’t have to go through MHRA testing, all in one place…

Shortfills - The Blend

 How the blend comes out depends on nicotine strength and amount of eliquid in the bottle. For example 40ml of eliquid and 20ml of nicotine would create a different blend to a 50ml eliquid/10ml nicotine blend.

Cotton & Cable and Twelve Monkeys an example of 50ml shortfills with flavour percentages designed to take 10ml of 18mg concentrate nicotine. Blending these volumes creates 60ml of 3mg nicotine strength eliquid.

Adding two shots would increase the nicotine volume, but in the case above flavour would start to be impaired as those shortfills are really designed for a 50ml/10ml blend.

Shortfills allow users to buy and carry fewer bottles, perfect if a shortfill flavour is your all-day-vape.  There’s also a little nostalgia attached… it’s like the pre TPD days when vaping was rebellious and cult.  And shortfills still allow users to purchase weird and wonderful blends, with crazy names…