UK Vaping Products Duty: What E-Liquid Makers Must Do Now

The UK now taxes e-liquid by volume. Since October 1, 2026, Vaping Products Duty has been charged at £2.20 per 10ml on vaping liquid made in or imported into the UK, and it is paid by manufacturers, importers and warehousekeepers that HMRC has approved. HMRC says VAT continues to be paid on vaping products, and the duty arrives alongside a new duty stamp scheme that will, by April 2027, require a stamp on every vaping product sold in the UK.

This is a manufacturer-level tax, not a retail one, so the decisions it forces fall on whoever makes or imports the liquid. This post covers what the law defines as a vaping product, who needs approval, how an overseas manufacturer gets product into the UK, and the dates that matter. It also covers the part HMRC has not spelled out: when, and from whom, duty is due on a nicotine base sold to another manufacturer rather than to a consumer. Every source cited here was checked on October 1, 2026.

What Took Effect on October 1, 2026

The charge comes from Part 4 of the Finance Act 2026, which received Royal Assent on March 18, 2026. Section 115 states that the duty "is charged at a rate of £2.20 per 10 millilitres, rounded down to the nearest penny," on vaping products produced in or imported into the UK. The operational detail sits in The Vaping Products (Production, Duty Stamps and Commencement) Regulations 2026, S.I. 2026/331.

HMRC's payment guidance puts the rate at 22 pence per millilitre and gives two worked examples of its own: £0.44 on a 2ml pod and £2.20 on a 10ml refill bottle. The same guidance says that where the label, invoice, delivery note and measured volume disagree, HMRC will use the greatest of them. By the same 22p rule, a 100ml shortfill bottle carries £22.00 of duty; that figure is our arithmetic, not an HMRC example.

The rate does not change with nicotine strength. The government's policy paper describes it as "a flat rate of £2.20 per 10 millilitres of vaping liquid, regardless of how much nicotine is contained in the product," and HMRC confirms the duty applies to liquid "whether they contain nicotine or not."

What Counts as a Vaping Product, Including Nicotine Bases

The legal definition is broader than "e-liquid in a bottle." Under section 116 of the Finance Act 2026, a vaping product is a liquid that either "contains nicotine and either or both of glycerine and a glycol" or "is intended to be vaporised by a vape," and is not a medicinal product or a tobacco product. The same section says a liquid can be intended for vaping "even if a consumer would be required to mix it with another substance" first.

HMRC's manual applies that to the products consumers mix themselves. It lists nic shots, "concentrated bottles of nicotine that are added to vaping product liquid to increase its strength," among the liquids the duty is levied on, alongside refills, pods, shortfills and longfills. Licensed medicines fall outside the definition, since section 116 excludes any liquid that is a medicinal product, so nicotine replacement therapy is not caught.

Bases and carriers are inside the regime, not outside it. HMRC's manual on scope of chargeability says "all substances intended for use in vaping," whether "pre-mixed or home-manufactured from components such as propylene glycol (PG), vegetable glycerine (VG), and flavourings," are within scope, and its wholesale and retail guidance says the same of "substances intended for vaping such as propylene glycol, vegetable glycerin and flavourings." A nicotine dilution in PG or VG also meets the first limb of the statutory definition word for word, and that limb has no retail packaging or strength threshold.

What HMRC has not spelled out is the mechanics for a base sold business to business. Its guidance does not walk through when duty falls due, and who accounts for it, on a PG or VG nicotine base supplied to an approved UK manufacturer that will dilute it further, and we found nothing on pure nicotine or a nicotine salt supplied with no carrier at all. Production is defined widely: section 117 treats mixing a non-duty-paid substance into something that ends up a vaping product as producing one, and HMRC's manual allows vaping products to move under duty suspension between approved manufacturers' premises.

So a UK-bound PG or VG nicotine base should be planned as a dutiable vaping product, and the open point is its route: whether it moves under duty suspension to an approved manufacturer or is duty-paid on import. Agree that with HMRC before the first shipment. HMRC's policy paper lists a contact address for the duty, and a written answer is worth more than any supplier's interpretation, ours included. Our page on nicotine dilutions in VG and PG describes the bases this question applies to.

Who Needs HMRC Approval

Approval is required to manufacture vaping products in the UK, to store them under duty suspension, or to buy and affix duty stamps, according to HMRC's approval guidance. HMRC opened applications on April 1, 2026, and its approval guidance says to apply at least 45 working days before the activity starts.

