The Tobacco Products Directive, widely known as the TPD, is the central piece of legislation that regulates the sale of vaping products in the UK and across Europe. Introduced in May 2016, the TPD has had a huge impact on how vape juice and devices are manufactured, packaged, and sold. For vapers, it explains why nicotine bottles are limited to 10ml, why tanks cannot hold more than 2ml of e liquid, and why health warnings appear on every label.
Although sometimes controversial, the TPD was introduced to ensure safety, transparency, and consumer protection in a fast-growing industry. To understand the vaping market in the UK today, you need to understand what the TPD is and why it matters.
The background to the TPD
Before 2016, the vaping industry in Europe was relatively unregulated. Products varied widely in quality and packaging, and there were concerns about safety and consistency. The EU responded with the Tobacco Products Directive, originally a law aimed at tobacco control but updated to include e cigarettes and e liquids.
The goal was to create a standardised framework across all EU countries. By applying the same rules to every member state, the TPD made sure consumers were buying products that had been tested, registered, and clearly labelled. When the UK left the EU, it retained the TPD rules, meaning they continue to apply today.
The main rules introduced by the TPD
The TPD brought in several specific requirements for vape juice and devices:
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Bottle size restriction: Nicotine-containing e liquids cannot be sold in bottles larger than 10ml.
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Nicotine strength limit: The maximum allowed strength is 20mg per ml.
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Tank capacity: Vaping tanks cannot hold more than 2ml of liquid.
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Packaging requirements: All bottles must be child-resistant, tamper-evident, and clearly labelled with health warnings.
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Ingredient disclosure: Manufacturers must submit a full ingredient list to the Medicines and Healthcare products Regulatory Agency (MHRA).
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Testing and notification: Every e liquid and device must undergo testing and be notified to the MHRA before being sold.
These measures were designed to protect consumers but also shaped the industry in ways that are still felt today.
How the TPD affected e liquids
The 10ml limit on nicotine bottles was the most noticeable change for vapers. Instead of buying 50ml or 100ml nicotine juices, customers had to purchase multiple small bottles, which increased waste and cost. The industry quickly found a workaround in the form of shortfills.
Shortfills are larger bottles of nicotine-free e liquid, sold in 50ml or 100ml sizes, with space left to add nicotine shots. Because they are sold nicotine-free, they do not fall under the TPD’s 10ml restriction. Customers can then mix in nic shots to reach their preferred strength. This simple but effective solution is why shortfills became a staple for vapers.
If you want to see how the TPD connects with other areas of vaping law, our Vape Regulations and Law hub brings together guides on compliance, MSDS documents, the 2026 vape tax, and shortfill legality.
How the TPD affected devices
The TPD also introduced strict rules for vaping devices. Tanks were capped at 2ml, frustrating many sub ohm vapers who prefer larger capacities. Devices also had to deliver nicotine consistently, avoiding spikes in strength that could harm users.
Manufacturers had to redesign many popular tanks and kits to comply with the new rules. While this limited some options compared to markets outside Europe, it also pushed companies to create more efficient coils and designs that perform well even within the 2ml capacity limit.
The TPD after Brexit
When the UK left the EU in 2020, there was speculation about whether the government would scrap or relax the TPD rules. However, the UK decided to retain them, with oversight handled by the MHRA instead of EU authorities. This means that for now, the same restrictions apply: 10ml bottles for nicotine liquids, 20mg strength caps, and 2ml tanks.
There is ongoing debate about whether the UK will change these laws in the future. Some argue that relaxing the 10ml rule would reduce waste and make vaping more appealing compared to smoking. Others believe that maintaining strict rules helps protect consumers and keeps the market regulated.
Why the TPD remains controversial
The TPD was welcomed for improving safety and transparency, but many vapers and businesses believe it goes too far. Common criticisms include:
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The 10ml rule increases plastic waste by forcing people to buy more bottles.
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The 2ml tank capacity is inconvenient for sub ohm vapers who use more liquid.
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The 20mg nicotine cap limits heavy smokers transitioning to vaping.
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The compliance process is expensive for small manufacturers, making it harder for new brands to enter the market.
Despite these criticisms, the TPD has provided a framework that ensures consistency and protects consumers from unsafe or untested products.
The link between the TPD and shortfills
Without the TPD, shortfills may never have existed. They emerged as the industry’s solution to the 10ml bottle rule, giving vapers larger volumes at lower cost. A 100ml shortfill typically costs around £10 and comes with free nic shots, making it far cheaper than buying ten 10ml nicotine bottles.
Shortfills are now the preferred format for most regular vapers, not just because of cost but also because of flavour consistency and reduced packaging waste. If you are interested in trying these larger bottles, check out our 100ml vape juice collection for a wide range of flavours at excellent value.
How businesses adapted to the TPD
For retailers and manufacturers, the TPD created significant challenges. Every product had to be tested and registered, which involved high costs and long timelines. Many smaller companies struggled to comply, while larger brands were able to invest in the necessary processes.
The result was a more consolidated industry with stricter oversight. While this improved consumer safety, it also reduced variety in some areas of the market.
Future of TPD-style rules in the UK
Looking ahead, vaping regulations in the UK may evolve further. The upcoming vape tax in 2026 shows that the government is willing to impose stricter financial and compliance rules. There is also growing discussion about flavour bans or tighter restrictions on marketing, particularly aimed at reducing youth vaping.
Whether or not the UK decides to move away from the TPD framework in the future, its influence is here to stay. It set the foundation for how the vaping market operates and continues to shape every bottle and device sold in the country.
FAQs
Why are nicotine bottles limited to 10ml?
The TPD set this rule to reduce risk if bottles were accidentally ingested and to standardise packaging across the EU.
Is the TPD still in force after Brexit?
Yes, the UK retained TPD rules after leaving the EU. The MHRA now oversees compliance.
Why are vape tanks only 2ml in the UK?
The TPD capped tank size at 2ml as part of safety regulations. Larger tanks are sold in non-TPD markets but not in the UK.
Are 100ml shortfills legal?
Yes. Because they are sold nicotine-free, they do not fall under the 10ml rule. Customers can add nic shots themselves.
Final thoughts
The TPD, introduced in 2016, remains the foundation of vaping regulation in the UK. It limits nicotine bottles to 10ml, caps strength at 20mg, and restricts tanks to 2ml, while requiring strict testing, labelling, and packaging. While these rules have improved safety and consistency, they have also created frustrations that reshaped the market.
Shortfills emerged as the industry’s solution to the 10ml rule and remain the most popular choice for vapers seeking value and flavour variety. Whether you agree with the TPD or not, it continues to define the vaping industry in the UK and will likely influence future regulation.
If you want the day-to-day meaning of those rules for bottles, labels and testing, read what does tpd compliant mean for a plain checklist. If you are tracking how policy will change pricing next year, pair this with the uk vape tax for the duty rate and examples.