I don't agree with quite a bit of what ECITA say here.
It really does all come down to the interpretation of the directive by UK (and other member states) lawmakers.
using a 'reasonable' interpretation of the directive I see it like this.
Rebuildables - not banned. tamperproof might well be taken to refer to device once it is built. It doesn't follow that because you can take it apart and rebuild it that that is 'tampering'. While it's certainly possible that harder line regulators could take the view that ECITA does here, it might not. Child resistant caps on things like medicines and e-liquid bottles can already be easily opened by children so there is precedent for a more reasonable interpretation of directives.
Refillables - not banned. It might only require a new design of dispenser bottle to enable refilling up to a standard that meets the new regulations. Regulators might take the view that as the devices are sold to adults only and any adult ought to be capable of inserting a dispensing cap into the right hole and squeezing e-liquid out through a one way valve in the bottle for example, would be good enough.
VV/VW: - not banned. Lots of devices on the market use identical electronics, and it would certainly be in the larger manufacturers interests (Innokin Vision etc) to get their products tested. So a genuine xxx mod might be able to be purchased that already meets the requirements and comes with the required certification to meet these (arbitrary and somewhat useless) standards. I don't see that each individual reseller would need to get the testing done. If say Innokin got their mods certified then they could sell to the whole of the EU market, and right now they are shifting a LOT of volume to EU customers. Any company that did that would be at a large advantage over their competitors that were denied access to the legitimate EU market.
As the law is now if you import items from outside the EU then legally you are the manufacturer (and would bear the responsibility for any testing required) but we could see manufacturers open EU based distribution centres to gain access to and supply EU certified devices to EU countries.
It would certainly push up prices and there'd be a time lag where products would be banned until such testing was completed.
I don't think in general that going through the directive and highlighting each point, taking a worst, or almost worst case view on each thing is ideal. I do agree that what ECITA outline in this blog could well happen and all of us, vendors, vapers, and friends and family of vapers need to raise holy hell and lobby our own MPs to make sure that UK regulations based on this god awful, soon to be thrown out, shoddy, piece of shit EU diective are as favourable towards vaping as they can be.
Until the regulations are proposed we don't know what will be banned or not, and we need to pressure UK lawmakers as much as we can to ensure that the laws that do get written are the best that they can be.
