E-liquids
Refill liquids for electronic cigarettes, with or without nicotine, including bases, flavour concentrates and DIY boosters where the market treats them the same way.
verified 10.07.2026 · TPD Pro regulatory desk
Not every value on this page is confirmed.
Fields carrying a Draft marker come from a measure that is not in force. Fields carrying Needs check have not yet been verified at source. Both are marked individually next to the value, and the open questions are listed at the foot of this page.
Position
Where this stands, in words.
Fully regulated under tobacco law and lawfully marketable subject to the requirements of TabakerzG and TabakerzV. Germany goes further than the directive in two respects: the scope was extended to nicotine-free e-cigarettes and refill containers by the second amending act of 23.10.2020, and the excise is high.
TabakerzG
Permitted where the business is registered and operates an age-verification system.
§ 22 TabakerzG; § 31 TabakerzV
Requirements
Every parameter, with its source.
A field with no source is not shown at all — not shown with a caveat, not shown. Anything missing from this table is missing because it has not been verified, not because it does not apply.
Legal basis
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Base law
The act the category is governed by in this market.
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Tabakerzeugnisgesetz (TabakerzG)
TabakerzG gesetze-im-internet.de verified 10.07.2026
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Implementing act
The decree, regulation or ordinance carrying the detail.
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Tabakerzeugnisverordnung (TabakerzV)
TabakerzV gesetze-im-internet.de verified 10.07.2026
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EU-level regulation
Whether and how the category is covered by EU law. A category outside EU law is regulated market by market, with no common floor.
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Directive 2014/40/EU (TPD2) — transposed
The second amending act to TabakerzG of 23.10.2020 (BGBl I 2020, 2229) extended the scope of tobacco law to nicotine-free e-cigarettes and refill containers, so the requirements apply to nicotine-free products as well.
Directive 2014/40/EU eur-lex.europa.eu verified 10.07.2026
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Competent authority
Who regulates, who supervises, and who receives the filing.
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BVL together with the Länder supervisory authorities; EU-CEG verification depends on the Land the business sits in
In Bavaria this is the LGL; other Länder designate other bodies. Identify the authority before filing.
bvl.bund.de verified 10.07.2026
Composition and limits
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Maximum nicotine
The ceiling on nicotine content, in the unit the act sets it in.
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20 mg/ml
Liquids that exceed it are not marketable.
§ 14 Abs. 1 S. 2 TabakerzG gesetze-im-internet.de verified 10.07.2026
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Container volume
Ceilings on refill container and tank or cartridge volume.
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Refill container 10 ml; disposable device or pre-filled pod 2 ml maximum
The volume limits attach to nicotine-containing products. Nicotine-free bases and pure glycerine are not caught by them. The same 10 ml limit applies to nicotine shots.
§ 14 TabakerzG gesetze-im-internet.de verified 10.07.2026
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Prohibited ingredients
Substances that may not be present, beyond the general prohibition on hazardous ones.
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Vitamins, caffeine, taurine and stimulant compounds, and any substance posing a risk
Ingredients suggesting a health benefit are prohibited alongside those posing a risk.
§ 28 and Anlage 2 TabakerzV gesetze-im-internet.de verified 10.07.2026
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Flavour restriction
Whether characterising flavours are restricted, and from when. One of the most widely misreported fields in this sector.
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Not restricted. A draft ministerial bill of 23.01.2026 would prohibit 13 flavour substances but is not in force Draft
Consultation closed 13.02.2026 and commencement is realistically no earlier than late 2026 or early 2027. Until then all flavours are lawful. This is a draft, not a statement of current law.
BMLEH Referentenentwurf, 23.01.2026 bvl.bund.de verified 10.07.2026
Packaging and labelling
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Mandatory warning
The statutory wording. Reproduced verbatim in the language of the act, because the text on the pack must match it.
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Dieses Produkt enthält Nikotin: einen Stoff, der sehr stark abhängig macht.
§ 27 TabakerzV gesetze-im-internet.de verified 10.07.2026
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Other packaging requirements
Leaflet, child resistance, tamper evidence, and prohibited presentation.
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Ingredients in descending order by weight; nicotine content and delivery per dose; batch number; a keep-away-from-children statement; a German-language leaflet headed Gebrauchsinformationen; child, tamper and leak protection
Attributing health or stimulant effects, or suggesting reduced harm, is prohibited.
§§ 26–27 TabakerzV gesetze-im-internet.de verified 10.07.2026
Notification
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Notification channel
Where the filing goes. Not an assumption: some markets take these products outside EU-CEG entirely, and some have no channel at all.
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EU-CEG; administered by the BVL
§ 24 TabakerzV bvl.bund.de verified 10.07.2026
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Lead time
How far ahead of market entry the notification must be filed.
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6 months before market entry
Substantial changes require the same six months before the changed product goes on sale.
§ 24 TabakerzV gesetze-im-internet.de verified 10.07.2026
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Data required
What has to be in the dossier.
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Formulation, toxicology, nicotine dose and uptake, per Implementing Decision (EU) 2015/2183
§ 24 TabakerzV; Decision (EU) 2015/2183 gesetze-im-internet.de verified 10.07.2026
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Annual reporting
The recurring obligation after market entry, and its deadline.
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Sales volumes for the preceding year, by 30 June
§ 25 TabakerzV gesetze-im-internet.de verified 10.07.2026
Sales
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Minimum age
The age below which sale is prohibited.
