The Tobacco & Related Products Regulation (TRPR) is the GB adaptation of the Tobacco Products Directive (TPD) and applies to nicotine containing products.

Although TPD and TRPR are very similar, there are a few variations which you should be aware of before submitting your notification.

Different portals

TPD notifications are to be submitted via the EU-CEG Portal, whereas TRPR notifications are to be submitted via the MHRA Portal.

Both portals vary in appearance, but their purpose is the same.

Packaging variations

It’s important to note that your packaging will vary depending on whether you’re submitting and application under TPD (EU) or TRPR (GB). Below, we've outlined some of the key differences:

Product conformity markings

Under TPD, the CE mark should be used to state conformity with EU directives.

Under TRPR, the UKCA mark should be used to state conformity with UK regulations.

Products can carry both the CE and UKCA markings, so long as they are fully compliant with both EU and UK directives/regulations.

Information leaflet

TPD requires products to be accompanied with a leaflet, regardless of the information displayed on outer packaging.

The leaflet should include:

• Product name
• Contents of pack
• Instructions for use (including refill if applicable)
• Contra-indications
• Warnings and precautions
• Possible side effects
• Addictiveness and toxicity statements
• Instructions for use and disposal
• Storage instructions
• Contact detailers of manufacturer/importer/responsible person

TRPR does not require products to be accompanied by a leaflet if all relevant information is displayed on outer packaging.

Cost of TPD/TRPR application

The cost of applications varies between not only TPD/TRPR, but also specific countries within the EU. For TPD submissions, you can expect to pay between €0-€1000 per notification. For TRPR, a flat rate of £150 per notification applies with an annual fee of £80.

Vape flavour bans in the EU

There are enforced or planned flavour bans in a number of EU countries including the Netherlands, Denmark, Hungary, Lithuania and Estonia.

There are currently no banned vape flavours for GB under the TRPR.

Due to TPD currently being a directive and not a regulation, individual countries within the EU can apply their own additional interpretations.

If you require assistance with your TPD/TRPR submission, get in touch: info@inter-scientific.com.