Vapouround magazine ISSUE 12 | Page 166

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 166 ISSUE 12 VAPOUROUND MAGAZINE 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