Study shows: Illegal e-cigarettes make up an estimated 40 to 60 percent of the German market - hundreds of millions of euros in tax losses
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ELFBAR Online trade in Germany, differences in EU regulations, and overburdened authorities are fueling the booming black market. - Untaxed e-liquid costs around 10 euros per liter – compared to 300 euros. with proper taxation
Berlin, November 12, 2025 – The illegal trade in e-cigarettes has developed into a billion-euro business in Germany: According to a new study by HG Innovation Limited commissioned and by FTI Consulting The study, titled "The Black Market for E-Cigarettes in Germany: Structures, Dynamics and Regulatory Challenges," reveals that high taxes, increasing regulation, and inadequate enforcement will result in tax losses of up to €390 million in 2024 alone.
As the brand owner of
Read our article on this topic as well. Statement on the research findings of LMU.
"The uncontrolled influx of illegal products undermines consumer protection and puts responsible manufacturers at a disadvantage. We want to work together with German authorities and market players on clear and consistent rules – with the aim of effectively curbing the black market," explains a spokesperson for [organization name].
Organized networks behind the boom
From producers outside the EU to intermediaries, and on to online shops and kiosks in Germany: Organised criminal groups exploit differences in taxation, regulation and control between member states to smuggle millions of illegal products into the market.
Countries with no or low excise taxes – especially the Netherlands – serve as gateways into the internal market.
Why consumers buy illegally
Price, product variety, and easy accessibility are driving demand. Online retailers without adequate age verification create access for minors and offer enormous price advantages: Untaxed e-liquid costs around 10 euros per liter, compared to around 300 euros per liter with proper taxation.
Overburdened control, limited effect
Around 98 percent of all e-cigarette shipments to Germany go unchecked. Many suppliers operate outside the EU and thus evade German jurisdiction. Differing national regulations for vaping products complicate Europe-wide coordination, while customs and tax authorities work with limited resources. According to a study, approximately 80 percent of all reports of illegal sellers go unanswered – a clear indication of structural overload.
A new generation of illegal products
The black market is becoming increasingly invisible and professional: Classic counterfeits are giving way to private labels from illegal suppliers that bear no labeling, warnings, tax stamps or ingredient lists.These products circumvent all safety standards – often with excessive volumes or nicotine concentrations, as well as demonstrably problematic ingredients. Especially so-called Big Puffs, Those that far exceed the legally permitted 2 milliliters are widespread.
Regulation with side effects
The study points out that while disproportionate taxation and restrictive measures have intended steering effects, they also produce counterproductive consequences: Legal products become less accessible to adult consumers, while the illegal market continues to grow – with decreasing consumer protection and increasing tax losses.
OUTLOOK: Breaking the cycle
The study shows that the current situation has arisen from the interplay of regulatory complexity, limited enforcement resources, and organized crime. To to curb the black market, supports HG Innovation Measures in four key areas of action:
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Tax policy: Moderate taxation strengthens the legal market – over-taxation fuels the black market.
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Organized crime: Effective enforcement, rather than further regulation, is crucial to dismantling criminal structures.
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Health policy: Relationship. Fair, science-based regulation protects consumers more effectively than bans.
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Youth protection: Protecting young people means preventing illegal access, not restricting the regulated market.
The illegal trade in e-cigarettes poses massive challenges to the German market. A recent analysis not only illuminates the complex structures and dynamics of this shadow market but also highlights the urgent regulatory gaps that must be closed. Those wishing to delve deeper into the details will find comprehensive data sources, illustrative graphics, and methodological background information in the full study. the black market for e-cigarettes in Germany.
About HG Innovation Limited/Heaven Gifts
HG Innovation Limited, also known as Heaven Gifts, was founded in 2007 and is a pioneer in innovative vaporization technologies as an alternative to smoking. Between 2018 and 2021, the company transformed from a trading platform to the brand owner of leading global e-cigarette brands such as...
