Approval is OnlyTemporary.
The deadline forTPD compliance was set to a particular day and a particular month back in 2016,since then most of the regulators in each of the European countries have takena light touch approach to overseeing the market.
In recent monthswe have started to see an increase in regulator activity, one of those areaswhich has effected several manufacturers is the use of extension/bubble tubeswhich have been supplied alongside the 2ml tube, and removable plugs which havebeen used to restrict a tanks volume to 2ml. Any refill containers suppliedwith a squonker must comply with the associated regulations. And only a small partof EU member states currently prohibit the sale of more than 2ml non-prefilled tank.
Such products havealready been reported for sale in European markets where the tank size for bothprefilled and empty tanks is restricted to 2ml. The United Kingdom is one suchmarket and how such actions could become a problem in that country is asfollows:
The regulator isthe MHRA, they are centrally based, they handle the notification invoicing andhave the final say on what products can and cannot be sold. A second muchlarger organisation referred to as ‘trading standards’ works with the MHRA andto enforce the law, trading standards has a regional presence so they oftenvisit local stores and businesses to ensure the products being sold comply andare approved for sale. Any products that are found not to match the details inthe notification are reported to the MHRA and the MHRA contacts themanufacturer, other products that are not notified are being removed to preventthem from being sold.
英国的监管机构是MHRA，他们是集中处理通告和发票，并对产品是否可以在英国销售有最终决定权。第二个更大的组织称为“Trading Standards”，与MHRA合作并负责执法，Trading Standards配备有区域执法人员，因此他们会经常访问当地商店和企业，以确保销售的产品符合相关法律法规要求并被批准销售。任何发现与通告中的详细信息不符的电子烟相关产品都会报告给MHRA，这时MHRA会联系制造商以寻求制造商的解释，其他未通告的产品将被从商店中移除以防止它们被出售。
Every country hasits own process for enforcing the law and when problems do arise the requiredsolution will differ from country to country. The solution will also differdepending on whether the manufacturer has been warned about the same, or othercompliance issues previously.
If such solutionsare not agreed with the regulator and quickly applied this could lead to asituation where products are removed from the approval list and eventuallybanned from sale. If this should occur regulators are obliged to share thatproduct information with other countries who may decide to do the same.
If anymanufacturers do experience such a problem please forward the relevantcommunications to us as soon as possible so a solution can be agreed andapplied.