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This Video will be illegal from May 2016
obijon Offline
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Post: #31
RE: This Video will be illegal from May 2016
I think the big companies like Cuts Ice will carry on. But the smaller companies like Mr Lords might struggle. I hope the likes of Mrs Lords keep going as they are the type of juice company I love.
14/12/15 10:40 AM
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Rojeans Offline
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Post: #32
RE: This Video will be illegal from May 2016
(14/12/15 10:40 AM)obijon Wrote:  I think the big companies like Cuts Ice will carry on. But the smaller companies like Mr Lords might struggle. I hope the likes of Mrs Lords keep going as they are the type of juice company I love.
There's also the possibility that the larger companies buy up some of the smaller operations (The good ones ie; Mrs Lords) and continue with their recipes. Some of these smaller ones are not geared mechanically either. The bottling process alone will be expensive, then with runs of less than 1k, per flavour and strength, the testing will be £crippling.

One of Liverpool's first and oldest 'independent' electronic cigarette shop
Now IBVTA member.
(This post was last modified: 14/12/15 11:40 AM by Rojeans.)
14/12/15 11:39 AM
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marlowejames Offline
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Post: #33
RE: This Video will be illegal from May 2016
Out of interest does anyone have a ball park figure of what it will actually cost to take a single flavour of e-liquid with say 6 nicotine strengths tested as per the TPD in order to comply with the TPD using a third party testing lab? I appreciate that there are other indirect administrative costs involved and there is obviously the option of testing in house (larger manufacturers) but insofar as the smaller manufacturers are concerned e.g. Mrs Lords what are they actually faced with?

14/12/15 11:51 AM
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dodderer Offline
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Post: #34
RE: This Video will be illegal from May 2016
(14/12/15 11:51 AM)marlowejames Wrote:  Out of interest does anyone have a ball park figure of what it will actually cost to take a single flavour of e-liquid with say 6 nicotine strengths tested as per the TPD in order to comply with the TPD using a third party testing lab? I appreciate that there are other indirect administrative costs involved and there is obviously the option of testing in house (larger manufacturers) but insofar as the smaller manufacturers are concerned e.g. Mrs Lords what are they actually faced with?

"There is no precedent for this type of testing, and very little toxicological data available for flavourings “by inhalation”, so the costs are likely to be in excess of £10K per flavour and strength."

http://article20legalchallenge.com/suppo...challenge/

On top of this is the admin for this

http://eur-lex.europa.eu/legal-content/E...32015D2183

and no doubt the MHRA will want to make a small profit on their oversight.Given some of their costs for medregs,it won't be cheap- see Annex. Costs of Compliance

http://webarchive.nationalarchives.gov.u...286852.pdf
14/12/15 01:14 PM
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marlowejames Offline
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Post: #35
RE: This Video will be illegal from May 2016
(14/12/15 01:14 PM)dodderer Wrote:  
(14/12/15 11:51 AM)marlowejames Wrote:  Out of interest does anyone have a ball park figure of what it will actually cost to take a single flavour of e-liquid with say 6 nicotine strengths tested as per the TPD in order to comply with the TPD using a third party testing lab? I appreciate that there are other indirect administrative costs involved and there is obviously the option of testing in house (larger manufacturers) but insofar as the smaller manufacturers are concerned e.g. Mrs Lords what are they actually faced with?

"There is no precedent for this type of testing, and very little toxicological data available for flavourings “by inhalation”, so the costs are likely to be in excess of £10K per flavour and strength."

