By C. Chai, director, UIC International B.V. Published 2026-08-21, last updated 2026-08-21. How we write these.
Vape product insert requirements are not a single rule you can look up. They are the residue of four or five separate EU frameworks, each of which says some information must reach the buyer and most of which let an accompanying document carry it.
An empty vape device is small. A 510 battery is the size of a pen, and it has no room for a legible manufacturer address, a batch code, a set of instructions and a recycling symbol at once. That physical constraint is why an accompanying document exists as a category in EU product law: several frameworks let information that cannot legibly sit on the product sit somewhere that travels with it instead.
So the useful question is not "what must be on the insert". It is "what information must reach the buyer, and which permitted carrier am I using for each item". Answer it in that order and the insert designs itself.
The General Product Safety Regulation (EU) 2023/988 is the floor for any consumer product no more specific rule covers, and it has applied since 13 December 2024. It does not tell you what to print. It sets the duty to place only safe products on the market, the traceability information a product must carry, and the requirement that an economic operator established in the EU stands behind it.
Two of those bite on the documentation you ship. The first is traceability: type, batch or serial identification, and the name and address of the operator responsible for the product. The second is the contact detail for that responsible person, which may appear on the product, on its packaging, on the parcel or in an accompanying document. That last option is exactly what an insert card is, and it is why a card beats shrinking an address onto a battery tube. Who holds the role when you brand a device is covered in the GPSR responsible person guide, and the list of eligible operators sits in Article 4 of Regulation (EU) 2019/1020, cited here in its consolidated form.
The GPSR also expects instructions and safety information to reach the consumer in a language the member state determines. Draft them for the product as you actually sell it, not for the family it belongs to.
Two waste frameworks add marks rather than text. Directive 2012/19/EU on waste electrical and electronic equipment is why the crossed-out wheeled bin appears on electronic products and why user information about separate collection has to be provided. It is a directive, so the detail lands in national law and national registers, which is the subject of the WEEE registration guide.
Regulation (EU) 2023/1542 on batteries and waste batteries entered into force on 17 August 2023 and sets labelling, marking and information duties for batteries, including batteries built into appliances. Its obligations phase in on their own timetable rather than all at once. Which of them apply to a specific cell in a specific year is a question to settle against the instrument itself before an artwork freeze, not against a supplier summary. The EU Battery Regulation guide tracks what we hold for the hardware side.
The packaging around the device is regulated separately from the device. Regulation (EU) 2025/40 on packaging and packaging waste, the PPWR, entered into force on 12 August 2026 and repeals the earlier packaging directive. That earlier instrument, Directive 94/62/EC on packaging and packaging waste, carries an end of validity of 31 December 2028 on its EUR-Lex record, and the PPWR is what replaces it. If a supplier's artwork template or a compliance memo still points you at the 1994 directive, that is the date to raise. Our reading of what the PPWR changes for a vape carton is in the PPWR packaging guide.
The practical consequence is scheduling: staged obligations and a repealed predecessor mean your artwork has a review date, not just a launch date. Keep that date with the print files.
| Item | Usual carrier | Framework behind it | Note |
|---|---|---|---|
| Type, batch or serial identification | Device, or retail box where the device is too small | GPSR | Has to identify the unit, not the family |
| Manufacturer name and address | Device, retail box, parcel or insert | GPSR | The brand owner is usually the manufacturer for these purposes |
| Responsible person contact | Device, packaging, parcel or accompanying document | GPSR, with the operator list in Regulation (EU) 2019/1020 | The widest carrier set here |
| Instructions and safety information | Insert card or leaflet | GPSR | Language determined by the member state |
| Crossed-out wheeled bin | Device, or packaging if the device is too small | WEEE Directive 2012/19/EU | National implementation varies; check each register |
| Battery marking and information | Battery, device or packaging | Regulation (EU) 2023/1542 | Obligations phase in; confirm the date for your cell |
| Packaging material and sorting marks | Retail box and outer carton | PPWR (EU) 2025/40, replacing Directive 94/62/EC | Some member states add a national sorting mark |
| CE marking | Device, or packaging and accompanying documents | The directives behind the mark for your SKU | See the CE marking guide |
Language is where insert projects go wrong, because it is decided per market and discovered late. The EU runs no single list. France is the clearest example of a market that legislates the point directly: the loi n° 94-665 du 4 août 1994 relative à l'emploi de la langue française, the loi Toubon, makes French compulsory in the designation, offer, presentation, instructions for use and description of the guarantee of a product. Our France compliance guide covers what else that market adds.
Three habits keep the cost down. Build the language list from your distribution plan, not from the EU membership list. Lay the card out so a language block can be added without redrawing it. And freeze the artwork only after the responsible person is named, because that contact is the item most likely to change after the print run is committed.
On QR codes: a code that opens a fuller manual is a useful addition. Treat it as an addition to the printed minimum rather than a replacement, unless your own adviser confirms the substitution is accepted in that market. A code is cheap to add and expensive to rely on.
The insert that ships with empty hardware should describe empty hardware. Anything printed about a fill becomes a claim by the brand whose name is on the card, and it travels with every unit in the run. Devices sold with no nicotine and no e-liquid are not tobacco-directive products in their own right, which is the subject of the TPD and empty hardware guide, so borrowing tobacco-style warning layouts adds obligations you did not owe. Keep the card to the device: what it is, how to use and charge it, the safety limits, who is responsible for it, and where it goes at end of life.
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. Where this page does not state a national rule, that is deliberate: we did not have a primary source we could verify, and you should confirm the point with the authority named.
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