You will also need a library of your ingredients in the form of their Chemical Abstract Service ( CAS ) number and detail each ingredients ’ toxic effect . You can go one step further with a final product Tox report if you wish . You will also need to create files on :
• Production , process and procedures that ensure the quality of your ingredients and final products .
• Picture files of your compliant product and packaging .
• Child proof certification and your detailed mechanism for leak free filling . You will need to have a Submitter ID and Etrustex account set up and ready via EU-CEG as well as a list of member states you intend to sell into . The above will allow you to generate your 6 declarations of conformity which you will need to be able to present upon request to the relevant authorities . There is a bit more to the entire process but I outline the basics in order not to bombard you with too much information and detail . The timings for this are dependent on when you start . If all runs in tandem , then you are looking at two weeks for up to 50 new notifications at a cost of around £ 1-2,000 per SKU , all inclusive . The “ sucker punch ” is that some member states can take up to 6 months to give you the nod that products can then be placed on the market and sold . Luckily , I and part of the Vape Compliance team will be in Malaysia for the next Vape Show and would be happy to meet and discuss any compliance matters in more constructive detail . If you wish to get in contact with us , please email us at info @ vapecompliance . com . Kind regards and hope to see you soon . S . B . Q – Next phase of TPD – M , D ’ Lores South Africa – Stephen , we understand what was required for product notification - not that we entered this process , yet . I would like to know in your opinion what is next , so that we can allocate a sufficient budget for EU Compliance . Your attention on this would be greatly appreciated , we read your articles online , keep up the great work . Mark Many thanks for your email and kind words Mark . If you asked me this time last year I would have rattled off a list of what could be on the horizon . However , based on recent events in Europe , I would almost tend to say that the tentacles of the black market might reach out to many companies not appearing on a regulators list . So sit back and watch the show unfold like America is . ( tongue in cheek ) Of course , I would not recommend going unrecognised by EU member state regulators , even though some vendors are requiring OTT information than is strictly necessary as proof of
notification . I see many manufacturers being bullied into releasing information to distributors and retail chains . Some companies that are tied in with or are competitor manufacturers are requesting information that has only just been confidentially uploaded to the EU portal prior to Christmas last . The industry that is on the eve of its first regulatory hurdle is still in a “ wild west ” type scenario . All that has happened , is that the guns and leather boots are of a tad higher quality , that ’ s all . Budget wise for TPD I could not guess to be honest . It really depends on the extent of your product portfolio and the number of member states you are going to pay registration fees to . Many chose the UK for its cross borders sales as they were originally one of the more realistically priced for fees . Some companies registering into tens of member states are paying thousands per SKU . It ’ s the old money grab issue again that this industry could of well done without from the off , but I guess that ’ s just how the powers that be work and why we vote them in and then out . Scientifically testing and justifying your products toxicity is another ball park figure . The price range on the testing available is dramatic , with some companies paying tens of thousands for a test that costs a fraction of that . I would advise looking at the test cost vs the method of testing and ensuring the test provider is operational to the requirements of E-Cig TPD . Shelf life is one for around the corner , and the
justification of , more like . These tests are , from what I ’ ve seen expensive and may not in my opinion be required for every product . We are not quite dealing with a Jam ( preserve not traffic ), as there are a multitude of varieties , but they are all along the same lines if you know what I mean . The component parts of an E-Liquid are in the majority carriers , and nicotine . In addition , there is a whole battery of other chemicals in pin drop quantities . The combination of these provide a taste or smell in vapour form , that mimics a food item to mask the malodour and sour / bitter taste interaction of nicotine or captivate the consumer to brand recognition . My attention to detail has turned into rambling as I am typing this from an airport lounge on little sleep ( not ideal ). Please get back to me on anything specific and how we may be able to best help . Kind regards , S . B . Well , the next time I write it may be to announce the sale of Vape Compliance , as I have had a few tempting offers of late . It has been an uphill struggle working with and for a rogue ’ s gallery of sorts . I will be glad to be rid of the negative side of this industry but will keep an eye on the technology into my old age . However , these next few months are busy , we will be opening a laboratory as promised , specifically for the vape industry , this will lower the cost of testing dramatically and will feed into our Toxicology and Notification tool . For those recently sold or selling out of the industry , be it in Blackburn or Weybridge , you know who you are , I hope you have broad smiles on your faces and at least keep one finger in the E-cig pie moving on . Have faith those that remain , unite and don ’ t give up . There is a smoker every 4 minutes switching to vaping in the UK alone according to the last report I read . I don ’ t know where they get their figures from , but never the less , if you find their contact details pass them on , as I have a PR project for them ! Until next time , please keep your questions coming in , as ever I try to reply to them all but can only publish a few .
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