Compliance · Retailers
UK vape retailer checklist
Ten checks for a shop or online store selling vaping products, with what changes on 29 October 2026. Each one quotes the official page it comes from. It is a checklist, not legal advice: where a rule differs by nation, the check says so.
Sources read
Stock only products on the MHRA list for your market
In forceUK-wideBefore you buy a nicotine vaping product, check its notification is published on the MHRA list for where you sell it: the GB list for England, Scotland and Wales, the NI list for Northern Ireland.
- If you cannot find a product, ask your supplier to confirm its notification and give you the details to check it.
- A published notification is not an approval and does not prove the product is labelled correctly; that stays your responsibility.
- Nicotine-free e-liquids and devices sit outside the MHRA scheme and are covered by general product safety law.
Sources
- “When procuring new supplies of e-cigarette or e-liquid products, always ensure that a notification has been published in one of the Notified Product lists provided above.”Advice for retailers and producers· MHRA · read 2 Oct 2026https://www.gov.uk/government/publications/advice-for-retailers-and-producers
- “Products may not legally be supplied until the notification has been published on the relevant list for Great Britain and/or Northern Ireland.”Advice for retailers and producers· MHRA · read 2 Oct 2026https://www.gov.uk/government/publications/advice-for-retailers-and-producers
Duty stamps, and selling through unstamped stock by 31 March 2027
In forceUK-wideFrom 1 October 2026 buy stamped vaping products, or keep evidence that unstamped stock was produced or imported before that date. Sell or clear that unstamped stock by 31 March 2027. From 1 April 2027 do not sell unstamped vaping products.
- The stamp goes on the outermost retail packaging and seals it.
- Vaping Products Duty is £2.20 per 10 ml and applies whether or not the liquid contains nicotine.
- A retailer that only sells duty-paid products does not need HMRC approval for the duty or the stamps scheme.
- HMRC can seize unstamped goods and charge penalties from £2,500 to £10,000 each time, and in the most serious cases may prosecute.
Sources
- “You can continue to store and sell unstamped stock that was produced or imported before 1 October 2026 until 31 March 2027.”Handling wholesale or retail vaping products in the UK· HM Revenue and Customs · read 2 Oct 2026https://www.gov.uk/guidance/handling-wholesale-or-retail-vaping-products-in-the-uk
- “From 1 April 2027, all vaping products outside duty suspension in the UK must have a vaping duty stamp attached. You must not sell unstamped vaping products from this date.”Handling wholesale or retail vaping products in the UK· HM Revenue and Customs · read 2 Oct 2026https://www.gov.uk/guidance/handling-wholesale-or-retail-vaping-products-in-the-uk
- “We may charge you a penalty if you sell, offer for sale or deal in unstamped vaping products packaged for retail sale. These penalties apply from 1 October 2026.”Vaping duty stamps: penalties and sanctions (CC/FS87)· HM Revenue and Customs · read 2 Oct 2026https://www.gov.uk/government/publications/compliance-checks-vaping-duty-stamps-penalties-and-sanctions-ccfs87/vaping-duty-stamps-penalties-and-sanctions-ccfs87
No single-use vapes
In forceUK-wideDo not sell, offer or keep for sale any single-use vape, with or without nicotine. Separate any left-over stock, label it unsellable, take it off the shop floor and your website, and send it for recycling.
- A vape is single-use if its battery cannot be recharged or it cannot be refilled.
- Keep evidence that the vapes you sell are reusable and that customers can buy refills and replacement coils separately.
- The fixed penalty is £200 in England, Wales and Scotland; Northern Ireland has no civil penalty and goes to court.
Sources
- “It is illegal for businesses to sell or supply single-use vapes. It is also illegal to offer to sell or supply single-use vapes, or to stock single-use vapes that you plan to sell or supply.”Single-use vapes ban: information for businesses· Defra · read 2 Oct 2026https://www.gov.uk/guidance/single-use-vapes-ban
- “The ban came into force on 1 June 2025 and applies to: sales online and in shops; all vapes whether or not they contain nicotine”Single-use vapes ban: information for businesses· Defra · read 2 Oct 2026https://www.gov.uk/guidance/single-use-vapes-ban
- “A person who supplies, offers to supply or has in their possession for supply a single-use vape is guilty of an offence.”The Environmental Protection (Single-use Vapes) (England) Regulations 2024, regulation 4· legislation.gov.uk · read 2 Oct 2026https://www.legislation.gov.uk/uksi/2024/1216/made
Product limits: nicotine strength, tank and refill size
In forceUK-wideDo not sell nicotine e-liquid above 20 mg/ml, refill containers above 10 ml, or tanks, cartridges and pods holding more than 2 ml. Products must be child-resistant and tamper-evident.
- This includes tank extenders and squonk bottles with more than 2 ml capacity, even inside a notified kit.
- The limits apply to nicotine-containing products.
