Shortfills: UK Regulations & Brexit Update

Shortfill products are a hot topic with many UK retailers making increased profits selling shortfill and nicotine shot kits (Nic Shots), rather than TPD 10ml multiple bottles. The unfortunate misconception is that shortfill products operate outside of regulation and therefore manufactures don’t require the expense or delays of testing and submission.

You may or may not be aware but 0% nicotine (shortfill) liquids are regulated under UK legislation namely the General Product Safety Regulations 2005 (GPSR). The regulations require that ‘Businesses must ensure products are safe for sale to consumers’. Therefore shortfill regulations are governed by the GPSR, not TPD directives.

With the emergence of new innovative technologies into the vape space such as CBD Vape and the recent issues and deaths in the USA regarding Vitamin E Acetate in illegal THC Vape there is an even greater need for non-nicotine vapes to be tested.

Shortfill Regulations & Brexit

Eco Vape call upon industry bodies such as the UKVIA to canvas the MHRA to update the The Tobacco and Related Products Regulations 2016 in light of our new found freedom from the EU.

Eco Vape ensure that safety of their non-nicotine containing liquids by using TPD converters ; TPD Converters are flavours that have been tested with Nicotine and registered with ETRUSTX. Only those tested flavours are then used in our non-nicotine portfolio.

Our testing / compliance partner Adact Medical strongly encourages all businesses in the shortfill market to consider the guidance for TPD notified products as a method of producing robust due diligence information across their Short-Fill product ranges. For the protection of the consumer and product investment, shortfill products should be tested ensuring that manufacturers and re-sellers meet the requirements of the GPSR.

Adact offer a three stage package:

• Analytical Testing
• Safety Assessment of Formulation
• Production of Material Safety Data Sheet (MSDS)*
• Notification of your product at www.tpd.expert

*Note: Any company selling e-liquids and shortfills in the UK must notify the National Poisons Information Service (NPIS) about their products and provide new Safety Data Sheets (SDS).

Again, I strongly encourage you to check with your supplier that all of their shortfill products (non-nicotine containing) meet the GPSR regulation and I also encourage you to complete this work with a reputable compliance agency like Adact.

The good news is that at Eco Vape we have already done the heavy lifting for you. Please note that you can check if a 10ml product is listed with the MHRA using Adact’s tpd.expert tool which provides details of all UK declared products.

Every industry has it’s rouges and bad eggs, there are some ‘less than ethical’ suppliers of 10ml and shortfill liquids in the UK market place which may cause harm to the consumer and undercut reputable manufactures and re-sellers; these liquids (and the people selling them) are damaging our industry as a whole and I encourage you to report theses to the MHRA  TPDsafety@mhra.gov.uk.

Eco Vape provide a comprehensive wholesale and white label service and currently provide millions of compliant product into the market place, all manufactured in the UK in our ISO accredited manufacturing facility. If you would like your own complaint white label product or indeed wish to purchase wholesale some of our award winning ranges please do get in touch. sales@eco-vape.co.uk

Robert Sidebottom is the Group Managing Director for the Eco Vape Group of Companies, he was also the former Interim Managing Director for Adact Medical Ltd. Robert describes himself as a Vape Activist!