UK Representative for Vaping Products Duty

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UK Representative for Vaping Products Duty

Medic Pro Limited is an HMRC-approved UK Representative under the Vaping Duty Stamps Scheme. If you manufacture vaping products outside the United Kingdom and want those products stamped before they ship, you must appoint a UK representative. We take that appointment.

The UK representative buys the stamps, remains legally responsible for them after they leave the UK, and is the person HMRC will hold to account if stamps are lost, misused or left unaccounted for.

Who needs a UK representative for Vaping Products Duty

You need this service if all three are true:

  • You manufacture, or have manufactured, vaping products outside the UK.
  • You intend those products to be sold or supplied in the UK.
  • You want the vaping duty stamp affixed at the overseas factory as part of packing, rather than after the goods arrive.

From 1 October 2026, liable vaping products released onto the UK market must carry a vaping duty stamp. From 1 April 2027 the same rule applies to all stock outside duty suspension, regardless of when it was made. Unstamped product can be seized. Repeated failures can lead to large fines and sanctions.

What the UK representative actually does

HMRC treats the UK representative and the overseas manufacturer as one and the same for the stamps.

We do

  • Hold and maintain HMRC approval as UK Representative and purchasing operator.
  • Onboard the overseas manufacturer against HMRC fit-and-proper and due-diligence expectations.
  • Take exclusive appointment under a written framework agreement.
  • Convert your production forecast into stamp orders within the purchase limit HMRC has set for us.
  • Buy wet or dry stamps from the HMRC-appointed supplier and have them shipped, tracked and signed-for, to your affixing site.
  • Remain legally responsible for every stamp from the moment it is delivered overseas.
  • Notify HMRC and the supplier of loss, theft, damage, unused returns and destruction.
  • Keep the records HMRC will ask to inspect: orders, receipts, activations, discrepancies and customer list.
  • Tell HMRC when we add or remove a manufacturer we represent.

You do

  • Share accurate forecasts and product data (volume to 0.1 ml, brand, SKU, nicotine, flavour).
  • Affix each stamp to the outermost retail pack so the pack cannot be opened without damaging the stamp or the pack.
  • Activate digitally enhanced stamps at the point of affixing and capture the required metadata.
  • Scan at the defined supply-chain points, including aggregation if you ship in cartons or pallets.
  • Not release stamped product onto the UK market before 1 October 2026.
  • Not affix a transitional stamp after the cut-off HMRC has set, and not affix anything other than a digital stamp once that window closes.
  • Fund the stamp order before we place it. Stamps are not transferable to another UK representative.

Stamps are not the duty

This is the distinction most manufacturers get wrong, and the one that will create a dispute if it is left fuzzy.

  • Vaping duty stamps are security labels. The UK representative pays the supplier for the labels and is financially exposed if they go missing.
  • Vaping Products Duty is the excise charge on the liquid — a flat £2.20 per 10 ml, nicotine or not. Duty becomes due when the product is released for UK consumption, or when it leaves duty suspension.
  • Appointing Medic Pro as UK representative does not, by itself, make us the importer of record or the person who submits the monthly Vaping Products Duty return.

If you want duty deferred at the border, the goods must enter an HMRC-approved warehouse or approved store. That is a separate commercial arrangement. We will tell you when that arrangement is required. We will not pretend a representative appointment replaces it.

How the service runs

  1. Enquiry and scope. We confirm you are an overseas manufacturer and that stamps will be affixed outside the UK.
  2. Due diligence. Ownership, premises, product range, intended UK volume, UK warehouse or importer, and any previous compliance issues.
  3. Framework agreement. Exclusive appointment as UK Representative and purchasing operator. Individual stamp orders sit under that framework. Signing the framework does not commit either side to a volume.
  4. Forecast. You give a quarterly throughput we can defend to HMRC. Purchase limits are set on a rolling three-month basis. Limits can move with evidenced demand.
  5. Pre-payment and order. You pay for the stamps. We place the order on the supplier portal and send them to your factory under tracked, signed-for delivery.
  6. Affixing and traceability. You apply the stamps to HMRC’s specification and scan the digital codes. We keep the UK-side records.
  7. UK landing. Duty is paid for at import. We ensure an audit trail. We do not operate a warehouse.

Why appoint Medic Pro

  • HMRC-approved UK Representative for the Vaping Duty Stamps Scheme
  • Inspectable London premises. Not a virtual office. HMRC’s own manual says brass-plate companies should not be approved.
  • Fifteen years as a regulatory consultancy in vape, pharmaceutical, medical device, cosmetics, biocides and CBD. The VDS appointment sits on that record, not on a newly formed shelf company.
  • Written policies for data ownership, record management, risk and due diligence, training and competence, and stamp pre-payment — the controls HMRC asked to see.
  • We already act as UK representative in adjacent product regimes. Manufacturers who need both an MHRA UK contact and a VDS UK representative can keep both roles in one firm.

Frequently asked questions

Do I need a UK representative for Vaping Products Duty if I already have a UK importer?

Only if stamps are to be bought and sent overseas for affixing at manufacture. If stamps will be applied in an approved UK warehouse after import, the warehousekeeper can apply for VDS approval in its own name. Most overseas brands that want factory-applied stamps still need a UK representative.

Is the UK representative legally responsible for the stamps?

Yes. Under the Finance (No. 2) Act 2026 the representative remains responsible for a stamp from the point it is delivered to the overseas person. Civil penalties can follow loss, misuse or failure to affix, activate, return or destroy a stamp within 12 months of issue. Repeated failures can end the approval.

Does Medic Pro pay Vaping Products Duty on my behalf?

No. This will be the UK haulier or import declarant.

Can I appoint more than one UK representative?

Not for the same products under our terms. The appointment is exclusive. HMRC also requires us to notify additions and removals of the manufacturers we represent.

How long does HMRC approval take if I try to do this myself?

HMRC has said applications can take at least 45 working days and longer if information is missing.

What is the difference between a transitional stamp and a digital stamp?

Transitional stamps have the physical security features only and are not scanned. They were a pre-implementation tool. Digitally enhanced stamps carry a data matrix and must be scanned at set points in the supply chain. From the date HMRC has set, only digital stamps may be affixed. We will not order the wrong type for the date you intend to affix.

Talk to us before you ship

If you are an overseas manufacturer planning UK supply, write to us with the product range, intended quarterly volume and the UK warehouse or importer you intend to use. We will tell you whether a UK representative appointment is the right route, or whether stamping should happen after import.