50 mg/ml of nicotine in just a few clicks: Europe and the parallel market for non-compliant e-cigarettes

A few simple searches are enough

AT Switzerland carried out an exploratory internet search using very simple combinations of terms such as “5% nicotine”, “50 mg/ml”, “50K”, “100K”, “150K”, “EU warehouse”, as well as the names of some products identified in our previous investigation.

We did not use any special investigative techniques, nor did we attempt to gain access to closed networks or underground platforms.

A simple search using an ordinary search engine is enough.

Within a few hours, we identified numerous websites offering e-cigarettes advertised as containing 5% nicotine, equivalent to around 50 mg/ml.

Some of the offers are particularly striking: stated liquid capacities of 25 ml, 50 ml, 60 ml or 70 ml; 50,000, 100,000, 150,000 puffs or more; 4-in-1 or 6-in-1 devices; several flavours in a single device; rechargeable batteries; and prefilled cartridges or pods.

More concerning still, several sellers explicitly state that the products are already stocked in an “EU Warehouse” and can be delivered within a few days.

Two and a half times the maximum permitted concentration

The contrast with European legislation is particularly stark.

Article 20(3) of Directive 2014/40/EU provides that nicotine-containing liquids placed on the market must not exceed a nicotine concentration of 20 mg/ml. For disposable e-cigarettes and single-use cartridges, tanks or cartridges must not exceed 2 ml; nicotine-containing refill containers are limited to 10 ml.

A product containing 50 mg/ml is therefore not just slightly above this limit: its stated nicotine concentration is 2.5 times the European maximum.

And when a product is simultaneously advertised, for example, as containing 17 ml at 50 mg/ml, the discrepancy no longer concerns nicotine concentration alone. The product’s design and stated capacity also raise obvious questions of compliance with the rules applicable to the category under which it is marketed.

A small selection of the offers identified

The table below presents some of the offers found during our exploratory search. It is neither a comprehensive market inventory nor a complete list of the sellers concerned. Offers change rapidly, and websites may modify products, stock levels or information at any time.

The geographic description should also be interpreted with caution: a national domain such as “.de” or “.fr” does not prove that the company operating the website is legally established in Germany or France. Some websites clearly target European markets while appearing to be operated from China.

This list is indicative. It reflects a rapid search conducted by AT Switzerland, not a systematic study of the entire European market. It should therefore be regarded as an illustrative sample – and very likely only the tip of the iceberg.

“EU Warehouse”: the problem is already inside Europe

One of the most concerning findings of our research relates to references such as “EU Warehouse”, “EU Stock” or “European Warehouse”.

In such cases, this is no longer simply a matter of individual European consumers ordering products from a Chinese platform.

Some sellers claim that the goods are already physically present in a warehouse within the European Union.

EU Vape Sales provides a particularly striking example. The website offers, among other products, an Elf Bar Combo Pro which, according to its own product description, contains 17 ml of liquid at 50 mg/ml. It advertises the product as being shipped from a European warehouse and delivered within three to seven days.

The same seller offers an Elf Bar Moon Night with 22 ml of liquid and 5% nicotine, also from a European warehouse, along with numerous other high-capacity devices.

The website also lists a WhatsApp number beginning with +86, the international country code for China. The operator itself distinguishes between shipments from its Chinese warehouse and shipments from its European warehouse.

This illustrates perfectly the new geography of this trade: the seller may be located outside the European Union while the goods are already stocked inside it.

Some sellers are already going beyond 5%

Our research produced another surprise.

Although we were specifically looking for products containing 5% nicotine, we also encountered offers going even further.

EU Vape Sales currently lists among its new products a device called the Bang Leader Stoll 520K, advertised as delivering up to 520,000 puffs and offered with nicotine concentrations of 3%, 5% or 8%.

Eight per cent corresponds – if the percentage is expressed according to the convention normally used by these sellers – to around 80 mg/ml, four times the European limit of 20 mg/ml.

