UK trade planning
UK Vaping Products Duty 2026: a wholesaler’s compliance checklist
From 1 October 2026, the UK’s Vaping Products Duty and Vaping Duty Stamps Scheme change how vaping liquids enter the market. This guide explains the dates, checks and records wholesalers should address with suppliers before buying or releasing stock.
Answer first
What does UK Vaping Products Duty mean for wholesalers?
From 1 October 2026, liable vaping liquid released onto the UK market is subject to Vaping Products Duty at £2.20 per 10 ml, whether or not it contains nicotine. Newly manufactured or imported products must carry a valid duty stamp. Wholesalers selling only duty-paid products do not normally need scheme approval, but they must check stock legitimacy and keep clear records.
This article provides general trade information, not tax, legal or regulatory advice. Check the current HMRC guidance and obtain professional advice for your circumstances.
What is Vaping Products Duty?
Vaping Products Duty, usually shortened to VPD, is a UK excise duty on vaping liquid. HM Revenue & Customs states that the duty covers liquid in bottles, cartridges and pods, including products that contain no nicotine. The flat rate is 22 pence per millilitre, equivalent to £2.20 per 10 ml.
HMRC gives two useful examples: a 2 ml pod attracts 44 pence of duty, while a 10 ml refill bottle attracts £2.20. The duty applies to the liquid rather than the rechargeable hardware itself, but a hardware buyer still needs to understand how pods and refill products will be documented, stamped and supplied.
Read HMRC’s VPD preparation guidanceWhich Vaping Products Duty dates matter to UK wholesalers?
The transition is easier to manage when procurement, warehouse and retail teams use the same date definitions. The most important dates are:
| Date | What changes | Wholesaler action |
|---|---|---|
| Before 01/10/2026 | Duty-stamped products must not be released onto the UK market early. | Review stock levels and ask suppliers how compliant stamped products will be provided. |
| 01/10/2026 | VPD and the stamp scheme begin. Newly manufactured or imported liable stock released to market needs a duty stamp. | Check stamps on new stock and retain supplier evidence, invoices and delivery notes. |
| 01/10/2026–31/03/2027 | Eligible unstamped stock produced or imported before 01/10/2026 may continue to be stored and sold during the grace period. | Keep evidence of the production or import date and manage sell-through separately. |
| 01/01/2027 | Only digital duty stamps may be affixed to products. | Confirm that suppliers and affixing operators have moved from transitional to digital stamps. |
| 01/04/2027 | All vaping products outside duty suspension in the UK must carry a valid duty stamp. | Do not hold, sell or supply unstamped products unless a lawful exception applies. |
HMRC says transitional physical-only stamps were available for approved operators to buy until 30 November 2026 and may be affixed until 31 December 2026. Digital stamps became available on 1 September 2026 and support authentication and supply-chain traceability.
Check the current duty-stamp timetableDo wholesalers need to register for Vaping Products Duty?
A business that only sells or distributes duty-paid vaping products by wholesale or retail does not need to apply for VPD or Vaping Duty Stamps Scheme approval. Registration may be required when the business also manufactures, imports, stores products under duty suspension, affixes stamps or represents an overseas manufacturer.
| Business activity | Approval position in HMRC guidance |
|---|---|
| Wholesale or retail distribution of duty-paid products only | No VPD or stamp-scheme approval normally required. |
| Manufacturing vaping products in the UK | HMRC approval is required before carrying out the activity from 01/10/2026. |
| Importing products into the UK | The importer may need to pay VPD at import unless goods enter an approved duty-suspension arrangement. |
| Storing products under duty suspension | Relevant HMRC warehouse or approved-store arrangements are required. |
| Affixing duty stamps | Only approved operators may purchase and affix stamps. |
| Representing an overseas manufacturer | The overseas manufacturer must appoint a UK representative for the stamp scheme. |
Activity matters more than the label a company uses. A “wholesaler” that also imports, owns stock in a non-approved warehouse or performs stamp-related work should use HMRC’s impact checker and obtain advice on the exact approval position.