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18 years
Applies to nicotine-free products as well. The Federal Court of Justice held on 11.03.2026 (I ZR 106/25) that the prohibition on supply to minors extends to empty replacement tanks, which are containers within the meaning of the JuSchG.
§ 10 JuSchG gesetze-im-internet.de verified 10.07.2026
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Online and distance sale
Whether the product may be sold remotely, domestically and across borders.
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Permitted with an age-verification system; cross-border distance selling requires registration
§ 22 TabakerzG; § 31 TabakerzV gesetze-im-internet.de verified 10.07.2026
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Vending machines
Whether unattended sale is permitted, and under what age control.
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Permitted with age control; free samples in public spaces are prohibited
§ 10 JuSchG; § 20a TabakerzG gesetze-im-internet.de verified 10.07.2026
Excise and chemicals
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Advertising
What promotion is permitted, if any.
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Prohibited on radio, in print and online; outdoor advertising prohibited since 01.01.2024
Search advertising and influencer content count as advertising and are therefore not permitted. Factual product information in a trader's own shop is permitted, and the exterior of a specialist shop is excepted from the outdoor prohibition.
§ 19 Abs. 1–3, § 20a TabakerzG gesetze-im-internet.de verified 10.07.2026
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Excise
The rate and its basis of assessment. Five markets use four different units, so the unit travels with the figure.
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0.32 €/ml
In force from 01.01.2026, the fourth step of the schedule: €0.16 from July 2022, €0.20 in 2024, €0.26 in 2025, €0.32 in 2026. The tax is assessed on volume, not on nicotine, and applies to nicotine-free liquids, bases, flavourings, nicotine shots and disposable devices alike. With VAT the total burden is roughly €0.38 per ml.
§ 1b TabStG; TabStMoG gesetze-im-internet.de verified 10.07.2026
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Excise mechanism
Who is liable, what marking is required, and through which system.
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Tax stamp (Steuerbanderole) mandatory since 13.02.2023; administered by customs
Products without a stamp are unlawful.
TabStG gesetze-im-internet.de verified 10.07.2026
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Chemicals legislation
REACH, CLP, safety data sheets and poison-centre notification, which apply in parallel to the product regime.
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CLP, REACH and the General Product Safety Regulation apply in parallel with tobacco law
Regulation (EC) 1272/2008; Regulation (EC) 1907/2006; Regulation (EU) 2023/988 bvl.bund.de verified 10.07.2026
Mandatory warning
The statutory wording, verbatim.
Reproduced exactly as the act sets it, in the language it sets it in. The text on your pack has to match this character for character, so it is never paraphrased and never machine-translated here. Where an English gloss is given it is unofficial and is not the text to print.
Dieses Produkt enthält Nikotin: einen Stoff, der sehr stark abhängig macht.
unofficial gloss — This product contains nicotine, a substance that is highly addictive.
§ 27 TabakerzV gesetze-im-internet.de
Commonly misreported
What the internet gets wrong.
Nicotine-free e-liquids fall outside German tobacco law.
what the source saysThey do not. The second amending act to TabakerzG of 23 October 2020 extended the scope to nicotine-free e-cigarettes and refill containers, so the tobacco-law requirements apply to both. The excise is assessed on volume rather than nicotine and catches nicotine-free liquids, bases and flavourings as well.
2. ÄndG TabakerzG of 23.10.2020, BGBl I 2020, 2229; § 1b TabStG gesetze-im-internet.de
Not in force
What is coming for this category.
None of this is law today.
Prohibition on 13 flavour substances in e-liquids
A draft. It is not law and does not bind anyone.
A BMLEH ministerial draft of 23 January 2026 would prohibit 13 named flavour substances. Consultation closed on 13 February 2026. Commencement is realistically no earlier than late 2026 or early 2027, with a transitional period expected. Until it is enacted every flavour remains lawful, and the final list of substances is not settled.
BMLEH Referentenentwurf, 23.01.2026 bvl.bund.de
TPD3 — revision of the EU Tobacco Products Directive
A draft. It is not law and does not bind anyone.
On 2 April 2026 the Commission published its evaluation of the Tobacco Products and Tobacco Advertising Directives (SWD(2026) 111). It found new public health concerns from e-cigarettes, heated tobacco and nicotine pouches, and problems with online promotion. A public consultation ran until 14 August 2026. A proposal to revise both directives is planned for December 2026 but has not been published.
Commission initiative 17612 (revision of Directives 2014/40/EU and 2003/33/EC); evaluation SWD(2026) 111 final, 02.04.2026 health.ec.europa.eu
Open questions
What we have not closed yet.
| Priority | Question | Where to look |
|---|---|---|
| Medium |
Prohibition on 13 flavour substances in liquids (draft of 23.01.2026): the final list, the commencement date and the transitional period. blocks: flavour-restriction |
BMLEH · Bundesrat · Bundesgesetzblatt |
| Medium |
Which authority verifies the EU-CEG notification depends on the Land the business is established in. Identify it before filing. blocks: competent-authority |
Merkblätter of the relevant Land |
| Low |
Currency of safety data sheets and CLP and GPSR labelling for e-liquids. |
Own technical documentation |
| Low |
Restrictions on where consumption is permitted are set by the Länder and by property rules; there is no single federal norm. |
The relevant Land or venue |
verified 10.07.2026 · TPD Pro regulatory desk