E-liquid & pod configuration
UK refill container vs cartridge: 2 ml, 10 ml and vape-kit checks
A Great Britain trade guide to the difference between nicotine refill containers, pre-filled pods/cartridges and tanks—plus the 2 ml and 10 ml capacity checks that apply to the exact retail presentation.
Answer first
What is the difference between a vape refill container and a cartridge in Great Britain?
A refill container is a receptacle holding nicotine-containing liquid—commonly an e-liquid bottle—used to refill an electronic cigarette. A cartridge is a liquid-containing component used with an electronic cigarette, such as a pre-filled pod/cartridge configuration. For nicotine liquid presented for retail sale, the relevant Great Britain product limits are not interchangeable: a dedicated refill container must not exceed 10 ml, while a single-use cartridge or tank must not exceed 2 ml.
This is general information for UK trade professionals aged 18 or over, not legal, regulatory, tax, medical or consumer-use advice. Confirm the exact product, intended market, notification/publication status and retail presentation with official guidance and qualified advisers before supply.
Key takeaways
- For a nicotine e-liquid presented for retail sale, Regulation 36 limits a dedicated refill container to 10 ml and a single-use cartridge or tank to 2 ml.
- “Pod” is a common product word, not a complete regulatory conclusion. Check whether the actual pod is a liquid-containing cartridge, part of a device, a refillable tank, or a component in a kit.
- A 2 ml capacity label does not prove notification, packaging, leak protection, nicotine strength or reusable-vape status.
- For a flavour or strength kit, the device, each liquid-containing component and the commercial outer pack must be mapped to the applicable product records—not treated as one generic family.
Refill container, cartridge, pod and tank: what is each item?
Start with the physical item supplied to the retailer or customer, then use the relevant terms consistently in the product file. MHRA retailer guidance calls a refill container a receptacle holding nicotine-containing liquid, commonly known as e-liquid. Product-type guidance separately includes a “refill container/cartridge containing e-liquid” option, while the regulations identify tanks and single-use cartridges when setting the 2 ml limit.
| Term used in trade | Useful Great Britain interpretation | Capacity question to ask | Record-matching question |
|---|---|---|---|
| Refill container / e-liquid bottle | A receptacle holding nicotine-containing liquid, commonly e-liquid, intended to refill an electronic cigarette. | Is the retail nicotine-liquid container 10 ml or less? | Does the published product information describe the exact bottle, liquid and intended Great Britain market? |
| Cartridge | A component associated with an electronic cigarette; a liquid-containing cartridge can be a refill container/cartridge product type in MHRA guidance. | If it is a single-use liquid-containing cartridge, does it stay at or below 2 ml? | Does the record correspond to the precise cartridge/pod variant supplied? |
| Pre-filled pod | A common commercial label. Depending on configuration, it can function as a liquid-containing cartridge and may also contain a coil. | What is the liquid volume per pod, and how does the system meet the relevant reusable-product requirements? | Is the pod matched separately from the rechargeable device and any outer kit? |
| Tank | The liquid-holding part of a refillable electronic cigarette; a refillable tank has its own 2 ml capacity ceiling. | Is the actual usable tank capacity 2 ml or less, without relying on non-essential inserts or plugs? | Does the product information describe the tank/device configuration actually supplied? |
| Kit / combination pack | A pack with multiple different device and/or refill-container/cartridge products under MHRA product-type guidance. | Does every liquid-containing component have the correct presentation and capacity? | Have the individual components and, where relevant, the kit/composite arrangement been mapped clearly? |
What are the 2 ml and 10 ml nicotine-liquid limits?
For nicotine-containing liquid presented for retail sale, Regulation 36 sets different maximum volumes for the product format. A dedicated refill container may be no larger than 10 ml. A disposable electronic cigarette, single-use cartridge or tank may be no larger than 2 ml. The capacity of a refillable electronic-cigarette tank must also not exceed 2 ml. These are presentation-specific limits, so a trade team should measure and document the actual liquid-holding item, not only the outer carton.
| Retail presentation in Regulation 36 | Maximum nicotine-liquid volume | Important trade interpretation |
|---|---|---|
| Dedicated refill container | 10 ml | This is the nicotine e-liquid container used to refill the electronic cigarette; it is not a 10 ml allowance for a pod or tank. |
| Single-use cartridge | 2 ml | The limit applies to the liquid-containing cartridge presentation. A multipack does not turn each individual cartridge into a 10 ml refill container. |
| Tank in a refillable electronic cigarette | 2 ml | MHRA retailer guidance warns that tanks above 2 ml cannot be supplied in the UK, including as part of a notified kit. |
| Nicotine liquid concentration | 20 mg/ml | This is a concentration ceiling, separate from volume. A 2 ml pod and a 10 ml bottle can have different total liquid content while both remain at or below the concentration limit. |
Regulation 36 also requires applicable electronic cigarettes and refill containers to be child-resistant, tamper-evident, protected against breakage and leakage, and equipped with a mechanism for refilling without leakage unless the product is a disposable electronic cigarette. Capacity is therefore only one row in a wider product-specific check.
