Short-Fill (UK) Regulations – Are You Ready?
Short-Fill products are a hot topic with many UK retailers making increased profits selling Short-Fill and nicotine shot kits, rather than TPD 10ml multiple bottles. The unfortunate misconception is that Short-Fill products operate outside of regulation and therefore manufacturers don’t require the expense or delays of testing and submission.
0% nicotine (Short-Fill) liquids are regulated under UK legislation namely the General Product Safety Regulations 2005 (GPSR).
The regulations require that ‘Businesses must ensure products are safe for sale to consumers’.
We are aware of increased activity by UK Trading Standards as we move into what we perceive as a ‘Period of Enforcement’.
Adact strongly encourages all businesses in the Short-Fill market to consider the guidance for TPD notified products as a method of producing robust due diligence information across their Short-Fill product ranges. For the protection of the consumer and product investment, Short-Fill products should be tested ensuring that manufacturers and resellers meet the requirements of the GPSR.
Adact offer a three-stage package:
- Analytical Testing
- Safety Assessment of Formulation
- Production of Material Safety Data Sheet (MSDS) – (We strongly encourage that you have a MSDS in place.)
Adact are happy to provide a single package.
Again, I strongly encourage you to ensure your Short-Fill products meet the GPSR regulation and I also encourage you to complete this work with a reputable compliance agency like Adact.
On a final note, we are all aware that there are some ‘less than ethical’ suppliers of 10ml andShort-Fill liquids in the UK marketplace which may cause harm to the consumer and undercut reputable manufactures and resellers; these liquids (and the people selling them) are damaging our industry as a whole and I encourage you to report theses to the MHRA TPDsafety@mhra.gov.uk.
You can check if a 10ml product is listed with the MHRA using our tpd.expert tool which provides details of all UK declared products.