Recently, I had the opportunity to read an excellent article by Lee.

Unfit for the counter - tobaccoreporter

In his latest piece, Lee addressed several interesting issues regarding the current situation and problems that exist in the vape market. I would like to touch on a few of his observations, which we also noticed over a year ago and partially implemented on our platform, and which could be a solution to these problems. Additionally, I would like to mention a few other things that, in my opinion, require attention. I should note that I am more of a technical person than a salesperson, so in many aspects, I may deviate from the norm. The aim of this article is not to suggest anything, but rather to showcase technical possibilities for solving current issues and encourage discussion. Some of these things may seem impractical to implement right now, but I assure you that technically, it is possible.

At the beginning, I would like to refer to Lee's remarks.

Right at the beginning of his article, Lee mentioned two main problems, which are selling products to minors and selling counterfeit products, as a result of which many people, as Lee mentioned, lose trust in these products.

I don't have as much experience in this field as Lee does, but I fully agree with him on the most common mistakes made when reporting products, such as:

  • inadequate checks to ensure e-liquid recipes do not contain inappropriate substances in specific markets;

  • copying competitors’ labeling;

  • notifying the wrong product type to the regulator;

  • reusing former identifier codes for new products; and

  • lacking systems for tracking adverse safety events.


We ourselves have noticed that even well-known brands (knowingly or unknowingly) often violate several of the above-mentioned points. As Lee pointed out in his article, there are many companies on the market that behave improperly and intentionally break the law. I would also add to this list the frequent situation where a product is designed with the intention or not in a way that suggests its target audience is children, which in my opinion should even be punishable.

 The above-mentioned problems force the government of Great Britain to introduce increasingly restrictive regulations. Of course, legal regulations are necessary, but an excess of regulations is also not good. In my opinion, self-regulation is a better solution than constantly expecting the government to enforce certain behaviors through the law. 

As I come from the IT industry, the idea of working groups beyond divisions is not unfamiliar to me. I really miss this idea in the vape market. A very cool thing, in my opinion, would be to create one big working group, combining the efforts of UKVIA, IBVTA, MHRA, and all interested parties to create self-regulation. Each member of such a group would be obliged to apply the implemented self-regulation. As we know, businesses react much faster to changing conditions and understand the market better than government institutions." 

I will now add a few additional problems that exist in my opinion: 

  • The problem with the exchange and availability of information that should be public.

  • Problems with verifying the legality of products.

  • Frequently missing UFI code on the product.


I believe that many people still view e-cigarettes through the lens of traditional cigarettes, which is a mistake. Why? Because e-cigarettes are electronic devices by definition, which gives us plenty of technical possibilities that can help solve the above-mentioned problems. I have had the opportunity to talk to some e-device manufacturers and I know that introducing an RFID/NFC chip, for example, would not significantly increase the cost of the product while greatly increasing its potential technical capabilities. 

The current situation on the market has changed significantly, as seen by the increased scrutiny of manufacturers and the government in implementing changes aimed at improving the market and regulations. For example, there has been an idea circulating for some time to increase the allowable limit from 2ml to 10ml. Increasing the capacity limit would reduce production costs and provide space for additional innovations in the products themselves. This opens the way for the introduction of interesting solutions. 

Before I proceed further, I should explain a few terms that I will be using below, for those who have not had the opportunity to familiarize themselves with these terms.



The Internet of things (IoT) describes physical objects (or groups of such objects) with sensors, processing ability, software and other technologies that connect and exchange data with other devices and systems over the Internet or other communications networks.

 UUID (version4)

 A universally unique identifier (UUID) is a 128-bit label used for information in computer systems. The term globally unique identifier (GUID) is also used.

 QR code

 A QR code (an initialism for quick response code) is a type of matrix barcode (or two-dimensional barcode) Barcode is a machine-readable optical image that can contain arbitrary information, often used as a label.


 Radio-frequency identification (RFID) uses electromagnetic fields to automatically identify and track tags attached to objects. An RFID system consists of a tiny radio transponder, a radio receiver and transmitter.


