Vapouround magazine Issue 06 | Page 75

TPD and having had more time here with different companies my attitude towards American Manufacturing standards have changed for the better. All those mentioned above have their finger on the pulse, the management systems and ISO 9001’s were more than adequate to justify the process required to ensure quality of ingredients and final product. I look forward in returning to California after the Moscow Vape show and I may look to work out there part time as the sunshine and people’s attitude is just. ……Nice. New York New york was next via internal flight and Bad Drip was first port of call, and there is nothing Bad about that company with Full Emissions completed, the Toxicity work is underway and Bad Drip could be one of the first US companies to notify, I will keep you posted. I had a few days to get my head around the fall out from being away from the UK for a month, with a few more local meetings and then it was a much needed weeks holiday with the wife and youngest daughter in a Welsh log cabin before getting stuck back to TPD business. Now then…. with the UK Brexit on the tip of everyone’s tongue whilst away, I have had as per usual a battery of questions about the what’s, whiff’s and butt’s ;) so below is a small section of the questions I received on this subject. Sometimes, a week can be a long time in politics. Since it was confirmed that Britain would be leaving the EU David Cameron has resigned and been replaced followed by most of the shadow cabinet. Nicola Sturgeon has raised the possibility of a second Scottish Independence referendum, and Sinn Fein has called for a vote on Irish union, I’m just glad what with all this political mayhem that I am a Jedi. In the UK’s journey to leave the EU, a voyage that could take two years or more, Instability abounds, both for the UK and any European countries that choose to follow our lead, or remain within an already fractured and exposed commission. The question everyone within the Vape Industry is asking is how does this affect our compliance and our responsibility to the TPD? Q Now that the UK has voted to leave the EU does this mean I won’t need to do my TPD compliance? Numerous people and companies have asked us this so far and the answer is a quite straightforward, NO, nothing changes with regard to the TPD. This is already law, and will be fully enforced in November. It will take a minimum of 2 years for full UK withdrawal, at which point the compliance regulations will still apply to anyone wanting to sell through to the rest of the EU, and within the UK we will have regulations of our own which are likely to be even more stringent than the existing EU TPD requirements. There was debate in the House of Commons in July that discussed TPD and the motion to address it was rejected, and quite rightly so. Quite rightly so I heard you think? YES Article 20 is the target not the whole TPD ;) The last thing the politicians would want is for cigarettes to come back into fashion, especially after their last 15 years effort via the EU Directives to achieve this. The UK has a perfect opportunity to regulate Vaping separate from that of smoking and I will seriously have the hump if we do not achieve this. Will I still be able to sell my TPD compliant products to the UK after or during this Brexit time? If your products are genuinely TPD compliant, and notifications have been approved in some way shape or form by the MHRA, it is likely that the UK will implement a compatible system, which will allow you to fully migrate your compliance. Britain is one of the most highly regulated countries in the world with regard to consumer health and health and safety, so whilst we should, in time, be able to rid ourselves of the more ridiculous and ill-fitting aspects of the TPD, it is likely the basic scientific framework will be the same and your TPD data will be fully transferable to any new system the UK decides to migrate to. The main advantage with a UK Brexit is that when we do revisit article 20, we can pass motions to scrap the likes of parts of the advertising ban, the 2ml tank and 10ml bottle limits, the nicotine content limit (maybe) ... I say maybe as the Scots vote d to remain, and although I doubt they will be accepted by the EU we had a better justification for bumping up the nicotine concentrations in liquids as nicotine has a proven ability to maintain, stabilise and improve upon the conditions associated with mental health conditions in humans. This is a bit political but out of my realms but Scotland has the highest concentrations of the population undertaking mental health treatment and this is great for justifying to UK Government that higher nicotine level containing liquids would only serve more advantageous to those switching from conventional combustible tobacco to liquid vapour delivery of nicotine. The TPD requirement is to have a “EU natural” importer, and I’ve chosen someone in the UK… Should I choose someone else, perhaps from Germany or Italy, to be my importer? No, definitely not! We will all still be members of the EU for at least another two years, so as long as you have already registered your EU importer this is perfectly acceptable. Choose your EU importer situated within your biggest market - if this is the UK your importer would ideally be based there. If you choose an importer somewhere else within the EU: for example let’s assume you went for your second biggest market and that was France... If France decides to follow the UK’s example and leave the EU, you will be in exactly the same position. So my advice is to ensure your named importer is in the country VAPOUROUND MAGAZINE ISSUE 06 75