24 February 2016

TPD compliant e-liquid packaging. Part 1.

Vapy e-liquids individual boxWith the new Tobacco Products Directive (TPD) on the way, there is much confusion among the e-liquid manufacturers: “What do I need to do to be TPD compliant?”, “How do I label and package my e-liquids according to TPD?” or “Is my e-liquid packaging good enough for TPD?” and similar questions being raised every day.
At CHEMNOVATIC we got the requirements for “TPD ready” e-liquid packaging worked out and can proudly say that our customers’ products are all meeting TPD requirements. The following article is a boiled- down version of TPD guidelines with a touch of our experience – TPD done our way.
Remember: The following regulations are the general guidelines introduced by the EU. Member states have the right to introduce their own, stricter regulations- please make sure to acquaint yourself with the regulations appropriate for your country.

E-liquid labels:

Warnings and pictograms depend on the CLP classification method. Please refer https://chemnovatic.com/Files/Classification-of-the-liquid-products-information.pdf to for details.

First CLP compliant method of nicotine classification:

For ALL e-liquids with nicotine strengths up to 20mg/ml:

One of the following warnings should appear on the label:

  • “If medical advice is needed, have product container or label at hand.”
  • “Product contains nicotine”

Second CLP compliant method of nicotine classification:

For e-liquids with strengths of 3mg/ml:

  • a pictogram:warning pictogram with WARNING written below
  • “Product contains nicotine”
  • “Harmful in contact with skin. Wear protective gloves/ protective clothing. IF SWALLOWED: Immediately call a POISON CENTER or doctor/ physician. IF ON SKIN: Wash with plenty of soap and water. Wash contaminated clothing before reuse. Dispose of contents/ container to properly labeled waste containers in accordance with national legislation.”

For e-liquids with strengths of 6mg/ml:

  • a pictogram: danger pictogramwith DANGER written below
  • “Product contains nicotine”
  • “Toxic in contact with skin. Wear protective gloves/ protective clothing. IF SWALLOWED: Immediately call POISON CENTER or doctor/ physician. IF ON SKIN: Wash with plenty of soap and water. Wash contaminated clothing before reuse. Dispose of contents/ container to properly labeled waste containers in accordance with national legislation.”

EXAMPLE OF OUR LABEL WITH MINIMUM REQUIRED INFORMATION:

  1. VAPY
  2. Ingredients: propylene glycol, vegetable glycerin, flavorings, nicotine
  3. Nicotine content: Depending on e-liquid strength, specified in mg/ml
  4. Nicotine content in ingested dose: Depending on e-liquid strength, specified in percent (%)
  5. Batch number: 201511240000, Best before: 23.11.2017
  6. Product not to be sold to people under the age of 18. Keep out of reach of children and animals.
  7. CHEMNOVATIC Ławecki Gęca Sp.j.
    Dobrzańskiego 3/BS002, 20-262 Lublin
    www.chemnovatic.com
    Tel. +48 81 475 44 42
  8. Product contains nicotine which is a highly addictive substance. Not recommended for non- smokers.

Individual packaging for e-liquids:

Individual packaging must contain the following:

  1. Brand name
  2. Ingredients listed in descending order by weight
  3. Nicotine content
  4. Nicotine content in ingested dose
  5. Batch number
  6. “Keep out of reach of children and animals.”
  7. Manufacturers information: name, address, phone number, www address.
  8. this product contains nicotine which is a highly addictive substanceHealth warning: “This product contains nicotine which is a highly addictive substance, it is not recommended to be sold to non- smokers.” (written in black, bold Helvetica font on white background; centered within the designated area, for cubical and collective packaging the warnings are parallel to the side edges of the individual or collective packaging. The warning text is parallel to the main text on the plane reserved for that warning. Health warning: visible on two biggest planes of the individual and collective packaging, takes up 30% of individual and collective packaging area.)

 

ADDITIONAL CONTENT TO BE DISPLAYED ON INDIVIDUAL E-LIQUID PACKAGING

  1. 35%PG/ 65%VG
  2. “Detailed information can be found on the attached flyer.” (label version)
  3. “Detailed information can be found on a flyer inside the box.” (individual packaging version)
  4. “18+” pictogram not suitable for people under 18 years of age
  5. “Not to be used during pregnancy” pictogram not to be used during pregnancy
  6. “Recycling” pictogramrecycling
  7. Individual packaging warnings:in case of emergency
    “E-liquid is a substance designated for use with e-cigarettes only.”
    “This product should not be used during pregnancy and the lactation period, by persons under the age of 18 or by anyone allergic to propylene glycol or glycerin.”
    “Keep the contents of this package in a dark, cool and dry environment, out of reach of children and animals.”
    “Wash hands and forearms thoroughly if in contact with the contents of the bottle. Exposure to eyes is harmful, flush with water if the product comes in contact with them. If spilled, dispose of safely and responsibly to protect the environment. When seeking medical advice, have the product container or label at hand. If swallowed, rinse mouth out, take this packaging and seek immediate medical advice.”
    “This product contains nicotine which Is a highly addictive substance.”

chemnovatic 10ml dropper with tactile triangleDepending on the country the bottle should also be marked with an embossed tactile triangle symbol.

The above information is a good checklist when designing your e-liquid labels and individual e-liquid packaging. If you are new to the market or not sure if you can handle the label and packaging redesign, please contact us, we are an OEM manufacturer for many brands around the globe and will gladly help. Visit https://chemnovatic.com/for-start-ups/ for more information.

Comments (2)

  1. Eric Coles says:

    We are interested in marketing our E-liquids in the EU and the UK. I have read many of the recent documents on the requirements. Obviously there is still much we have to learn. After reading this post I am wondering how much of the information can actually be put on a 10 ml bottle label. do you have any examples of such a label? Can some of this simply be on the exterior container? And what if you don’t have an exterior container for the bottle?

    Any advice would be appreciated. We are looking for some council on all the TPD compliance matters.

    Eric

    • Hi Eric,
      We have designed the labels for VAPY e-liquids with the TPD in mind, hence they contain all the information required by the Directive.
      As for the exterior container , the TPD does not require e-liquids to have a box, the term “individual packaging” may as well refer to the bottle itself, nevertheless it still needs to display all the required information on the label, if the bottle is not big enough then it requires a flyer that is permamently attached to the bottle and contains all information required by law. Do not forget that the individual packaging needs to display a nicotine health warning taking up at least 30% of the packaging.
      Hope that helps :)

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