Are you ready for HMRC’s Vaping Products Duty and Vaping Duty Stamps Scheme arriving in 2026?

HMRC have recently published updated guidance on preparing for the new Vaping Products Duty (VPD), which takes effect from 1 October 2026. This new excise duty will apply to all vaping products and substances intended for vaping, including e-liquids and even products made at home from certain ingredients, regardless of whether they contain nicotine. 

This is set to be a significant change and will impact:

1. UK manufacturers and producers of vaping products
2. Importers and non-UK suppliers bringing vaping products into the UK
3. Warehouse keepers storing vaping products in the UK
4. Retailers selling vaping products to consumers

Please note, specific rules will apply in Northern Ireland. 

Although 1 October 2026 feels like a long way off, businesses need to prepare now. Without the right HMRC approvals in place, manufacturing, selling or storing unstamped vaping products will become illegal, with civil and criminal penalties for non-compliance.

What’s changing and why it matters

From 1 October 2026: 

1. VPD will become payable when vaping products are made or imported into the UK for sale.
2. Non-reusable vaping duty stamps (purchased from specialist suppliers to be announced by HMRC) will need to be attached to the retail packaging of every vaping product before it enters the market.
3. These costs will apply in addition to any VAT, meaning a noticeable increase in retail prices. 

HMRC have indicated that a flat rate of £2.20 VPD per 10ml bottle of vaping liquid will apply, likely bringing the total cost (including VAT at 20%) to around £2.64 a bottle. 

For affected businesses, this means not just higher costs but also more compliance and administration obligations. As a result, you’ll need to ensure your production sites and supply chain are HMRC-approved, that stamps are applied correctly and tracked, and that you can evidence compliance in case of audit. 

Key dates to remember 

These dates may seem like a long time away, but HMRC have stated that approval checks for applications could take up to 45 working days. Leaving applications to the last-minute risks stock delays and disruption to your business. 

What you need to do 

It is important to note that different stakeholders will have different obligations; there’s not one rule for all, and it’s your duty to stay up to date with what’s expected of you. Failing to prepare could mean operational delays, seized stock or financial penalties. 

1. Manufacturers and producers

If you’re a manufacturer and producer, you will need to obtain HMRC’s approval for your manufacturing sites and processes before 1 October 2026, along with the ability to purchase and apply vaping duty stamps. Mixing of liquids for use in vapes will also need to be done in approved facilities. 

2. Importers and overseas suppliers

Non-UK based persons importing/supplying vaping products to the UK will need to appoint a UK representative approved by HMRC for the vaping duty stamps scheme to buy vaping duty stamps on the non-UK person’s behalf and take responsibility for compliance. The UK representative will be legally and financially liable if stamps go missing or are misused, and a financial guarantee may be required. 

3. Warehouse keepers

If you’re a warehouse keeper, you will need to review your current authorisations and request amendments where required to store vaping products or to be able to apply stamps to vaping products from 1 October 2026 onwards before they are released from duty suspension. HMRC will require clear physical separation of approved areas if manufacturing and storage are in the same building. 

4. Retailers

If you’re a retailer, you will need to put controls in place to ensure that, from 1 October 2026, products received from suppliers carry valid stamps. Any existing unstamped stocks from pre-1 October 2026 will need to be sold before 1 April 2027, after which it will be illegal to sell any vape stock without duty stamps attached. 

Applications and approvals for VPD and the Vaping Duty Stamps Scheme

When applications open in April 2026, businesses will need to provide detailed information, including:

• business name, address, and VAT/CT number (if appropriate)
• name of a responsible person
• premises plan showing where products are made/stored and how control and site security will be maintained
• business plan and financial guarantee (if required by HMRC).

HMRC approvals can cover more than one premises where vaping products are stored (for example, a factory and a duty-suspended store), but only one manufacturer will be allowed per building. If in the same physical building, these must be clearly and physically separated. Failing to obtain approval before October 2026 could mean having to halt production entirely until permission is granted. 

If approved, HMRC will issue a letter confirming the details of your approval and any additional conditions. If approval is refused, temporary approval may sometimes be granted during a review or appeal process. HMRC also have the power to cancel approvals where rules are not followed, in which case manufacturing of vaping products must stop immediately. 

Returns, payments and record-keeping 

VPD returns will normally need to be submitted online by the 7th of each month, with payment of VPD required by the 15th day of the month following the accounting period (or the next working day if 15th falls on a weekend or bank holiday). HMRC will confirm exactly what information must be included, but businesses should expect to report: 

• volumes produced or imported
• number of stamps purchased and used
• stock movements in and out of duty suspension. 

Accurate record-keeping will be essential, as HMRC may carry out audits and inspections. Errors could result in underpayment or overpayment of VPD, both of which will require correction and could result in penalties or interest charges. 

Penalties and compliance risks

HMRC have confirmed that civil and criminal sanctions/penalties may apply where the required approval is not obtained in time for VPD’s introduction, where VPD is not paid or stamps are not used correctly from 1 October 2026 onwards. This includes:

• possessing or selling unstamped vaping products
• importing or transporting vaping products without duty stamps
• forging, tampering with or attaching counterfeit stamps
• failing to comply with HMRC-approved storage or security requirements.

Even non-duty-liable stock will need to carry vaping duty stamps after 1 April 2027, following a 6-month grace period, so systems must be robust well before that date.  

HMRC have also stated there will be very limited VPD exemptions. Small quantities of vaping products brought into the UK for personal use may fall under duty-free allowance limits, which will be confirmed by HMRC before October 2026. Other potential exemptions may apply where required by law, such as for supplies to diplomatic missions, but for most businesses, VPD will apply in full. 

We’re here to help

HMRC have indicated it will continue updating its guidance as the implementation date approaches. While HMRC have set up a dedicated email address for questions, our advice is to monitor developments closely. We will keep our clients updated as further detail is released. 

The new rules represent one of the most significant changes to the excise regime in recent years and will create significant compliance and administrative burdens, particularly for businesses with complex supply chains or multiple production sites. 

Contact your usual UHY adviser to discuss how we can support you in preparing for the introduction of VPD. Acting early will give you time to implement changes, avoid last-minute disruptions and remain fully compliant when the new rules take effect. 

For more information, please read more on GOV.UK: Manufacturing vaping products overseas to send and sell in the UK