A UK manufacturer needs a physical base. S.I. 2026/331 allows approval only where the applicant "has a fixed place of business in the United Kingdom," and HMRC's manual describes a single manufacturer approval that covers both the factory and the store. Mixing counts as manufacturing even inside a warehouse: HMRC's manual says that combining PG and VG in an excise warehouse "is classed as manufacturing," so the warehouse would need manufacturer approval too.

Operating without approval is not a paperwork lapse. HMRC's approval guidance states that producing vaping products without approval is an offence and that HMRC "can also confiscate any vaping products, packaging, equipment or substances used in the production of vaping products." Businesses that only sell duty-paid stock wholesale or retail do not need approval.

Two Routes Into the UK for an Overseas Manufacturer

Manufacturer approval requires a fixed place of business in the UK under S.I. 2026/331, which an overseas maker without a UK establishment does not have, and HMRC's guidance says overseas manufacturers "do not need to apply for approval," and that their UK duty stamps representatives must. That leaves two routes, both described in HMRC's own material.

1. Stamp at origin through a UK representative. The representative is approved, buys the stamps on your behalf, and the importer pays the duty on the customs declaration when the goods are released (HMRC import guidance). HMRC's manual says a representative must have premises HMRC can inspect, and that a "brass plate" presence should not be approved.
2. Ship into duty suspension. Goods can enter an approved customs or excise warehouse, be stamped there by an approved warehousekeeper, and pay duty when they leave suspension. Retail-packed imports can generally move in suspension only once, from the place of import to an approved premises. This is also where a manufacturer without a representative ends up: HMRC's preparation briefing says the importer then "will have to make sure they've got another way to put the vaping duty stamps on your products in the UK, before they leave customs control or duty suspension."

The representative route carries real liability. HMRC's briefing says the representative will be "legally and financially responsible for the stamps" and will normally have to provide a financial guarantee. Choosing a representative is therefore a commercial negotiation as much as a compliance step.

The Duty Stamp Dates Through April 2027

Every product made in or imported into the UK from October 1, 2026 needs a duty stamp on its retail packaging (HMRC), and HMRC's stamp guidance says it must be fixed to the outermost retail packaging so the pack cannot be opened without damaging it. The stamps are bought from HMRC's appointed supplier for a fee of £14.47 per 1,000, set in HMRC's Force of Law Notice and separate from the duty itself. When a stamp is applied, the guidance requires the volume, brand, flavour, product type and nicotine content in mg/ml to be recorded against it.

The transition runs on four dates:

• November 30, 2026: last day to buy transitional stamps (HMRC, September 1, 2026)
• December 31, 2026: last day to affix transitional stamps (HMRC, October 1, 2026)
• January 1, 2027: digital stamps become mandatory for new products made in or imported into the UK (HMRC, October 1, 2026)
• April 1, 2027: every vaping product sold in the UK must carry a valid stamp, ending the grace period for unstamped stock made or imported before October 1, 2026 (HMRC wholesale and retail guidance)

One detail catches early movers. Stock made or imported before October 1, 2026 carries no duty liability, according to HMRC's manual, but section 141 of the Finance Act 2026 charges duty on pre-October products that were stamped, as if they had been produced or imported on October 1, 2026.

What a Flat Per-Millilitre Rate Changes for Pricing

Because the duty ignores nicotine strength and price, it is a larger share of the selling price on a cheaper product than on a premium one. A 10ml bottle at 3mg/ml and one at 20mg/ml pay the same £2.20 under the statutory rate. HMRC's payment guidance also taxes the largest of the stated or measured volumes, so fill tolerance has a direct cost now in a way it did not before.

Whether the duty is passed on is, in HMRC's words, "a commercial decision." What a manufacturer can control is the cost base underneath it: the nicotine concentration it buys, how many dilution steps happen before filling, and whether those steps happen inside or outside an approved premises. Liquid exported from duty suspension pays no UK duty, according to HMRC's import and export guidance, which matters to a UK filler serving other markets.

For a buyer, the practical next step is to settle the route before the next order rather than after it reaches a UK border. If you are reviewing a PG or VG nicotine base for UK production, our guide to choosing between VG and PG carriers covers the formulation side, and you can request a quote or documentation for the concentration you plan to use.

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