EU TPD Update: Stricter Health Warnings on Vape Packs

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EU TPD regulation update: Electronic cigarette products need to add health warnings

The European Commission released a revised draft of the Tobacco Products Directive (TPD) on February 28, 2024, which proposes stricter labeling and health warning requirements for electronic cigarette products.

Main revision content

1. Packaging warning requirements

The new draft requires that electronic cigarette product packaging must include the following warning information:

Front warning (occupying no less than 30% of the front area of the packaging)

-This product contains nicotine and is addictive -Use uniform black warning text and white background

Back warning (occupying no less than 40% of the packaging back area)

Must include one of the following health warnings: -Nicotine can damage the brain development of adolescents -Pregnant women using it may harm the fetus -This product is not suitable for non-smokers to use

2. Ingredient disclosure requirements

Production enterprises need to submit more detailed product information to the EU:
Information typeCurrent requirementsNew requirements
Ingredient ListMain IngredientsAll Ingredients (>0.1%)
Toxicological dataBasic dataComprehensive assessment report
Emission DataOptionalMandatory
Update frequencyAnnualQuarterly

3. Strengthening advertising restrictions

The new draft further tightens electronic cigarette advertising: - Prohibit social media promotion : Completely prohibit product promotion on social media platforms -Influencer marketing ban: Prohibition of collaborating with internet celebrities/KOLs to promote electronic cigarettes -Sponsorship restrictions: Prohibiting sponsorship of sports events and music festivals - Display Restrictions : Retail store product displays must follow uniform standards

Compliance Schedule

Revised TPD Expected Implementation Schedule: <>

Suggestions for enterprise response

Regarding the upcoming new regulations, it is recommended that companies take the following measures:

Immediate Action (Q2 2024)

1. Regulatory Tracking : Designate a dedicated person to track the progress of TPD revisions 2. Impact Assessment : Evaluate the compliance of existing product lines 3. Packaging redesign : Start designing packaging that meets new requirements

Mid term preparation (Q3 to Q4 2024)

1. Ingredient testing : Complete ingredient analysis for all products 2. Toxicological evaluation : Entrusting a third-party organization to conduct the evaluation 3. Database update : Preparing for data updates for the EU Common Entrance System

Long term planning (2025)

1. Product Adjustment : Eliminate non compliant products 2. Market Strategy Adjustment : Redesign the EU market strategy 3. Compliance system construction : Establish a long-term compliance monitoring mechanism !<>

Differences in Conversion Across Countries

It should be noted that there may be differences among member countries when converting TPD: -Germany may increase stricter measures to protect teenagers -France may expand restrictions on the use of public places - Italy : Additional requirements may be imposed on online sales -The Netherlands is considering a comprehensive ban on disposable electronic cigarettes

The impact on export enterprises

For Chinese electronic cigarette export enterprises, the new regulations bring the following challenges: 1. Cost increase : Packaging redesign and testing certification costs 2. Product Adjustment : Some products may no longer be able to continue exporting to the European Union 3. Compliance complexity : Need to meet stricter information disclosure requirements 4. Market Competition : Increasing Compliance Threshold Will Eliminate Some Competitors

Related resources

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--- This article is based on the revised draft released on February 28, 2024, and the final regulatory content shall be subject to the official release