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Guide

Age verification and trade-only selling in the EU

By C. Chai, director, UIC International B.V. Published 2026-08-21, last updated 2026-08-21. How we write these.

Two different checks sit behind a vape hardware order in Europe, and confusing them is how a wholesaler ends up either doing the wrong work or doing none. This page separates them and states plainly which one is ours.

Two checks, not one

The phrase "age verification" covers two jobs with almost nothing in common.

Consumer age verification controls the sale to the person who will use the product. It runs at the point of sale, it is about a date of birth, and where it exists it is set by national law in the market where that sale happens.

Trade verification controls who may hold an account at all. It runs before pricing is shown, it is about a legal entity rather than a person, and it establishes that the counterparty is a registered business buying for resale.

Empty Vapes does the second. We run no consumer checkout, sell no single units to individuals, and sell no e-liquid or cannabinoids. That is a description of the business, not a legal opinion.

What trade-only means in practice

Trade-only is a set of operational choices, not a badge. The ones that change behaviour:

  • Pricing sits behind an approved account. If trade prices are visible to anyone landing on the page, the site is a consumer shop with a slogan on it.
  • Minimum order quantities a consumer would not place. A genuine wholesale MOQ does more work than a checkbox. See the MOQ guide.
  • Business delivery addresses. Goods to premises, not a doorstep.
  • A named human on the account. Someone with authority to bind the buyer, recorded by name and role, so the counterparty is not an email address.
  • An intended-market declaration. The buyer names the market the goods are going into, which is what makes the rest of the compliance conversation possible.
  • No consumer-facing marketing. If your advertising reads as aimed at end users, a regulator will not be persuaded by your terms and conditions.

What we check at account opening

The useful way to present a verification process is not a list of what you ask for, but of what each thing establishes and what it leaves open. Most checklists fail because nobody wrote the third column.

Trade account checks: what each one establishes, and what it does not
What we ask forWhat it establishesWhat it does not establish
Registered company name and numberA registered legal entity in a named jurisdictionAnything about who ultimately holds the product
VAT number, checked against VIESA number the Commission's service returns as validThat the user of it is authorised, or that the business is tax-compliant
Business delivery addressGoods consigned to commercial premisesThat the premises hold any licence the market requires
Named signatory with authorityAn accountable human is attached to the accountThe age of anyone downstream of the buyer
Declared intended marketWhich national regime the buyer says appliesThat the buyer has registered in that market
Trade-only resale confirmationThe account is on trade terms, in writingAny substitute for the buyer's own consumer-facing controls

The VAT step is the only one leaning on an external service. The European Commission publishes VIES on-the-Web, a VAT number validation service. A screenshot of a result beats a note saying the number "looked right".

What the check does not prove

This is the section most suppliers leave out, and the one that protects you. A completed trade check tells you about a company. It tells you nothing about a shelf.

Once the goods leave your warehouse the controls that matter are the buyer's: point-of-sale checks, staff training, shelf placement, national registrations. A wholesaler cannot inherit those and should not pretend to. What it can do is refuse to be the weak link: approve accounts deliberately, keep the file, and decline the order that does not look like a trade order. See the supplier documentation guide and the guide on selling vape hardware to EU retail.

The corollary is worth saying out loud. If a buyer asks you to confirm that your check discharges their obligation, the answer is no. Saying so in writing beats a comfortable sentence that fails the first time anyone tests it.

Why there is no age table on this page

A table of minimum ages by member state would be the most linkable thing we could publish, and we are not publishing one. We could not source every market at its own authority, and a table right for eighteen countries and wrong for nine is worse than none: the reader cannot tell which row they are on.

Two figures we did read at source, each stated by a national authority about its own market:

  • Switzerland: 18. The Bundesamt für Gesundheit (BAG) states that a minimum supply age of 18 applies to all products covered by the Swiss Tobacco Products Act, in force since 1 October 2024. Switzerland is not an EU or EEA state, so nothing about that figure reads across into the EU.
  • Portugal: 18. Portugal's Direção-Geral da Saúde states, on a page dated 19 September 2019, that sale has been prohibited to under-18s since 1 January 2016. That page is old enough to re-check before relying on it.

