Complexity of flavours in TPD/TRPR products
Jun 11, 2021

Have you ever wondered what the impact is of using different flavours in your e-liquids?

The Tobacco Products Directive (TPD)/Tobacco and Related Products Regulations (TRPR) requires manufacturers to publicly report all e-liquid ingredients included at 0.1% or more.

With thousands of e-liquids placed on the market globally with varying flavours and formulations, it can be hard to make sense of what the ingredients list means especially in relation to flavours. 

In this article, we take a detailed look into flavour ingredients to help you understand more and ensure the safety of your e-liquid product.

Natural/artificial flavourings

Do you know whether your product contains natural or artificial flavours, or a mixture of both? 

Natural flavours are substances that have undergone extraction, distillation or similarly derived from plant or animal matter, either as is or after it has been roasted, heated or fermented, and whose function is for flavor, not nutrition. 

Artificial flavours are substances that do not come from plant or animal sources but they are usually made in labs using similar, if not the same, molecules as found in natural flavour counterparts. 

Neither one is safer than the other and differentiating between natural and artificial flavours based solely on flavour would be incredibly difficult. Reading product labels would be the only way to be sure whether a product contains natural, artificial or a mix of both flavours.

How many flavour ingredients does your e-liquid really contain?

E-liquids can include one flavour from one supplier, or have several flavours from the same or different suppliers mixed together to create a unique sensation.

Each flavour itself may contain varying amounts of different ‘ingredients’ referred to as flavour compounds. 

A typical ‘simple’ flavour can have up to 15 compounds whilst more ‘complex’ flavour could contain upto 100 compounds.

With countless combinations of flavour compounds, it can be easy to get confused when looking at compound/ingredient lists. 

Popular flavours include classic tobacco and menthol then branch out into many fruit and sweet flavours, by combinations of hundreds of flavouring compounds which can be made with artificial or natural ingredients.

It has been suggested that fruit and sweet flavours can help prevent smokers from returning to cigarettes as they taste completely different to traditional tobacco/menthol flavoured cigarettes.

Product labels are not required to list every single flavour compound and groups of flavourings can be banded together under one name, e.g. strawberry flavouring. Therefore, it isn’t possible to know exactly how many flavourings are present in one product, it could be as few as two or contain hundreds.

Identifying flavours by CAS numbers

To further confuse identifying the ‘ingredients’ within flavours, flavour compounds can often have multiple chemical names based upon functional groups, or shortened names they are commonly known/sold as. 

To combat the confusion of chemicals being named in different ways, each chemical is issued a Chemical Abstracts Service (CAS) number that is universally known and understood to mean a certain chemical. 

When submitting ingredient information for TPD/TRPR product notification, CAS numbers are always used in addition to the chemical name to clarify the chemical in question. 

CAS numbers are made up of 2-6 digits – 2 digits – 1 digit e.g. xxxxxx-yy-z, the CAS number for Nicotine is 54-11-5.

Banned ingredients

TPD regulations have banned a number of ingredients, including colourings, caffeine and taurine as they pose a risk to public health when used in ENDS. 

Ingredients that have CMR (carcinogenic, mutagenic or reproductive) toxicity properties are also banned, e.g. Diacetyl and Diethylene glycol.

At Inter Scientific we create our TPD toxicology reports with this in mind and look in depth into these areas of interest to make sure nothing we submit is harmful or damaging.

Flavour ingredients are present in almost all e-liquids which are currently on the global market. With countless combinations of flavour compounds, it can be easy to get confused.

In the research and development phase of your e-liquid flavours, Inter Scientific can help you conduct pre-evaluations of your e-liquid formulas to assess the toxicology of your flavours and verify acceptable safety margins for each ingredient. 

Click here for more information on the TPD/TRPR process. For support, please contact us.

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