Answer first
A UK vape product change-control log is a controlled record linking every proposed formula, device, pack, label or supply-chain change to a defined product, its evidence, regulatory assessment, decision and release status. For Great Britain, it should make clear whether the change may require a new MHRA notification and preserve an auditable version history.
Key Takeaways
- Give each request a unique ID and connect it to the exact product, market, specification revision, owner and affected batch boundary.
- Assess regulatory impact before purchase, production or release; do not call a change minor without a recorded rationale.
- Keep evidence, approvals, notification references and post-release verification linked to the entry rather than scattered across teams.
- Use one log across product, quality, regulatory, packaging and operations, while keeping Great Britain and Northern Ireland scope distinct.
Build a controlled product baseline
A reliable log begins with the approved product baseline, not with the proposed change. For every entry, record the brand and variant name, internal SKU, intended market, notification identifier where applicable, formula or bill-of-materials revision, artwork revision, packaging configuration and current status. The team can then state exactly what changes, rather than comparing files informally or relying on memory.
Record which organisation is accountable. The MHRA defines a producer as a manufacturer, importer or business that rebrands a product as its own. Assign a named product owner and regulatory approver, and record the producer and relevant UK contact. The MHRA’s producer guidance and Aerova’s overview of MHRA notification for private-label products provide starting points.
The log should be a concise register with links to controlled files, rather than a store for every attachment. Reference the specification, supplier declaration, technical evidence, packaging proof, notification submission and decision record by document ID and revision.
| Checkpoint | Record in the log | Purpose |
|---|---|---|
| Product identity | Brand/variant, SKU, market, notification reference and baseline revision | Connects the decision to one defined presentation |
| Change scope | Old/new specification, reason, supplier or site and first affected batch | Sets an unambiguous version boundary |
| Impact and evidence | Requirements considered, documents reviewed and gaps | Shows how the conclusion was reached |
| Approval and release | Owners, decision, conditions, implementation date and verification | Prevents unauthorised release and enables closure |
Assess regulatory impact before implementation
Every change needs a documented regulatory decision before it becomes an engineering, artwork or purchasing action. In Great Britain, regulation 31 of the Tobacco and Related Products Regulations 2016 requires a producer to notify a substantially modified electronic cigarette or refill container. In the normal current case, notification must be made at least six months before intended first supply of a product or modified product.
The regulation specifies notification information where relevant, including producer contacts, ingredients and emissions by brand and variant, toxicological data, nicotine dose and uptake, component description, production process, and declarations on conformity, quality and safety. Add a substantial-modification assessment field to every entry. State the question, affected notification data, evidence reviewed, conclusion, decision-maker and, if applicable, submission reference. If the conclusion is uncertain, stop the release clock and seek suitable regulatory advice or official clarification. The log supports the decision; it does not replace notification.
Use repeatable prompts. A change to an ingredient, nicotine strength, fill volume, tank capacity, device component, refill system, child-resistant or tamper-evident feature, or leakage control should be assessed against regulation 36. Record the requirement considered and supporting evidence.
It has been illegal for businesses to sell, supply, offer to supply or hold for supply single-use vapes in the UK since 1 June 2025. Defra’s current guidance identifies a reusable vape by reference to a rechargeable battery, a refillable container and, where a coil is present, a removable and replaceable coil. A hardware change should capture the reusability assessment and parts-availability evidence. Use Aerova’s guide on what makes a vape reusable in the UK alongside the official guidance.
Link product, pack and duty-data changes
A change to artwork or pack configuration is a product change until review establishes its impact. Regulation 38 restricts pack features that create a misleading impression or suggest comparative harm, health or lifestyle benefits, food or cosmetic resemblance, environmental advantages, or economic advantages. The scope includes words, symbols, names, trade marks and graphics. Link old and proposed artwork PDFs to the entry and capture a documented packaging review. Aerova’s UK vape packaging and labelling guide helps organise that review.
For relevant businesses, HMRC’s Vaping Products Duty recordkeeping guidance requires records and supporting evidence to be retained for at least six years. It covers liquid batch data, inputs, yields and losses, label-volume reconciliation, stamp application, SKU and batch inventory, incidents, and master-data change logs. Where the requirements apply, add a duty-data impact field for SKU or pack-size changes, batch mapping, stamp-process effects, stock status, reconciliation owner and record location. This is a documentation prompt, not tax advice; consult current HMRC guidance for your circumstances.
Electrical-device changes should also trigger an environmental record review. UK WEEE guidance can require producer registration, the crossed-out wheeled-bin symbol, recycling information and document retention. Check records and markings when a device, battery, branding or import route changes. See Aerova’s resource on vape recycling and WEEE takeback.
Release, verify and retain the history
The log must control release, rather than reconstruct a decision afterwards. Use statuses such as Draft, Under assessment, Awaiting evidence, Approved with conditions, Implemented, Verified and Closed. Do not permit artwork release, purchasing or first production to progress until the named approvals are recorded. At implementation, capture the first affected batch, SKU activation, stock disposition and communication to affected functions.
Close the entry only after confirming that the released product, pack and records match the approval. Link any later complaint, safety concern, corrective action or withdrawal record. This supports annual producer reporting under regulation 32, covering sales volumes by brand and variant, consumer-preference information, mode of sale and market-survey summaries.
General information only: this article is for UK trade-documentation purposes and is not legal or tax advice. Check current official requirements and obtain advice appropriate to your product, role and market before release.
FAQ
Is a change-control log the same as an MHRA notification?
No. The log manages internal evidence and decisions; notification is a separate statutory process. It should identify potential substantial modifications and record the outcome.
Should a brand-name or artwork change be logged?
Yes. Product names, claims, imagery and presentation fall within packaging restrictions. Record proposed and approved versions; do not automatically treat a pack-only change as having no market or notification impact.
How long should change records be retained?
Retention depends on the record and activity. Where Vaping Products Duty applies, HMRC requires at least six years. Keep linked records retrievable.
Official sources
- MHRA: E-cigarettes regulations for consumer products
- Tobacco and Related Products Regulations 2016, Part 6
- MHRA: Advice on names, presentation and packaging for Great Britain
- Defra: Single-use vapes ban information for businesses
- HMRC: Keeping records for Vaping Products Duty and the Vaping Duty Stamps Scheme
- OPSS and Defra: WEEE regulations
For B2B teams defining a prospective UK-market specification and its documentation requirements, use Aerova’s request form to submit project details for a trade discussion.