As part of our membership of the IBVTA, we've been working with the MHRA to seek clarification on certain aspects of the TPD implementation, as well as trying to appeal against certain restrictions.
We've heard back this week from the MHRA specifically with regards to our ability to stock certain new products after November 20th this year. Despite our best efforts, they have ruled that after Nov 20th, we cannot bring to market any new tanks over 2ml in volume, or e-liquids in strengths greater than 20mg, even if we were to submit and pay for the required notifications and testing.
We're also required to ensure that all new products coming in after Nov 20th adhere to the regulations covering health warnings, so expect to see some changes to product packaging before the end of the year.
From one point of view, this is disappointing, as the earlier guidance had suggested we would be able to bring technically 'non-compliant' products to the market right through to the May 2016 deadline. The MHRA has made it clear that it expects a move towards full compliance within the industry ahead of May 2017, which as a responsible company we fully respect and will achieve.
It is, however, welcome to have final clarification from the MHRA.