What 2ml TPD compliance means, and what it does not
Understand the core product limits in the EU Tobacco Products Directive (2014/40/EU), the documents to request, and the destination checks to make before ordering. A 2ml capacity alone does not establish compliance or permission to sell in every country.
The TPD limits we list against
These are the product requirements for nicotine-containing e-cigarettes and refill containers under the Directive.
| Requirement | Limit |
|---|---|
| Tank, pod or cartridge capacity | Maximum 2ml |
| Nicotine strength | Maximum 20mg/ml |
| Refill container (e-liquid bottle) | Maximum 10ml |
| Safety | Child-resistant and tamper-evident packaging; refillable devices must resist leakage |
| Information | Health warning on the pack and a leaflet inside |
| Market entry | Notification to the competent authorities through EU-CEG before the product is placed on the market |
Puff counts are not a TPD measure. A device marketed by puffs only, with no capacity in ml, cannot be assessed against the 2ml limit. We state capacity in ml on every product.
EU-CEG notification explained
Before a nicotine e-cigarette or refill container reaches the EU market, its manufacturer or importer must notify the competent authorities of each Member State where it will be sold. The notification goes through the EU Common Entry Gate (EU-CEG) and is made well before launch, with a six-month lead time for new products. A significant change to a product needs a new notification.
Who notifies
The manufacturer or importer responsible for placing the product on the EU market.
What we show
Request the notification reference, leaflet and relevant test documentation for the exact product variant and intended market.
Before you order
Confirm the responsible manufacturer or importer and the notification status for your intended market. A submission reference is not an EU approval certificate.
Country rules
TPD sets the minimum product rules. Member States add their own restrictions on disposables, flavours and distance sales, so eligibility must be checked for the intended destination.
Product category
Check whether disposable devices or your specific product category may be supplied in the destination market.
Flavours & packaging
Confirm local flavour restrictions, language requirements and the correct national health warning.
Sales route
Check distance-sales rules, registration, age verification and obligations for your business role.
Distance sales
The Directive does not ban cross-border distance sales between Member States, but it leaves the details to national law. Retailers in the EU generally have to register with the authority of the destination country before selling to its consumers, and some countries prohibit it. Requirements also depend on whether the transaction is a consumer sale or a business supply. Confirm the rules for your sales route before ordering.
Labels, leaflets and test reports
On the pack
The nicotine health warning, ingredients list, nicotine content and child-resistant, tamper-evident closure.
In the box
A leaflet with instructions for use and storage, contraindications, warnings for risk groups, possible adverse effects, addictiveness and toxicity, and the contact details of the manufacturer or importer.
What to verify
Capacity, nicotine strength, EU-CEG ID, child-resistance and tamper-evidence, leaflet PDF, test report PDF and sellable countries.
Frequently asked questions
What does “2ml TPD compliant” mean?
The tank, pod or cartridge holds no more than 2ml, the nicotine strength is no more than 20mg/ml, and the product has been notified through EU-CEG with the required packaging, warning and leaflet.
Is a 600-puff disposable TPD compliant?
If its capacity is 2ml or less, it can meet the TPD capacity limit. It still needs notification, and it is banned in some countries, such as Belgium and France.
Can I sell your products in every EU country?
No. TPD sets the product rules, but each country sets its own rules on disposables, flavours and distance sales. Confirm eligibility for the exact product and destination before ordering.
Can I get the documents before ordering?
Request samples and documents and tell us the exact product, variant and destination country. Availability must be confirmed.
Reference: European Commission — electronic cigarettes and Article 20. Check national requirements separately.