UK Vaping Products Duty: Eight Actions Businesses Must Take Immediately Before 1 October 2026

Eight Actions for Businesses

1. Establish which HMRC approvals your business needs: Not every business in the supply chain needs HMRC approval. From 1 October, businesses must hold the appropriate HMRC approval before manufacturing vaping products, storing them under duty suspension, purchasing or affixing duty stamps, or acting as the approved UK representative of an overseas manufacturer. Importers who are not themselves an approved warehousekeeper or stamp purchaser must confirm that their goods move directly to an approved duty-suspension warehouse, or that duty has been paid and stamps affixed before or at the point of import.
   
   Applications opened on 1 April 2026. HMRC allows at least 45 working days, around nine weeks, to process an application. With under four weeks left before 1 October, any business that has not already applied should treat itself as at high risk of missing the start date, and should apply immediately to limit further delay.
   
   Overseas manufacturers who want duty stamps applied before export must appoint a UK representative. That representative takes on legal and financial responsibility for the stamps and must itself hold Vaping Duty Stamp Scheme approval. This is a substantial liability and should be set out in a formal written agreement between the parties, not left as an informal arrangement.
   
   Existing authorised warehousekeepers who want to store vaping products under duty suspension need to request an amendment to their current approval, not a fresh application.
2. Calculate your Vaping Products Duty liability: The duty is £2.20 per 10ml (£0.22 per ml) on all vaping liquid, including zero-nicotine liquid. VAT continues to apply separately, on top of the duty. In practice: a 2ml pod attracts 44p in duty, a 10ml bottle attracts £2.20, and a 100ml shortfill attracts £22, before VAT and any other pricing effects. HM Treasury expects the duty to raise more than £550 million a year by 2030-31.
3. Order and prepare to affix the correct duty stamps: Products manufactured or imported on or after 1 October 2026 must be stamped before release for UK consumption, unless they remain under an approved duty-suspension arrangement. A stamp must seal the outermost retail packaging, so that opening the product damages the stamp and it cannot be reused. Only approved manufacturers, warehousekeepers and UK representatives may buy stamps, from the appointed supplier's secure ordering platform; build in time for supplier lead times and for secure on-site storage, since stamps are themselves treated as high-value excise items.
   
   Transitional stamps, carrying security features only, can be purchased until 30 November 2026 and must not be affixed to products from 1 January 2027 onwards.
   
   Digital stamps, available since 1 September 2026, are not simply a tax label: they are a track-and-trace system requiring scanning and data upload at the point of affixing, on movement under duty suspension, and on release for consumption, including the time, date and address of affixing and the operator's identity. From 1 January 2027, only digital stamps may be affixed. Check now whether your warehouse management system can integrate with the HMRC portal, or budget for manual data entry, which is slower and more error-prone.
4. Set up your import and duty-suspension arrangements: Once vaping products are packaged for retail sale, they can generally only be moved in duty suspension once, either between two approved places or from the point of import to a single approved location. Plan storage and distribution routes accordingly, since a second duty-suspended movement is not normally available. HMRC is also considering whether financial guarantees will be required for businesses purchasing stamps; waivers are expected for established manufacturers and warehousekeepers with a clean compliance record, but businesses newer to the market, or with a weaker compliance history, should be prepared for the possibility of a bond or bank guarantee and are advised to raise this with HMRC early.
5. Clear your transitional stock correctly: Eligible products manufactured or imported before 1 October may continue to be sold unstamped until 31 March 2027. This is a sell-through allowance for existing stock, not permission to keep importing or manufacturing unstamped products after 1 October. The burden of proof sits with the business: be ready to show, through documentary evidence such as purchase orders and shipping manifests, that stock was manufactured or imported before 1 October 2026. A first-in-first-out stock system will help avoid unstamped and stamped stock becoming commingled. From 1 April 2027, all vaping products outside duty suspension must carry a valid stamp.
6. Set up Vaping Products Duty returns, payments and records: Approved businesses must submit an online VPD return by the seventh day of each month. Payment is due by the 15th day of the month following the accounting period, or the next working day where that falls on a weekend or bank holiday. Build this into existing VAT and excise reporting cycles rather than treating it as a standalone process.
7. Check your Northern Ireland, single-use and wider retail exposure: This briefing sets out the general UK position. Northern Ireland businesses, particularly those acquiring vaping products from EU member states, follow a different process and should take route-specific advice before 1 October. Single-use vapes are a separate issue again: they have been illegal to sell or supply since 1 June 2025, with no stock exception, and any leftover stock must be recycled rather than sold through, regardless of its duty or stamp status. Separately, from 29 October 2026, retailers face a statutory age-18 sale limit, a proxy-purchase offence, and restrictions on giving away or heavily discounting vaping and nicotine products for promotional purposes. Government has also confirmed it intends to introduce a separate Nicotine Approval Scheme controlling the supply of nicotine, though the timetable has not yet been confirmed; this is worth watching, since it may affect organisations beyond finished-vape manufacturers.
8. Verify your supply chain and prepare your evidence: The new regime creates shared exposure across the supply chain. Before 1 October, request written confirmation from suppliers that they hold the correct HMRC approvals, and from customers that they are entitled to receive unstamped or duty-suspended stock. If a customer buys unstamped stock without the correct approval, the supplying business can be exposed too; if a supplier's approval is refused or withdrawn, a business built on that supply chain can lose its stock overnight. Collate the purchase orders and shipping documents that prove your own transitional stock is eligible (see Action 5) as part of the same exercise.

The Cost of Getting This Wrong

HMRC's published sanctions for the duty stamp scheme are not nominal. Civil penalties for unstamped products scale with volume and repetition, from £2,500 for a first offence involving fewer than 100 units up to £10,000 for repeated or larger-scale breaches; a lost or stolen stamp attracts a penalty of five times the duty due on a standard 10ml quantity. Products and stamps can be seized and permanently forfeited, and repeated non-compliance can see a business barred from buying stamps at all. In serious cases, HMRC can pursue criminal prosecution, carrying an unlimited fine, imprisonment of up to two years, or both.

Why This Matters Beyond Compliance

The new duty and stamp scheme are being introduced into a market that enforcement agencies already describe as contested. Our companion briefing, "From Tax Evasion to Controlled Drugs: Why Illicit Vapes Are Becoming a Customs and Crime Problem," sets out what the evidence shows, and does not show, about the illicit vaping market, and why lawful operators have a direct commercial interest in a market that plays by the rules.