Analytical Laboratory Testing of E-liquids
E-liquid testing is an important part of TPD compliance. Article 20(2)(b) of the Tobacco Products Directive requires e-liquid manufacturers to get products tested at an analytical laboratory before sale in the EU but it does not specify lab location requirements; manufacturers are free to do e-liquid testing at a lab in the UK or further afield. However, there are some benefits of testing in the UK, including:
English is widely spoken at the agencies in the EU, which is important because they will need to understand the test method (submitted as part of the notification). However, it can be beneficial to communicate with the agency in the local language particularly when dealing with tricky compliance issues.
Technical staff and equipment
E-liquid testing is a specialist area and requires specially trained technical staff and bespoke equipment. Many UK labs often provide a similar service for large global pharmaceutical companies so they are more likely to have the required experience and equipment.
E-liquid testing at a specialist lab is a TPD requirement
How to test an e-liquid
E-liquid testing involves drawing on an e-cigarette containing the candidate e-liquid and capturing the emitted chemicals and metals under controlled conditions by an experienced laboratory technician. The emissions (name and quantity) are reported in the product notification to the authorities. Some examples of the reported emissions include:
Aldehydes: acrolein, acetaldehyde, formaldehyde
Metals: aluminium, chromium, cadmium, tin, mercury, iron, lead
In addition, an indication of the nicotine dose of the product is to be reported. This involves capturing the nicotine in several series of puffs.
The method of the test that was used to capture the emissions must also be submitted. The report should contain enough detailed information for the authorities to be able to replicate the method.