Sources
- “Nicotine-containing liquid which is presented for retail sale must be in- (a) a dedicated refill container in a volume not exceeding 10 millilitres; or (b) a disposable electronic cigarette, a single use cartridge, or a tank, in a volume not exceeding 2 millilitres.”The Tobacco and Related Products Regulations 2016, regulation 36· legislation.gov.uk · read 2 Oct 2026https://www.legislation.gov.uk/uksi/2016/507/regulation/36
- “restrict e-liquids to a nicotine strength of no more than 20mg/ml; require nicotine-containing products or their packaging to be child-resistant and tamper evident”E-cigarettes: regulations for consumer products· MHRA · read 2 Oct 2026https://www.gov.uk/guidance/e-cigarettes-regulations-for-consumer-products
- “Squonkers with a reservoir or tank exceeding 2ml capacity do not meet regulations and cannot be supplied in the UK.”Advice for retailers and producers· MHRA · read 2 Oct 2026https://www.gov.uk/government/publications/advice-for-retailers-and-producers
Age of sale: 18 for every vaping and nicotine product
From 29 October 2026 · in 27 daysUK-wideFrom 29 October 2026 do not sell any vaping product, with or without nicotine, or any nicotine product such as pouches, to anyone under 18, in store or online. Train staff to refuse proxy purchases.
- In England, Wales and Northern Ireland this replaces the old rule that covered nicotine vapes only.
- Scotland: you must already run a written age verification policy (ask for ID from anyone who looks under 25 at least) and keep it for inspection; it must say how staff handle refusals.
- England, Wales and Northern Ireland: the age checks that give a defence will be set by regulations; until then the defence is taking all reasonable steps. Challenge 25 and a refusals log are good practice, not a legal requirement there.
- The fixed penalty is £200 in England, Wales and Scotland, and £250 in Northern Ireland subject to Assembly approval.
Sources
- “From 29 October 2026, it will be an offence for retailers, including online retailers, to sell any vaping product or nicotine product to anyone under the age of 18.”Selling vaping and nicotine products· Department of Health and Social Care · read 2 Oct 2026https://www.gov.uk/guidance/selling-vaping-and-nicotine-products
- “It is an offence to sell a vaping product or nicotine product to a person who is under the age of 18.”Tobacco and Vapes Act 2026, section 10· legislation.gov.uk · read 2 Oct 2026https://www.legislation.gov.uk/ukpga/2026/18/section/10
- “It is currently an offence for a person to carry on a tobacco or vaping product business without operating an age verification policy in respect of the premises.”Age verification policies: guidance for retailers· Scottish Government · read 2 Oct 2026https://www.gov.scot/publications/selling-tobacco-products-vaping-products-nicotine-products-cigarette-papers-herbal-smoking-products-age-verification-guidance-age-verification-policies-retailers/
No vending machine sales
From 29 October 2026 · in 27 daysUK-wideFrom 29 October 2026 do not have a vending machine that sells or dispenses vaping or nicotine products to customers on premises you manage or control.
- A machine used only by staff as secure storage is allowed.
- Scotland already bans vape vending machines; the UK already bans tobacco ones.
Sources
- “This means that a vending machine can be used as secure storage, as long as it is not used to sell or dispense products to customers.”Tobacco and vaping product vending machine ban· Department of Health and Social Care · read 2 Oct 2026https://www.gov.uk/guidance/tobacco-and-vaping-product-vending-machine-ban
- “A person commits an offence if the person has the management or control of premises on which a vape vending machine or a nicotine product vending machine is available for use.”Tobacco and Vapes Act 2026, section 12· legislation.gov.uk · read 2 Oct 2026https://www.legislation.gov.uk/ukpga/2026/18/section/12
No free samples or substantial discounts
From 29 October 2026 · in 27 daysUK-wideFrom 29 October 2026 do not give away vaping or nicotine products or coupons, and do not sell them at a substantial discount, such as 10p vapes, to promote them.
- This covers in-store, online and third-party promotions, and branded non-vape items given away to promote vaping.
- Normal discounting, clearing unsold stock at a lower price, and bulk or trade discounts are not affected.
- The fixed penalty is £200 in England, Wales and Scotland (£100 in England and Wales and £150 in Scotland if paid early), and £250 in Northern Ireland subject to Assembly approval.
Sources
- “From 29 October 2026, it will be an offence to give away any vaping or nicotine product, or coupon, to a member of the public. This offence applies if the purpose is or effect will be to promote vaping or nicotine products.”Selling vaping and nicotine products· Department of Health and Social Care · read 2 Oct 2026https://www.gov.uk/guidance/selling-vaping-and-nicotine-products
- “These restrictions do not affect normal discounting practices. Retailers can continue to sell unsold stock at a reduced price as part of normal business.”Selling vaping and nicotine products· Department of Health and Social Care · read 2 Oct 2026https://www.gov.uk/guidance/selling-vaping-and-nicotine-products
- “In England and Wales, the FPN amount for the offences in this guidance will be £200 (reduced to £100 for early payment).”Tobacco, vaping and nicotine products: fixed penalty notices· Department of Health and Social Care · read 2 Oct 2026https://www.gov.uk/guidance/tobacco-vaping-and-nicotine-products-fixed-penalty-notices
Take back waste vapes, free
In forceUK-wideAccept customers’ waste vapes and vape parts (pods, coils, batteries) free of charge in store, or set up an alternative collection point. Vape retailers cannot use the Distributor Take Back Scheme.
