With the new TPD regulations coming in place on 20 May in the UK, I have a question regarding the nicotine in the DIY juice that I provide for my clients.
New regulations state that the bottles cannot be more than 10 ml in volume. However, the regulation only takes places if the juice contains nicotine.
So my question is - what if I gave my customer a 60ml bottle of juice WITHOUT nicotine, and then gave them the required amount of nicotine separately for free, so they could mix it in themselves (taste and mixing issues aside), would that still be considered illegal, even if they are over 18?
Having no nicotine in ejuice seems to significantly ease the legality issues with DIY ejuice, so that's why I'm asking.
If you are a vendor you need to consult the actual laws. Since you used the term "clients" I am assuming that's what you are, and not someone selling to your friends or family. This is a DIY sub. We can't help you with that here. If you are really just a DIYer selling to a few people, you shouldn't really be worried.
Sorry, English is not my first language, so you might have misinterpreted my words :P
I'm only selling to a few people at my work, and I like to call them clients because they are usually 20+ years older than me and it just sounds cool.
But I'm planning to sligthly increase my client base so decided to ask you guys. Better safe than sorry :P
Thank you.
If you sell privately (no receipt, no tax, money straight in your pocket) then why even bother following the law about size regulations.
If you intend to increase your clientele the you need to register a business or if the laws allow it to be considered a revenue from a hobby (there is that option at least in Sweden).
I think the main issue is the fact that it is a product containing nicotine.
The way around this is to short fill your 60 ml bottle with 50 ml of juice and the get them to buy and add the nicotine shot separately. You can not give it away for free s this would make it part of the deal and that would be a problem
I would suggest that if 60 ml would normally cost eg £20 to sell it for £18.50 and then sell the nicotine shot for £1.50.
Good luck mate
Edit: the best thing to do though is to speak to the MHRA and trading standards and get something in writing from them to confirm if you in fact do the above
This is what a number of vendors are doing (although they seem to be listing it at different prices for different nic levels)
For example VapeGoo (who I don't personally use) are selling 60ml bottles, which comes with 60ml liquid/0ml nic for 0mg, 50ml liquid/10ml nic for 3mg and 40ml liquid/20ml (2x10ml bottles) nic for 6mg - they are charging different prices for the different nic levels (which makes me think they're splitting the liquid/nic out into seperate line items on the accounts system, but the customer just pays for 60ml @ 3mg and doesn't have to worry about how many nic shots to buy ...
Isn't the issue that you have a max nic level aswell iirc (I'm Swedish so I don't keep track of all international laws)
Let's assume a client wants 12 mg nic in his 60 ml mix so basically 50 ml at 0 nic + 10 ml max nic (20 mg?) Still lacking 26 ml of nic juice to have a final product of 12 mg
Or is my calculations way off (currently in bathroom waiting for shower and vaping so I have limited visibility and rapid deterioration of said visibility for every puff)
We are facing similar restrictions in Sweden aswell in January so I'ma bit curious and worried myself.
Yes, so the max nic in a 10ml bottle is 20mg/ml ... so if you wanted 60ml of 12mg, you'd have 24ml of PG/VG/flavouring and then you'd have to add 36ml (so realistically you'd need 4 x 10ml) of nic shots ... this is why I've just bought 1 litre of 72mg/ml nicotine to decant and store in the freezer and start DIY'ing :)
The TPD is an EU directive. I would try to find out if this will be transposed into UK law. It probably will, but there is a chance it won't.
It is already UK law. Full implementation starts in five days time. (May 20 2017)
After that date, everything has to be fully compliant. It's a crock of sh*t, but that's how it is.