Non-nicotine e-liquids and e-cigarettes must be TPD notified in Germany – when is the deadline?
The new regulation came into force on 1 January 2021. Consequently, if from the new year we want to sell nicotine-free liquids on the German market, they will require TPD registration and verification of ingredients. But what is the exact timeline?
- If your product was already present on the German market in 2020 – you have 6 months to register it according to the new legislation;
- If you want to introduce a completely new product to the German market – you need to notify your product and wait 6 months before you will be able to introduce your product on the market.
But what happens if you didn’t test and register liquids before 01/01/2021?
The sale period for unreported e-liquid products ends on March 31, 2021
You have to register e-liquids that are currently available on the market no later than 6 months from the date of entry into force of the new regulations, i.e. January 1, 2021. However, if you don’t want to TPD register the non-nicotine products you can sell them out before March 31, 2021. Moreover, e-liquids without nicotine are now equal in terms of the composition requirement with nicotine liquids. In Germany, there is a special list of banned substances that can be extended at any time.
German new TPD notification rules – what do you need to know?
Let’s sum up the most important information concerning new TPD rules in Germany:
- Restrictions on advertising – Just like liquids with nicotine, from January 1, 2021, you cannot advertise premixes and longfills in the mass media.
- No need of 10 ml packaging – Nicotine-free liquids will not have a 10 ml limit per pack, nor a special nicotine warning requirement on the pack. The above restriction remains only for the nicotine liquids.
- 6 month transition period – The new regulation entered into force on January 1, 2021. If the nicotine-free liquid was on the market before this date, there are 6 months to register it from January 1, 2021
- Shortfills also need to be TPD notified – Shortfills also fall under this nationally extended definition of a refillable container within the meaning of Art. 2 No. 17 of TPD Directive.
We can help you to maintain your sales in Germany
Our highly skilled TPD Specialists have conducted several hundreds of successful TPD registration in every EU country. We have the necessary experience with foreign authorities and their requirements. With us, you will have the guarantee that we will guide you through the process easily and without any unnecessary problems.