Nicotine Base Liquid and the TPD - Update from MHRA

[Postmodern Smoking]

The MHRA has clarified the status of nicbase under the TPD:

Nicotine Base Liquid

The TPD requirements on nicotine concentration (20mg/ml maximum) and size of presentation (10ml maximum for refill container and 2ml maximum for e-cigarettes) apply to products sold to end consumers (irrespective of whether the end consumer intends to modify the product).

The requirements do not apply to ‘trade sales’ i.e. where you are not selling direct to a consumer.

Source document: here

Pretty much what we thought, but now it has been spelt out. 

[Bob]

So to get round these stupid laws we can all incorporate ourselves

[Postmodern Smoking]

That's been discussed before on an other forum Bob , but unlikely to work, as the onus will be on the supplier to not sell to a consumer... and periodically ordering a litre or so of nicbase (probably) won't fool anyone.

[buckowski]

I'm hoping by the time I've used my 1.5 litre 72mg stash, there'll be a workaround of some sort

[Richard46]

May 27, 2016 16:42:07 GMT buckowski said:

I'm hoping by the time I've used my 1.5 litre 72mg stash, there'll be a workaround of some sort

I am sure there already are but sadly they do not involve any benefits for UK (or EU) retailers.

[Perpetua]

Inevitably it will mean ( to my way of thinking ) for the UK consumer that instead of buying higher strength/larger volumes of Nicotine Base from known reputable home sources, then they will go overseas to purchase.

How that pans out I guess only time will tell - the reality is, instead of the TPD providing ' protection ' it has the potential to have completely the opposite effect.

[VapingBad]

What about an Avon type franchise or agent set up, we could buy litres, dilute and to sell in 10 ml (would have to register I believe), with (a lot, most) tax deductible wastage/spoilt/spilt/out of date that we disposed of properly and deffo didn't vape ourselves.

[Deleted]

May 27, 2016 20:01:36 GMT VapingBad said:

What about an Avon type franchise or agent set up, we could buy litres, dilute and to sell in 10 ml (would have to register I believe), with (a lot, most) tax deductible wastage/spoilt/spilt/out of date that we disposed of properly and deffo didn't vape ourselves.

Funny i was thinking surly we could set up a co-op as a business  if all are co-owners then could all use it ???

[cigeliquid]

May 27, 2016 16:49:02 GMT Richard46 said:

May 27, 2016 16:42:07 GMT buckowski said:

I'm hoping by the time I've used my 1.5 litre 72mg stash, there'll be a workaround of some sort

I am sure there already are but sadly they do not involve any benefits for UK (or EU) retailers.

As you say after TPD the risks for UK / EU retailers will be far higher than the benefits


Risk to a retailer
Have in mind when many come back to restock on nicotine base in 5-10 years the TAX position on nicotine containing liquids might be very different


The chances are the "work around "will involve some sort of risk in the same way as importing cigarettes or tobacco.