18+ only · B2B compliance guide for vape distributors and resellers in the EU.
The Tobacco Products Directive (TPD) is the European Union’s central regulatory framework for vapor products. Since it came into force in May 2016, every refillable, disposable, and pod-based product placed on the EU market must be notified, tested, and labelled per TPD rules. In 2026 the framework is being tightened again — child-resistant packaging becomes a formal requirement from October 1, 2026, and a TPD revision (sometimes called TPD3) is on the legislative runway for 2027. This page summarises what an EU vape distributor must know today and what’s coming next.
Table of contents
- What TPD actually covers
- The two hard limits: 20 mg/ml and 2 ml
- EU-CEG notification — the central registry
- Child-resistant packaging (Oct 2026)
- TPD3 timeline and what to expect
- Country-specific rules and flavour bans
- A distributor’s compliance checklist
- Frequently asked questions
1 · What TPD actually covers
TPD 2014/40/EU regulates all “tobacco-related” products, including e-cigarettes and e-liquids. It does not cover heated tobacco (those fall under a separate framework) or nicotine pouches (those are mostly national-level). For vapor products, TPD sets hard limits on nicotine strength and tank size, mandates an EU-wide ingredient notification, and requires child-resistant packaging and tamper-evident seals from October 1, 2026.
2 · The two hard limits: 20 mg/ml nicotine, 2 ml tank
The two headline limits every EU distributor must respect:
- Nicotine strength ≤ 20 mg/ml. Above this, you cannot place the SKU on the EU market. Most disposables are sold at 20 mg/ml (the legal maximum) or 0 mg/ml (no nic).
- Tank size ≤ 2 ml. For disposable and pod devices, the internal reservoir cannot exceed 2 ml. Devices that exceed this are required to be sold in the UK or non-EU markets only. Refill bottles for open-system devices are capped at 10 ml.
3 · EU-CEG notification — the central registry
Every SKU placed on the EU market must be entered in the EU Common Entry Gate (EU-CEG) — a centralised portal run by the European Commission. The notification is filed by either the manufacturer or the importer (which is often the EU distributor). The notification must include ingredient lists, emissions data, toxicology summary, and proposed labelling. After a 6-month standstill, the SKU is publicly visible on the EU-CEG portal under its unique notification ID.
4 · Child-resistant packaging (October 1, 2026)
From October 1, 2026, every disposable vape and refill bottle shipped within the EU must carry third-party-verified child-resistant packaging (CRP). The requirement is a third-party test certificate, not a self-declaration. Manufacturers must commission an ISO 17025-accredited lab test (commonly the ASTM D3475 protocol for child-resistant packaging) and supply the certificate with the EU-CEG notification. Distributors should request and archive these certificates per SKU before each quarter’s purchase.
5 · TPD3 timeline and what to expect
The European Commission has signalled a TPD review (sometimes called TPD3) with the following timeline:
- 2026 Q2 — Commission evaluation report published;
- 2026 Q2–Q3 — evidence-gathering and stakeholder consultation;
- 2026 Q3 — public consultation closes;
- 2026 Q4 — Commission proposal expected;
- 2027 — Council + Parliament co-legislation (likely 12–24 months);
- 2028+ — phased implementation in member states.
The likely topics for TPD3 include flavour restrictions (especially for disposables), plain packaging, online age-verification standards, and a possible EU-wide ingredient ban list. Distributors should not pre-stock SKUs that depend on a flavour category that could be banned.
6 · Country-specific rules and flavour bans
Beyond the EU-wide TPD, several member states have additional rules. The current (as of 2026 Q3) landscape:
- Belgium — banned nicotine disposables from 2025 onward. Do not stock.
- France — banned nicotine disposables from 2025. Do not stock.
- Netherlands — flavour ban for non-tobacco flavours under discussion.
- Germany — TPD-compliant across the board; no extra flavour bans.
- Italy — TPD-compliant; local excise tax applicable from 2026.
- Spain — TPD-compliant; national track-and-trace system live.
- Poland — TPD-compliant; some flavour restrictions for open systems.
7 · A distributor’s compliance checklist
If you’re a vape distributor or wholesaler operating in the EU, keep these documents per SKU and per quarter:
- EU-CEG notification ID and a screenshot of the public listing.
- TPD ingredient declaration from the manufacturer.
- CLP safety data sheet (SDS).
- ISO 17025 lab test report (emissions, heavy metals).
- Child-resistant packaging certificate (after Oct 1, 2026).
- Your VAT invoice with the SKU’s EU-CEG ID in the description.
- Records of which country each SKU was shipped to.
8 · Frequently asked questions
Is every disposable vape in the EU TPD-compliant?
A: No — only SKUs with a valid EU-CEG notification ID and ≤20 mg/ml / ≤2 ml tank. Always verify.
What happens if I import a non-compliant SKU?
A: Customs will hold the shipment, request the EU-CEG notification, and either release (if you can prove compliance) or destroy the goods.
When does the child-resistant packaging rule take effect?
A: October 1, 2026 for all new shipments into the EU.
Will TPD3 ban flavours?
A: Possibly. The Commission’s 2026 Q4 proposal will set the direction.
Where do I file an EU-CEG notification?
A: Through your member state’s competent authority portal — typically the national health / consumer protection agency.
This page is for general information and does not constitute legal advice. Consult a local regulatory advisor for the specific member state you sell in.