EU rules for prefilled pods, before TPD3 moves them.
The EU framework is under revision. This page sets out the limits that govern a pod today, the notification reality across 27 member states, and how to design a range that does not need retooling when the ceilings move.
The governing framework
TPD Article 20, state by state
Directive 2014/40/EU sets one envelope for the whole Union, but access to it is granted 27 times over. The product is designed once; the paperwork is filed per country.
A range built for 2027 should assume the ceiling can move. Keep the pod geometry modular so a change in capacity or permitted format re-specifies the pod without invalidating the host device.
- Governing law
- Directive 2014/40/EU (TPD), Article 20
- Applies to
- 27 EU member states
- Nicotine ceiling
- 20 mg/ml
- Pod / tank ceiling
- 2 ml
- Refill container
- 10 ml maximum, with limits on nozzle size
- Notification
- Per member state via EU-CEG, six months before sale
The UK inherited the same 2 ml / 20 mg/ml envelope, so one compliant configuration travels from Berlin to Birmingham unchanged — only the filings differ.
Hard limits
What TPD fixes today, and what it does not
The directive fixes the product envelope EU-wide. Everything around single-use products and flavours is left to the member states, which is where the divergence lives.
| Item | EU position | Effect on your project |
|---|---|---|
| Nicotine strength | Maximum 20 mg/ml | Ceiling for every pod SKU sold in the EU |
| Pod / tank capacity | Maximum 2 ml | Same chamber limit as the UK; shared tooling |
| Refill container | Maximum 10 ml | Applies if you also ship bottled liquid |
| EU-CEG notification | Per member state, 6 months before sale | Multi-state filing; fees differ by state |
| Single-use vapes | No EU-wide ban; member states decide | Belgium removed them in 2025; others in progress |
| Flavours | No EU-wide ban; some states restrict | Verify the destination state before naming ranges |
| TPD3 | Proposal expected around Q4 2026 | Design hardware modular to today's ceilings |
Swipe the table sideways to see every column →
The notification workload is the part buyers underweight. Six months of lead time per state, filed six months before the product ships, means the regulatory calendar starts before the tooling order does.
Timeline
How the EU got here
2014
TPD2 adopted
Directive 2014/40/EU fixes the Article 20 envelope: 20 mg/ml, 2 ml tanks, 10 ml refills, prescribed warnings.
20 MAY 2016
Rules apply EU-wide
Member states transpose the directive. EU-CEG becomes the single notification channel, filed per country.
2025
Member-state single-use bans
Belgium removes single-use vapes from sale; other states move on their own timetables. No EU-wide ban exists.
Q4 2026 (expected)
TPD3 proposal
Ceilings, flavours and environmental rules all on the table. Treat every current position as provisional until the text lands.
Buyer checklist
Five things to settle before you quote an EU launch
- 01 · Confirm the format
- Rechargeable host, swappable prefilled pod
- 02 · Design to 2 ml / 20 mg/ml
- The envelope the UK shares, so one build serves both
- 03 · Map the filings
- One EU-CEG notification per destination state, fees differ
- 04 · Track TPD3
- Avoid hardware commitments that assume today's ceilings
- 05 · Name the responsible person
- Notification sits with the brand holder in each state
The AISILE platform is built to the 2 ml / 20 mg/ml envelope by default, and the pod geometry stays modular so a TPD3 re-specification does not retool the device.
Questions
EU questions buyers ask first
No. Under TPD Article 20 every member state runs its own notification, filed through the EU-CEG system at least six months before the product is placed on that market. One EU launch is a multi-state filing exercise, and fees differ by state.
20 mg/ml maximum nicotine strength, a 2 ml maximum tank or pod capacity, and 10 ml maximum for refill containers, with prescribed health warnings on packaging. These are the same ceilings the UK applies, so a single 2 ml / 20 mg/ml configuration serves both.
There is no EU-wide ban. Single-use restrictions are decided member state by member state — Belgium removed them from sale in 2025 and others are moving — so check the destination country. A rechargeable host with swappable prefilled pods stays outside every single-use definition proposed so far.
TPD3 is the pending revision of the Tobacco Products Directive, with a proposal expected around Q4 2026. Ceilings, flavours and environmental rules are all on the table, so treat today's positions as provisional and keep pod hardware modular enough to re-specify.
No. It is a summary of published rules intended to help a buyer frame a project. Confirm the current position with your own regulatory consultant before you rely on it.
Next step
Designing for the EU? Send the brief and the destination states.
The factory configures to the 2 ml / 20 mg/ml envelope by default and will say plainly when a requirement sits outside it.
EU enquiries
Selling prefilled pods into the EU?
Send your destination states and volume band and we confirm the TPD-ready configuration, the manufacturer-side documentation each notification needs, and the lead time on a trial run.
- moyucong@yunmiaonet.cn
- +86 15561912527
- Sampling
- 7–15 days
- Production
- 15–30 days
- MOQ
- Set per SKU — tell us your target volume