Measure

Nicotine Approval Scheme and Vaping Products Duty 

The measure

The government has launched a 12-week consultation on the policy design of a Nicotine Approval Scheme (NAS). The NAS will introduce controls on the supply of high-strength nicotine in the UK to help tackle the illicit domestic manufacture of vaping liquid and subject to consultation will be implemented from 1 April 2028. 

Alongside this measure, following the commencement of Vaping Products Duty (VPD) on 1 October 2026, the government will introduce legislation in Finance Bill 2026-27 to correct VPD legislation and enable HMRC officers to seize any article involved in the illicit manufacture of vaping products.  

 

Who will be affected?

Manufacturers, retailers, and consumers of vaping products.

 

When will the measure come into effect?

Subject to consultation, implementation is anticipated from 1 April 2028. 

The amendment for the seizure of articles involved in the illicit manufacture of vaping products for offences that occur on or after 4 November 2026 will take effect on 1 January 2027. The amendment for the deeming provision will take effect on 4 November 2026.

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Our view

The proposed NAS represents a further tightening of the government’s approach to protecting the new Vaping Products Duty (VPD), which came into force on 1 October 2026. 

Changes to legislation will also provide a power for HMRC to ‘deem’ that suspected vaping products were imported or manufactured after VPD’s introduction on 1 October 2026, further strengthening HMRC's ability to enforce VPD.