Zero Nicotine Regulation and Notification – Zero Expert

Short-fill this Short-fill that!

Zero nicotine products predominantly ‘Short-Fill’ liquids remain a significant disrupter to the UK and European vaping industry. As industry professionals we all aware zero nicotine products fall out of the scope of TPD / TRPR but do fall under the General Products Safety Regulations 2005 (GPSR). Section 5 (General safety requirement) of the GPSR makes it clear that no producer shall place a product on the market unless the product is a safe product or agree to supply a product expose or possess a product for supply unless the product is a safe product.

As the intended use of a zero nicotine vape product is vaping then it is incumbent on the producer to take the necessary steps to ensure that the product is safe for its intended use. Following TPD as a due diligence process is a robust method to help ensure these products meet the requirements of GPSR.

The MHRA cannot list zero nicotine products on their spreadsheets due to lack of legal locus, and concerns that including products that fall out of the scope of TRPR may cause confusion for consumers, sections of the industry and enforcers as well as having the potential to create an unfair commercial advantage for those choosing to notify products. The position is in direct relation to listing the products via the EU-CEG. However the MHRA have also indicated that they would in principle support, indeed they advocate, an industry led voluntary notification system for zero nicotine products (ideally in partnership with a Primary Authority). It should also be noted that there is a significant appetite from producers / manufactures of e-liquids to set their zero nicotine products apart and have them viewed as safe for their intended use in accordance with the GPSR.


Please also note the comment of Mark Oliver, Trading Standards Business Hub Manager, Cambridgeshire and Peterborough Trading Standards:

A notification system for zero nicotine products is progressive and demonstrates that the UK vaping industry is keen to self-regulate and lead the way for consumer safety and compliance. Following the TPD as a due diligence process is a robust method to help ensure these products meet the requirements of the General Product Safety Regulations.”

Test, Analyse and Notify!

Adact feel strongly that a voluntary notification for all zero nicotine products that are produced, tested, analysed and marketed using TPD as a due diligence process will set ethical producers apart, improve consumer confidence in all vaping related products and support the continued growth of the industry.

The voluntary zero notification database ( that Adact are about to release will be available to the entire vaping industry to list zero nicotine products. The online database follows on from the significant success of TPD Expert ( where all UK declared TPD products are presented in an easy to use database promoting productivity in the industry. The database will list all GPSR compliant zero nicotine products, this includes short-fill, 10ml Zero nicotine and CBD products.

Adact are seeking support and partnership from the entire vaping industry for the notification system which will provides a comprehensive database of zero nicotine products that have been produced, tested, analysed and subsequently notified using the regulations of TPD as a due diligence process.

The zero nicotine products fall into four categories:

  1. TPD to Short-fill converted products
  2. Zero Nicotine 10ml products
  3. Standalone Short-Fill products (not previously tested under TPD)
  4. Other zero nicotine products such as CBD with flavours and base flavours for DIY market

As the compliance agency with the greatest number of TPD / TRPR submissions, Adact have evidence that a significant proportion of the zero nicotine products are ‘Short-fill convertors’. These convertor products are derived from a TPD compliant 10ml nicotine containing liquid which for commercial purposes the nicotine has been removed and the flavour then sold sans nicotine in a variety of larger bottle sizes. It is expected that ‘Short-fill convertor’ products will make up the majority of initial listings.

Adact are also witnessing a significant uplift in the amount of standalone products submitted for testing.

The Zero Expert notification system will allow producers and manufacturers to print bespoke reports on their products and create certificates. As part of the terms and conditions of listing; if a product is found to not follow the TPD as a due diligence process then Adact reserve the right to remove the product without refund.

Having zero nicotine liquids that have had their ingredients assessed and emissions tested in line with TRPR is only the first step in ensuring that product are safe for the consumer. Manufacturers and producers who wish to be notified are required to meet / commit to the recommendations provided the Adact Primary Authority Partnership regarding:

Producers and Manufactures can be listed in one of the following ways.

  1. Directly into the Database as customers of Adact
  2. Certified by Partner Compliance Agencies (Xyfil, EOS, EL Science etc)
  3. Self-Certification providing emissions testing evidence / MSDS sheet and affidavit

Stick on bits and Technology

The Zero Expert site in line with TPD Expert will be in constant development. Functionality for the future includes registration of all manufacturers / producer so that they may add additional links, images and details of their compliant products, submit for review branding changes and upload evidence of compliance such as risk assessments & emissions reports.

Support your industry – Don’t let it go up in Smoke

Adact are hopeful that this notification system will begin a process of separation in the industry from reputable / ethical manufacturers and those who continue to damage the industry by selling dangerous, untested products that are often in bottles that are attractive to children and not child proof. In addition the notification system will provide increased productivity in the , confidence to the consumer and the ability for enforcement agencies to check the relative safety of all vaping product.


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