Understanding the UK Tobacco Products Directive (TPD) and TRPR

European tobacco law began with the EU Tobacco Products Directive 2001 (Directive 2001/37/EC). Its goal was to harmonise national rules on tobacco across the EU and protect public health. In practice, the first TPD set common standards for cigarettes and other tobacco, for example: maximum yields of 10mg tar, 1 mg nicotine and 10mg carbon monoxide per cigarette (from 2004); mandatory health warnings on all packs (covering at least 10% of the front and back); a ban on misleading descriptors like “light” or “mild”; and a requirement that manufacturers report their ingredients.

By Christopher Banks

Published on June 13, 2025

GUide on Vape Pods

Over the next decade, with the introduction of electronic cigarettes, it became clear that the rules needed updating to accommodate new products and scientific knowledge. The EU, therefore, revised the TPD, culminating in a new Tobacco Products Directive in 2014 (officially Directive 2014/40/EU, often called TPD2).

TPD2 introduced limits on e-cigarette hardware (see below) and required pre-market notification of all tobacco and vape products. The new Directive was agreed by March 2014 and entered into force in May 2014 (with EU countries needing to apply it by May 2016). Its aim was “to improve the functioning of the internal market for tobacco and related products, while ensuring a high level of health protection for European citizens”.

Implementing the TPD in the UK: TRPR 2016

When the UK was still an EU member, it transposed TPD2 into domestic law as the Tobacco and Related Products Regulations 2016 (TRPR). These regulations took effect in May 2016 and apply across England, Scotland and Wales (and, in modified form, in Northern Ireland).

TRPR 2016 implements all key EU requirements for consumer vape products (note: vapes are authorised as medicines and are regulated separately). In particular, the UK rules require exactly the kinds of controls that TPD2 introduced. As the UK government’s guidance explains, TRPR 2016 introduced rules to ensure:

  • Safety and quality standards for e-cigarettes and refill liquids.
  • Full information for consumers so they can make informed choices.
  • An environment that protects children from being drawn into vaping.

Concretely, the TRPR sets limits and requirements for every product on the market. Any manufacturer or importer placing a vaping product on sale in Great Britain must comply. For example, under TRPR 2016:

  • Tank size (capacity): Refillable vaping tanks or pods may hold no more than 2 ml of e-liquid. (Disposable pods and single-use vapes also count; they cannot exceed 2 ml either.)
  • Bottle size: Any nicotine-containing refill container sold separately must be 10 ml or less to be TPD-compliant. (Vape shops often sell larger 50ml “shortfill” bottles, but these must have no nicotine in them.)
  • Nicotine strength: E-liquids may not exceed 20 mg/ml nicotine. This cap applies to the final product the consumer vapes.
  • Child-resistant packaging: All nicotine liquids (and their containers) must use child-proof, tamper-evident closures and be leak-resistant.
  • Banned additives: TPD compliance also means that nicotine liquids cannot contain certain additives. For example, food colourings, caffeine, taurine, and vitamins are forbidden ingredients. (Essentially, only clean, pure ingredients – nicotine, PG/VG base, flavourings – are allowed in a ready-to-vape nicotine liquid.)
  • Labelling requirements: Products must carry clear information. A standard health warning – “This product contains nicotine, which is a highly addictive substance” – must appear on every e-cigarette unit packet (along with other health statements, ingredient lists, batch numbers, and age restrictions). The item must also include instructions and an ingredient list.
  • MHRA notification: Before a vape or e-liquid can be sold, the producer must notify the product to the UK regulator (MHRA). The MHRA keeps a public registry of all notified products. No new vaping product may legally enter the GB market until it has been submitted and approved in this way.

These requirements come directly from the UK’s TRPR, which closely followed the EU’s TPD2 rules. In plain language: every vape sold in Britain must meet these technical limits. Tanks/pods must be ≤2ml, bottles ≤10ml, and nicotine ≤20mg, and packaging must be child-proof with the correct warnings.  Makers of vapes and e-liquids must get products approved by the MHRA first, and they are forbidden from adding any unapproved ingredients. The overall effect is that UK vaping products look and behave very much like the rest of Europe – a uniform set of safety rules keeps everything consistent.