Near-field communication (NFC) is a set of communication protocols that enables communication between two electronic devices over a distance of 4 cm (1.57 in) or less.


I would like to note that I am a strong supporter of the idea of IoT. In my opinion, it introduces many possibilities that help to secure products, increase their safety, and streamline sales and usage processes. Great Britain has always been a creative center of interesting ideas and has often been the first to implement amazing ideas that were later copied by the rest of the world. Perhaps, with our joint efforts, we will be able to introduce another interesting initiative.

The list of problems and their potential technical solutions:

Product identification and validation

Currently, it is relatively difficult to verify whether a given product is notified to MHRA, due to the fact that product names on packaging often differ from those notified to MHRA. In addition, there is no unique identifier for a given product that would allow for easy identification. MHRA does not require the ECID to be placed on the product packaging, nor is there an obligation to send the barcode (EAN13) to MHRA. Secondly, MHRA does not require product photos to be sent. To properly identify a product, at least three elements are needed:

  • Product name

  • Packaging and product photo

  • Barcode (EAN13) and/or UUID (QR code, which would be even better because you only need a phone with a camera to verify the product)


Please note how much easier it is to verify a product to an officer by scanning a barcode or QR code than by searching for the product by name. In my opinion, this is a key problem that requires an immediate solution.

The above functions have been implemented on our platform for a long time. Unfortunately, these are additional pieces of information that manufacturers have to provide to us themselves. It is not currently required by law. Fortunately, some companies have already provided us with this information. Excellent examples are Eco-Vape, Aspire, Juice Sauz, Bowmans, and Nictel. This data is already available on our platform and greatly facilitates product identification.


Protection against counterfeiting

Many companies have already introduced their own product verification solutions, but there is a lack of a central place that would allow for product verification, and often the adopted solutions are not compatible with each other. Most of these solutions are based on QR security labels, which is the cheapest and easiest level of security."

Example: Elf Bar product verification

 Below are the levels I have divided technical solutions into:

 Level 0: 

  • QR security label (any type of ID number, ex: elf bar using integer number)

  • Random range of products protected


Level 1: Bach level 

  • QR security label (any type of ID number)

  • Bach range only, each batch have own code


Level 2: Product level (IoT) 

  • QR security label (any type of ID number) / RFID/NFC

  • Each product have own code


In my opinion, the identifier should be based on UUID version 4, which allows generating unique identifiers without collisions, even without access to a central database. Of course, such a code is less user-friendly, but that's why we have QR codes. Introducing a solution at level 2 would enable many interesting possibilities, such as protection against counterfeiting, protection against sales to minors, and easy localization of dishonest sellers. I think that many sellers would consider more carefully who they sell the product to if they were aware that they could be easily located.

UUID should be generated at the level of an individual product (Level 2), which should be linked to the expiration date of the product. Generating UUIDs at this level would allow blocking/reporting of codes stolen by dishonest sellers and manufacturers, as well as blocking of a specific product. Additionally, it would allow tracking of where a particular product was sold, which leads us to the next point on the list.


Sale of products to minors and locating places of illegal product sales

As mentioned above, introducing UUID at the product level would significantly improve the situation in this area. Of course, it would not completely solve the problem, but it would make illegal practices much more difficult.


Age restriction / (Smart E-cig)

With technology as an ally, one could even consider implementing an age restriction feature into the device. For example, the product would be locked until the user verifies their age online. Of course, implementing such a security measure would result in a significant decrease in revenue as a large portion of underage users would be cut off from using such devices, while at the same time exposing which manufacturers truly care about respecting the law. This is an extreme measure, but technically possible to implement.

In conclusion, there are many technical possibilities, and this article aims to present potential solutions only. I understand that some of these ideas may be difficult to implement from a practical or business point of view, but I believe it is worth discussing them.


If you found this article interesting and would like to discuss it with us, please feel free to contact us.




Raphael Calm
Techstream Group LTD
2023-05-02 10:46:26