The short answer
Who needs approval for UK Vaping Products Duty, when duty stamps apply, how the 2026/27 old-stock window works and what retailers must check.
The UK Vaping Products Duty and Vaping Duty Stamps Scheme start changing the way businesses manufacture, import, warehouse and sell vaping products from 1 October 2026. The first question is not simply “do I sell vapes?” It is what activity does my business perform?
Manufacturers, importers, businesses handling duty stamps and certain warehouse or overseas-representative arrangements may need HMRC approval. A business that only sells or distributes duty-paid stock wholesale or retail generally does not need that approval, but it must still check stamps, supplier evidence and the transition dates before buying or selling stock.
The duty itself is charged at a flat rate of £2.20 per 10 millilitres of vaping liquid, or 22 pence per millilitre, whether or not the liquid contains nicotine. It is an excise duty on the vaping liquid, not a percentage of the retail price. A 2ml pod therefore produces an illustrative duty liability of £0.44 before any rounding, while 10ml produces £2.20. HMRC says the liability is rounded down to the nearest penny on each monthly return. VAT, customs duty, product safety and tobacco rules remain separate questions.
Approval depends on the activity
The key start date is 1 October 2026
Old stock has a limited window
Who may need HMRC approval
You should review the approval requirement if your business does any of the following:
- manufactures vaping products in the UK, including products made from ingredients on the premises;
- stores vaping products under duty suspension;
- purchases or affixes vaping duty stamps as a UK manufacturer or warehousekeeper; or
- acts as the UK representative for an overseas manufacturer that needs access to the stamp system.
HMRC says the approval must be for a single legal entity. It is not a blanket approval for a group of unrelated companies, and a joint application can be rejected. Applications should normally be made at least 45 working days before the intended activity, although HMRC may need longer for a complex case.
From 1 October 2026, the required approval must be in place before a regulated activity begins. Producing without the required approval can lead to civil or criminal consequences, confiscation and penalties. Keep the approval letter and any premises, business-plan or financial-guarantee conditions with the compliance file.
What the duty and stamps cover
Vaping Products Duty applies to vaping liquid, including liquids with or without nicotine. HMRC describes products made from substances such as propylene glycol, vegetable glycerine and flavourings as within the scope where they are intended for vaping. The detailed chargeability and duty-point rules still depend on how the product is made, imported, held and released.
The duty stamp is attached to the outermost retail packaging. Digital stamps include a scannable feature and supply-chain events can require activation or scanning. Businesses also need accurate product and stock data, such as the product description, barcode, volume and product type, when using the stamp system.
Do not treat a duty stamp as proof that every tax or product-safety requirement has been met. The stamp scheme is one part of the excise and supply-chain compliance process.
Calculate the duty and identify the duty point
Start the calculation with the volume of vaping liquid, not the number of devices or the selling price. HMRC can use the volume shown on the retail packaging, invoice, delivery note or a similar commercial document. If different documents state different volumes, the largest reasonable stated or measured volume can be relevant, subject to obvious-error treatment. Keep the source document that supports the volume used in the return.
The duty point depends on what happens to the product. For a UK manufacturer, duty can become due when the product is released for consumption. For imports, duty is generally due when the product arrives in the UK unless it enters an approved duty-suspension arrangement. Goods in duty suspension are not the same as duty-free goods: the business must maintain the approved movement and warehouse records and account for the duty when the duty point is triggered.
An importer should therefore record the route of every shipment: origin, customs declaration, warehouse or suspension status, release date, volume and party responsible for the duty. A retailer cannot infer from a supplier invoice that duty has been paid if the product has been moved under suspension or is still subject to a later duty point. Ask the supplier for evidence of the relevant status and retain it with the stock record.
Stamps, activation and transitional stock
From 1 October 2026, liable vaping products released onto the UK market must carry a vaping duty stamp unless they are moving under duty suspension. The stamp is fixed to the outermost retail packaging. Digital stamps include a scannable feature and supply-chain tracing data, while transitional stamps have physical security features but no digital element.
HMRC's current timetable has several separate dates:
- digital stamps became available to approved businesses from 1 September 2026;
- transitional stamps can be purchased until 30 November 2026;
- transitional stamps may be affixed up to 31 December 2026;
- only digital stamps may be affixed from 1 January 2027; and
- by 1 April 2027, all vaping products outside duty suspension must carry a valid stamp.
Do not confuse the date a stamp can be purchased with the date a stamped product can be released. Stamped products cannot be released onto the open UK market before 1 October 2026. From 1 January 2027 a business cannot solve a missing digital process by applying a new transitional stamp.
Digital-stamp operators must activate the stamp when affixing it and capture the required product and movement information. HMRC also says activation must occur within the applicable period after receipt. Keep the stamp order, activation record, scan or aggregation record and product identifier together. A stamp cannot be reused once it has been affixed.
What retailers and wholesalers should do
If you only sell or distribute duty-paid vaping products, HMRC says you do not need to apply for approval merely because you are a wholesale or retail seller. You still need a supplier-control process:
- Ask suppliers how stock was produced or imported and whether a stamp is required.
