Client Alert: UK Vaping Products Duty and Duty Stamps – Key Requirements from October 2026
The UK government will introduce a new Vaping Products Duty (VPD) from 1 October 2026, alongside a mandatory Vaping Duty Stamps Scheme. These measures will significantly impact manufacturers, importers, distributors, and overseas producers supplying the UK market.
This alert summarises the key requirements and actions businesses should take now.
1. Introduction of Vaping Products Duty
From 1 October 2026, all vaping products released for sale or supply in the UK will be subject to VPD.
The duty rate will be £2.20 per 10ml of vaping liquid
Duty will apply when products are released for consumption in the UK (i.e. outside duty suspension)
2. Mandatory Duty Stamps
From 1 October 2026, vaping duty stamps must be applied to products when they are placed into retail packaging.
Stamps must be affixed to each individual vaping product
From 1 April 2027, all vaping products in the UK outside duty suspension must carry a valid stamp
This requirement is similar in concept to tobacco fiscal marks and is designed to support enforcement and combat illicit trade.
3. Approval Requirements (from 1 April 2026)
Businesses must obtain HMRC approval to:
Manufacture vaping products in the UK
Participate in the Vaping Duty Stamps Scheme
Obtain and use duty stamps
Key points:
Applications open on 1 April 2026
HMRC recommends applying at least 45 working days before 1 October 2026
Approval times may be longer if HMRC requires further information
Approval is a prerequisite to obtaining duty stamps from the authorised supplier.
4. Imports and Stamping Rules
Imported vaping products must have duty stamps applied before arrival in the UK
Exception: products entering duty suspension (e.g. customs or excise warehouse) may be stamped later
Failure to comply will prevent lawful entry to the UK market.
5. Duty Suspension and Warehousing
Vaping products may be stored without payment of duty in:
Excise warehouses
Customs warehouses
Other approved duty-suspension premises
Duty becomes payable when products are released for UK consumption.
6. Structural and Approval Conditions
HMRC approval is subject to strict operational requirements:
Approval must be granted to a single legal entity
An approval may cover multiple premises
Manufacturing and storage areas must be clearly and physically separated
HMRC states that only one manufacturer may operate within a building
Businesses operating shared facilities should review their structures carefully.
7. Overseas Manufacturers
Non-UK manufacturers cannot apply directly for the stamps scheme.
They must:
Appoint a UK representative
The representative applies for approval and orders stamps
The representative is legally and financially responsible
This has important liability implications and should be reflected in contractual arrangements.
8. Financial Guarantees
HMRC may require a financial guarantee as part of approval.
This is likely in higher-risk cases or where HMRC deems it necessary
UK representatives for overseas manufacturers will generally need to provide a guarantee unless a waiver applies
9. Key Actions for Businesses
Businesses should act now to prepare:
Assess whether approval is required within your supply chain
Identify who will act as the approved entity (and UK representative if applicable)
Review warehousing and supply chain structures
Prepare documentation for HMRC approval
Submit applications as early as possible from April 2026
Engage with the duty stamp supply process early
10. How We Can Help
We support clients with:
HMRC approval applications for VPD and duty stamps
Structuring UK representative arrangements
Excise and customs warehousing strategy
VAT and duty interaction analysis
Compliance frameworks and audit readiness
If you would like to discuss how these changes affect your business, please get in touch.
