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Robbing Barstuards

Discussion in 'General Chat' started by MrDJ, Nov 18, 2016.

  1. MrDJ

    MrDJ Legend

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    Courtesy of FlavourArtUK on UKV


    There has been much discussion regarding pricing of TRPR (TPD) compliant products.
    Just to put a little perspective on what the costs are, here are some examples.

    For a UK manufacturer to achieve TRPR (TPD) compliancy of 50 flavours in 3 strengths,
    it would cost around £225,000 plus an annual fee of £9000 (Some might be paying more
    than the £225k, others a little less).


    Here's another turdlike bit of the regs that even the MHRA have admitted they weren't
    fully aware of until recently....this affects retailers/resellers.

    If you buy products from an EU manufacturer/supplier which have been Notified in their country,
    but not Notified to the MHRA, each SKU must be Notified to MHRA before it can be sold in the UK.
    The manufacturer can do this when they Notify in their country, but they can then ask you to pay for it,
    which is £150 per SKU plus you still have the Annual fee to the MHRA.
    The MHRA were originally under the impression that an EC-ID meant a compliant product could be sold in all
    EU countries where the sale was legal without further need to Notify, but the TRPR 2016 has it buried deep within
    its shitty little enclave. Some countries are free, others totally extortionate, as below.

    Example: For a retailer to sell 50 flavours in 3 strengths (150 SKUs) bought from a member state,
    you would still have to pay the MHRA £22,500 + £9,000 annual maintenance for the privilege!!

    Per SKU:
    Austria - Unknown
    Belgium 165 €
    Czech rep - No fees
    Denmark 4956 € + annual maintenance
    France 550€
    Germany No fees
    Greece 50€
    Luxemburg 5000 €
    Holland 44,85€
    UK 174€ + annual maintenance




    Here's another piece of crap buried at the end of the regs!
    A number of member states have banned cross-border sales.
    UK has not banned cross-border sales.

    ARTICLE 24

    Free Movement

    1. Member States may not, for considerations relating to aspects regulated by this Directive, and subject to paragraphs 2 and 3 of this Article, prohibit or restrict the placing on the market of tobacco or related products which comply with this Directive.

    2. This Directive shall not affect the right of a Member State to maintain or introduce further requirements, applicable to all products placed on its market, in relation to the standardisation of the packaging of tobacco products, where it is justified on grounds of public health, taking into account the high level of protection of human health achieved through this Directive. Such measures shall be proportionate and may not constitute a means of arbitrary discrimination or a disguised restriction on trade between Member States. Those measures shall be notified to the Commission together with the grounds for maintaining or introducing them.

    3. A Member State may also prohibit a certain category of tobacco or related products, on grounds relating to the specific situation in that Member State and provided the provisions are justified by the need to protect public health, taking into account the high level of protection of human health achieved through this Directive. Such national provisions shall be notified to the Commission together with the grounds for introducing them. The Commission shall, within six months of the date of receiving the notification provided for in this paragraph, approve or reject the national provisions after having verified, taking into account the high level of protection of human health achieved through this Directive, whether or not they are justified, necessary and proportionate to their aim and whether or not they are a means of arbitrary discrimination or a disguised restriction on trade between the Member States. In the absence of a decision by the Commission within the period of six months, the national provisions shall be deemed to be approved.EN L 127/30 Official Journal of the European Union 29.4.2014
     
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  2. SMKD
  3. pfvapes

    pfvapes Premium Vendor

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    Its a shitstorm
     
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  4. Smut

    Smut Veteran

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    Everyone knows that juice makers rake in more a year then Escobar ever did, so thats chump change to them :)
     
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  5. CBD Vape Shot
  6. Lee

    Lee Vendor

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    Another point thats worth mentioning -

    Even if a vendor sinks £Xk into getting their liquids through the TPD..... they could still deny your product for whatever reason when they review your notification.... for me, thats why we went the nic shot route.

    Risk almost £50k of cash, even then its still not certain your products will be approved. In the event of them not being approved, tough shit, your moneys gone.

    I wish anyone who has gone through with it the very best of luck, i really do. But for me it was business suicide, we simply couldnt risk it.

    Shit shit shit situation to be in for everyone right now!

    Good luck guys!
     
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  7. shiningstar

    shiningstar Postman

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    Thanks for this information! No doubt the price of legit juices will go up to cover costs and there will be a lot of bootlegging market traders offering ' under the counter' premium toilet water! How does this affect our chinese friends and the supply of equipment and juice from them?
     
  8. Colonelboom

    Colonelboom Vendor

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    I
    Thought you had gone through with it all? I'm surprised to read this tbh as most of your threads in the run up had me thinking it was a done deal and like us you were just waiting on the submission to be done?

    I'm not sure why your application would be denied as its subject to tests coming back clean with accurate nicotine doses etc. As long as those were being met I believe that going through was a formality.

    We are cutting our range considerably but with good reason that we had too many flavours with too much production needed. As a result we are releasing our cut flavours as one shots eventually but I still believe that just offering nic free and concentrates is very niche compared to vaping as a whole so for us it was business suicide not to stand firm and put our money plus hard earned reputation where our mouth was...

    How else could we justify charging above bathtub mixer prices with the perceived view that we were building for a post tpd future.

    Fair play though, you have to make a choice and it's not going to be an easy one at this stage in the game
     
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  9. ZT

    ZT Super Moderator Staff Member

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    Remember they consider this "light touch" as well
     
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  10. Colonelboom

    Colonelboom Vendor

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    I've barely noticed it's happening. So light, like a sponge cake :)
     
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  11. DakotaMai

    DakotaMai Vendor

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    Light...like a breeze block yeah?
     
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  12. Colonelboom

    Colonelboom Vendor

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    Yeah, a light breeze block delivered to the face by a truck.
     
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