http://article20legalchallenge.com/suppo...challenge/

On top of this is the admin for this

http://eur-lex.europa.eu/legal-content/E...32015D2183

and no doubt the MHRA will want to make a small profit on their oversight.Given some of their costs for medregs,it won't be cheap- see Annex. Costs of Compliance

http://webarchive.nationalarchives.gov.u...286852.pdf

So in theory, a small cottage e-liquid manufacturer who has just 6 flavours being sold at 3mg, 6mg, 9mg, 12mg, 15mg & 18mg could be faced with a £360K+ cost if the £10K figure turns out to be an accurate figure? Do we know if these are one off costs in that once tested that's it for the indefinite future or will for example a tweak to the recipe mean that a complete new testing regime is then necessary and required? My instincts tell me that whilst these figures may be broadly accurate for outsourcing at one of the top end Pharma type labs, logic dictates that one could employ a laboratory chemist, buy a whole load of testing equipment and for far less money achieve the same result. How long does it take to actually test for 18 different e-liquids? I tend to recall (it may have been myvapery?) posting that this was the route that they were going down. Take all car garages with MOT facilities they all need to have emission testing on site and I'm just trying to gauge what the real implications from a cost perspective will be for the smaller manufacturers. Perhaps the reality is that in the ultra competitive world of e-liquid sales that the fear factor of testing costs is also being used by existing suppliers to put off any future competition? I only pose this as I've noticed a few new e-liquid manufacturers starting and I can't believe that anyone would be foolish enough to start a new enterprise post the TPD without doing their homework regarding the financial implications of testing.

14/12/15 01:58 PM
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Rojeans Offline
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Post: #36
RE: This Video will be illegal from May 2016
(14/12/15 01:58 PM)marlowejames Wrote:  
(14/12/15 01:14 PM)dodderer Wrote:  
(14/12/15 11:51 AM)marlowejames Wrote:  Out of interest does anyone have a ball park figure of what it will actually cost to take a single flavour of e-liquid with say 6 nicotine strengths tested as per the TPD in order to comply with the TPD using a third party testing lab? I appreciate that there are other indirect administrative costs involved and there is obviously the option of testing in house (larger manufacturers) but insofar as the smaller manufacturers are concerned e.g. Mrs Lords what are they actually faced with?

"There is no precedent for this type of testing, and very little toxicological data available for flavourings “by inhalation”, so the costs are likely to be in excess of £10K per flavour and strength."

http://article20legalchallenge.com/suppo...challenge/

On top of this is the admin for this

http://eur-lex.europa.eu/legal-content/E...32015D2183

and no doubt the MHRA will want to make a small profit on their oversight.Given some of their costs for medregs,it won't be cheap- see Annex. Costs of Compliance

http://webarchive.nationalarchives.gov.u...286852.pdf

So in theory, a small cottage e-liquid manufacturer who has just 6 flavours being sold at 3mg, 6mg, 9mg, 12mg, 15mg & 18mg could be faced with a £360K+ cost if the £10K figure turns out to be an accurate figure? Do we know if these are one off costs in that once tested that's it for the indefinite future or will for example a tweak to the recipe mean that a complete new testing regime is then necessary and required? My instincts tell me that whilst these figures may be broadly accurate for outsourcing at one of the top end Pharma type labs, logic dictates that one could employ a laboratory chemist, buy a whole load of testing equipment and for far less money achieve the same result. How long does it take to actually test for 18 different e-liquids? I tend to recall (it may have been myvapery?) posting that this was the route that they were going down. Take all car garages with MOT facilities they all need to have emission testing on site and I'm just trying to gauge what the real implications from a cost perspective will be for the smaller manufacturers. Perhaps the reality is that in the ultra competitive world of e-liquid sales that the fear factor of testing costs is also being used by existing suppliers to put off any future competition? I only pose this as I've noticed a few new e-liquid manufacturers starting and I can't believe that anyone would be foolish enough to start a new enterprise post the TPD without doing their homework regarding the financial implications of testing.
That is exactly what's been noted by some vendors in the vendor sub forum. They ain't done their research, other than looking at Chinese sites (EG Alibaba) to see how much profits they can make, (Been there done that STOPED that pretty quick)

One of Liverpool's first and oldest 'independent' electronic cigarette shop
Now IBVTA member.
14/12/15 02:40 PM
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xxxxx Offline
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Post: #37
RE: This Video will be illegal from May 2016
(14/12/15 01:58 PM)marlowejames Wrote:  
(14/12/15 01:14 PM)dodderer Wrote:  
(14/12/15 11:51 AM)marlowejames Wrote:  Out of interest does anyone have a ball park figure of what it will actually cost to take a single flavour of e-liquid with say 6 nicotine strengths tested as per the TPD in order to comply with the TPD using a third party testing lab? I appreciate that there are other indirect administrative costs involved and there is obviously the option of testing in house (larger manufacturers) but insofar as the smaller manufacturers are concerned e.g. Mrs Lords what are they actually faced with?

