Article Text

Download PDFPDF
Compliance of e-cigarette refill liquids with regulations on labelling, packaging and technical design characteristics in nine European member states
  1. Charis Girvalaki1,2,
  2. Alexander Vardavas2,
  3. Manolis Tzatzarakis2,
  4. Christina N Kyriakos2,
  5. Katerina Nikitara1,
  6. Aristidis M Tsatsakis2,
  7. Constantine I Vardavas1,2
  1. 1 European Network for Smoking and Tobacco Prevention, Brussels, Belgium
  2. 2 Laboratory of Toxicology, University of Crete School of Medicine, Heraklion, Greece
  1. Correspondence to Dr Constantine I Vardavas, Laboratory of Toxicology, University of Crete School of Medicine, Heraklion 70013, Greece; vardavas{at}


Objective To evaluate electronic cigarette (e-cigarette) product compliance with European regulations (Tobacco Products Directive (TPD), Implementing Decisions), with a focus on labelling/packaging practices and technical design/safety features.

Methods Before the implementation of the TPD, in early 2016, we randomly selected e-cigarette refill liquids from the five top-selling companies in France, Poland, Germany, Netherlands, UK, Spain, Romania, Hungary and Greece. Identical products were purchased after the implementation of the TPD (early 2018) and assessment of compliance was performed on self-matched samples (n=107) using a prospective cohort design. Compliance with the Classification, Labelling and Packaging (CLP) regulations was also evaluated.

Results Following the implementation of the TPD, improvements were noted with regards to the existence of text-only warnings (32.7% pre vs 86.0% post, p<0.001), child-resistant fastenings (93.3% pre vs 100.0% post, p=0.016), tamper-proof vials (58.9% pre vs 86.9%, post p<0.001) and maximum refill volume ≤10 mL in vials (86.9% pre vs 94.4% post, p=0.008). Lower compliance was noted with regards to the inclusion of a leaflet (26.2% pre vs 53.3% post, p<0.001), refilling instructions (28.0% pre vs 51.4% post, p<0.001) and health warnings on the box, vial or leaflet (32.7% pre vs 86.0%, p<0.001). Overall, 86.0% of products had a warning label in the post-TPD phase in comparison to 32.7% of products before the implementation of the TPD (p<0.001). Compliance with the CLP regulations, also increased in the post TPD follow-up phase.

Conclusions This is the first study to evaluate the level of implementation of the e-cigarette regulations in nine EU member states. Our results indicate that refill liquids had substantial but not full compliance in most of the characteristics evaluated. Further effort is needed to ensure complete compliance.

  • electronic nicotine delivery devices
  • packaging and Labelling
  • public policy

Statistics from

Request Permissions

If you wish to reuse any or all of this article please use the link below which will take you to the Copyright Clearance Center’s RightsLink service. You will be able to get a quick price and instant permission to reuse the content in many different ways.


  • Contributors All contributors have read and approved the revised version of this manuscript.

  • Funding This work was supported by a grant from the European Commission (Horizon2020 HCO-6-2015;EUREST-PLUS: 681109; Vardavas).

  • Competing interests None declared.

  • Patient consent for publication Not required.

  • Provenance and peer review Not commissioned; externally peer reviewed.

  • Data availability statement All data relevant to the study are included in the article or uploaded as supplementary information.