Unravelling the TPD, A vapers attempt to understand article 20.

[knome]

One consolation with the impending TPD (only a very small consolation, and of no benefit to us vapers other than a snigger) Is the headaches that the legislators in Brussels will suffer when it comes to "medical product or TPD?" the b'stards won't know where to turn.

You're joking. Think of the opportunities for Memo creation and Box tickability.

 

[Tubbyengineer]

OK So I've just sent the following E-mail to the GLD (Government Legal Department)

Dear Sir / Madam,

I am seeking clarification on certain sections of the Tobacco and Related Products Regulations 2016, I’m unsure if you are the correct department to address the enquiry to, if you are not please could you furnish me with the details of the appropriate person or department to contact.

My enquiry is as follows:

In part 6 Section 36 it states…

36.— (1) No person may produce or supply an electronic cigarette or a refill container which contains a
nicotine-containing liquid unless it complies with paragraphs (2) to (11).
(2) The nicotine-containing liquid must be in—
(a) a dedicated refill container not exceeding a volume of 10 millilitres;
(b) a disposable electronic cigarette; or
(c) a single use cartridge where the cartridge or tank does not exceed a volume of 2 millilitres.


Section 2c contains a reference to “a single use cartridge where the cartridge or tank does not exceed a volume of 2 millilitres.”, Could you please clarify if this applies only to tanks that come prefilled with liquid or does it apply to all types of atomisers including the type known as “Rebuildable Tank Atomisers” which contain a reservoir for liquid often referred to as a tank but which is a permanent and non removeable part and is supplied without liquid.

Now to wait and see what reply I get (If any)...

 

[Tubbyengineer]

OK So I've just sent the following E-mail to the GLD (Government Legal Department)

Dear Sir / Madam,

I am seeking clarification on certain sections of the Tobacco and Related Products Regulations 2016, I’m unsure if you are the correct department to address the enquiry to, if you are not please could you furnish me with the details of the appropriate person or department to contact.

My enquiry is as follows:

In part 6 Section 36 it states…

36.— (1) No person may produce or supply an electronic cigarette or a refill container which contains a
nicotine-containing liquid unless it complies with paragraphs (2) to (11).
(2) The nicotine-containing liquid must be in—
(a) a dedicated refill container not exceeding a volume of 10 millilitres;
(b) a disposable electronic cigarette; or
(c) a single use cartridge where the cartridge or tank does not exceed a volume of 2 millilitres.


Section 2c contains a reference to “a single use cartridge where the cartridge or tank does not exceed a volume of 2 millilitres.”, Could you please clarify if this applies only to tanks that come prefilled with liquid or does it apply to all types of atomisers including the type known as “Rebuildable Tank Atomisers” which contain a reservoir for liquid often referred to as a tank but which is a permanent and non removeable part and is supplied without liquid.

Now to wait and see what reply I get (If any)...

Well that was pants...

 

[Tubbyengineer]

Anyone know a friendly legal eagle who doesn't want to give me a walletectomy for reading 2 paragraphs and uttering a few words?...

 

[MrTeaTime]

Do vapers in power have this covered? Thought they would (should) be all over this?

 

[Mark]

I totally get that the Legal Department don't offer 'legal advice' to individuals.

It's a thin line between clarifying or explaining the law and advising on the meaning of the law in particular circumstances to individuals. Last thing they want is to say yay or nay and us quoting their 'advice' in future litigation.

Their ought to be a department who ought to be able to assist though.

 

[srs]

...a reservoir for liquid often referred to as a tank but which is a permanent and non removeable part and is supplied without liquid...

Bzzt! Definition alert. Tanks are removable

 

[Tubbyengineer]

Do vapers in power have this covered? Thought they would (should) be all over this?

Hmm possibly - @Diche? anyone you know know anything about this?

 

[MrTeaTime]

I'm not knocking VIP, But if there to be taken seriously them they need to have this sort of stuff covered. I WANT to support everything that they do, and send more money to them BUT I want them to OWN this and ANY other issue related to the TPD.....

 

[Diche]

Here is a bit more reading material for you.

1) Main draft law: https://www.gov.uk/government/uploa..._data/file/440989/SI_tobacco_products_acc.pdf
2) Advertising bit: https://www.gov.uk/government/publications/proposals-for-uk-law-on-the-advertising-of-e-cigarettes
3) Notification bit: http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1448620667626&uri=CELEX:32015D2183
4) Leak-free refilling bit: https://www.dropbox.com/s/p6ui4k2tv... standards for refill mechanism (1).docx?dl=0

SPOILER ALERT - the last one is actually reasonable! "

UPDATE 9.1.16:

MHRA consultation (the one that saves mods): https://www.dropbox.com/s/vjcg8wemm...e-cigarettes_-_consultation_document.pdf?dl=0
Dept of Health Response to consultation: https://www.gov.uk/government/uploa...nt_data/file/489981/TPD_Cons_Gov_Response.pdf