"There is no precedent for this type of testing, and very little toxicological data available for flavourings “by inhalation”, so the costs are likely to be in excess of £10K per flavour and strength."

http://article20legalchallenge.com/suppo...challenge/

On top of this is the admin for this

http://eur-lex.europa.eu/legal-content/E...32015D2183

and no doubt the MHRA will want to make a small profit on their oversight.Given some of their costs for medregs,it won't be cheap- see Annex. Costs of Compliance

http://webarchive.nationalarchives.gov.u...286852.pdf

So in theory, a small cottage e-liquid manufacturer who has just 6 flavours being sold at 3mg, 6mg, 9mg, 12mg, 15mg & 18mg could be faced with a £360K+ cost if the £10K figure turns out to be an accurate figure? Do we know if these are one off costs in that once tested that's it for the indefinite future or will for example a tweak to the recipe mean that a complete new testing regime is then necessary and required? My instincts tell me that whilst these figures may be broadly accurate for outsourcing at one of the top end Pharma type labs, logic dictates that one could employ a laboratory chemist, buy a whole load of testing equipment and for far less money achieve the same result. How long does it take to actually test for 18 different e-liquids? I tend to recall (it may have been myvapery?) posting that this was the route that they were going down. Take all car garages with MOT facilities they all need to have emission testing on site and I'm just trying to gauge what the real implications from a cost perspective will be for the smaller manufacturers. Perhaps the reality is that in the ultra competitive world of e-liquid sales that the fear factor of testing costs is also being used by existing suppliers to put off any future competition? I only pose this as I've noticed a few new e-liquid manufacturers starting and I can't believe that anyone would be foolish enough to start a new enterprise post the TPD without doing their homework regarding the financial implications of testing.

They could possibly restrict testing to a set of 'trusted' providers or jack up certification requirements to circumvent such innovative workarounds

Vaping is just another habit
14/12/15 02:47 PM
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dodderer Offline
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Post: #38
RE: This Video will be illegal from May 2016
(14/12/15 02:47 PM)xxxxx Wrote:  They could possibly restrict testing to a set of 'trusted' providers or jack up certification requirements to circumvent such innovative workarounds

I think there are standards (being) set - not sure where things stand at the moment

http://ec.europa.eu/health/tobacco/docs/..._sr_en.pdf

There was also something in the UK - Lorien was involved - but I've forgotten what - probably this!

http://ecita.org.uk/ecita-blog/summary-b...-pas-54115

Also may use 'central' manufacturer e.g.

http://www.theguardian.com/society/2015/...egafactory

Would make sense to use big specialist manufacturer who could get all certifications - customers would then just retail but obviously giving up some margin.Recipes then might become more secret - subject to Art 20 requirements!
(This post was last modified: 14/12/15 03:19 PM by dodderer.)
14/12/15 03:14 PM
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NorthStaR Offline
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Post: #39
RE: This Video will be illegal from May 2016
So how come current testing on a juice is around £100 a sample? Simple short answer please Smiling I'm no scientist...
14/12/15 03:14 PM
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FlavourArtUK Offline
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Post: #40
RE: This Video will be illegal from May 2016
Current testing is a very basic analysis of the liquid.
TPD testing requires emission and toxicology information.
I have heard of a £4.5k quote for this for 1 flavour/strength.

FlavourArt Italy are putting details around an end to end package that will offer a testing
and registration service conducted by FEM2 Ambiente, the bio-tech company from Milan University.
This will initially be for liquids using FlavourArt flavourings as FEM2 already have the data stored
following the testing already completed. The pricing should be competitive and FEM2 are extremely
skilled and experienced in this field.

John.

√-1 2^3 ∑ π and it was delicious!
İmage
14/12/15 03:23 PM
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