It’s been 6 months since the introduction of the Tobacco Products Directive (TPD). The TPD covered all Tobacco products and to the dismay of many also included Vaping Products. Article 20 of the TPD regulates the Vaping Market and introduced some basic legal requirements:
- Maximum eliquid bottle size - 10ml
- Maximum nicotine strength - 20mg/ml (2%)
- Maximum cartridge or tank size - 2ml
- Leak-proof refilling mechanism
- Consistent nicotine dose from devices
- Product testing and notification
Much discussion has been made of the new regulations but they’re here to stay (for the moment). Probably the most annoying part of the regs is the 2ml max tank size and 10ml max e-liquid bottle size. However, probably the best part of the new regulations is the safety and quality aspects in relation to e-liquid (see more about this below).
Since the intorduction of the TPD regulations on 20th May 2016 there has been a transitional period to allow Manufacturers and Retailers of Vaping products to start to comply with the new regulations.
E-Liquid Manufacturers had to submit test results to the MHRA through a European Common Entry Gate (EU-CEG) notification portal by the 19th of November 2016. For e-liquid sales there is still a transitional period for “old stock” that was produced and bottled before the 19th November to be legally sold but if the e-liquid has been produced after the 20th of November 2016 then it will have to be fully TPD Compliant.
All Vaping hardware that was made before the 19th of November 2016 can still be sold until the 19th of May 2017 without the need for test submissions but thereafter the TPD Regulations will come into full effect and anyone manufacturing and or retailing vaping equipment will have to comply fully.
See chart below for an easy to understand guide to dates and regs:
The vaping industry has often been portrayed as a "Wild West" kind of environment, where mad chemists slap together the ingredients for eliquid to get them out the door as quickly as possible. Even if this portrayal is inaccurate, this age has come to an end and in our opinion this can only be a good thing.
The regulations will ensure that you are buying quality products that have been properly tested – this is especially important with e-liquid.
Most British eliquid manufacturers have processes and policies in place to be compliant with the Tobacco Products Directive, one requirement of which is to use high quality ingredients in the manufacture of eliquids.
We suspect that many vape juice manufacturers will go out of business as they will not be able to afford the testing and compliance procedures of the TPD. It maybe that their liquid might not be of a high enough quality or the testing reveals safety issues and their liquid is deemed not fit for sale.
ALL E-LIQUID THAT WE SELL IS FULLY TPD COMPLIANT
We have completely committed to the TPD since May 2016. All the E-liquid we sell has been laboratory tested and a standards based production of eliquids specifically to the requirements of the TPD has been put in place.
We are focused on giving our customers the highest quality and safest eliquids possible. One of the areas in which we do this is to ensure that the chemicals we use for eliquid flavours are safe - and this includes not using chemicals which have been shown to be harmful.
TPD compliance and how it makes your vape better
All incoming ingredients are tested for contamination and consistency before production starts. Production itself takes place in a clean room environment which ensures no contamination, with equipment being cleaned and sanitized between each flavour. Recipes for each flavour are strictly followed to ensure consistency - the Cherry Menthol eliquid you taste from us this month will be the same taste that you get a year from now, unless we improve our formula. Product improvements are also ongoing - if we receive complaints about flavours, they are tested to see if they require improvement, and we take measures to improve the recipe if they do.
TPD compliance requires that we test each ingredient and emission for toxicology, and if it does not pass these tests, it doesn’t go into eliquid recipes. More importantly, we don’t just test the ingredients as a raw material; we also test it as vapour for full toxicology emissions profiling.
Some of the ingredients such as propylene glycol, vegetable glycerin and nicotine have generally not been called into question by the scientific community. The only potential “problem” ingredients are the chemicals used in flavourings, and we are careful to avoid chemicals that have been deemed unsafe for eliquids. The TPD gives us the processes we need to follow to ensure that these flavourings don’t make it in, and our additional quality standards build even more firewalls against unsafe ingredients ending up in your vape juice.
All our eLiquids are diacetyl-free
The leading flavour ingredient which should be off every manufacturer's list is diacetyl. This is the chemical which creates “popcorn lung” and is toxic to inhale. It’s a mystery as to exactly why it was used in eliquid flavourings in the first place, but probably has something to do with the beginning of the industry being non-scientists fiddling about in their garage workshops. Its chemical cousin, 2,3-pentanedione, is also kept out of our eliquids.
Other chemicals and ingredients of concern we keep out
Naturally-occurring cinnamon is a known irritant and has been removed from all of our eliquids. Any cinnamon flavours are created with artificial flavouring components. Vanillin and benzaldehyde can be respiratory irritants at higher levels, and are used and monitored to be kept at low levels within the regulatory requirements of the Tobacco Products Directive.
These are just some known offenders that we either do not use or use at low, safe levels - as previously stated, we don’t use anything that tests positive on any toxicology tests, and mark the ingredient on a banned list for future use if it comes up.
Allergies and vaping
If you are allergic to something, you should avoid purchasing flavours which would contain those flavours if you were to order their real-world counterparts in a restaurant. In many cases, artificial flavouring is used to mimic a natural flavour, but there are instances where flavour is derived naturally. If you are allergic to nuts, for example, you should avoid eliquid which may contain flavourings from nuts.
It isn’t enough to get our customers off of smoking - we want to make sure they are doing it in a safe way with our eliquids. If you have concerns about particular ingredients, we invite you to contact us with questions.
Q and A about the TPD
How do I know if the e-Liquid I’m buying is TPD compliant?
As of now there are no certification marks to show TPD compliance. However, a number of warnings and specific information must be shown on the bottle, including the batch number, ingredients and quantity of each ingredient etc... The easiest thing to look for is the batch number - if your eliquid doesn’t have one, it’s not TPD compliant. Additionally, if it doesn’t have a childproof cap, it’s not TPD-compliant.
What if I still have a 30ml or larger bottle that I’m using past May 2017?
The regulations are pretty much for Manufacturers and Retailers - you can still safely possess one of these bottles until you have used the product. Just don’t try to sell it.
What if I have and use equipment that is not TPD Compliant?
After the 19th of May 2017 you definitely won’t be able to purchase tanks with a greater capacity of 2ml. If you like to use larger tanks then it may be prudent to buy a couple (for spares) prior to this date.
Replacement atomiser coils may cause you a problem - coils for some older model tanks may or will become un-sellable as they will have never been tested for TPD compliance and the manufacturer may consider the testing procedures too expensive. Again, it might be sensible to buy more than you would normally to ensure you have a supply going forward past May 2017.
Got a question – Let us know and we’ll try and answer it for you.
More information on the new TPD regulations can be found here: https://www.gov.uk/guidance/e-cigarettes-regulations-for-consumer-products