MY ADVICE IS TO ENSURE YOUR NAMED
IMPORTER IS IN THE COUNTRY THAT REPRESENTS
YOUR BIGGEST MARKET. THE IMPORTANT THING IS THAT
YOU’VE NAMED YOUR IMPORTER, AND THAT THEY ARE A
CURRENT EU NATURAL.
human consumption in the opinion of the MHRA until they
have reviewed your data and a ny company who attempts to
guarantee this should be utterly ashamed of themselves.
A good compliance company will highlight any red flags and
steer you in the right re-formulation direction and not by offering
a product they either manufacture or supply as an easy fix
replacement. Do not mug yourselves off by these types of
tactics, but if your e-liquid contains something implicitly harmful
to humans in the vapour phase by liquid inclusion or generation,
or if your chosen company’s analytical methodology is not
adequate, you will simply fail to satisfy the MHRA.
We suspect they will reject approximately 80% of all
submissions, so try to ensure your compliance is provided from
a company with an excellent pedigree, and a fitting analytical
emissions methodology to satisfy the TPD requirements. One
final negative pointer to look out for in any company you are
considering or have already instructed is the typical dodgy
salesman approach.
We are often contacted by large e-liquid manufacturers who
say they have found a company, who offers money back TPD
guarantees, and I would say to you the customer, beware,
beware, beware! Adequate emissions testing is expensive for
e-liquids, and even more expensive for devices, so any company
who tell you they can do it for free, or a few hundred pounds per
product, is definitely NOT in a position to get you through the
TPD.
TRUST
PREVENTS
DISAPPOINTMENT
Well I hope that has cleared up some of your immediate TPD
issues. Whether you are small retailer with only one Vape shop,
or a large manufacturer with multiple e-liquids living outside the
EU’s border, you all have a responsibility to the TPD, at a variety
of different levels. Good business practice implemented straight
away will ensure you will still be able sell your products to the
EU market beyond November 20th.
Whether you decide to consult with Vape Compliance or any
other Compliance company, do it sooner rather than later. We
expect the MHRA will be looking to slim down the currently
unregulated industry quite substantially in order to manage it a
bit more effectively. Please take your responsibility to the TPD’s
regulatory requirements very seriously, and do take some action
before it is literally too late.
CHECK your existing Compliance Company against the
standards we have recommended above, or if you have still not
addressed your TPD responsibility do so now by contacting us ;)
Everyone has a TPD responsibility to bear... From individual
shop audits for independent retailers, to large scale e-liquids
Technical and Toxicological Dossiers for huge manufacturers,
we offer a level of service for everyone, so if you would like
to know how Vape Compliance can still help you, please
contact us urgently for a specific quote: info@vapecompliance.
com or check out our website www.vapecompliance.com for
testimonials from the market leaders we work with.
LOOK OUT FOR THE NEXT ISSUE AS
THERE IS A FULL INTERVIEW WITH
OUR VERY OWN STEPHEN BUSS
78 ISSUE 06 VAPOUROUND MAGAZINE