Our Commitment to Responsible and Compliant Vaping Products

At ELF BAE LTD, compliance is an important part of how we operate.

As both a retailer and wholesale supplier of vaping and nicotine alternative products through ElfBae.com, we recognise our responsibility to source and supply products in accordance with the laws and regulatory requirements that apply in the United Kingdom.

The vaping industry continues to develop rapidly, with regulation covering areas including product composition, nicotine strength, packaging, labelling, product notification, age restrictions, advertising, product safety and taxation.

Our aim is straightforward:

To provide our retail customers and wholesale partners with products sourced through a responsible, transparent and compliance-focused supply chain.

Understanding TPD and TRPR Compliance

Many customers and retailers refer to UK vaping regulations simply as “TPD compliance.”

The European Union’s Tobacco Products Directive introduced rules covering tobacco and related products, including nicotine-containing e-cigarettes.

In the UK, the key requirements for consumer e-cigarettes and refill containers are implemented principally through the Tobacco and Related Products Regulations 2016 (TRPR), as amended.

The Medicines and Healthcare products Regulatory Agency (MHRA) is the competent authority responsible for the UK’s notification scheme for nicotine-containing e-cigarettes and refill containers.

At ELF BAE, when we refer to TPD-compliant products, we are generally referring to products intended to comply with the applicable UK TRPR requirements and associated regulations.

Our Approach to Compliance

ELF BAE works with established suppliers, distributors, importers, manufacturers and brands to help ensure that products we offer are appropriate for the UK market.

Our compliance-focused approach may include:

checking product specifications;
reviewing supplier information;
checking applicable MHRA notification status;
reviewing nicotine strengths and liquid capacities;
checking packaging and labelling;
monitoring regulatory developments;
responding to product-safety information;
working with suppliers where additional information is required; and
removing or suspending products where a compliance concern arises.

Compliance is an ongoing responsibility rather than a one-time check.

As regulations change, we continually review our product range and supply arrangements.

MHRA Product Notification

Nicotine-containing e-cigarettes and refill containers intended to be placed on the UK consumer market are subject to an MHRA notification scheme where applicable.

This is sometimes incorrectly referred to as “MHRA approval” or “MHRA authorisation.”

For ordinary consumer vaping products, the more accurate term is generally notification.

Manufacturers and producers responsible for placing qualifying products on the market must submit the required information through the relevant notification process.

Retailers are not ordinarily responsible for submitting notifications simply because they sell a product, unless they also fall within the legal definition of a producer.

As a retailer and wholesaler, ELF BAE aims to source applicable nicotine-containing products that have been properly notified for the UK market.

Checking Notified Products

The MHRA publishes lists of notified e-cigarette and refill-container products.

When sourcing products subject to the notification requirement, we may check relevant information including:

brand;
product name;
nicotine strength;
product format;
manufacturer or producer;
notification status; and
relevant product identification details.

Where appropriate, we may also request confirmation or supporting information from our suppliers.

The appearance of a product on a notification list should not be treated as a blanket guarantee of every aspect of product compliance, so our sourcing process may involve additional checks.

Nicotine Strength

For nicotine-containing consumer vaping products covered by the TRPR, nicotine-containing liquid presented for retail sale must not exceed:

20mg/ml nicotine

This is commonly referred to as 2% nicotine strength.

ELF BAE takes this requirement into account when sourcing nicotine-containing products intended for supply to UK consumers.

Products regulated separately as licensed medicines may be subject to different requirements.

E-Liquid Refill Bottle Size

Under the applicable TRPR rules, nicotine-containing refill containers supplied to consumers are generally limited to:

10ml maximum capacity

This requirement applies to nicotine-containing refill liquid presented for retail sale.

Different regulatory requirements may apply to products that do not fall within the same legal category.

Tank, Cartridge and Pod Capacity

For consumer nicotine-containing e-cigarettes subject to the TRPR, tanks, single-use cartridges and relevant prefilled containers are generally limited to:

2ml maximum capacity

The regulations also restrict the capacity of refillable electronic-cigarette tanks to 2ml.

