Vaping Products Duty: get approved, pay the duty and use duty stamps

Vaping Products Duty is a new excise duty on vaping liquid, charged from 1 October 2026, with a duty stamps scheme that reaches every product on the UK market by 1 April 2027. This guide covers approval, returns and payment, stamps and, if you only sell duty-paid stock, the sell-through of unstamped stock. For the dated milestones in one place, see the update Vaping products duty starts on 1 October 2026.

1. What the duty is and who it applies to

From 1 October 2026, Part 4 of the Finance Act 2026 charges excise duty on vaping liquid produced in, or imported into, the UK. It is charged on the liquid, not the device, at a single flat rate by volume, whether or not the liquid contains nicotine. Shortfills, nicotine shots and liquids that must be mixed before use are all in scope; only medicinal and tobacco products fall outside the definition. The duty applies across the UK, including Northern Ireland, and VAT is charged on top of it.

Two neighbouring regimes are easy to confuse with it. Tobacco products duty and tobacco track-and-trace apply to tobacco only, so a business dealing in both runs two separate stamp systems. The Tobacco and Vapes Act 2026 is a public-health regime enforced by Trading Standards, not HMRC: it governs who you may sell to, not what you pay.

The duty reaches you if you make vaping liquid in the UK (including mixing non-duty-paid liquid), import it, hold it in duty suspension or represent an overseas manufacturer. If you only sell duty-paid stock, go to section 5.

2. Get approved before you produce, import into suspension or store

From 1 October 2026 you must hold an HMRC approval before you produce vaping products or hold them in duty suspension. That covers UK manufacturers, including anyone who mixes non-duty-paid liquid; excise and customs warehousekeepers, who must ask HMRC to amend their existing approval; and UK representatives of overseas manufacturers. An importer whose goods go straight into duty suspension needs approved premises to receive them, and anyone who will affix stamps needs the stamps scheme approval too.

You must apply as a single legal entity with a fixed place of business in the UK, and HMRC must be satisfied that you are fit and proper. A financial guarantee is a condition of approval unless HMRC waives it; the waiver criteria and the lead time HMRC asks for are guidance rather than law. Applications have been open since 1 April 2026. HMRC says that carrying on an approvable activity without approval from 1 October 2026 will expose you to civil or criminal sanctions and to seizure of products and equipment.

3. Make monthly returns and pay the duty

If you hold a Vaping Products Duty approval, each calendar month is an accounting period. A stamps scheme approval on its own, such as a UK representative's, does not create a monthly return obligation. You must submit a return for every month, including a nil return, through the Manage your Vaping Products Duty online service by the 7th of the following month, and pay the duty shown on it by the 15th. The regulations give the payment date a next-business-day extension but give the return date none, so plan to file by the 7th even when it falls on a weekend. The first return, for October 2026, is due on 7 November 2026 and the first payment on 16 November 2026. Deferring payment to the return depends on your guarantee covering the amount.

If you import and your goods are released for UK consumption at the border, you pay through the customs declaration at release, unless they go straight into duty suspension. Goods released duty-paid at the border must already be stamped, in practice overseas under an approved UK representative. Late-payment interest runs from 1 October 2026. In Northern Ireland, commercial movements from the EU must travel duty-suspended to approved premises.

4. Buy, affix and activate duty stamps

Every vaping product produced in or imported into the UK on or after 1 October 2026 must carry a duty stamp at or before the duty point, on the outermost layer of the retail packaging, sealing it. From 1 April 2027 every product outside duty suspension must be stamped, whenever it was made, unless an exception such as export or a private individual's own use applies. Only approved stamp holders may buy stamps, from HMRC's appointed supplier, for a fee that is separate from the duty. Stamps may be affixed only on approved premises in the UK, or on the overseas premises named in a UK representative's application, and must not be transferred before they are affixed and activated.

Digital stamps carry a scannable code. You must activate each one at affixing with the prescribed product data and scan it at affixing, before any duty-suspended movement and before release for consumption. A stamp not used, returned or destroyed within its activation window is treated as lost and charged for. Do not stamp goods for export.

Transitional stamps have no scannable code. Products bearing one stay lawfully stamped until 21 January 2032, but the window to buy and affix them is closing.

5. If you only sell duty-paid stock: wholesalers and retailers

HMRC says you do not need its permission to sell vaping products by wholesale or retail, as long as you deal only in duty-paid stock. Registers and age-of-sale rules under the public-health regime are separate: see Specialist retail licences and registrations.

Unstamped stock produced or imported before 1 October 2026 carries no duty and may be sold until 31 March 2027; by then it must have been sold, returned to the supplier, exported, destroyed or otherwise lawfully dealt with. There is no published route for a non-approved wholesaler or retailer to have leftover stock stamped: only approved holders may stamp, only on approved premises, and stamping pre-October stock triggers the duty, so returning stock works only if the supplier is an approved holder with duty-suspended premises. From 1 April 2027 holding or selling unstamped product is a criminal offence, whenever it was made.

From 1 October 2026 HMRC expects you to check every delivery: the stamp, the supplier's paperwork and, for unstamped goods, evidence of pre-October production or import. No public stamp checker has been announced, so these are physical checks. If you cannot satisfy yourself that stock is legitimate, do not buy or sell it, and report it to HMRC or Trading Standards (district councils in Northern Ireland). HMRC also says you should keep records of your sources, stock and checks. That is HMRC's expectation rather than a duty in the vaping regulations for pure retailers, but it is how you show that stock was sold lawfully and that you had no reason to suspect it was unstamped.

6. Penalties and enforcement

Dealing in unstamped retail-packaged products attracts an escalating civil penalty under section 125 of the Finance Act 2026, scaled by units and by how often you have been penalised; the table is in section 5. Because "unstamped" means required to be stamped but not stamped, the better reading is that it does not reach pre-October stock during sell-through, though HMRC has not said so.

Approved persons face civil penalties under the Finance Act 1994 for any failure to comply with Part 4 or the regulations, and a per-stamp charge for stamps lost or not activated in time. Unstamped products, invalid stamps and products bearing them are liable to forfeiture, and lawful stamped stock on the premises can be seized alongside them. From 1 April 2027 dealing in unstamped products, or permitting their sale as manager of premises, is an offence carrying imprisonment or an unlimited fine on indictment, and a court may ban the premises from selling vaping products after a conviction.

HMRC collects the duty, runs approvals and prosecutes. Trading Standards in Great Britain, and district councils in Northern Ireland, may investigate and inspect.