As part of the UK’s exit from the EU, TPD data is shifting to a new MHRA system which could see your notifications withdrawn if you don’t take immediate action.
Under the Tobacco Products Directive (TPD), manufacturers and importers of tobacco products, electronic cigarettes, vaping devices and refill containers must submit information to the authorities in the EU member states in which their products are sold. When the Brexit transition period ends on 31 December 2020, the Medicines and Healthcare products Regulatory Agency (MHRA) will move all TPD notifications from the EU Common Entry Gate (EU-CEG) portal to their own new system.
Unlike EU-CEG, the MHRA system has the ability to check for incomplete and incorrectly compiled submissions. We understand the majority of notifications made in 2016—and in many cases more recently—were missing a crucial element that is required to validate submissions in the new system.
We are pleased to say we have already validated legacy submissions for ADACT customers in the new MHRA system.
If you used a different agency or did your own notifications, you should check the validity of your notifications before 31 December 2020 to avoid them being withdrawn by checking the following:
- Toxicological monographs (studies) on each CAS flavour number
- Ensure your declarations of conformity are signed
- Ensure you have declared all your CAS data above 0.1%
- Correct production files with current procedures
- Opening/Refill files match your product
- Emissions testing certificates
- Consistent nicotine dosing files
- Correct product weights
- Ensure your ingredients are in mg/product unit (not percentages)