Before a vape product may be placed on the market in an EU member state, the manufacturer or importer has to notify the competent authority of that state, six months in advance, through the EU common entry gate. EU-CEG is the technical system behind that requirement. It is not a marketing notification, it does not grant a licence, and it is not transferable between countries.
The obligation comes from Article 20 of the Tobacco Products Directive. Understanding what it covers explains several things that look arbitrary from the outside: why a product can be sold in Germany but not in Austria with identical packaging, why a supplier's product range changes before a national rule changes, and why a retailer asks for a notification reference before listing a new brand.
What the notification contains
The file is substantial, and it is submitted per product rather than per brand. Its core components are:
| Element | What is declared |
|---|---|
| Identity | Manufacturer, importer and responsible person, with contact details |
| Ingredients | All ingredients and their quantities by weight |
| Emissions | Testing results for the aerosol under specified conditions |
| Nicotine dose | Dose delivered per puff when tested under those conditions |
| Toxicology | Toxicological data on ingredients and emissions |
| Components | Device parts and, where relevant, the refill mechanism |
| Packaging | Samples and design of the outer packaging and warning |
| Production | The production process, described in enough detail to be auditable |
| Commercial | Entry into the market, mode of sale, and annual volumes |
A dual or triple flavour device makes this heavier rather than lighter: one hardware platform with three liquid formulations produces three sets of ingredient and emission data, not one. That is a cost that shows up in why small brands launch fewer variants than their advertising suggests.
Six months is a floor, not a waiting period
The notification has to be submitted at least six months before the product is placed on the market. In practice the period is longer, because the submission has to be complete: a file that is missing emission data is not a submitted notification, and the clock does not start until the authority accepts it.
This is why new product ranges appear in a predictable rhythm. A device announced in spring for a summer launch was notified in the previous autumn, and a range that appears with unusual speed usually means the platform and formulations were notified earlier under a different name.
One notification per country
There is no single EU-wide notification. The system is common, but the obligation is national: a product intended for sale in Germany, Czechia and Sweden requires a notification in each of those member states, and a product intended for all 27 requires 27.
Member states may also charge a fee, and the fees vary widely. Some charge nothing, some charge a few hundred euros per product, some charge per variant. That cost structure is why a manufacturer launching across the EU often staggers the rollout: the notification cost for a small market can exceed the revenue that market will produce.
This is also the mechanism behind a pattern that puzzles buyers: a product page in one country lists a flavour that a neighbouring country's page does not. It is not a logistics gap. The variant was notified in one country and not the other.
Who is responsible
The obligation falls on the manufacturer and on the importer. For a product made outside the EU, the importer established in the EU becomes the responsible party for the market it places the product on. That is a substantive role, not a formality: the importer's name goes into the file, and the importer is the party the authority contacts.
For a brand selling into the EU through distribution, this pushes responsibility down the chain. A wholesaler importing directly carries the notification burden for the markets it serves, which is why some wholesalers will only supply retailers with products already notified in the relevant countries. Our wholesale guide covers how that shapes a supply agreement.
What happens after notification
Notification is not a one-off. The file has to be updated when the composition changes, when the packaging changes, and when the production process changes. Each year the notifier must also report sales volumes, the preferences of different consumer groups, and the modes of sale used, which is a market-surveillance instrument rather than a formality.
Authorities use the data to compare what is declared with what is on the shelf. A discrepancy between the declared nicotine content and a tested sample is the usual starting point for enforcement, and the consequence is withdrawal of the product from the market rather than a fine on the labelling.
What notification does not do
It does not authorise the product. A notified product can still be non-compliant on labelling, on advertising, or on a national flavour rule, and it can still be banned outright by a member state. The Article 20 walkthrough separates the notification duty from the other obligations in the same article.
It also does not travel. A notification in Germany says nothing about Austria, which has its own restrictions on distance selling and its own timetable for a disposable ban. The country-by-country picture is in our flavour rules guide and, for the northern member states, in the Baltic overview.
What a retailer should ask a supplier
Four questions cover the ground. Which member states has this product been notified in? What is the notification reference for each? Who is the responsible importer for our market? And what changed in the last revision? A supplier who cannot answer the first two is selling stock that cannot be lawfully placed on the market in the country you are selling into, whatever the invoice says.
The packaging side of the same obligation — warnings, font sizes, child-resistant closures — is covered in EU packaging and labelling rules. The tax side, which is national and separate, is in vape tax across Germany, Austria and France.
Frequently asked questions
Is EU-CEG a registration or an approval?
A registration. It creates a record and starts the six-month clock; it does not certify compliance or grant permission to sell.
Can a retailer submit the notification?
Only if the retailer is also the importer placing the product on the market. A shop buying from an EU distributor is not the notifying party.
Does a nicotine-free product need notification?
The Article 20 notification duty attaches to nicotine-containing products. Nicotine-free products fall under general product safety and national rules, which vary, and several member states restrict them separately.
What is the penalty for selling an unnotified product?
It varies by member state and typically includes withdrawal from the market, a fine, and in some countries a prohibition on the responsible person trading in the category for a period.
Does a reformulation require a new notification?
It requires an update to the existing one, and the updated file has to be in place before the changed product is placed on the market.
