Bottle Rental

[Badboybez]

So, you are selling juice and charging your mates for it and want to know if it's ok to charge them a fee of about 50p to rent the bottle?

As long as you are selling eliquid, regardless of the way you are trying to circumvent the regs then you are going against the laws of the UK/EU.

Unless it is zero mg nic you are selling your eliquids as.

If you are selling the juice as containing nic then technically you are the same as any other vendor and therefore subject to the rules and regs of the land ie test the juice, nothing bigger than 10ml if it has nic in it.

As one of the other members have said, why draw attention to yourself? Everyone knew there would be a 'black market' when the TPD etc came in.

I am sure you will not be the only one doing it, but some people just cannot keep it quiet

Oh and a seperate business would need to be registered as such as it cannot be connected to your current one as two vastly different trades.

Why give yourself such a headache?

Hi Miss Pepper,

The TPD / TRPR regs have always had some "grey" areas in them.
I am not an expert, but my understanding was that private / personal sales were not included, only if selling as a business ???

Regards badboybez

 

[Mr Toff]

Ok please forgive me.
You're a genius for finding this legal loophole. You will be applauded throughout history as a hero... nay a saint.
Like the vape version of Robin Hood.
Good job!

cock

 

[RaymondoBeyondo]

cock

Eloquently put sir. The best statement you have posted so far.

 

[Clifford_vapes]

This is stupid @Mr Toff.... just continue as your are, say nothing to nobody and you'll be fine.... there isn't enough law enforcement to bring drug dealers etc to justice so I highly doubt any of them give a rats turd about you selling a few bottles of e liquid here and there.

 

[crustyfolker]

I think you missed out the money for each product to be tested, these tests are to prove the goods are upto EU standard, you can't just make a liquid and sell it (as a vendor) with just notification and the annual fee, at a guess the testing gets or must be done after registering it and there is probably a set amount of waiting time before you get all this done and are given TPD compliance for each variant. So it costs a lot more than you think

 

[Badboybez]

OK, a little history.
I only ever started making juice for myself.
One of my workmates caught a whiff of my vape.
He liked the smell, asked for a taste, liked it.
Asked me to sell him some.
Someone else in work saw me passing him a bottle.
Asked me if I'd make him some too.
Couple of weeks later, and I'm supplying 7 people.
All I'm looking for is a workaround in case the law comes looking for me.
The guys I'm supplying to are not stupid, they know that it costs £150 to register each variant of each product you are selling.
So, each recipe, at each strength would cost me £150 to register.
7 people, with 7 different tastes, that's £1050
If I'm renting a 30ml bottle for £4 , I'd have to rent 37 bottles of each flavour, and at the same nic strength just to cover my costs.

Renting a bottle for £4, that's a bit steep.
If someone in the pub wants juice I give them a 30ml bottle, later they buy me a pint, about £3..........
They can do what they want with the bottle !

 

[Badboybez]

I think you missed out the money for each product to be tested, these tests are to prove the goods are upto EU standard, you can't just make a liquid and sell it (as a vendor) with just notification and the annual fee, at a guess the testing gets or must be done after registering it and there is probably a set amount of waiting time before you get all this done and are given TPD compliance for each variant. So it costs a lot more than you think

Hi crusty,
That's what I said.
I think the full cost is about £1500.

 

[Mr Numpty]

Hi Miss Pepper,

The TPD / TRPR regs have always had some "grey" areas in them.
I am not an expert, but my understanding was that private / personal sales were not included, only if selling as a business ???

Regards badboybez

That was/is my understanding also. That if you make juice and sell it to friends, it is not covered by the TRPR. No?

 

[Tubbyengineer]

I appreciate the advice, but would really like to hear from someone with a legal background.
Yes, I'm renting a bottle to a friend.
I'm not convinced a judge would be worried about the contents, while my mixes would be unregistered, I'm not sure they would be illegal.

Actually the Judge would be very worried about it - It shows intent to defraud. You were fine until you opened a giant can of worms by posting all this stuff in a public forum. Keep schtum, buy the nic and if anyone asks it's all personal use. Charging "rental" is just going to make things worse...

 

[Tubbyengineer]

This is from the government paper on the new nicotine laws.
£150 to register each product
£80 if you modify your recipe
£60 annual Fee (I'd forgotten about that fucker, so I'd have definitely run at a loss )

Fees
The fees for submitting a notification are a set out in The Electronic Cigarettes etc. (Fees) Regulations 2016. MHRA consulted on the level of these fees in January 2016 and the Government Response to the consultation can be found here.

The current costs of notifications are as follows:

Notification fee: £150

Annual Fee: £60 (payable from April 2018)

Substantial Modification Fee £80 (payable from April 2018)

MHRA has given a commitment to review the level of fees in the light of the number of notifications received in the first year.

Invoices

You forgot the huge fees for testing the juices so they can be submitted - we've been round this topic before on here and know what we're talking about...