Short fill Testing Service
We provide analytical testing services to retailers, wholesalers and manufacturers of short fill – shake n vape – to help them comply with the General Product Safety Regulations (GPSR).
Under the GPSR, products should only be placed on the market if they are safe. In order to check the safety of a short fill, an important step is to get it tested at an analytical laboratory.
Most short fill testing services work by testing all products under the same testing scheme on a ‘one size – or test – fits all’ basis. Our service is different.
Our short fill testing service looks into a number of different aspects of your business such as operations, suppliers, manufacturing and works out a testing strategy that should work out cheaper than the ‘one test fits all’-type service.
With lab testing costs around £200 per short fill, for manufacturers who have a large portfolio of short fill 50+ flavours the cost of testing can be high. But by adopting a risk-based testing strategy, not all short fills may need to be tested.
This is what our service does – it adopts a risk-based strategy. This helps our clients save money while maintaining compliance with GPSR.
In relation to product safety, the General Product Safety Regulation states: (1) No producer shall place a product on the market unless the product is a safe product.
Our risk-based testing strategy has its roots in the pharma industry – the industry on which e-cigarette regulation is based. It is acceptable practice for pharma companies to use a risk-based testing strategy when testing for compliance with medicine regulation.
In other words, pharma manufacturers may not need to conduct full testing of products to comply with the applicable regulations. The strategy is quite complex but, essentially, takes into account a number of aspects of the business including how the business operates and the compliance activities of its suppliers and manufacturers.
We can help vape businesses adopt a similar risk-based strategy. We will work with you to put in place a risk-based strategy to minimise the compliance testing while ensuring compliance with GPSR.
1) Questionnaire
We shall ask a range of questions about your business, your raw material suppliers and manufacturers. Based on your response, we shall devise a testing strategy specific to your business.
2) Analytical Testing
We shall send a number of short fills to an analytical lab for testing in line with the testing strategy. You shall receive a copy of the report for your records.
3) Regulatory support
As part of the service, we shall:
* Support is provided for 6 months from date of testing. After this period, additional regulatory support fees may apply.
As part of the analytical lab testing, we shall check for known chemicals of concern including:
The labs we use must meet a specific requirements. They are as follows:
Per manufacturer: £595
Per short fill: To be determined
The cost per short fill is to be determined because it depends on a number of factors including the total number of short fills and the response to the questionnaire. See Case study below.
A vape business markets fifty short fills from five different manufacturers. A breakdown of cost is below:
Cost per manufacturer: £595 x 5 = £2,975
Risk-based Test Strategy: Based on the responses from the questionnaire, and discussion with the client, a risk-based strategy was devised and analytical testing cost was placed at around £5000.
In this case study, the overall cost of GPSR compliance for 50 short fills from 5 manufacturers would be £7975 (2,975 + 5000). This works out at just under £160 per short fill.
Up to now, the authorities have taken a light touch to short fill regulation and little has been done to scrutinise vape businesses for regulatory compliance. But things are starting to change. The signals from the authorities – the MHRA and Trading Standards – indicate they are starting to clamp down on non-compliant vape stores and manufacturers.
The MHRA announced in the Parliamentary Science Committee meetings that they were supporting Trading Standards in the testing of marketed products. Click here to learn more about what they said.
In addition, Trading Standards have conducted research into the extent to which retailers comply with the TRPR. Read the results of the report here. Only physical vape stores were visited in this study – online stores will be subject to a separate review (results of which are yet to be published).
Act now to ensure you don’t get caught out. The cost to your business of non-compliance comes can lead to loss of sales and business. (Read more about the powers of Trading Standards here).
We are a London-based regulatory affairs consultancy providing services to the biocide, CBD, e-cigarette, cosmetic and pharmaceutical industry. We help e-cigarette companies comply with the Tobacco Products Directive and pharmaceutical companies obtain and maintain medical product licences. We also offer UKAS accredited biocide and CBD analytical testing services.
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