Which TPD testing service should you use?
There are now a number of different types of companies in the UK and internationally offering an e-cigarette testing service. How do you know which one to choose?
There are a number of considerations when making your choice, which include:
- Is the company independent of the e-cigarette industry? Does it have any competing interests?
- What is their expertise and experience in e-cigarette testing?
- Are they supported by a regulatory consultant or TPD consultant?
- How much do they charge? Does it meet the minimum requirements?
1. Is the company independent of the e-cigarette industry? Does it have competing interests?
The e-cigarette test results and the test method should be regarded as highly confidential and should not be shared with third parties that have associations with other e-cigarette companies or have competing interests. Some companies offering an e-cigarette testing service also manufacture and distribute a number of other brands including their own, which in our view represent competing interests.
We make sure any testing laboratory we use is truly independent and has no competing interests or associations with other e-cigarette companies. Medic Pro is also independent and has no competing interests – read more here.
2. What is their expertise and experience in TPD testing?
E-cigarette testing is a specialist area and not all laboratories have the expertise (or equipment) to be able to offer the service. It is essential that the test is conducted by specialist technical staff that have the training, skills and experience in e-cigarette testing. The results should be expertly and accurately written up in a report as they may undergo scrutiny by the authorities at a later date.
We visit the site and meet with the technical staff of candidate laboratories. Only when we are sure they are properly set up to test e-cigarettes do we commission any testing.
3. Are they supported by a regulatory consultant or TPD consultant?
E-cigarette testing is a specialist area and even the most well-established and experienced e-cigarette testing laboratories require dedicated expert regulatory support. The authorities may have questions on the test procedure or request a justification for the design of the test. It is important to have expert regulatory knowledge in order to respond to agency requests for information.
The laboratories that conduct e-cigarette testing for our clients receive our full support for all regulatory matters. We address any questions the laboratory might have about the product being tested or agency questions on the design of the test. Note: all devices should not tested the same way. The design of the test may differ between e-liquids and types of devices; a ciga-a-like is tested under different conditions to RDA’s, for example.
4. How much do they charge? Does it meet the minimum requirements?
It is important to consider the e-cigarette testing fee at the laboratory (prices can range from £70 – £900 per e-liquid) and what emissions they test for. If the price is too low the test may not meet the minimum requirements; if the fee is too high they may be needlessly testing above and beyond the requirements.
We understand the minimum requirements and the likely cost of such a test. Any test we arrange with a laboratory is, at the very least, to the minimum requirements and at a sensible price.
We have a thorough knowledge of the TPD testing requirements and extensive testing experience with vape products. Should you require expert opinion on a service provider’s TPD testing please contact us.
Minimising testing costs
An important part of our service is to keep testing costs down. We do not sell testing services unless it is necessary. We also work closely with our clients to minimise the impact on business of new and emerging regulations, which, in turn, helps our clients to save money.
Read more about why our clients choose us
Legal basis for TPD testing
Article 2 b) of the Tobacco Product Directive reads as follows:
“A new notification shall be submitted for each substantial modification of the product. The notification shall, depending on whether the product is an electronic cigarette or a refill container, contain the following information:
(b) a list of all ingredients contained in, and emissions resulting from the use of, the product, by brand name and type, including quantities thereof;”