Introduction

If you sell nicotine-containing e-liquid in the EU, your packaging isn't just a design choice — it's a legal requirement. The Tobacco Products Directive (TPD, 2014/40/EU) sets specific rules for how refill containers must be built. This guide breaks down what the directive actually requires and how that translates into choosing a bottle.

What TPD Article 20 Requires

Article 20(3)(g) of the directive states that refill containers must be child- and tamper-resistant, protected against breakage and leakage, and fitted with a mechanism that allows refilling without spillage. In practice, this means your bottle needs a genuinely child-resistant closure — not just a tight-fitting cap — plus a tamper-evident seal that shows if the bottle has already been opened.

Volume and Strength Limits

Alongside the packaging rules, the TPD sets hard limits on the product itself:

• Nicotine-containing liquid in refill containers must not exceed 10 ml
• Nicotine concentration must not exceed 20 mg/ml
• Cartridges and tanks are capped separately at 2 ml

These limits shape which bottle sizes are relevant for nicotine-containing e-liquid in the first place — anything above 10ml simply isn't an option for a nicotine refill container, regardless of how it's closed.

How Compliance Is Demonstrated

The directive doesn't specify one single test method, but EN ISO 8317 is the standard most commonly used across the EU to demonstrate that a closure is genuinely child-resistant. Bottles certified to this standard — like Copackr's Unicorn V3, Aviator CR, and Spiral CR ranges — give you a documented basis for compliance rather than relying on the closure looking secure.

Labelling Also Matters

Packaging compliance under TPD goes beyond the closure. Nicotine-containing products must carry a health warning stating that the product contains nicotine, which is a highly addictive substance, along with ingredient and batch information. Bottle shape and label area — covered in our bottle size guide — directly affects how much space you have to meet these requirements.

Practical Takeaway

If you're launching or reformulating a nicotine e-liquid product for the EU market, start from the packaging requirements, not the label design: confirm your bottle is CR-certified to EN ISO 8317, stays within the 10ml / 20mg/ml limits, and leaves room for the mandatory warning text. Getting this right from the start avoids costly repackaging later.