- From 1 October 2026, check that new liable stock has the required stamp on the outermost retail packaging.
- If stock is unstamped, retain evidence that it was produced or imported before 1 October 2026 or that another lawful exception applies.
- Do not buy, supply or sell stock that appears unstamped, damaged, reused, altered or unsupported by credible commercial records.
- Keep invoices, delivery notes, supplier details, production/import dates and the checks made on each relevant stock line.
The transition is not permission to sell unknown stock. If the supplier cannot explain why an unstamped product is lawful, resolve the issue before the stock enters your supply chain.
Transitional dates for 2026/27
| Date | What businesses should check |
|---|---|
| 1 October 2026 | New liable products released onto the UK market generally need a vaping duty stamp; required approvals must be in place before regulated activities begin. |
| 1 October 2026 to 31 March 2027 | Eligible unstamped stock produced or imported before 1 October 2026 may continue through the limited sell-through period if the business keeps evidence. |
| 1 January 2027 | HMRC guidance says only digital stamps may be affixed from this date. |
| 1 April 2027 | Vaping products outside duty suspension must carry a duty stamp; unstamped stock should no longer be sold or held for sale. |
Dates do not replace the product and movement tests. For example, an imported product may have different steps depending on whether it enters duty suspension, is released at import or is stamped through an approved UK representative.
Returns and the online service
An approved vaping-products manufacturer should enrol in HMRC's Manage your Vaping Products Duty online service as soon as it receives its approval ID. HMRC says the service is used for monthly returns and payments, and a nil return is still required for a month in which no vaping products were manufactured. The first return is due on 7 November 2026 according to the current service guidance.
The online-service obligation is separate from the approval application and from the duty-stamp supply-chain process. Keep a reconciliation between production volumes, stock movements, duty calculations, stamps and each return. If your business imports, exports or holds goods under duty suspension, use the specialist HMRC guidance rather than assuming the manufacturer workflow applies.
For a manufacturer, the monthly reconciliation should tie together litres produced, opening and closing stock, goods released, goods destroyed or returned, goods in suspension, stamps used and the duty calculated at £0.22 per millilitre. Investigate differences before submitting the return. A nil return can still be required where the business remains registered or approved but has no liability for the period; do not stop filing solely because production paused.
Records and evidence
A defensible file should show:
- the legal entity responsible for each activity;
- HMRC approval numbers and approval conditions, where applicable;
- production, import, warehouse and release dates;
- product volumes and stock-keeping-unit data;
- stamp orders, activation or scanning evidence where relevant;
- supplier invoices, delivery notes and origin information; and
- what happened to unstamped, returned, exported, destroyed or otherwise non-compliant stock.
HMRC's retail guidance says businesses should keep clear records for at least 6 years. Use the current HMRC record-keeping instruction for the exact record and retention requirement that applies to your role.
Frequently Asked Questions
Do vape shops need approval for Vaping Products Duty?
When do vaping duty stamps become mandatory in the UK?
Can I sell unstamped vape stock after 1 October 2026?
Who must submit Vaping Products Duty returns?
Is Vaping Products Duty the same as VAT?
How early should I apply for Vaping Products Duty approval?
When is the first Vaping Products Duty return due?
Can paper vaping duty stamps be used after 1 January 2027?
How long should a vaping-products business keep its records?
Start with HMRC's impact checker, then read the approval guidance if your business manufactures, imports, warehouses or handles stamps. For wider indirect-tax context, see the UK VAT registration guide and keep this scheme separate from ordinary VAT registration decisions.
Reconcile the stock position before release
Create a stock schedule by product and batch showing production or import date, duty status, stamp status, supplier, warehouse location, quantity and release date. Reconcile the schedule to invoices, delivery notes, customs records, production records and the monthly duty return. Flag stock that is damaged, returned, exported, destroyed or transferred between duty-suspension arrangements, and retain the evidence for the decision. A retailer should be able to explain why every unstamped unit is within a stated transition or exception rather than relying on a supplier’s verbal assurance.
Official sources
- HMRC: Check if you are impacted by Vaping Products Duty
- HMRC: Apply for approval for Vaping Products Duty
- HMRC: Handling wholesale or retail vaping products
- HMRC: How vaping duty stamps work
- HMRC: How to pay Vaping Products Duty
- HMRC: Vaping Products Duty online service
- HMRC: One month until Vaping Products Duty and the Vaping Duty Stamps Scheme start
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Review notes and assumptions
Reviewed
2026-09-22
Assumptions
- This guide reflects HMRC guidance available on 20 September 2026. Businesses should check the latest HMRC notices and approval letter before importing, manufacturing, stamping or releasing stock.
- The guide is about UK Vaping Products Duty and the duty-stamp scheme, not tobacco, nicotine-product safety rules or general VAT treatment.
- Whether a product is liable, in duty suspension or covered by an exception depends on the product, movement and supply-chain facts.