whether they have nicotine in them or not and as nicotine strength
varies, it can be easy to create a nicotine ‘hotspot’ as users don’t
know exactly how much nicotine is in the shot if they add more
or too much.”
“Some retailers have made increased profits selling short-
fill and nicotine shot kits, rather than 10ml multiple bottles, as
the perception is that short-fill products mean that manufactures
don’t have the expense or delays of TPD regulation. However 0%
nicotine (short-fill) liquids are regulated under the General Product
Safety Regulations 2005 (GPSR). The regulations require that
businesses must ensure products are safe for sale to consumers.
I strongly recommend that all businesses in the short-fill market
consider the guidance for TPD notified products as a method of
producing robust due diligence information across their product
ranges and that they consult with a compliance agency such as
Adact for assistance.”
Robert Sidebottom
Managing Director
VM15 | 73