When selecting products for ElfBae.com, we consider these requirements as part of our compliance checks.

Ingredients and Product Quality

The TRPR includes requirements relating to the ingredients used in nicotine-containing e-liquids.

Among other requirements, qualifying nicotine-containing liquids must:

use ingredients of appropriate purity;
comply with restrictions on certain additives;
contain only notified ingredients other than technically unavoidable trace substances; and
comply with applicable health and safety requirements.

Responsibility for manufacturing and submitting the required technical information primarily sits with the relevant producer or manufacturer.

ELF BAE supports this process by sourcing from suppliers and brands we consider appropriate for the UK market.

Packaging and Labelling

Applicable vaping products must meet legal requirements concerning packaging and information provided to consumers.

Depending on the product, these requirements can include:

health warnings;
ingredient information;
nicotine content;
batch information;
instructions for use;
storage instructions;
appropriate warnings;
manufacturer or producer information; and
required information leaflets.

Our goal is to supply products presented for the UK market with the appropriate packaging and labelling required for their category.

Child-Resistant and Tamper-Evident Packaging

Applicable nicotine-containing vaping products must meet requirements designed to reduce the risk of accidental exposure.

This can include requirements for certain products to be:

child resistant;
tamper evident;
protected against breakage and leakage; and
designed to minimise leakage during refilling.

These requirements form part of the wider regulatory framework intended to improve product safety.

Responsible Retailing

Compliance does not end with the product itself.

As a retailer of age-restricted vaping and nicotine products, ELF BAE takes responsible retailing seriously.

We operate age-verification measures and may require customers to demonstrate that they meet the applicable legal minimum age before completing an order.

From 29 October 2026, UK rules will make it an offence for retailers, including online retailers, to sell any vaping or nicotine product covered by those rules to a person under 18.

ELF BAE will continue to review its age-verification procedures as those requirements develop.

Our Wholesale Responsibilities

As a wholesale supplier, ELF BAE recognises that our trade customers depend on us to provide reliable product and compliance information.

We aim to work with our wholesale partners by:

sourcing appropriate products for the UK market;
maintaining accurate product information;
identifying relevant regulatory changes;
communicating important compliance or safety information;
supporting product-recall processes where required; and
responding to reasonable trade compliance enquiries.

Where we become aware of a significant compliance concern affecting a product, we may suspend supply while the matter is investigated.

Responsibilities of Our Trade Customers

Wholesale customers also have their own legal responsibilities.

Retailers purchasing products from ELF BAE for resale are responsible for ensuring that their own business complies with applicable requirements.

Depending on the products sold and where the business operates, this may include:

age-of-sale laws;
age-verification procedures;
product-display rules;
advertising restrictions;
promotional restrictions;
appropriate product storage;
staff training;
record keeping;
environmental responsibilities; and
other applicable retail regulations.

Purchasing a product from ELF BAE does not remove the retailer’s own legal obligations.

Marketing and Advertising Compliance

Vaping advertising and promotional activity is subject to specific restrictions in the United Kingdom.

ELF BAE aims to ensure that our marketing activities comply with applicable legislation and advertising standards.

We do not treat vaping products as medicines unless a product has the appropriate medicinal authorisation, and we do not intend to make unauthorised medicinal claims about ordinary consumer vaping products.

Our marketing approach is intended for appropriate adult audiences and is reviewed as regulations develop.

Product Safety Monitoring

Product compliance continues after products enter the market.

We take product-safety concerns seriously and may work with:

manufacturers;
distributors;
importers;
regulatory authorities;
suppliers; and
customers

where a possible product-safety concern is identified.

If appropriate, we may:

temporarily suspend sales;
request additional information from a supplier;
notify customers or trade partners;
remove stock from sale;
cooperate with a recall; or
take other appropriate action.

Reporting Product Concerns

If you believe a vaping product purchased from ELF BAE may present a safety issue, please stop using it where appropriate and contact us.

