TPD and having had more time here with different companies
my attitude towards American Manufacturing standards have
changed for the better. All those mentioned above have their
finger on the pulse, the management systems and ISO 9001’s
were more than adequate to justify the process required to
ensure quality of ingredients and final product.
I look forward in returning to California after the Moscow Vape
show and I may look to work out there part time as the sunshine
and people’s attitude is just. ……Nice.
New York
New york was next via internal flight and Bad Drip was first port
of call, and there is nothing Bad about that company with Full
Emissions completed, the Toxicity work is underway and Bad
Drip could be one of the first US companies to notify, I will keep
you posted.
I had a few days to get my head around the fall out from being
away from the UK for a month, with a few more local meetings
and then it was a much needed weeks holiday with the wife and
youngest daughter in a Welsh log cabin before getting stuck
back to TPD business.
Now then…. with the UK Brexit on the tip of everyone’s tongue
whilst away, I have had as per usual a battery of questions about
the what’s, whiff’s and butt’s ;) so below is a small section of the
questions I received on this subject.
Sometimes, a week can be a long time in politics. Since it was
confirmed that Britain would be leaving the EU David Cameron
has resigned and been replaced followed by most of the shadow
cabinet. Nicola Sturgeon has raised the possibility of a second
Scottish Independence referendum, and Sinn Fein has called
for a vote on Irish union, I’m just glad what with all this political
mayhem that I am a Jedi.
In the UK’s journey to leave the EU, a voyage that could take
two years or more, Instability abounds, both for the UK and any
European countries that choose to follow our lead, or remain
within an already fractured and exposed commission. The
question everyone within the Vape Industry is asking is how
does this affect our compliance and our responsibility to the
TPD?
Q Now that the UK has voted to leave the EU does this
mean I won’t need to do my TPD compliance?
Numerous people and companies have asked us this so far and
the answer is a quite straightforward, NO, nothing changes with
regard to the TPD.
This is already law, and will be fully enforced in November. It will
take a minimum of 2 years for full UK withdrawal, at which point
the compliance regulations will still apply to anyone wanting to
sell through to the rest of the EU, and within the UK we will have
regulations of our own which are likely to be even more stringent
than the existing EU TPD requirements.
There was debate in the House of Commons in July that
discussed TPD and the motion to address it was rejected, and
quite rightly so.
Quite rightly so I heard you think? YES
Article 20 is the target not the whole TPD ;) The last thing the
politicians would want is for cigarettes to come back into fashion,
especially after their last 15 years effort via the EU Directives to
achieve this.
The UK has a perfect opportunity to regulate Vaping separate
from that of smoking and I will seriously have the hump if we do
not achieve this.
Will I still be able to sell my TPD compliant products to the
UK after or during this Brexit time?
If your products are genuinely TPD compliant, and notifications
have been approved in some way shape or form by the MHRA,
it is likely that the UK will implement a compatible system, which
will allow you to fully migrate your compliance.
Britain is one of the most highly regulated countries in the
world with regard to consumer health and health and safety,
so whilst we should, in time, be able to rid ourselves of the
more ridiculous and ill-fitting aspects of the TPD, it is likely
the basic scientific framework will be the same and your
TPD data will be fully transferable to any new system the
UK decides to migrate to.
The main advantage with a UK Brexit is that when we do revisit article 20, we can pass motions to scrap the likes of parts
of the advertising ban, the 2ml tank and 10ml bottle limits, the
nicotine content limit (maybe) ... I say maybe as the Scots vote d
to remain, and although I doubt they will be accepted by the
EU we had a better justification for bumping up the nicotine
concentrations in liquids as nicotine has a proven ability to
maintain, stabilise and improve upon the conditions associated
with mental health conditions in humans.
This is a bit political but out of my realms but Scotland has
the highest concentrations of the population undertaking
mental health treatment and this is great for justifying to
UK Government that higher nicotine level containing liquids
would only serve more advantageous to those switching from
conventional combustible tobacco to liquid vapour delivery of
nicotine.
The TPD requirement is to have a “EU natural” importer,
and I’ve chosen someone in the UK… Should I choose
someone else, perhaps from Germany or Italy, to be
my importer?
No, definitely not! We will all still be members of the EU for
at least another two years, so as long as you have already
registered your EU importer this is perfectly acceptable. Choose
your EU importer situated within your biggest market - if this is
the UK your importer would ideally be based there.
If you choose an importer somewhere else within the EU:
for example let’s assume you went for your second biggest
market and that was France... If France decides to follow the
UK’s example and leave the EU, you will be in exactly the
same position.
So my advice is to ensure your named importer is in the country
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