Read TRPR Regulation 36 product requirementsDoes 2 ml in a pod mean the product is legal to supply?
No. A 2 ml capacity can be a relevant threshold, but it is not a complete approval test. The same item still needs a product-specific assessment of the applicable notification and publication status, nicotine concentration, pack/leaflet information, child resistance, tamper evidence, leakage protection, refill architecture and intended market. MHRA tells retailers that publication does not guarantee UK labelling compliance.
Equally, the word “single-use” in the Regulation 36 capacity wording should not be treated as permission to sell a disposable vape. The UK ban on single-use vapes has been in force since 1 June 2025. A reusable-vape assessment asks separate questions about the battery, refill route, coil replacement route and separate availability of relevant refills or replacement components.
How should a trade buyer assess a pre-filled pod?
Assess a pre-filled pod as a liquid-containing component first, then assess the rechargeable device and retail bundle around it. A pod may be described in marketing language as a cartridge, capsule or refill, but the buyer needs evidence for the actual liquid capacity, nicotine strength, physical product type, brand/sub-type, notification/publication match and role in the reusable system.
- Identify the liquid-holding item.
Confirm whether the pod arrives pre-filled, can be re-filled, or is empty hardware. Record the liquid volume per pod and whether it is sold alone or with a device.
- Separate volume from concentration.
Check the pod’s millilitres and nicotine concentration as different fields. A 2 ml pod at 20 mg/ml contains up to 40 mg of nicotine in the liquid; that arithmetic is not a per-puff delivery statement.
- Match the product type and public record.
MHRA product-type guidance includes “refill container/cartridge containing e-liquid”. Use ECID/GBID, submitter, brand, sub-type and product type to compare the exact liquid-containing part with the published record.
- Check the reusable route at system level.
For a reusable pod system, a rechargeable battery and separately available replacement pods/refills are part of the separate reusable-vape test. If the coil is in the pod, the removable and replaceable pod can provide the coil-replacement route described in GOV.UK guidance.
- Review the pack and leaflet in the correct hierarchy.
Check the product, unit pack and any outer pack against applicable warning, information and presentation requirements. Do not rely only on the pod label or an online product image.
Do flavour or nicotine-strength variants change the compliance file?
A flavour name or strength label should be treated as a specific product-variant attribute, not merely a creative label. MHRA’s product-type guidance uses an example of a kit containing a selection of flavour or strength cartridges, where the empty electronic cigarette product and each cartridge refill container have all been individually notified. That makes flavour/strength mapping a practical due-diligence question for buyers sourcing e-liquid or pod ranges.
| Variant question | Why it matters | Evidence to request or match |
|---|---|---|
| Is each flavour/strength cartridge identified? | Different liquid variants should not be collapsed into one generic device record when checking a product range or kit. | Exact brand/sub-type, liquid variant, product type and ECID/GBID mapping for the item supplied. |
| Is the flavour presentation factual and appropriate? | MHRA presentation guidance allows flavour references, while restricting misleading presentation, health/lifestyle claims and product presentation that resembles food or cosmetics. | Approved artwork, label hierarchy and confirmation that any food-ingredient image corresponds to an ingredient or flavouring without making food-like claims. |
| Is the nicotine label unambiguous? | Strength and liquid volume answer different questions. Product checks need both, alongside any required delivery-per-dose information. | Strength in mg/ml, any percentage shorthand, volume, and product-specific label/leaflet files. |
| Has the commercial configuration changed? | Changing the refill liquid, cartridge, pack or product architecture can affect the product mapping and notification assessment. | Written supplier explanation of the exact component and pack configuration for the intended market. |
How should a device-and-pod kit be checked?