Providing information such as the following can help us investigate:

order number;
product name;
flavour;
nicotine strength;
batch number;
photographs;
videos; and
a description of the problem.

Important suspected adverse reactions or safety concerns relating to vaping products may also be reportable through the UK’s Yellow Card safety-reporting system.

Battery and Device Safety

Many vaping devices use lithium-ion or similar rechargeable batteries.

These batteries are safe when handled correctly but can present risks if they are:

damaged;
incorrectly charged;
short-circuited;
exposed to excessive heat;
modified; or
used with incompatible equipment.

Customers should always follow the manufacturer’s safety instructions.

Battery Safety Precautions

When using rechargeable vaping devices or removable batteries:

use suitable and compatible charging equipment;
follow manufacturer charging instructions;
avoid leaving batteries charging unnecessarily or unattended;
do not use visibly damaged batteries;
do not use batteries with torn or damaged wraps;
keep loose batteries away from keys, coins and other metal objects;
use a suitable protective battery case where appropriate;
do not expose batteries to excessive temperatures;
never deliberately short-circuit a battery; and
discontinue use immediately if a battery behaves abnormally.

Overheating or Damaged Batteries

Stop using a device or battery immediately if it:

becomes excessively hot;
swells;
leaks;
emits an unusual smell;
shows visible physical damage;
behaves unexpectedly; or
appears unsafe.

Move the device away from combustible materials if it is safe to do so and follow appropriate manufacturer or battery-safety guidance.

Do not continue using a battery that you reasonably believe may be damaged.

Unexpected Device Activation

If a vaping device activates unexpectedly or appears to malfunction:

stop using it immediately;
switch the device off if this can be done safely;
disconnect removable components where appropriate and safe;
do not continue using the device until the cause has been identified; and
contact ELF BAE or the manufacturer if further advice is required.

Do not dismantle or modify a device in an attempt to repair a potentially unsafe battery fault unless you are appropriately qualified to do so.

Battery Storage

Loose batteries should be stored safely.

Where appropriate:

use a protective battery case;
keep batteries away from metal objects;
avoid extreme temperatures;
store batteries in a dry location;
keep them away from children; and
inspect them periodically for damage.

Loose lithium-ion cells should never be carried unprotected alongside coins, keys or other conductive objects that could cause a short circuit.

Charging Safety

Only use chargers and cables that are suitable for the device or battery being charged.

Customers should:

follow manufacturer instructions;
avoid using obviously damaged charging equipment;
charge on an appropriate surface;
monitor batteries during charging;
disconnect charging equipment when appropriate; and
discontinue charging if unusual heat, swelling, smell or other abnormal behaviour occurs.

Where a device manufacturer specifies a particular charging method, those instructions should take priority.

Battery Modifications

Customers should not modify, rewrap, rebuild, combine or otherwise alter batteries or battery packs unless they have the appropriate technical knowledge and equipment.

ELF BAE cannot accept responsibility for damage arising from customer misuse, unauthorised modification, inappropriate chargers or improper battery handling where liability may lawfully be excluded.

Nothing in this statement limits liability that cannot legally be excluded.

Environmental Responsibility

Vaping devices, batteries and electrical components should be disposed of responsibly.

Lithium batteries should not be placed into ordinary waste where doing so would be unsafe or inconsistent with applicable disposal guidance.

We encourage customers to use authorised battery and electrical recycling facilities.

ELF BAE will comply with applicable environmental obligations relevant to our activities.

Vaping Products Duty – 2026

The UK regulatory landscape is changing further in 2026.

From 1 October 2026, the UK is introducing Vaping Products Duty.

The current duty rate is:

£2.20 per 10ml of vaping liquid

The duty applies to vaping liquid whether or not it contains nicotine.

This is equivalent to 22 pence per millilitre.

ELF BAE is preparing its retail and wholesale operations for the introduction of the new duty regime.

Vaping Duty Stamps

A new Vaping Duty Stamps Scheme is also being introduced.

