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MHRA e-cigarette notification: GB and NI producers pay one fee for two markets

Producers placing vaping products in Great Britain or Northern Ireland must publish an MHRA notification before sale, face tank, refill and nicotine limits, and pay one fee whether they notify for one market or both.

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Five Pawns E-liquid booth. Photographed 2013-09-20. File photo: Lindsay Fox from Newport beach, United States / Wikimedia Commons, CC BY 2.0. Image: Lindsay Fox from Newport beach, United States Image source · CC BY 2.0 · Display crop and size variants; source image content retained.

Key points

  • Producers must notify the MHRA and have products published before e-cigarettes or e-liquids can be sold in Great Britain or Northern Ireland.
  • Producers notify Northern Ireland through EU-CEG and Great Britain through the domestic GB system, under requirements set out for new products from 1 January 2021.
  • One notification fee applies whether a producer notifies for one of the two markets or both.
  • Tanks are limited to 2ml, nicotine-containing refill containers to 10ml and nicotine strength to 20mg/ml, and certain ingredients including colourings, caffeine and taurine are banned.
  • Retailers need not submit information unless they also qualify as producers, which covers anyone who manufactures, imports or re-brands a product.
On this page
  1. Two notification routes split along the Irish Sea
  2. Who counts as a producer and who does not
  3. Product limits and labelling sit alongside the notification
  4. Medicines-authorised products fall outside TRPR
  5. What changes for exporters and distributors
  6. The notification file keeps changing
  7. Questions readers ask

Producers must notify the MHRA and have their products published before they can be sold in Great Britain or Northern Ireland, and the same single notification fee applies whether a producer files for one of the two markets or both.

Two notification routes split along the Irish Sea

Producers placing products on the Northern Ireland market notify through the EU Common Entry Gate (EU-CEG) system for tobacco and e-cigarette products, the MHRA says. Producers placing products on the Great Britain market notify on the Great Britain domestic system.

The MHRA describes itself as the competent authority for the notification scheme for nicotine-containing vaping products in both markets, working with other regulatory bodies. The route split follows the Tobacco Products and Nicotine Inhaling Products (Amendment) (EU Exit) Regulations 2020, which the agency says set out notification requirements for new products from 1 January 2021.

Who counts as a producer and who does not

A producer is anyone who manufactures or imports these products, or who re-brands any product as their own. Retailers do not need to submit information for products they sell unless they also qualify as a producer.

The obligation sits with the party named on the notification, not with the shop. A distributor that imports a brand from outside the UK, or puts its own label on a device, meets the producer definition under the MHRA’s wording.

Product limits and labelling sit alongside the notification

Part 6 of the Tobacco and Related Products Regulations 2016, as amended, sets the product rules the notification scheme accompanies. The MHRA lists the following requirements.

Requirement Limit or rule
E-cigarette tank capacity No more than 2ml
Nicotine-containing e-liquid per refill container No more than 10ml
Nicotine strength No more than 20mg/ml
Packaging Child-resistant and tamper evident for nicotine-containing products or their packaging
Banned ingredients Includes colourings, caffeine and taurine
Labelling New labelling requirements and warnings apply
Market access All e-cigarettes and e-liquids must be notified and published by the MHRA before sale

The MHRA frames these rules around minimum standards for safety and quality of e-cigarettes and refill containers, consumer information, and an environment that protects children from starting to use the products.

Medicines-authorised products fall outside TRPR

The Tobacco and Related Products Regulations 2016 do not cover nicotine-containing products authorised as medicines. Those products follow a separate licensing route, which the MHRA signposts on the same guidance.

What changes for exporters and distributors

Analysis: for Shenzhen manufacturers and exporters selling into the UK, the notification is the gate rather than a formality, because a product cannot be sold before MHRA publication. Filing and paying for a GB notification does not automatically cover Northern Ireland, since that market uses EU-CEG, and producers should budget office time and fees by market rather than by product line. Buyers placing orders may ask for evidence that a SKU appears on the MHRA published list before committing.

The notification file keeps changing

The MHRA guidance page records repeated updates to its lists of submitted, published and withdrawn products, alongside revisions to its e-cigarette analysis print. The agency last logged a content refresh on 16 August 2024, having first published the page on 29 February 2016.

That maintenance pattern means the status of a specific SKU is a moving item. Producers and buyers checking a product’s place on the published list need to confirm it against the current version rather than an earlier download.

Questions readers ask

Does a retailer in Great Britain need to notify the MHRA for products it sells?

No, unless the retailer also qualifies as a producer. The MHRA defines a producer as anyone who manufactures or imports the products or re-brands a product as their own.

Can a producer file one notification to cover both Great Britain and Northern Ireland?

No. Northern Ireland notifications go through EU-CEG and Great Britain notifications go through the domestic GB system. The MHRA states that notifiers pay one fee when notifying for one market and the same one fee when notifying for both.

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18+ only. This site is for adult readers and provides news and information only. It is not medical, legal or purchase advice. Nicotine is addictive. Always check the official text of any regulation in your market. Health Information

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