A GOOD COMPLIANCE COMPANY WILL
HIGHLIGHT ANY RED FLAGS AND STEER YOU IN THE
RIGHT RE-FORMULATION DIRECTION AND NOT BY
OFFERING A PRODUCT THEY EITHER MANUFACTURE
OR SUPPLY AS AN EASY FIX REPLACEMENT.
that represents your biggest market. The important thing is
that you’ve named your importer, and that they are a current
EU natural. Contact us as we can discuss the advantages of a
temporary import licence that provides a short-term fix.
How do I know I’ve chosen the right compliance company
to represent me?
Well that’s probably the best question I’ve been asked so far
and the most common! As the regulations will not be enforced
until November it’s an unpleasant and uncertain wait to find out
whether your compliance company has been successful.
There are however a number of questions you should ask
yourself with regard to your chosen representative that would
immediately highlight a bad compliance company…
Firstly, has your chosen compliance company issued you with
your submitter ID? This is an essential first step in the process of
gaining compliance.
Secondly, is your chosen company testing for emissions on the
vapour phase? Whilst this tends to be the most expensive part
of the process, it is the testing methods that generate the results
of these types of test, what really matters to the MHRA is the
methodology, this is essential.
At Vape Compliance we only ever use a UK based laboratory
that is both MHRA accredited and FDA approved, this adds
the highest credibility to your scientific results and reporting.
They have worked closely with the MHRA to devise a suitable
methodology moving forward into the years ahead.
Is it too late to instruct a compliance company now?
No, it’s not too late; although this is something I would now
agree should be a top priority for anyone wanting to continue
selling e-liquids or devices into the EU after November. If you
are a small retailer and you only sell other companies’ products
you still have a liability to ensure those companies products are
compliant and that you are even registered as a retailer … in this
instance a good compliance company can provide Shop Audit
Programmes with prices starting at approximately £2000.
If, however, you are a large e-liquid or device manufacturer you
really need to get a move on as the necessary emissions tests
are time consuming and you really need to have the laboratory
tests organised as quickly as possible, and the toxicological data
in hand.
Manufacturers need to lean on their flavour suppliers as we are
legally bound to provide ingredient information, this is being held
back in the main due to intellectual property, is this an excuse or
isn’t the NDA you signed good enough?
Are there any Compliance Companies to avoid?
Well it would be totally inappropriate for me to name any names
76 ISSUE 06 VAPOUROUND MAGAZINE
and shame any games at this point, and trust me there is a
few companies and associations bang at giving uneducated
expensive misinformation, but again, there are a number of
pointers to look out for… Is your Compliance Company also
a manufacturer or retailer or have any affiliation with such
companies? Do they supply ingredients into the industry and
bind you to supply for notification and testing ownership? This is
what is called a direct conflict of interest and will not sit well with
the MHRA if the corners are cut off from the likes of the scientific
testing and research presented.
Has your Compliance Company “guaranteed” you that your
products will “pass the TPD”? If so, what a load of nonsense!
Unless they have reformulated your products with a view
to future supply, and that again as mentioned above is not
ideal. There are no guarantees that your products are fit for