Example:

Most modern pod systems (like Juul, Vuse Alto, etc.) have refillable cartridges that hold 2ml of e-liquid. That is on purpose, manufacturers design them to hit the maximum allowed, without breaking the rule. If a new pod held 3ml, it would be illegal in the UK. Similarly, tanks on box mods are capped at 2ml. In practice, British vapers never see (and stores cannot sell) any bottle or tank that exceeds these limits.

Example:

To work around the 10ml nicotine limit, many UK e-liquid brands sell “shortfill” bottles. These are large (e.g. 50ml or 100ml) bottles with no nicotine but flavourings. The user then adds one or more 10 ml nicotine booster shots (at 18–20mg/ml) to reach the desired strength. Each booster is a nicotine container of 10ml or less, so it obeys the law, and the final mix (once combined) is up to 20mg/ml at most. This simple trick is fully compliant with TRPR: it keeps each nicotine-containing bottle under 10 ml, and ensures no final liquid exceeds the 20 mg limit.

Example:

DIY liquid mixers also navigate the rules. A home blender will use nicotine base in 10ml bottles at or below 20mg/ml (the legal max). They then mix in flavour concentrates. The law doesn’t stop people from mixing at home, but any nicotine base they sell must follow TRPR (10ml, ≤20mg, childproof bottle, etc.). In effect, all nicotine sold for mixing comes in 10ml shot bottles at 18–20 mg/ml – the maximum allowed.

In short, TRPR 2016 made the EU’s 2014 vaping rules UK law. UK authorities (MHRA and local trading standards) enforce the same caps on size and strength, the same packaging standards, and the same notification scheme. The result is a consistent regulatory environment: a UK vaper can buy an e-cigarette and e-liquid just as in any EU country, without unexpected loopholes or differences.

Brexit and Post-EU Changes

After Brexit, the TRPR remained on the books as retained law, but some adjustments were needed. In 2019–2020, the UK passed “EU Exit” regulations to adapt the vape rules now that the UK was no longer an EU member. The core limits (2 ml, 10ml, 20mg, packaging rules, etc.) stayed the same, but how they applied to Great Britain versus Northern Ireland changed.

Specifically, the UK government used the Withdrawal Agreement and Northern Ireland Protocol framework to decide which system to follow. Under these amendments, Northern Ireland continues to apply the EU’s TPD rules (since NI is in the UK yet also aligned with the EU single market). Great Britain (England, Scotland, Wales) now applies the TRPR as amended by UK law. For most vapers, this means that products for GB must be notified in the UK (domestic) system, while products for NI can use the EU notification system.

From 1 January 2021, new rules said:

  • Producers selling vape products into Northern Ireland must notify via the EU Common Entry Gate (EU-CEG), just as before Brexit.
  • Producers selling into Great Britain must notify via the new UK (Great Britain) system.
  • In practice, a company selling to both GB and NI will often register in both systems (and pay separate fees).

These changes simply split the notification process – they did not relax any of the safety rules. Whether a liquid is notified in EU-CEG or UK-CEG, it still must meet the same UK/TPD limits on size, nicotine, packaging, etc. The MHRA remains the “competent authority” for both systems in practice. (Note: businesses in NI can still also sell into the EU under EU rules, and vice versa; retailers in GB who wish to sell to EU consumers now have to register in each EU country separately, since the UK no longer automatically covers the EU market.)

Brexit did not eliminate the vaping rules; it simply moved them into the UK's hands. The TRPR stays in force, but UK law now governs implementation. Key UK amendments since Brexit include separate UK/NI notifications and changes to cross-border sales registration. All core product standards remain as they were under the EU Directive, but the UK can now modify them independently if it wishes (and indeed, has chosen some specific divergences, as we’ll see below).