From 1 October 2026, vaping products manufactured or imported into the UK under the new regime will be subject to duty-stamp requirements on final retail packaging.

The scheme is designed to help demonstrate that applicable vaping products have entered the legitimate UK duty-paid supply chain.

There are transitional arrangements, and from 1 April 2027, vaping products outside duty suspension in the UK will generally need to carry the required duty stamp.

ELF BAE is monitoring the implementation of these requirements and adapting our sourcing and supply processes accordingly.

Preparing Our Wholesale Customers for 2026

The introduction of Vaping Products Duty will affect manufacturers, importers, wholesalers and retailers across the vaping supply chain.

ELF BAE is working to prepare for these changes so that our trade customers can continue sourcing products with confidence.

As implementation progresses, we aim to provide relevant information to our wholesale customers regarding:

duty-compliant stock;
duty stamps;
transitional stock;
product availability;
pricing changes;
relevant deadlines; and
other practical developments affecting trade customers.

Retailers remain responsible for understanding and complying with any requirements that apply directly to their own businesses.

Anti-Slavery and Responsible Supply

Responsible sourcing extends beyond product regulation.

ELF BAE does not support modern slavery, forced labour or human trafficking.

We expect suppliers and business partners to operate responsibly and to comply with applicable laws relating to employment practices, forced labour and human trafficking.

Where appropriate, we may take action if serious concerns arise regarding conduct within our supply chain.

Continuous Compliance Monitoring

The vaping industry is subject to frequent regulatory change.

We therefore continually review developments relating to:

TRPR requirements;
MHRA guidance;
age restrictions;
advertising;
product safety;
environmental requirements;
Vaping Products Duty;
duty stamps; and
other legislation affecting the vaping and nicotine sector.

Where regulation changes, we aim to adapt our products, processes and policies accordingly.

Customer Satisfaction and Product Quality

Compliance and customer service go hand in hand.

If you have concerns regarding:

product quality;
product authenticity;
packaging;
labelling;
product safety;
suspected compliance issues; or
any product purchased through ElfBae.com,

please contact our customer-support team.

We take genuine product concerns seriously and will investigate them appropriately.

Compliance for Retail Customers

When shopping through ElfBae.com, our goal is to provide customers with confidence that the products they are purchasing have been sourced with UK regulatory requirements in mind.

We aim to provide:

responsibly sourced products;
accurate product information;
appropriate age controls;
transparent customer support; and
prompt action where genuine safety concerns arise.

Compliance for Wholesale Customers

For trade customers, compliance is particularly important because the products purchased from ELF BAE may ultimately be sold onward to consumers.

Our wholesale proposition is therefore built around more than price and availability.

We aim to combine:

competitive trade pricing;
fast-moving products;
dependable supply;
responsible sourcing;
relevant compliance checks; and
ongoing awareness of regulatory developments.

Our Compliance Commitment

At ELF BAE, regulatory compliance is not something we treat as an afterthought.

It is part of the way we select products, choose suppliers, manage our range and build relationships with retail and wholesale customers.

As the vaping industry moves through significant regulatory and taxation changes, our objective is to remain a responsible and dependable supplier.

Responsible sourcing. Compliant products. Reliable supply. Informed retail and wholesale partnerships.

Contact ELF BAE

If you have a question about product compliance, product safety or a product supplied by ELF BAE, please contact us through ElfBae.com.

ELF BAE LTD
44 Century Square
Peterborough
England
PE1 3FR

Company Number: 14468196
Website: ElfBae.com

Where your enquiry concerns a specific product, please provide the product name and, where available, your order number and relevant batch information.

Your Retail & Wholesale Compliance Partner

Whether you’re shopping with us as an individual customer or sourcing products for your business, ELF BAE is committed to building a responsible and dependable vaping supply chain.

For our trade partners in particular, our goal is to make compliance part of the overall service — alongside competitive pricing, strong availability and fast-moving products.

TPD & UK Vaping Compliance at ELF BAE