Both are about nicotine-containing vaping products in one national market. Neither is about empty hardware, neither is about anywhere else, and we will not build a European rule from two data points. For any other market, ask its authority in writing and file the reply. Our own trade terms run at 18+ or 21+ by market: a floor we set commercially, not a legal position asserted on your behalf.

The data you collect is personal data

One consequence gets discovered late. The moment you collect identity documents, dates of birth or a director's passport copy, you are processing personal data about an identified natural person. The instrument governing that in the EU is Regulation (EU) 2016/679, the General Data Protection Regulation. Its EUR-Lex record carries no end of validity.

We will not summarise the GDPR here: a paraphrase of a data protection regulation on a hardware supplier's site is exactly the kind of confident sentence that gets retracted. The practical point instead: decide what you are keeping and why before you build the upload form. A process built on the assumption that more evidence is always safer produces a document store nobody wanted, in a category where a breach is worse than most.

What this page does not say

Four things. No minimum age for any market we did not source, which is most of them. No advice on your own consumer-facing obligations, which depend on your national law and your own adviser. No claim that a trade check satisfies any statutory duty. And no named age-verification vendor, because we have tested none. For the wider picture, start with the EU compliance pillar and the guide to starting a vape brand in Europe.

Frequently Asked Questions

Does a B2B vape hardware seller need age verification?
A trade-only seller runs trade verification, which is a different thing. It establishes that the counterparty is a registered business buying for resale, and it is done at account level before pricing is shown rather than at checkout. Consumer age verification is a control on the sale to the end user, a sale a trade-only supplier does not make. Whether your own business owes a consumer-facing duty depends on national law in the markets you sell into, and that is a question for your own adviser.
What is the minimum age to buy vape products in Europe?
There is no single European figure we could source, so this page publishes no table of ages. Two we did verify: the Swiss Federal Office of Public Health states that a minimum supply age of 18 applies to all products covered by the Swiss Tobacco Products Act, and Portugal's Direção-Geral da Saúde states that sale has been prohibited to under-18s since 1 January 2016. Both are statements about a single national market. Check your own with its national authority.
What does a VAT number check actually prove?
Less than people assume, which is why it is one check among several rather than the whole gate. The European Commission publishes VIES on-the-Web, a service that validates a VAT number. A valid result tells you the number is one the service returns as valid. It does not tell you the person using it is authorised to, that the business is solvent, or anything about who ends up holding the product. Pair it with a company number, a business delivery address and a named signatory.

Sources

  • VIES on-the-Web, European Commission. Linked as the service we use; we state nothing about the legal effect of a result.
  • Tabakproduktegesetz, Bundesamt für Gesundheit (BAG), Switzerland, for the minimum supply age of 18 and the 1 October 2024 start date of the Swiss Tobacco Products Act.
  • Cigarros Eletrónicos, Direção-Geral da Saúde, Portugal, page dated 19 September 2019, for the prohibition on sale to under-18s from 1 January 2016.
  • Regulation (EU) 2016/679 (GDPR), EUR-Lex. Named as the instrument governing the personal data a verification process creates; its record carries no end of validity. We summarise none of its requirements.
  • Not cited: no national minimum age is stated for any market other than Switzerland and Portugal, because we verified none at its own national authority. No vendor, industry body or law firm page is used as a source here.

Trade guidance for B2B buyers, not legal advice. We sell empty hardware only (no cannabinoids, no e-liquid), B2B trade only, 18+ / 21+ per market; you are responsible for the fill and for finished-product compliance in your market. The buyer that brands the device and places the finished product on the market carries the national registrations, the consumer-facing controls and the age checks that go with them, and should take its own legal advice in each market it sells into.

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