TPD3 - Short-Fill (UK) Regulations & EU - UPDATE.

Short-Fill products are a hot topic with many UK retailers making increased profits selling Short-Fill and nicotine shot kits (Nic Shots), rather than TPD 10ml multiple bottles. The unfortunate misconception is that Short-Fill products operate outside of regulation and therefore manufacturers don’t require the expense or delays of testing and submission.

You may or may not be aware but 0% nicotine (Short-Fill and Long-Fill) liquids are regulated under UK legislation namely the General Product Safety Regulations 2005 (GPSR). The regulations require that ‘Businesses must ensure products are safe for sale to consumers.  

With the emergence of new innovative technologies into the vape space such as CBD Vape and the recent issues and deaths in the USA regarding Vitamin E Acetate in illegal THC Vape there is an even greater need for non-nicotine vapes to be tested.

Eco Vape call upon industry bodies such as the UKVIA to canvas the MHRA to update the The Tobacco and Related Products Regulations 2016 in light of our newfound freedom from the EU.

Eco Vape ensures that safety of their non-nicotine containing liquids by using TPD converters; TPD Converters are flavours that have been tested with Nicotine and registered with ETRUSTX. Only those tested flavours are then used in our non-nicotine portfolio. The requirement for testing of non-nicotine containing flavours has increased due to the forward-thinking of the German and Danish authorities who now require all zero nicotine products to be tested in accordance with TPD.

Our testing/compliance partner Arcus Compliance strongly encourages all businesses in the Short-Fill market to consider the guidance for TPD notified products as a method of producing robust due diligence information across their Short-Fill product ranges. For the protection of the consumer and product investment, Short-Fill products should be tested ensuring that manufacturers and re-sellers meet the requirements of the GPSR.

*Note:Any company selling e-liquids and short-fills in the UK must notify the National Poisons Information Service (NPIS) about their products and provide new Safety Data Sheets (SDS).

Again, I strongly encourage you to check with your supplier that all of their Short-Fill products (non-nicotine containing) meet the GPSR regulation and I also encourage you to complete this work with a reputable compliance agency like Arcus

Every industry has its rouges and bad eggs, there are some ‘less than ethical’ suppliers of 10ml and Shortfill liquids in the UK market place which may cause harm to the consumer and undercut reputable manufactures and re-sellers; these liquids (and the people selling them) are damaging our industry as a whole and I encourage you to report these to the MHRA  [email protected]. 

Eco Vape provide a comprehensive wholesale and white label service and currently provide millions of compliant product into the market place, all manufactured in the UK in our ISO accredited manufacturing facility. If you would like your own complaint white label product or indeed wish to purchase wholesale some of our award-winning ranges please do get in touch. [email protected]

Regards

Robert

Robert Sidebottom is the Group Managing Director for the Eco Vape Group of Companies.

Robert describes himself as a Vape Activist!