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TPD e-liquid UK rules, what they cover and what they don't

Written by Mathilde Carrère · · 7 min to read

TPD e-liquid UK rules, what they cover and what they don't
Image: SHAN LU / Unsplash

“TPD compliant” appears on many British e-liquid pages, usually as a selling point. Behind those three letters sit a set of UK regulations, a notification scheme run by a government agency, voluntary European standards and, on some imported bottles, a French certification. None of them means quite the same thing. Reading TPD e-liquid UK rules properly therefore starts with a simple question, which of these layers is actually in play on the bottle in front of you, and what each one checks.

TPD e-liquid UK rules in one paragraph

In Britain, TPD e-liquid UK rules refer to Part 6 of the Tobacco and Related Products Regulations 2016, the British text that implemented the EU Tobacco Products Directive and still applies, as amended since Brexit. A nicotine e-liquid must be notified to the MHRA and published before it can be supplied, sold in bottles of 10ml at most, at no more than 20mg/ml, labelled with the UK warning and packed with a leaflet.

Standards such as the European EN series or France’s AFNOR scheme sit alongside that framework. They are voluntary, they go further on some points, and none of them replaces the legal minimum.

What TPD compliant means on a UK bottle

The Medicines and Healthcare products Regulatory Agency (MHRA) is the competent authority for the UK notification scheme. It summarises the requirements in a handful of lines, and each one can be traced on the bottle itself if you know where to look.

The limits

Nicotine-containing e-liquid is limited to 10ml per refill bottle and 20mg/ml in strength, and refillable tanks to a capacity of 2ml. Certain ingredients are banned, including colourings, caffeine and taurine. Nicotine products or their packaging must be tamper-evident and fitted with a safety closure.

The label and the leaflet

The label lists the ingredients in descending order of weight, the nicotine content and the batch number. The warning “This product contains nicotine which is a highly addictive substance” covers 30% of the front and back surfaces. Inside the box, a leaflet gives instructions for use and storage and the maker’s contact details.

The notification

Every e-cigarette and e-liquid must be notified and published by the MHRA before sale. Products for Great Britain go through the domestic system, those for Northern Ireland through the EU Common Entry Gate. The agency states that a product may not legally be supplied until its notification has been published.

What the MHRA listing does not tell you

Being on the list is necessary, but it is not a full check. The MHRA itself sets out the limits of its published lists, and they matter as much to a buyer as to a retailer.

Publication of a notified product does not confirm that its label meets UK requirements, according to the agency’s advice for retailers. A listed liquid can still carry a faulty warning or a missing batch number, and the retailer remains responsible for selling compliant stock.

Nicotine-free e-liquids fall outside these regulations entirely. The MHRA places 0mg liquids under general product safety rules, which is why a nicotine-free shortfill needs no notification, while the nic shots you add to it do.

Standards next to the law, the European EN series

Standards are a separate world from regulations. They describe good practice that makers can choose to follow, and they are drafted by standards bodies rather than by government.

European standards for e-cigarettes and e-liquids are written by the CEN technical committee 437. In Britain, the British Standards Institution committee CH/437 handles the UK input into that work, into the ISO subcommittee ISO/TC 126/SC 3 and into British Standards on the subject.

Two European standards published in 2022 matter most for a bottle of e-liquid. EN 17648 deals with e-liquid ingredients, and EN 17647 with the manufacturing, filling and storage of e-liquids. A maker may follow them, but nothing on a UK label is required to say so.

Where France’s AFNOR fits

French bottles sometimes reach British vapers with an AFNOR logo on the label. That logo refers to a voluntary French system with no legal force in the UK, and it can even refer to something other than the liquid itself.

AFNOR publishes the experimental French standard XP D90-300-2 on requirements and test methods for e-liquids, first issued in March 2015 and revised in January 2022. AFNOR Certification runs a separate certification scheme based on it, with laboratory tests on five products, audits of every manufacturing and bottling site, a three-year certificate and annual surveillance checks.

The certified products appear in a public list, reference CDP001, 46 pages long in its 24 March 2026 edition. The certification also caps the best-before date at 18 months after manufacture and allows the stated nicotine strength to vary by no more than 5%. None of this replaces MHRA notification for a bottle sold in the UK.

An AFNOR logo can also mean the Origine France Garantie label, which attests where a product is made, not what it contains. Our close read of Alfaliquid’s Ice Rocket shows a French label carrying that logo.

Law, European standards and AFNOR side by side

The table sums up the three layers most often confused. Read it column by column, and it shows that one bottle can meet all three, two of them, or the law alone.

UK law (TRPR 2016)European standards (CEN)AFNOR certification (France)
StatusCompulsoryVoluntaryVoluntary, audited
Who applies itEvery producerMakers who choose toCertified makers only
Who checksMHRA and Trading StandardsNo third party by defaultAFNOR Certification
What you seeUK warning, batch, 10mlNothing requiredLogo and a listed product

FAQ

These questions come up whenever “TPD” or a foreign logo appears on a bottle. The answers stick to what the MHRA, BSI and AFNOR publish, without reading more into a selling point.

Is the TPD still the law in the UK after Brexit?

The rules continue through the Tobacco and Related Products Regulations 2016, as amended. Great Britain and Northern Ireland now use different notification systems, but the core limits of 10ml, 20mg/ml and 2ml tanks remain.

Are nicotine-free e-liquids covered by these rules?

No. The MHRA treats e-liquids without nicotine as outside the scope of the 2016 regulations and subject to general product safety rules instead.

Can a French AFNOR-certified e-liquid be sold in the UK?

Only once it has been notified to the MHRA, published on the relevant list and labelled to UK requirements. The French certification adds nothing to that process and does not replace any step of it.

Does “TPD compliant” on a shop page prove anything?

It is the seller’s own claim. The checks that count are the MHRA published list and the label itself, with the exact UK warning, the batch number and a size of 10ml or less for a nicotine bottle.

Are there limits on tank size as well?

Yes. A refillable tank may not exceed 2ml, and the MHRA treats extension tanks above that capacity as non-compliant, even when sold alongside a notified kit.

The law sets the minimum for every nicotine bottle, the MHRA listing confirms notification, European standards describe voluntary good practice, and a French AFNOR logo belongs to a system with no weight in UK law. Each layer answers a different question.

Faced with a bottle, check the MHRA list, then the label and leaflet, and only then any logo. Read in that order, TPD e-liquid UK rules stop being a slogan and become a short checklist you can run in a couple of minutes.

On the same shelf

Written for adult readers only. Vaping products usually contain nicotine, which is addictive, and nicotine vaping products are not for sale to under-18s in the UK. La Fiole Bleue describes bottles and labels, and nothing here is a buying recommendation.