- Tell customers about the service in writing: a notice in store, and on your website if you sell online.
- Give customers at least 28 days to bring a waste item back.
- Keep records of what you collect and how you dispose of it, and of how you tell customers, for 4 years.
Sources
- “If you sell vapes, you must take back waste vapes in store or set up an alternative collection point.”Electrical waste: retailer and distributor responsibilities· GOV.UK · read 2 Oct 2026https://www.gov.uk/electricalwaste-producer-supplier-responsibilities/join-the-distributor-takeback-scheme
- “Vape retailers are excluded from DTS.”Regulations: Waste Electrical and Electronic Equipment (WEEE)· Office for Product Safety and Standards and Defra · read 2 Oct 2026https://www.gov.uk/guidance/regulations-waste-electrical-and-electronic-equipment
- “If you sell vapes (are a ‘distributor’), you must offer a ‘take back’ service. This means you must accept vapes and vape parts (such as used pods, coils or batteries) that customers return for recycling.”Single-use vapes ban: information for businesses· Defra · read 2 Oct 2026https://www.gov.uk/guidance/single-use-vapes-ban
Scotland: register every premises
In forceScotlandRegister every premises that sells vapes on the Register of Tobacco and Vaping Product Retailers. From 29 October 2026 premises selling nicotine products such as pouches must register too.
- Registering for vapes is already required; trading unregistered can lead to an on-the-spot fine of £200, a fine of up to £20,000, or a selling ban of up to 24 months.
- Businesses newly covered from 29 October 2026 have until 29 April 2027 to register before the registration offences apply to them.
- Under-18 staff may sell vaping or nicotine products only with written authorisation from the registered person, kept at the premises.
Sources
- “From 29 October 2026, businesses selling nicotine or herbal smoking products must also join the Retail Register.”Register of Tobacco and Vaping Product Retailers· mygov.scot · read 2 Oct 2026https://www.mygov.scot/tobacco-vapour-register
- “section 69 and schedule 9 (extension of retailer register etc) of the Act come into force on 29 October 2026”The Tobacco and Vapes Act 2026 (Commencement No. 1, Transitional and Saving Provisions) (Scotland) Regulations 2026· legislation.gov.uk · read 2 Oct 2026https://www.legislation.gov.uk/ssi/2026/210/made
Keep supplier and stock records for 6 years
In forceUK-wideHMRC says you should keep, for at least 6 years, where each product came from and the checks you made: supplier details, invoices, delivery notes and dates, what you bought and sold, when unstamped stock was produced or imported, and what you did about suspect stock.
- Keep evidence of your MHRA list checks and of the reusability checks for the vapes you sell.
- If a product looks unstamped, unclear, or as if it does not meet the rules, ask the supplier, and record the issue, their answer and what you did.
- These records are what a due diligence defence rests on.
Sources
- “You should keep records for at least 6 years showing: where your vaping products came from; the supplier name, address and contact details; invoice numbers, delivery notes and dates received”Handling wholesale or retail vaping products in the UK· HM Revenue and Customs · read 2 Oct 2026https://www.gov.uk/guidance/handling-wholesale-or-retail-vaping-products-in-the-uk
- “it is a defence that the supplier exercised all due diligence to avoid committing the offence.”The Tobacco and Related Products Regulations 2016, regulation 50· legislation.gov.uk · read 2 Oct 2026https://www.legislation.gov.uk/uksi/2016/507/regulation/50
Beyond the ten
Also check
No vape advertising online
In forceUK-wideDo not advertise electronic cigarettes on websites, apps or social media; product information that is not promotional is allowed.
- These rules stay in force until the Tobacco and Vapes Act replaces them.
Sources
- “No person may in the course of a business include, or procure the inclusion of, an electronic cigarette advertisement in an information society service provided to a recipient in the United Kingdom.”The Tobacco and Related Products Regulations 2016, regulation 43· legislation.gov.uk · read 2 Oct 2026https://www.legislation.gov.uk/uksi/2016/507/regulation/43
Northern Ireland: the retail register is being extended to vapes
From 1 March 2027 · in 150 daysNorthern IrelandWatch for the date the Northern Ireland register opens to vape and nicotine businesses; trading unregistered can draw a fixed penalty from 1 March 2027.
- The registration start date is set by the Northern Ireland Health Minister and was not yet published when we checked.
Sources
- “In Northern Ireland, from 1 March 2027, a person may be issued with an FPN if they: run a tobacco, vape or nicotine products business when unregistered”Tobacco, vaping and nicotine products: fixed penalty notices· Department of Health and Social Care · read 2 Oct 2026https://www.gov.uk/guidance/tobacco-vaping-and-nicotine-products-fixed-penalty-notices
Check your stock file
Upload your EPOS export and see, line by line, which products are on the MHRA list, which are missing stamp fields, and which must be sold by 31 March 2027. The stock check opens soon.