FYI
UK’S LEADING TPD EXPERT
STEPHEN BUSS
With up to 20% of MHRA notifications being provided by Vape Compliance Ltd, the UK’s leading TPD
expert Stephen Buss is back with the latest on his company developments. His regular science and
regulation Q&A feature is back by popular demand where he debunks the toxicology requirement
controversy, compliance file requirements, declarations of conformity and give a heads up on what TPD
notification status really means to you.
The Periodic Deadline
Are you a survivor?
We have seen numerous member state
changes since the May deadline, if ever
there was a time to read an article with
a notepad to hand, this is the time, as
I bring you a hot off the press update.
The most exciting thing about your
notification confirmations, is that not
only the technology, but that your
products have been accepted by the
“powers that be” to the extent this
category required a form of initial
regulation.
This in turn will enable all those
companies who plucked a Submitter ID
from the EU, the chance to survive and
compete in one of the most exciting
industries so far, this Century.
I say survive and compete, because
not all notifications will be the same.
The content and extent of justifications
submitted will be the difference between
in what we all understand as in the
world of Tesco the “value” and “finest”.
I expect there will be bouts of hilarity
when the regulators open the box.
This industry might have generated the
most millionaires under the age of 30,
but now that the regulatory door has
been opened and we have entered
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the compliance arena, some of you
will sink and some of you will swim.
The “wild west” that happened in the
mobile phone industry will repeat here.
Regulation, closure and consolidation
will also repeat. You have been warned.
The last 6 months have passed in
a been a blur. Lessons learnt have
resulted in some rather interesting
transitions both at home and abroad
and in both business and personal
development.
Recent developments in Finland
have seen me cancel my summer
vacation there. Joking apart, I am very
disappointed at what is a money grab
by that Government. Having confirmed
the ban on flavours and banned internet
advertising, all products submitted prior
to those decisions are still bound by
the registration fee. “Kippis! Thanks for
your notification, it’s in the bin, but we
still want the registration fee per SKU”
is how it seems.
Within a month before non-compliant
stock was pulled off the shelf, it
potentially leaves plenty of time for a
couple more muppet member states to
ban common taste and flavour profiles.
If lobbied, and the EU follow through
on its own guidance, flavoured liquid
could be banned across Europe. This
is important for our industry.
It’s not an indication that flavours per se
are bad, it’s an indication as to which
member states are influenced by the
Big pharma or tobacco industry in my
view.
Unfortunately, I had to cancel my