Part 6 of the Tobacco and related Products Regulations (TRPR) the Tobacco Products and Nicotine Inhaling Products(Amendment) (EU Exit) Regulations 2020 .
The requirements:
● “Restrict e-cigarette tanks to a capacity of no more than 2ml .
● Restrict the maximum volume of nicotine-containing e-liquid for sale in one refill container to 10ml .
● Restrict e-liquids to nicotine strength of no more than 20mg/ml .
● Require nicotine-containing products or their packaging to be child-resistant and tamper evident .
● Ban certain ingredients including colourings, caffeine and taurine .
● Include new labelling requirements and warnings .
● Require all e-cigarettes and e-liquids be notified to the MHRA before they can be sold.
Supplying a product to the UK market will require separate notifications for a product via EUCEG (Northern Ireland) and the MHRA submission portal (Great Britain).
Regarding the package warning picture submitted for e-cigarette notification: Northern Ireland still refers to the EU TPD and Great Britain refers to the warning picture in Annex A1 of TRPR.
If your e-cigarette product does not contain nicotine when sold, but can be used to contain nicotine, the warning statement ‘this product contains nicotine which is a highly addictive substance’ must still be applied.
Manufacturers, Importers and Distributers of e-cigarettes also need to comply with the Restriction of Hazardous Substances in Electrical and Electronic Equipment Regulation 2012 (known as RoHS).
The TRPR does not include any requirements as to where testing of e-cigarettes and refill containers has to take place. The notifier will need to be satisfied as to the standards of any testing carried out as they have to submit a declaration that they bear full responsibility for the quality and safety of the product when placed on the market and used under normal or reasonably foreseeable conditions.
E-cigarettes testing items for UK
Test items for e-liquids
NO. |
Testing Item |
Limit |
1 |
Nicotine concentration |
20 mg/ml |
2 |
Stimulant compounds (such as caffeine or taurine) |
N.D. |
3 |
diacetyl |
N.D. |
4 |
Pentane 2,3 dione |
N.D. |
5 |
diethylene glycol |
N.D. |
6 |
ethylene glycol |
N.D. |
7 |
Formaldehyde, Acetaldehyde, Acrolein |
N.D. |
8 |
Heavy metals(cadmium, chromium, iron, lead, mercury andnickel |
N.D. |
Test items
for emissions
NO. |
Testing Item |
1 |
Nicotine/ Nicotine consistency |
2 |
Formaldehyde, Acetaldehyde, Acrolein |
3 |
Heavy metals(Aluminium,Iron,Chromium, Nickel, Tin, lead, mercury) |
4 |
tobacco specificnitrosamines:NNN, NNK, NAT, NAB |
5 |
ethylene glycol、diethylene glycol |
6 |
Diacetyl, pentane 2,3 dione |
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