How to get round the TPD - Review of the new ecig regulations June 24 2015, 1 Comment
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May 2016 is a big date in the calendar for all vapers in Europe. Its the month when the much talked about, rashly implemented and heavily criticised set of regulations come in to being in totality. After this date, all European ecig shops and vaping businesses must work inside of the framework put in place by the EU.
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We have discussed before the differing ways this will affect the range of products and juices on the market, so now we start out breakdown of how vapers can continue to cloudchase without breaking the rules.
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Part 1: Tanks
The regulations advise that tanks must be:
- Child safe
- Max capacity of 2.0ml
Up until April 2015, one may think that most subtanks will die a death because of these rules. This was until a lesser known manufacturer in China sort to turn the tide in our favour. Beyang, launched their CVS subtank and gave us a glimpse into how the industry can start to turn the tables.
The Beyang subtank is a top filling unit, that requires the user to push the drip tip down and twist clockwise, to open up a refill hole. This level of minor complexity one may argue is no different to the standard push down and twist child safety lids on medications worldwide; in addition, the top fill with easily closable juice hole, makes the tank leakproof in all but the most clumsy of hands. Thin needle tip bottles fit neatly into the hole making the refill experience a micro version of filling up your motor vehicle. While the tank still allows for the unit to be unscrewed to be topped up with droppers, this feature refill option is a great way for tanks to operate well within the regulations. Now, the Beyang falls down on the next requirement; tank capacity - but whats to say a 'manufacturers suggested refill level' etched onto a 3ml tank wouldn't suffice?
We've all broken the glass on a tank, and know that replacement pyrex/glass tubes are now available to buy widely for all manner of tanks - expect manufacturers to phase in 2.0ml capacity tanks with access to spare pyrex for whatever uses you may require of it. There is no regulations in place on pyrex tubing with threaded ends...... a loophole perhaps.
Following up on the work the Beyang team have done; Aspire announced the release on 22nd June 2015 of their Triton tank. Top fill and with a capacity of 3.5ml. Again this falls foul of the 2.0ml capacity regulation but Aspire also make readily available pyrex tubing. If the worst happens, expect 2.0ml tube to appear online. We will make sure our friends are kept in the loop in this eventuality.
Vape and Juice have the Beyang available instore in their ecig shop in Southend and the vape shop in Southchurch, Essex. Come check it out to see what we are talking about.
The Triton is currently on order and we expect to see it on our shelves by early July in the Vape and Juice shop in Canterbury, Kent; Clacton and Colchester, Essex; Enfield, London; as well as our ecig stores in Southend.
Interestingly, article 20 which cover ecig regulation in TPD states the following points, both of which we offer the following observations:
3. Member States shall ensure that:
(a) nicotine-containing liquid is only placed on the market in dedicated refill containers not exceeding a volume of 10 ml, in disposable electronic cigarettes or in single use cartridges and that the cartridges or tanks do not exceed a volume of 2 ml;
"A Tank with more than 2ml capacity is not placed on the market with nicotine containing liquid - Therefore a packaged new empty tank sold without any volume of eliquid, does not violate this regulation. The EU would need to take a vendor to court and deal with this ambiguity before any enforcement could be finalised"
(g) electronic cigarettes and refill containers are child- and tamper-proof, are protected against breakage and leakage and have a mechanism that ensures refilling without leakage.
"Most bottles on the market with eliquid are child and tamper proof for reasons of commercial quality, and most are protected against breakage. A good many tanks are prone to breakage through human error, although the use of pyrex and metal sheaths makes tanks well protected against breakage. With tanks such as the Beyang and the Triton having a 'mechanism' for refilling without leakage, it should not matter that they also have a mechanism for refilling that may cause leakage. The regulation simply states that there must be a mechanism for spill free refilling - those tanks meet that requirement. Failure to be more specific is a problem that the EU will have to tackle if they wish to go down that route, when they have a good deal of other problems to deal with right now - Grexit anyone?"
We will be following market changes closely over the coming months and will make sure we update you all in due course, thanks for reading and please share if you know someone who may find this interesting.
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