TPD Directive and Elfbar What does "compliant" mean?
The TPD (Tobacco Products Directive 2014/40/EU) is the EU Tobacco Products Directive and is implemented in Germany through the Tobacco Products Act (TabakerzG) and the Tobacco Products Ordinance (TabakerzV). "TPD-compliant" means that an e-cigarette meets the requirements regarding nicotine, tank size, ingredients, warnings, and reporting.
What does the TPD regulate regarding e-cigarettes?
The TPD sets EU-wide minimum standards for nicotine-containing e-cigarettes and refill containers. In Germany, these requirements are further specified in the... Tobacco Products Ordinance (TabakerzV) In more detail. The most important points from a consumer perspective:
- Maximum 20 mg/ml nicotine in liquids and pods
- Maximum 2 ml of liquid per disposable vape or pod
- Maximum 10 ml capacity for refill bottles
- Mandatory warnings and full list of ingredients
- Prohibition of certain additives (Annex 2 Tobacco Products Ordinance)
- Mandatory notification of each product to the BfArM before market launch
Which sections of the Tobacco Products Ordinance are relevant?
The most important parts of the German implementation:
- §27 Tobacco Products Ordinance: Ingredient list, mandatory information, warnings on 30% of the two largest packaging areas ("This product contains nicotine: a highly addictive substance").
- §28 Tobacco Products Ordinance: Prohibition of certain ingredients (e.g. vitamins, caffeine, diacetyl), list in Annex 2.
- Tobacco Products Act §§4–6: Notification requirements and national market requirements.
What does "TPD-compliant" mean for ELFBAR ?
A TPD-compliant one
- Nicotine content clear in mg/ml (e.g. 20 mg/ml, 10 mg/ml, 0 mg/ml).
- Tank volume 2 ml for disposable and prefilled pods.
- Warning in German on the two largest packaging surfaces.
- Ingredients list in descending order of quantity.
- package insert including operating, safety and disposal instructions.
- Batch number for traceability.
If any of these elements are missing or only available in a foreign language, it indicates a grey market import or a counterfeit. Where you can buy legally in Germany is shown here. Where
Which devices are affected?
The TPD applies to all nicotine-containing e-cigarettes and refill containers. Specifically, regarding
- Disposable vapes How
Elfbar 600 V2: 2 ml tank, max. 20 mg/ml nicotine. -
ELFA and ELFX Pod systems: Pods with 2 ml of liquid, nicotine strengths 0/10/20 mg/ml. -
ELFLIQ 10 ml bottles: maximum container size according to TPD. - Nicotine-free products (0 mg/ml): are also subject to the Tobacco Products Ordinance requirements regarding ingredients and labeling.
What is not regulated by the TPD?
The TPD/Tobacco Products Ordinance regulates the product. Other issues are addressed elsewhere.
- Age limit 18: Youth Protection Act (JuSchG) — see Youth protection when vaping.
- Take-back of old devices: ElektroG, extended from 2026-07-01 — see Obligation to take back returns from the 1st.July 2026.
- Battery requirements: EU Battery Regulation 2023/1542 — see EU Battery Regulation & Vape.
- Advertising and sponsorship: separately regulated in the Tobacco Products Act.
Are TPD regulations being monitored?
Yes. In Germany, the Federal Institute for Drugs and Medical Devices (BfArM) (for notification) and the market surveillance authorities of the federal states are responsible. Products without proper notification may not be placed on the market. Imports from third countries without TPD compliance are illegal—even if offered online. Therefore, anyone wanting genuine devices should order from authorized dealers within the EU.
What if I own a non-TPD-compliant device?
From a consumer perspective: Such devices may deviate from TPD standards in terms of ingredients, nicotine content, or safety. We recommend not using them and disposing of them via the German Electrical and Electronic Equipment Act (ElektroG). Sales processing and evidence gathering are the responsibility of market surveillance authorities—we do not offer legal advice.
How does the TPD help me when buying something?
The TPD also serves as a shopping aid: If you're holding a package and all the mandatory elements are present—nicotine content, warning label in German, ingredient list, batch number, and package insert—you're very likely dealing with a legal, approved product. If any of these elements are missing, caution is advised. In practice, we see two main pitfalls:
- Imports from third countries: Often with a higher nicotine concentration, a larger tank, or lacking German labeling. This is not a bargain, but an unauthorized product.
- Forgeries: Outwardly very similar to the original, but with unclear ingredients. An authenticity check will help here — see Fake
Elfbar recognize.
What role does the BfArM play?
The Federal Institute for Drugs and Medical Devices (BfArM) maintains the national notification database for e-cigarettes. Before any market launch, manufacturers must register the product at least six months in advance—with all relevant data on ingredients, aerosol composition, and device characteristics. This obligation is the backbone of the TPD implementation in Germany: without notification, there is no legal sale.
How does TPD relate to advertising and sales?
The TPD not only sets product standards but also influences advertising and cross-border mail order. In Germany, tobacco and e-cigarette advertising is heavily restricted in most media. Cross-border mail order sales to private customers between EU countries are subject to national notification requirements. For consumers, this means that ordering from a German shop in Germany offers the least effort and the highest level of assurance that the product is correctly notified.
What does TPD compliance mean in the long term?
The TPD has been in force since 2014, but it is regularly reviewed and adapted to new findings. Among the issues currently under discussion are stricter regulations for flavorings, lower maximum nicotine levels, more precise labeling, and closer alignment with the EU Battery Directive. What is considered "compliant" today could be subject to new obligations in two or three years. For reputable manufacturers like
What buyers should take away from three sentences
First: TPD-compliant means a nicotine limit of 20 mg/ml, a 2 ml tank, a 10 ml refill bottle, complete German labeling, and notification to the BfArM (Federal Institute for Drugs and Medical Devices). Second: Anyone buying from authorized retailers in Germany is automatically within the compliant framework. Third: Non-compliant imports—no matter how great the price advantage may seem—pose a risk in terms of safety, contents, and legality. With this filter, you'll make the right purchase decision in 95% of cases.
Conclusion
"TPD compliant" is not advertising, but a legal minimum requirement: 20 mg/ml, 2 ml, full labeling, notification.
Last updated: May 2026. This article does not constitute legal advice. For legal questions, please consult a qualified professional.