Product information

The 2 ml, 10 ml and 20 mg/ml Checks: a Product-Presentation Matrix

A practical Great Britain presentation matrix for adult vape trade teams checking 2 ml capacity, 10 ml refill containers and the 20 mg/ml nicotine ceiling.

By Aerova Trade Information Team · Published 18/10/2026 · Updated 18/10/2026

Answer first

For nicotine-containing vape presentations intended for end consumers in Great Britain, use three separate checks: 2 ml for an e-cigarette tank, cartridge or comparable liquid-holding presentation; 10 ml for one refill container; and no more than 20 mg/ml nicotine. These are baseline format checks, not evidence that a product may be supplied.

Key Takeaways

In Great Britain, a refillable e-cigarette tank must not exceed 2 ml, while a dedicated nicotine-containing refill container must not exceed 10 ml.
20 mg/ml is the maximum nicotine concentration for nicotine-containing liquid presented for retail sale in an e-cigarette or refill container.
Capacity, nicotine strength, notification status and pack presentation are connected checks; passing one does not settle the others.
Since 1 June 2025, a reusable-vape assessment is also needed: a 2 ml format alone does not establish that a device is reusable.

Start with the legal distinction, not the sales description

The most reliable way to apply the 2 ml, 10 ml and 20 mg/ml checks is to identify what is being presented to the end consumer before reviewing names, artwork or commercial descriptions. The Tobacco and Related Products Regulations 2016 (TRPR) distinguish between an electronic cigarette and a refill container. In the legislation, nicotine-containing liquid presented for retail sale may be in a dedicated refill container of no more than 10 ml, or in a disposable electronic cigarette, single-use cartridge or tank of no more than 2 ml. A refillable e-cigarette’s tank capacity must also be no more than 2 ml. The nicotine concentration ceiling is 20 mg/ml. See TRPR regulation 36 for the statutory wording.

For trade purposes, do not treat a 2 ml pod or cartridge as a 10 ml refill container merely because both contain liquid. The first is assessed through the 2 ml presentation route; the separately supplied bottle designed to hold nicotine-containing liquid for refilling is assessed through the 10 ml route. The refill container versus cartridge guide can help teams document that distinction consistently.

This is a Great Britain information aid. Businesses planning supply in Northern Ireland should use the relevant Northern Ireland notification route and guidance. The matrix does not replace product-specific regulatory review.

The 2 ml, 10 ml and 20 mg/ml matrix

Apply the figures separately and record the evidence for each conclusion. The MHRA also requires child resistance, tamper evidence, labelling and notification before sale; see MHRA consumer-product regulations.

Check	What to identify	Great Britain trade check	Evidence to retain or review
2 ml	Tank, cartridge, pod or other e-cigarette liquid-holding presentation	Confirm the relevant capacity is no more than 2 ml. Do not assume an insert, plug or accessory resolves an over-capacity tank.	Product specification, presentation record and matching notified-product details where applicable
10 ml	Dedicated refill container holding nicotine-containing liquid	Confirm the volume of one refill container is no more than 10 ml.	Bottle specification, label artwork and pack configuration
20 mg/ml	Nicotine concentration in liquid presented for retail sale	Confirm the declared concentration does not exceed 20 mg/ml. Check units and label consistency.	Formula or specification record, notification data and final artwork
Presentation	Unit pack, container pack, name and graphics	Check that the format does not make prohibited or misleading claims and that required information is present.	Approved artwork, pack copy and version control

The figures should not be blended: 20 mg/ml does not permit a larger tank, and a 2 ml tank does not alter the refill-container limit. For terminology, see MHRA e-cigarette product types for Great Britain.

Complete the check from notification record to finished pack

A presentation review starts with the format and ends with the consumer-facing configuration. The MHRA says products must be notified and published before sale. A producer includes a manufacturer, importer or a business re-branding a product as its own; a retailer that only sells products does not normally notify. Use MHRA advice for retailers and producers for role and publication checks.

Publication is not a shortcut for the rest of the review. MHRA guidance says publication of a notified product does not guarantee UK labelling compliance. Match the exact product and presentation to the relevant published entry, then assess the final label, pack and supplied components separately. The private-label MHRA notification explainer and UK packaging and labelling guide cover those stages.

Presentation rules go beyond the front panel. Under TRPR regulation 38, a pack must not create an erroneous impression about characteristics, health effects, risks or emissions; suggest comparative harm, health or lifestyle benefits; resemble food or cosmetics; or suggest environmental advantages. The restriction covers names, text, symbols, trademarks and graphics.

Add the reusable-vape check before making supply decisions

The matrix does not determine whether a device meets the reusable-vape definition. The ban on supplying single-use vapes has applied since 1 June 2025. Defra says a reusable vape needs a rechargeable battery, a refillable liquid container and, if it contains a coil, a user-removable and replaceable coil. Refills and relevant replacement items should be separately available. These requirements apply whether or not the vape contains nicotine; see Defra’s business guidance.

Accordingly, a 2 ml rechargeable device still needs a separate reusability check. Keep capacity, nicotine-concentration and architecture evidence together, but do not collapse them into one assertion. Where uncertain, seek appropriate regulatory advice or contact the relevant enforcement authority. This is general information, not legal, tax or regulatory advice.

For an adult-only B2B discussion of a proposed presentation and the information required to assess it, contact the Aerova UK trade team.

FAQ

Is 2 ml the maximum for a nicotine-containing refill bottle?

No. The 2 ml check applies to an e-cigarette tank and to nicotine-containing liquid in a single-use cartridge or tank. A dedicated refill container holding nicotine-containing liquid has a separate maximum volume of 10 ml under regulation 36.

Does 20 mg/ml mean that any 20 mg/ml presentation is acceptable?

No. It is the maximum nicotine concentration, not a complete compliance outcome. The appropriate capacity rule, notification and publication status, labelling, packaging and, where relevant, reusable-vape requirements still need separate review.

Does appearing on an MHRA published list settle the packaging check?

No. MHRA retailer guidance states that publication does not guarantee compliance with UK labelling requirements. Trade teams should verify the exact presentation and retain a separate artwork and packaging review record.

Official sources