What does it mean to be TPD compliant?
Alternatively, read about the: 9 Things you don’t need! (to be TPD compliant)
If you are a importer or manufacturer of e-cigarettes or e-liquids you need to get your products TPD compliant before you can sell in the EU. But what does it mean to be TPD compliant and how can we help you get your products TPD compliant?
The TPD – stands for Tobacco Products Directive – lays down the rules for the sale and marketing of e-cigarettes and e-liquids in the EU. It came into effect in May 2016. Any product must be fully compliant with the TPD before it is placed on the EU market.
The key rules of the TPD include:
1) Product Characteristics: New products must comply with product requirements such as size of bottle, tank size, child-resistant and tamper-evident packaging as well as refill mechanism technical regulations.
2) Notification: Information on the product characteristics, formulation/toxicology (e-liquids only) and emissions, among other things, are submitted to the MHRA via the EU-CEG portal prior to product launch.
3) Packaging and labelling: New rules apply to the packaging; health warning must appear on the label and certain warnings and precautions must appear in the leaflet, for example. Each member state has its own regulations (not only should the health warning be in the local language, but the health warning statement differs market to market – see Country-specific information).
4) Classification of Packaging and Labelling regulation (‘CLP’): Rules on the labelling of mixtures that pre-date the new e-cigarette regulations apply to e-liquids. These include the requirement of an exclamation mark or skull and bones pictograms, and precautionary statements.
What are the CLP Regulations for e-liquids? Click here
5) Producer Registration: Companies must register with the authorities (where applicable) if they wish to sell direct to customers via the Internet.
How can we help you get TPD compliant?
1) Product Characteristics: We can conduct a full review of the products characteristics to check it is TPD compliant. We can inform you of the TPD rules (with background information) and help you understand if your product meets the child-resistant and tamper-evident packaging rules. We can review the refill mechanism and confirm it meets the technical requirements as laid down by the applicable legislation.
2) Notification: We can notify your products on your behalf or provide support so your company can make the notification. We offer advice and guidance on the notification requirements such as toxicology (e-liquids only) and emissions testing, among other things, and help you to submit through the portal. We can arrange the emissions testing – also known as a ‘TPD test’ through a independent and specialist analytical laboratory.
Request a TPD Test
3) Packaging and labelling: We can provide country-specific information so your packaging complies with the rules in each Member State including the health warning and any other information that should appear in the leaflet. We can also advise on whether the health warning should appear on the outer carton or label or both which differs market to market.
4) Classification of Packaging and Labelling regulation (‘CLP’): We have been trained in the CLP regulation and can offer advise in this regard. We advise on the necessary warnings and precautionary statements that should appear on the pack and where the tactile warning should be presented (on the carton or on bottle itself).
5) Producer Registration: We provide the link to the documentation for you to complete. Should you have any questions in completing the form we will advise. Read more about registration below.
Please feel free to contact us for more information on how we can help.