UK compliance
MHRA ECIG product types in Great Britain: device, refill container, cartridge and kit guide
A primary-source guide to the Great Britain ECIG product-type categories and the buyer checks that distinguish a device, fixed combination, refill container/cartridge, individual part and kit.
Answer first
What product type should a vape be under in the MHRA ECIG system?
The right ECIG product type depends on the exact product being placed on the Great Britain market—not on the broad retail label “vape”. MHRA’s product-type guidance distinguishes rechargeable and refillable devices, fixed combinations supplied with one e-liquid, device-only products, kits, liquid-containing refill containers/cartridges and certain individual parts. The correct category helps a buyer compare a public ECIG record with the actual commercial configuration.
This guide is general information for UK trade professionals aged 18 or over. It is not legal, regulatory, tax, medical or consumer-use advice. Confirm the exact product, notification route and supply arrangement with official guidance and qualified advisers before making a compliance or supply decision.
Key takeaways
- The current Great Britain guidance lists eight ECIG product-type options, from device-only products to kits and individual liquid-containing parts.
- A rechargeable product that can also be used as refillable should be reported under the refillable category, according to MHRA’s guidance.
- Product type is a matching field: it helps verify whether the published ECIG record describes the product, pod, refill or kit actually being supplied.
- Product type does not settle every other obligation. Capacity, nicotine concentration, packaging, reusable-vape status, notification/publication and market route still need their own checks.
What are the eight MHRA ECIG product types for Great Britain?
The ECIG product-type menu separates the commercial configuration from the broad product family. This distinction matters because a refillable device, a pre-filled cartridge, a replacement pod and a multi-item starter kit may be sold under one brand but are not necessarily the same type of notified product.
| Great Britain ECIG product type | MHRA guidance summary | Buyer matching question |
|---|---|---|
| Rechargeable, fixed combination | A rechargeable e-cigarette supplied as one unit with a single-use cartridge containing one type of e-liquid. | Is the item in hand a rechargeable device supplied with one defined cartridge, rather than a refillable system or device-only product? |
| Rechargeable, device only | A rechargeable e-cigarette supplied without e-liquid. If it can also be used as refillable, MHRA says it should be reported as refillable instead. | Can the device be refilled with liquid? If so, do not rely on a device-only description without a product-specific review. |
| Refillable, fixed combination | A refillable e-cigarette supplied with one specific refill container holding one type of e-liquid; the device can later be refilled from separately purchased refill containers. | Is the supplied device genuinely refillable, and does the entry correspond to the specific supplied liquid configuration? |
| Refillable, device only | A refillable e-cigarette supplied without a liquid-containing product. | Does the ECIG entry describe the reusable device itself, or is the buyer actually receiving a liquid-containing cartridge or starter configuration too? |
| Kit | A pack containing more than one different e-cigarette device and/or more than one different refill container/cartridge. | Does the retail pack combine several different notified products, devices or liquid-containing products? |
| Refill container/cartridge containing e-liquid | A liquid-containing refill container or cartridge. | Is the supplied pod/cartridge itself the nicotine-liquid product being checked, rather than merely an empty component? |
| Individual part capable of containing e-liquid | A characteristic e-cigarette part that can contain e-liquid; the notification should name and clearly describe it. | Is this an essential liquid-containing part, such as a tank, atomiser or cartridge, rather than a generic accessory? |
| Other | An e-cigarette or refill container outside the listed categories; the notification should name and clearly describe the product/part. | Has the supplier explained why the product falls outside the standard options and supplied a clear mapping to the public record? |
What does “fixed combination” mean in the ECIG product-type guidance?
A fixed combination describes a device that is placed on the market together with one type of e-liquid; it does not mean the wider brand cannot later offer compatible refills. MHRA gives separate descriptions for rechargeable and refillable fixed combinations. In each case, the device may later be used with products purchased separately, but the notification category should reflect the exact configuration placed on the market.
For a buyer, this is a pack-level question. Photograph the retail unit, identify whether it includes a device and a liquid-containing cartridge/refill container, then ask the supplier which product entries are intended to cover each component. A brand-family page or device-only record does not answer the question for a liquid-containing combination pack.
How do you classify a device, pod, cartridge or kit before checking ECIG?
Classify the physical commercial item first, then search for a record that matches it. The following order does not replace a producer’s notification decision, but it gives a trade buyer a repeatable way to ask the right questions before approving stock or requesting documents.
- Identify what is being supplied as one retail unit.
Record whether the product is a device only, device plus a liquid-containing component, replacement pod/cartridge, refill bottle, a multi-item pack or an individual component. Do not classify only from a product-family name.
- Ask whether the hardware is rechargeable, refillable or both.
If a rechargeable product can also be used as a refillable product, MHRA’s product-type guidance says it should be reported in the refillable category. Treat “rechargeable” and “refillable” as separate product attributes.
- Identify whether nicotine-containing liquid is part of the item.
A liquid-containing refill container/cartridge is a different ECIG product type from a device-only entry. Check the exact pod, cartridge or refill-container configuration being supplied.
- Check whether the retail pack is a kit.
A kit means a pack containing more than one different e-cigarette device and/or more than one different refill container/cartridge. A seller should be able to explain the relationship between the retail kit and each notified component.
- Separate characteristic liquid-containing parts from generic accessories.
MHRA says individual parts only need notification where they are essential elements and capable of containing nicotine. Guidance gives tanks, atomisers and cartridges as examples; batteries and mouthpieces are excluded examples.
- Match the result in ECIG to the intended market and product presentation.