The very existence of such offers shows how rapidly this market is evolving. Our previous article asked: “Today 150,000. And tomorrow?”

Less than twenty-four hours of research already provides part of the answer: some sellers are now advertising 300,000 and even more than 500,000 puffs.

European websites that are sometimes European only in appearance

The situation is further complicated by the lack of transparency of many webshops.

A “.de”, “.fr” or “.se” domain, or a Spanish-language version of a website, may give consumers the impression that they are dealing with a domestic company.

That is not necessarily the case.

Some websites provide little information allowing the legally responsible company to be readily identified. Others offer pages in several European languages while providing contact details in China. Still others combine an Asian commercial structure with stock located in the European Union.

It is therefore important not to describe a seller as “German”, “French” or “Spanish” solely on the basis of its domain name.

This opacity, however, raises a fundamental question in itself: who is responsible for placing the product on the market?

The European directive specifically provides that where the manufacturer is not established in the Union, the importer bears responsibilities regarding the compliance of products placed on the European market.

If thousands of e-cigarettes containing 50 mg/ml are genuinely stored in European warehouses, it should therefore be possible to identify the economic operators responsible for their importation and supply.

A European market surveillance problem

The results of this research therefore go far beyond the issue of individual purchases from Chinese websites.

We appear to be dealing with at least three overlapping distribution channels:

1. sellers apparently established in a European country directly offering 5% products;
2. operators located outside the European Union but claiming to hold stock in European warehouses;
3. Asian sellers shipping products directly to European consumers.

The growing role of European warehouses is particularly important.

If the products have already entered the territory of the Union, the issue is no longer limited to checking small parcels at external borders. It becomes a matter of internal market surveillance, traceability of importers and distributors, and effective enforcement of the law.

An equally important challenge for Switzerland

Switzerland is obviously not isolated from this enormous online market.

Swiss consumers now have direct access to hundreds of foreign online shops. Some offer German- or French-language interfaces, ordinary electronic payment methods and international delivery.

The proximity of European warehouses may shorten supply chains even further.

Even if not all the websites identified in our research necessarily deliver to Switzerland, and even if their terms and conditions may change, the scale of the international offer makes it unrealistic to rely solely on controls of Swiss retailers.

There is a simultaneous need to identify importers, monitor online offers, cooperate with European authorities and develop mechanisms allowing rapid intervention when clearly problematic products are offered to consumers.

What can be found in a few hours should also be detectable by the authorities

This may be the most troubling conclusion.

AT Switzerland has neither a customs service, nor a commercial police force, nor a market surveillance laboratory.

Yet a few ordinary internet searches are enough to identify dozens of offers openly displaying:

50 mg/ml. 5%. 25 ml. 50 ml. 70 ml. 50,000 puffs. 100,000. 150,000. EU Warehouse. EU Stock.

These are not products hidden on the dark web.

They are indexed by ordinary search engines, displayed with photographs, prices, bulk-purchase discount tables and buttons allowing them to be added directly to a shopping cart.

The central question therefore becomes difficult to avoid:

if AT Switzerland can identify these offers within a few hours, why do they remain so easily accessible to European consumers?

The tip of the iceberg

Our research makes no claim to be exhaustive.

We examined only a limited number of brands and models, primarily those we had already encountered in our Swiss investigation. We did not systematically review all languages, countries, marketplaces, or offers circulated through social media and messaging services.

Despite this, the number of sellers and products identified is already considerable.

Everything therefore suggests that the examples presented here represent only the tip of the iceberg.

The phenomenon now merits systematic investigation at both Swiss and European level: mapping sellers, identifying companies and importers, locating warehouses, carrying out test purchases, laboratory analysis of the concentrations actually contained in products, and cross-border cooperation between market surveillance authorities.

Because the question is clearly no longer whether e-cigarettes containing 50 mg/ml are accessible in Europe.

They are. They are openly offered. Some are even advertised as already stocked within the European Union.

The real question now is: how can such a visible market continue to flourish when the legal limits are equally clear?