Governments response to consultation paper on Tpd

[pfvapes]

OK so I've had a thought. And given the vaping communities general piss poor organisation, may not work BUT what is to stop us registering a cooperative. This would allow for one registration of a product between the co op. The biggest issue I see is that to amortise the registration cost the markup on a product would need to cover this before it gets superseded and you stock the next best thing. I would be willing to help anyone with this, but propose that if it were in some way linked to the forum we could also keep POTV alive?

The more b&m's , manufacturers and vendors we can get on board the more affordable it becomes

 

[Mawsley]

OK so I've had a thought. And given the vaping communities general piss poor organisation, may not work BUT what is to stop us registering a cooperative. This would allow for one registration of a product between the co op. The biggest issue I see is that to amortise the registration cost the markup on a product would need to cover this before it gets superseded and you stock the next best thing. I would be willing to help anyone with this, but propose that if it were in some way linked to the forum we could also keep POTV alive?

Erm. Unless you are planning on submitting joint accounts and tax returns this is an absolute fail.

 

[scrumpox]

My understanding, for what it's worth, was that each imported product has a single nominated "importer" who or which is responsible for product registration. One product, one registration. Effectively this means an importing agent who may also distribute throughout the country. That's pretty much standard practice. This point was raised in question 11 of the consultation and the policy agreed.
It makes no sense for each product to have to be registered at each point of sale, there is no precedent for that in any industry, plus the registering body would be dealing in thousands upon thousands of duplicate registrations.
No UK retailer would be responsible for product registration unless they initiate the importation with the non-EU manufacturer.

I would imagine that many products already have such "agency" agreements.

Remember the TPD objective around track and trace?

This will stop the geezer buying 20 items from FastTech and flogging them in his online store. It means stores have to buy from the registering agent ... paperwork trail from manufacturer to consumer ... isn't it?

 

[pfvapes]

I'm unsure as yet but it may even simply be integrated into the CE marking compliance as with the machinery directive, I was talking more of the non mainstream products, the ones that would otherwise be prohibitive,

Clarity when typing on my phone is not one of my strong points for sure!

 

[Rickster]

 

[lorraineh46]

That sounds real sensible and makes me smile. Just have to work out now how to all the eliquids will be tested ,,,,,

 

[scrumpox]

I'm unsure as yet but it may even simply be integrated into the CE marking compliance as with the machinery directive, I was talking more of the non mainstream products, the ones that would otherwise be prohibitive,

Clarity when typing on my phone is not one of my strong points for sure!

What do you mean by non-mainstream products?

The document makes it clear that either the manufacturer or the importing agent is responsible for registration of e-cigarette products. Peripherals like drip tips and batteries are exempted. What are non-mainstream products?

 

[lorraineh46]

Oops. Should say how all the eliquids can be tested and at what cost !!!!!

 

[pfvapes]

I mean anything made in short runs by the little guys, not the mass produced products we purchase from China. If the costs are as (relatively) low as they are being presented I would imagine the large volume players outside the EU would simply conform. Many are genuinely CE marked as consumer products already, and it wouldn't take much more to integrate the registration into that. But to continue to support the low volume made to order products it could be a reasonable work around

It would, by a long shot, not be the first time I have uttered total bollocks,

but for the last 10 years have specified, audited and purchased from China, and the majority its though a Chinese national dealing directly with a state owned business, which a lot are. These guys are hugely proactive when it comes to paperwork for various legislation

 

[cheersm8]

The most important thing about the TPD, for vapers is what is not mentioned, included, or defined within the regulations.
Voltage, Watts, Amps and Ohms being delightfully conspicuous by their absence. Along with these four little gems there is also NO definition of "dose" or "level", and both of these are described in plural terms ie "dosages" and "levels" which can only mean that they are variable and that consistency can only apply product by product and not conclusive to every product.
It's easy to over think the TPD.