Use product type alongside ECID/GBID, submitter, brand and sub-type. Confirm whether the record is for Great Britain and whether it describes the actual item, rather than a similar component or a different retail combination.
When can a kit be assessed through its individual notified components?
MHRA guidance says a kit or composite product can avoid a separate notification only in a limited, documented scenario: the individual components have been notified and no re-branding has occurred. For example, if a rechargeable device and each flavour/strength cartridge are individually notified, and the component brand names are clear to retailers and consumers, a kit may not require a separate notification. This is not a general assumption that every mixed pack is covered.
The same guidance says that, when a kit/composite product has not been separately notified, sales data for the combination must still be submitted. Buyers do not need to run the producer’s reporting process, but should ask a supplier to explain the product architecture rather than accept a generic “the kit is on the list” statement.
| Kit question | Evidence-led buyer question |
|---|---|
| Are the device and liquid-containing components individually notified? | Request the precise ECID/GBID or the record-matching details for each relevant component. |
| Has any component been re-branded in the kit? | Ask whether the product/brand mapping remains clear on the commercial pack and in the public records. |
| Does the kit contain products of different types? | Check device, refill container/cartridge and kit logic separately instead of treating the outer carton as the only product. |
| Has the supplied kit changed from the approved configuration? | Escalate alterations to the supplier/compliance team; Regulation 31 addresses substantially modified products. |
Which parts need attention—and which are generic accessories?
Individual e-cigarette parts are not all treated alike. MHRA product-type guidance says separately sold parts fall within TRPR only if they are essential elements of an electronic cigarette and capable of containing nicotine. It gives tanks, atomisers and cartridges as examples that can fall within scope; replacement batteries, mouthpieces and generic items such as washers, O-rings and screws are examples that may fall outside the reporting obligation.
That distinction does not mean accessories are automatically free from other product-safety, battery or market requirements. It means the buyer should not assume that every accessory has an ECIG record, nor assume that a liquid-containing part can be cleared by a device-only record. Check the feature that matters: whether the component is an essential, liquid/nicotine-containing element of the electronic cigarette.
How do ECIG product types relate to reusable-vape rules?
ECIG product type and the reusable-vape definition answer different questions. A product may be described as rechargeable, refillable, a cartridge or a kit in the ECIG system, while the UK’s separate single-use vape rules ask whether it has a rechargeable battery, a refillable container and—where it contains a coil—a removable and replaceable coil. Refills and relevant replacement items should be separately available to buy.
For a reusable pre-filled pod system, a trade team should therefore record both dimensions: the ECIG product type for the device and liquid-containing pod, and the evidence that the system meets the reusable definition. One label cannot safely stand in for the other.
Read GOV.UK guidance on reusable vape requirementsWhat must still be checked after selecting a product type?
Product type helps match the right notification record; it does not replace product-level compliance checks. The applicable item still needs to be reviewed for its precise market, notification/publication status, capacity, nicotine concentration, safety features, pack/leaflet content and relevant supply-chain duties.
| Separate check | Why it remains separate from product type | Relevant Aerova resource |
|---|---|---|
| Notification and publication | The matching product needs an appropriate published record for the intended market; a category name alone proves nothing. | How to match an MHRA ECIG listing |
| Capacity and nicotine limits | Regulation 36 sets applicable 2 ml, 10 ml and 20 mg/ml limits by product presentation; these need checking on the actual product. | Nicotine strength labels guide |
| Packaging and leaflet | The retail unit and pack hierarchy must meet applicable information and warning requirements. | Packaging and labelling guide |
| Reusable architecture | A product-system check considers rechargeable battery, refill route, coil replacement and separate availability—not merely ECIG type. | Reusable vape definition guide |
| Product modification | Substantially modified products have notification requirements of their own under Regulation 31. | TPD/TRPR buyer checklist |
Frequently asked questions
What is an MHRA ECIG product type?
It is the classification selected when a manufacturer or importer notifies an e-cigarette or refill container for the Great Britain market. It describes the product configuration, such as refillable device only, liquid-containing cartridge or multi-item kit, and determines which notification fields apply.
Is a pod a cartridge or a refill container in the ECIG system?
A liquid-containing pod can fall within the “refill container/cartridge containing e-liquid” category. The exact classification depends on the product in question, so compare the physical item and supplier documentation to the published record rather than relying on retail terminology alone.
Is a rechargeable vape always classed as rechargeable device only?
No. MHRA guidance says that a rechargeable product which can also be used as refillable should be reported under the refillable category. The product must be reviewed for the way it can actually be used and supplied.
Does a kit need its own ECIG notification?
Not always. MHRA guidance describes circumstances where a kit made from individually notified components does not need a separate notification, provided there is no re-branding and the component brand names are clear. This needs product-specific verification.
Do batteries and mouthpieces need an ECIG notification?
MHRA guidance gives replacement batteries and mouthpieces as examples of components that are not required to be notified as individual parts. Other product-safety and market requirements can still be relevant, so do not treat this as a blanket clearance.
Official sources
- MHRA: Chapter 2 — product type guidance, Great Britain
- MHRA: ECIG Dynamic Search — Great Britain published products
- MHRA: e-cigarette and vape advice for retailers / producers
- GOV.UK: single-use vapes ban — reusable vape definition
- legislation.gov.uk: TRPR Regulation 31 — notification requirements
- legislation.gov.uk: TRPR Regulation 36 — product requirements
From product type to product brief
Build the device, pod and kit architecture into the documentation request.
Use the RFQ route to share the intended market, reusable system, product-type questions, packaging format and evidence requirements for a UK trade programme.
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