From 1 October 2026 all vaping products, whether or not containing nicotine, are subject to a UK excise duty of £2.20per ml.
Vaping products placed on the UK market after 30 September 2026 must have a tax stamp. For products imported or produced before 1 October “transitional stamps” can be used to run down stock until 31 March 2027.
The tax regime is supported by a system of tax stamps. There are specific legal obligations on producers, importers and sellers of vaping products containing eliquids.
Definition
A vaping product is defined for the UK (FA26 s116) as being a liquid that either:
contains nicotine and either glycerine or glycol (or both), OR
is intended to be vaporised by a vape
In principle therefore use of other transport liquids such as propanediol in vaping products will still be caught by the second limb.
Duty Stamps
The process for obtaining stamps involves application to HMRC for permission to produce and/or store vaping products of liquids, followed by contract with the designated 3rd Party supplier of stamps.
Non-UK manufacturers can participate in the scheme if they wish to apply stamps to products in their own country to be sold in the UK but they must appoint a UK representative.
UK representatives must apply to HMRC for approval under the scheme. A representative is legally responsible for the stamps and may have to provide a financial guarantee. Representatives will be subject to audit and control by HMRC at a level commensurate with the risk.
Use and control of stamps. Stamps are requested by the user (or their representative). Stamps must be used within 12 months.
Holders must maintain controls over their duty stamps, including:
secure storage and access controls
routine reconciliations of stamps ordered, received, used, returned and destroyed
incident processes for loss, theft, damage, or discrepancies
arrangements for returns or adjustments for unused stamps where permitted.
Transitional stamps regime. After 30 September anyone entering the market is unlikely to be able to use the transitional scheme.
Digital Stamps
Transitional stamps do not include digital features, but regular stamps do have these features.
For digital stamps affixing operators must activate stamps at the point of affixing and capture prescribed metadata.
Scanning is required at defined points, including:
affixing
movements under duty suspension where permitted
release for consumption.
Certain metadata must be captured. This typically includes:
time, date and address of affixing
operator identity
manufacturer, and product descriptors (including volume in millilitre to the nearest 0.1 millilitre)
movement state
Digital stamps must be activated within 12 months of receiving them.
Product and aggregation data
There are specific data fields that will be required when businesses add product stock keeping units (SKUs) to the system.
In addition to the Digital Activation System (DAS) module, the Data Repository also provides affixing operators with an Application Programming Interface (API) that is compliant with the GS1 Electronic Product Code Information Services (EPCIS) standard. The API is supplied by a 3rd party, not HMRC.
The API defines an Aggregation Event, which allows affixing operators to report the parent-child relationship between the unique ID of duty stamps with the aggregate codes affixed to higher-level container elements such as cartons, master cases and pallets.
Payment
VPD is payable when the products reach an excise duty point. For importers this will be when the products arrive in the UK, unless they are placed in duty suspense. For products manufactured in the UK, the duty is payable at the point of manufacture, unless the goods immediately enter duty suspension.
Wholesalers and retailers
Persons who only sell or distribute duty-paid vaping products wholesale or retail do not need to apply for approval for VPD or the Vaping Duty Stamps Scheme.
But after 30 September vaping products sold in the UK must be duty stamped unless they were produced or imported before 1 October. If selling unstamped stock sellers need to hold evidence that the duty status has been verified by them. After 31 March 2027, all vaping products sold in the UK must bear a duty stamp.
In principle duty stamps should make it easier for Trading Standards to verify if vape retailers are compliant. However, it is probable that some will attempt to use or pass off fake stamps.
Excise and Customs Warehousing
Vaping products subject (or potentially subject) to excise duty can be stored without duty payment in an excise or customs warehouse.
Storage control and security for warehouses will need to be properly set up.
Loss of goods in duty suspense
Vaping products lost due to theft or misaccounting will incur duty. It will be necessary to prove that the lost goods have not been placed on the UK market (for example, exported or destroyed under supervision) in order to avoid the tax charge.
uty is an offence.