A device-and-pod kit should be reviewed as a retail configuration made of identifiable parts—not as a simple hardware SKU. MHRA product-type guidance defines a kit as a pack containing more than one different e-cigarette device and/or more than one different refill container/cartridge. In limited cases, individually notified components may mean the composite kit does not need a separate notification, provided there is no re-branding and component brands are clear. This must be assessed for the actual product, not assumed from the word “kit”.
| Component of a kit | What the buyer should keep distinct |
|---|---|
| Rechargeable device | Device architecture, reusability evidence, brand/sub-type, product type and any individual notification/publication mapping. |
| Pre-filled pod/cartridge | Liquid capacity, strength, flavour variant, liquid-containing component record and the relationship to the device. |
| Refill bottle | Its own 10 ml maximum retail-container presentation, label/leaflet requirements and suitable refill mechanism. |
| Outer retail carton | Clear component identity and pack-level presentation; it must not obscure which individually notified products the buyer is receiving. |
Refill container and cartridge buyer checklist
Use the following checklist to build an evidence request before approving a nicotine-liquid, pod or kit programme for Great Britain. It is designed to prevent the common error of accepting a single “2 ml” or “10 ml” statement as the entire regulatory file.
- Describe the product as supplied.
Record whether it is an e-liquid bottle/refill container, pre-filled pod/cartridge, tank, empty part, device plus liquid, or multi-item kit.
- Record the actual liquid capacity.
For nicotine liquid presented for retail sale, compare the bottle to the 10 ml rule and any cartridge/tank to the 2 ml rule. Escalate a mismatch before supply.
- Record nicotine concentration separately.
Verify mg/ml, percentage shorthand where shown, container volume and total liquid content without turning a concentration calculation into a delivery claim.
- Map every flavour and strength variant.
Match the specific liquid-containing item, not just the device family, to the supplier’s written product map and relevant published ECIG information.
- Check the kit and re-branding logic.
Ask which components are individually notified, whether the outer kit is separately notified where relevant, and whether brand identifiers remain clear.
- Verify the Great Britain market route.
Search the MHRA ECIG publication database and compare ECID/GBID, submitter, brand, sub-type and product type. Great Britain and Northern Ireland notification routes should not be assumed to be interchangeable.
- Review pack, leaflet and reusable-system evidence.
Check applicable presentation, warnings, safety features, leak protection and rechargeable/refill/replacement path evidence before listing or accepting stock.
Frequently asked questions
Is a 10 ml bottle a vape cartridge?
Not normally. For nicotine liquid presented for retail sale, a dedicated refill container can be up to 10 ml. A cartridge is a different liquid-containing component associated with an electronic cigarette; a single-use cartridge has a 2 ml limit under Regulation 36. The exact product should be assessed by its physical configuration and documentation.
Is a pre-filled pod limited to 2 ml in Great Britain?
If a pre-filled pod is the liquid-containing cartridge presentation, the relevant 2 ml limit should be checked. “Pod” by itself is a commercial term, so confirm the exact configuration, capacity, product type and intended market with the supplier and official guidance.
Can a 2 ml pod and a 10 ml refill bottle be sold together in a kit?
Capacity is only one part of the analysis. The 2 ml pod/cartridge and 10 ml refill container must each meet their applicable product and presentation requirements. The kit, component notification/publication mapping, packaging and reusable system should also be checked as the actual commercial configuration.
Does 20 mg/ml mean the product can have any container size?
No. Nicotine concentration and liquid volume are separate limits. Regulation 36 sets a maximum nicotine concentration of 20 mg/ml, while the relevant maximum volumes are 10 ml for a dedicated refill container and 2 ml for a single-use cartridge or tank.
Can flavour names appear on vape pods and refill containers?
MHRA presentation guidance permits references to flavour, but packaging must not create a misleading impression, make health or lifestyle claims, resemble food/cosmetics, or suggest an economic advantage. Product-specific artwork should be reviewed against the current rules and guidance.
Can a published ECIG entry prove that a pod or bottle is compliant?
No. MHRA advises that publication does not guarantee UK labelling compliance. A published record should be matched to the exact product alongside capacity, strength, pack, leaflet, safety feature and market-route checks.
Official sources
- legislation.gov.uk: TRPR Regulation 36 — product requirements
- MHRA: e-cigarette and vape advice for retailers / producers
- MHRA: Chapter 2 — product type guidance, Great Britain
- GOV.UK: single-use vapes ban — reusable vape definition
- MHRA: presentation and packaging guidance for nicotine products / refill containers
- MHRA: ECIG Dynamic Search — Great Britain published products
From liquid configuration to trade brief
Define the bottle, pod, flavour variant and kit architecture before requesting a quote.
Use the RFQ route to share the intended market, reusable system, refill format, flavour/strength variant plan, packaging format and evidence requirements for a UK trade programme.
Request a Trade Quote