If your e-liquid comes from overseas, the 1st of October 2026 changes the maths. Vaping Products Duty applies to your stock the moment it enters the country, unless that stock goes straight into duty suspension. So the real question for any cross-border brand isn’t just “how much will VPD cost me?” It’s this: does importing still make sense once VPD, customs, and duty stamps all stack up together?
This article walks through what actually changes for imported liquid, and also where UK-made production sidesteps some of that complexity entirely.
What changes for imported e-liquid on 1 October
Right now, many brands treat import as a simple supply chain step. Order stock, clear customs, sell it on. From 1 October, that changes in three concrete ways.
First, you account for VPD at the point of import, unless the goods move directly into an approved excise or customs warehouse under duty suspension. If they don’t, the duty falls due there and then. It doesn’t wait until you sell the stock.
Second, duty stamps have to be on the product before it’s released for UK consumption. If your overseas manufacturer applies the stamps before shipping, someone in the UK still has to manage that process. That someone is a UK representative, approved by HMRC specifically to purchase and handle stamps on behalf of an overseas manufacturer.
Third, your customs declaration now carries excise weight, not just trade weight. You need the correct tariff code and an accurate net liquid volume. You also need the paperwork behind it — invoices, packing lists, bills of lading. Get any of that wrong, and you risk delays or a seizure, not just a queried invoice.
The UK representative problem, in plain English
Here’s the part that catches most import-led brands off guard. If your manufacturer sits overseas, they can’t simply apply for UK duty stamps themselves. HMRC requires a UK-based entity to act as their representative instead. That entity needs its own approval, and it manages the stamps on the manufacturer’s behalf.
That leaves a cross-border brand with a real choice before October. Find, and vet, a UK representative your overseas manufacturer trusts. Or find a UK partner who removes the question entirely by manufacturing here in the first place.
Either way, someone in your supply chain has to own this. It can’t sit with nobody.
Stacking the real cost of importing after VPD
Before VPD, an overseas manufacturing route usually looked cheaper on paper. After 1 October, that comparison gets more complicated. The cost of imported liquid now includes several layers stacked on top of each other:
- The landed cost of the product itself — manufacturing, freight, and any existing import duty or tariff
- VPD at £0.20 per ml (that’s £2.20 for a 10ml), due at import unless you’ve arranged duty suspension
- The UK representative arrangement, if your stamps get applied overseas
- Customs brokerage, plus the extra declaration detail excise treatment now demands
- The operational risk of a shipment held up, or stock seized, over a stamp or paperwork error
None of this makes importing impossible. But the gap between a cheap overseas quote and landed, compliant, sellable UK stock gets wider. It’s worth measuring properly, rather than assuming the old numbers still hold.
Manufacturing in the UK removes several of those layers at once. There’s no import accounting step and no separate UK representative to arrange. There’s also no cross-border shipment sitting at risk of a stamp error before it even reaches your warehouse.
The risk you inherit, not just the cost
Cost is only half the picture. When you buy finished liquid from overseas, you’re also trusting someone else’s compliance. That’s someone you can’t easily audit, and who may not fully understand UK excise law.
If stamps are missing, wrong, or applied by an unapproved party, HMRC can seize the stock. That’s not a fine you negotiate afterwards. It’s stock that simply doesn’t reach your customers. And because the duty stamp scheme is new for everyone, an overseas manufacturer’s confidence isn’t the same thing as their compliance.
Questions worth asking before you commit
If you’re weighing up whether to keep importing, put these questions to any current or prospective overseas supplier:
- Who is your approved UK representative for duty stamps, and have you verified their HMRC approval yourself?
- Will the stamps be applied before the stock leaves origin, or once it reaches the UK?
- What documentation will you receive to prove duty has been correctly accounted for?
- What happens, contractually, if a shipment gets held or seized over a stamping or paperwork issue?
If those answers feel vague, treat that as the signal to act.
Why brands are moving production onshore
None of this is about avoiding VPD. The duty applies to UK-made and imported liquid alike, and the rate doesn’t change based on where you manufacture. What changes is how much complexity sits between production and a compliant sale.
Manufacturing in the UK collapses that chain. There’s one legal entity responsible for the product and one compliance relationship to manage. There’s no cross-border handoff where responsibility can blur. For a brand that’s spent the last few months untangling UK representative rules and import declarations, that simplicity is the real appeal.
Xyfil’s HMRC approval for Vaping Products Duty has been granted, and this covers importing as well as manufacturing within the UK. For more on our Vaping Products Duty services, read more here.