TPD notification, demystified for buyers.
One product, 27 filings. This page walks the EU-CEG process end to end — who registers, what data goes in, the six-month clock that starts before tooling, and where the factory's responsibility ends and yours begins.
The mechanism
One portal, twenty-seven doors
EU-CEG is the European Commission's single IT platform for TPD notifications — but each member state validates and charges inside it separately. One EU launch is a multi-state filing exercise on one system.
The clock nobody plans for: notifications must be filed six months before the product is placed on each market. The regulatory calendar starts before the tooling order does.
- Portal
- EU Common Entry Gate (EU-CEG), European Commission
- Legal basis
- TPD Art. 20(13); format per Implementing Decision (EU) 2015/2183
- Access
- EU Login account + Submitter ID (registration takes days)
- Submission modes
- Standalone XML Creator, or system-to-system (AS4)
- Lead time
- Six months before sale, per member state
- Responsibility
- Art. 23 chain: EU manufacturer first; importer if manufacturer is outside the EU
There is no EU-wide "one filing" shortcut. The data is uniform; the validation, fees and timelines are national.
The process
Six steps from data to market access
Who owns each step matters more than the steps themselves. The factory's portion is documentation; the filing is yours.
| Step | What happens | Who owns it |
|---|---|---|
| 1. Submitter ID | Register with EU Login; the Commission issues a Submitter ID after reviewing company documents | Brand holder |
| 2. Product data | Ingredients, emissions data, toxicology, device and pod specifications, pack design | Factory prepares manufacturer-side data |
| 3. XML creation | Build the notification file with the Commission's free XML Creator (standalone) or an AS4 pipeline (system-to-system) | Brand holder or consultant |
| 4. Upload per state | Submit through EU-CEG to each destination member state | Brand holder |
| 5. Validation and fees | Each state validates and charges separately; resubmission on changes | Brand holder |
| 6. Market placement | Six months after filing, the product may be placed on that market | — |
Swipe the table sideways to see every column →
Budget note: fees are national, so the same pod range can cost materially different amounts to file in Berlin and in Lisbon. The data is identical; the invoice is not.
Buyer checklist
Four things to settle before the EU-CEG clock starts
- 01 · Name the responsible person per state
- The Art. 23 chain decides, not preference
- 02 · Commission the manufacturer-side data early
- Ingredients, emissions and specs are the factory's deliverable
- 03 · Budget per-state fees
- Same filing, different invoices
- 04 · Back-plan from the six-month clock
- Filing date = market date minus six months, per state
Every AISILE specification sheet already carries the device and pod data a notification needs — the factory-side portion of the file is a deliverable with the order, not a follow-up project.
Questions
Notification questions buyers ask first
The notification is filed per member state by the person responsible for placing the product on that market. Under the TPD's responsibility chain, an EU-established manufacturer carries the duty first; where the manufacturer is outside the EU, the importer carries it. In practice that means the brand holder files, and the factory supplies the manufacturer-side data the filing contains.
The six-month clock is the binding constraint: notifications must reach each member state at least six months before the product is placed on that market. Registration for a Submitter ID adds days of its own, and validation plus fees differ by state. Start the calendar before the tooling order.
Product name and type, the ingredient list with emissions data, toxicological information, device and pod specifications and the pack design — the format for e-cigarettes and refill containers is fixed by Commission Implementing Decision (EU) 2015/2183. The factory prepares the ingredient, emissions and specification portions.
We produce the manufacturer-side documentation the filing depends on and we work with your regulatory consultant, but the submission itself sits with the brand holder — the same division of labour as the UK's MHRA notification.
No. It summarises the European Commission's published EU-CEG guidance to help a buyer frame a project. Confirm the current position with your own regulatory consultant before you rely on it.
Sources
Official instruments behind this page
- EU Common Entry Gate (EU-CEG) — European Commission, DG SANTE
- European Commission: EU-CEG frequently asked questions
- Commission Implementing Decision (EU) 2015/2183 — notification format for electronic cigarettes and refill containers
- Directive 2014/40/EU (TPD), Articles 5(5), 20 and 23
Every regulatory claim on this page traces to one of these published instruments. Rules change; the citations stay checkable. This page is guidance, not legal advice.
Related guides
Continue from here
Next step
Filing in several member states? Start the data early.
Send your destination states and the factory returns the manufacturer-side documentation pack a notification needs, with the sampling timetable attached.
Documentation enquiries
Preparing a TPD notification?
Tell us the destination states and your volume band. The factory returns the manufacturer-side documentation the EU-CEG filing needs: ingredients, emissions data, device and pod specifications and pack artwork.
- moyucong@yunmiaonet.cn
- +86 15561912527
- Sampling
- 7–15 days
- Production
- 15–30 days
- MOQ
- Set per SKU — tell us your target volume