How should wholesalers check vaping products from 1 October 2026?
HMRC expects wholesalers to take reasonable steps before buying, holding or supplying stock. A practical purchasing check should cover the product, stamp, supplier and commercial records together.
- Confirm whether the product needs a stamp.
Newly manufactured or imported liable products released from 01/10/2026 should normally be stamped. Ask the supplier to explain any unstamped stock.
- Inspect the outermost retail packaging.
The stamp should be attached so that opening the pack damages the packaging or the stamp. A stamp cannot be reused.
- Check the supply-chain source.
Record where the goods came from, the supplier’s company details and the associated invoice and delivery-note references.
- Separate grace-period stock.
If stock is unstamped, retain evidence that it was produced or imported before 01/10/2026 and monitor its sale or return before 01/04/2027.
- Resolve inconsistencies before purchase.
Do not buy, supply or sell goods when the stamp is missing, damaged, reused, altered or attached incorrectly unless the issue has been satisfactorily resolved.
These checks should sit alongside ordinary product due diligence. VPD status does not replace MHRA notification checks, reusable-product requirements, packaging and labelling review, battery documentation or other market obligations.
Which records should a vape wholesaler keep?
HMRC’s wholesale and retail guidance says businesses should keep clear records for at least six years. Records should show what was purchased, where it came from, what checks were performed and why any unstamped stock could lawfully be handled during the grace period.
| Record category | Information to retain |
|---|---|
| Supplier | Name, address, contact details and evidence that the supplier appears credible. |
| Transaction | Invoice numbers, delivery notes, receipt dates and stock quantities. |
| Product | Product description, volume, batch or SKU information and whether a stamp was required. |
| Timing | Production or import date, especially for unstamped grace-period stock. |
| Due diligence | Checks made, issues found, supplier explanations and action taken. |
A documented receiving checklist is stronger than relying on visual memory. It gives purchasing, warehouse and compliance teams a common record and makes it easier to respond if HMRC asks how particular stock was assessed.
Read HMRC’s wholesaler and retailer guidanceWhat information is linked to a digital vaping duty stamp?
HMRC’s stamp guidance describes a detailed product record for digital stamps. Required SKU and affixing data includes the product name and description, barcode, liquid volume to the nearest 0.1 ml, brand, flavour, product type, nicotine content and, where nicotine is above 0 mg/ml, the ECID or GBID. A product image is also part of the SKU data.
For a private-label or imported range, this data requirement affects more than label production. It makes consistent product master data, barcode ownership, pack imagery and notification identifiers important inputs before an affixing operator can manage the stamp workflow efficiently.
Plan product and packaging data with AerovaFrequently asked questions
What is the UK Vaping Products Duty rate in 2026?
The rate is £2.20 per 10 ml of vaping liquid, equivalent to 22 pence per millilitre. It applies to liable vaping liquid whether or not it contains nicotine.
Can wholesalers sell unstamped stock after 1 October 2026?
Eligible unstamped stock produced or imported before 1 October 2026 may be sold until 31 March 2027. The wholesaler should keep evidence showing why the stock qualifies for the grace period.
Do refillable pod kits attract Vaping Products Duty?
The duty applies to the vaping liquid, including liquid in prefilled pods and cartridges. Rechargeable hardware without vaping liquid is not itself the liquid subject to VPD, but the full product configuration and packaging should be checked.
Does a VPD stamp prove full UK product compliance?
No. A duty stamp relates to the VPD and stamp regime. It does not replace MHRA notification, reusable-product, packaging, labelling, battery, age-of-sale or other applicable checks.
How long should wholesalers keep VPD records?
HMRC’s guidance says wholesalers and retailers should keep clear business records for at least six years, including supplier, transaction, product, timing and due-diligence information.
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