What’s Coming Soon: Disposable Ban and Vape Tax

Two major changes are on the horizon for UK vaping:

  • Disposable (single-use) vape ban (June 2025): The UK government has announced that all single-use or “disposable” vapes will be illegal to sell from 1 June 2025. This ban covers every non-rechargeable vape, whether it contains nicotine or not. The ban is motivated by environmental concerns (disposables create a lot of plastic/electronic waste), but it means that shops can no longer stock any throwaway vapes after that date. Only rechargeable, refillable devices (or those with replaceable parts) will remain on sale. (Importantly, the technical TRPR rules above still apply to any remaining products – for example, refillable mod kits still must have ≤2 ml tanks, etc.)
  • E-liquid excise tax (Oct 2026): In the 2024 Budget, it was confirmed that from October 2026, the UK will introduce a flat excise duty on vape juice. The rate will be £2.20 per 10 ml of e-liquid. For example, a 10ml bottle will incur £2.20 of duty, a 50ml bottle £11.00, and so on. (To keep relative prices the same, the government also planned an extra duty rise on cigarettes so that 100 cigarettes would go up by £2.20.) In practice, this tax will raise the cost of vape juice and is intended to reduce youth access to very cheap products. Nicotine liquids will be subject to this tax. Vapers should expect their e-liquids to become noticeably more expensive after October 2026.

Both of these upcoming measures will interact with the existing TRPR framework. The disposable ban is a purely domestic decision (not part of the 2014 EU directive) and replaces any earlier EU discussion of disposables. The tax is also a UK policy (the EU has no excise on vapes). In other words, on top of the EU-based TRPR rules, the UK is layering new regulations of its own. After these changes take effect, the legal picture will be:

  • Any device sold in GB must still follow the 2ml/10ml/20mg limits and packaging rules. After June 2025, no single-use (non-refillable) model may be sold at all. Only refillable devices will be legal.
  • Any nicotine liquid sold will still be max 20mg and 10ml in size, but additionally, excise duty at £2.20 per 10ml will apply from Oct 2026. (Merely being more expensive, the tax does not change the product rules.)

These future changes highlight that UK vaping law is evolving. But the core TRPR requirements outlined above remain the foundation: product limits, safety standards, labelling, and notification rules still govern what vapers see on the shelves today.

Summary

In plain terms, UK vaping products are regulated by a blend of EU-origin and UK-origin rules. The 2001 EU Tobacco Products Directive started the process of harmonising tobacco law (including health warnings and yield limits). In 2014, the EU overhauled its policy to cover e-cigarettes as well. The UK adopted the 2014 rules into its own Tobacco and Related Products Regulations in 2016. Since Brexit, the UK has kept the same technical standards in force, only tweaking how they apply (e.g. UK vs NI notifications).

Today, any vaper in England, Scotland or Wales must obey a clear list of restrictions: tanks ≤2ml, nic bottles ≤10ml, nic ≤20mg/ml, child-proof packaging, mandatory warnings, and MHRA registration of each product. In everyday life, this means pod kits and refill bottles sold in the UK look very similar to those in other European countries. Knowing the rules can help vapers, retailers, and hobbyists make sense of product labels and avoid surprises (for example, why you can’t buy a 30ml 18mg bottle, or a disposable with 5ml inside – those simply aren’t allowed by law).

All in all, the UK’s TPD/TRPR framework aims to balance safety with harm reduction: vapes must meet high-quality standards and not target kids, but smokers can still access a wide range of legal alternatives. This guide should serve as a go-to reference for the UK vaping community – an accessible summary of the laws you’ll encounter on the ground. For full details and updates, always check the official MHRA and GOV.UK guidance (for example, MHRA’s vape regs hub and the single-use vape ban notice).

Christopher Banks

Christopher Banks - Vape Expert

Store Assistant & Content Writter

Chris works at Alectrofag as a shop assistant, where he has spent years getting to grips with vaping, both the technology and the people behind it. He’s always on hand to help out on the shop floor, offering advice that comes from real experience, not just theory. When he’s not chatting to customers, you’ll find him writing about vaping tech, digging into the details of new products, or answering the questions that pop up most. Outside of the shop, Chris is usually lost in music, playing his guitar and chasing fresh sounds. For him, it’s not about the jargon, it’s about making sense of the vaping world and sharing that with anyone who wants to understand it better.