A quickly increasing illicit marketplace for disposable e-cigarettes is undermining European rules, fuelling youth vaping and costing governments important tax revenues, in response to a brand new research by the Fraunhofer Institute.
The analysis highlights rising considerations that Europe’s regulatory framework is struggling to maintain tempo with the booming recognition of disposable vaping merchandise, lots of which seem to violate present European Union guidelines.
The research, commissioned by technique consultancy SKR and introduced in Brussels, suggests {that a} important share of the disposable vape market now operates in what researchers describe as an “irregular market” — merchandise bought exterior the regulatory framework established by the EU’s Tobacco Merchandise Directive (TPD).
The illicit market, valued at €6.6 billion in 2026, is projected to extend to €10.8 billion by 2030, exposing gaping holes in EU customs controls, tax enforcement, and client safety. These variations and gaps between member states create gray zones the place unlawful commerce can flourish. China is the EU’s major supply of imports relating to liquids, primarily.
Supply routes for on-line direct orders in China
In keeping with the report, deliveries happen largely through rail and maritime routes. By sea freight, 30 million containers arrived on the ports of Rotterdam, Antwerp and Hamburg. Round 30,000 containers per week arrived in 2024, and Eire and the Netherlands are the principle patrons for vaping merchandise, which provide the remainder of the EU.
In keeping with calculations by the European Fee, practically 800 million parcels had been despatched from China to the European Union in 2024.
In mid-July 2025, Belgium’s Central Financial Council (Conseil central de l’économie) warned of “an uncontrollable inflow of parcels from China. ” In keeping with the CCEas much as 4 million parcels are presently being declared every day at Belgian customs.
Researchers warn that the expansion of this parallel market raises considerations not solely about public well being but in addition about tax revenues, regulatory enforcement and the enlargement of organised crime networks.
Disposable vape growth
Disposable e-cigarettes have turn into one of many fastest-growing segments of the nicotine market in Europe.
Low cost, brightly colored and accessible in a variety of flavours, these single-use gadgets have surged in recognition over the previous few years, notably amongst youthful shoppers.
Nevertheless, researchers say the fast progress of the market has additionally created alternatives for non-compliant and doubtlessly unlawful merchandise to enter Europe by means of advanced world provide chains.
The Fraunhofer research discovered widespread proof that many merchandise presently accessible throughout European markets fail to adjust to EU rules.
Among the many most typical violations recognized had been:
• exceeding the EU restrict of 2ml of e-liquid
• nicotine concentrations above the authorized restrict of 20mg/ml
• lacking or incomplete well being warnings
• failure to inform authorities by means of the EU’s product registration system
Researchers warn that such merchandise are more and more seen throughout a number of EU member states.
Youth entry raises considerations
The rising recognition of disposable vapes amongst youngsters has turn into one of the controversial facets of the market.
In the course of the presentation of the research, SKR AG managing accomplice Rico Behind stated the analysis was initially prompted by considerations about vaping amongst schoolchildren.
“I heard from my daughter that college students aged 12 to fifteen had been already vaping,” he stated in the course of the briefing.
“That raised critical questions for me about how widespread this market truly is.”
Disposable gadgets are sometimes bought in vibrant packaging and candy flavours akin to fruit, sweet or comfortable drinks — traits that critics argue might make them notably interesting to younger shoppers.
Public well being specialists warn that early publicity to nicotine might enhance the danger of dependancy and long-term well being penalties.
Enforcement challenges
Underneath the EU’s Tobacco Merchandise Directivewhich regulates tobacco and nicotine merchandise throughout the European Union, e-cigarettes are topic to strict limits designed to guard shoppers.
These embody caps on nicotine power, limits on e-liquid volumes and necessities for product notification and well being warnings.
Nevertheless, enforcement of those guidelines largely is dependent upon nationwide authorities and customs companies.
Researchers say that the more and more globalised nature of vape provide chains makes monitoring compliance tough.
Merchandise manufactured exterior the EU can enter by means of a number of channels, together with cross-border commerce, on-line marketplaces and small impartial retailers.
In some circumstances, non-compliant gadgets are reportedly bought overtly in outlets regardless of failing to satisfy EU regulatory necessities.
A wider illicit nicotine market in Europe
The emergence of unlawful vape merchandise is going on alongside a broader enlargement of illicit tobacco markets throughout components of Europe.
International locations with excessive tobacco taxes and strict regulatory regimes have seen a rising commerce in unlawful cigarettes and counterfeit tobacco merchandise.
France presently has the most important illicit cigarette market in Europe.
Current estimates recommend that 18.7 billion illicit cigarettes had been consumed in France in 2024representing roughly 37.6% of complete cigarette consumption. In sensible phrases, meaning multiple in three cigarettes smoked in France could also be unlawful.
Excessive retail costs — typically €11 to €13 per pack — have created sturdy incentives for smuggling networks and counterfeit producers.
Authorities report that organised legal teams play a major position on this commerce, utilizing smuggling routes, hidden factories and on-line gross sales channels to distribute unlawful merchandise.
French authorities have dismantled seven unlawful cigarette factories since 2021highlighting the dimensions and class of those operations.
Belgium is rising as a manufacturing hub
Belgium has additionally emerged as a major hub for unlawful tobacco manufacturing and distribution.
Customs authorities dismantled twelve unlawful cigarette factories in 2024adopted by ten extra closures in 2025.
Belgium’s central location and in depth transport infrastructure make it engaging for organised crime teams concerned in cross-border trafficking.
Throughout a parliamentary dialogue final yr, Belgian Inside Minister Bernard Quintin cited federal police findings suggesting that staff are typically recruited by means of on-line ads providing well-paid jobs overseas.
In some circumstances, staff are reportedly transported throughout Europe and compelled to work in unlawful cigarette factories.
Whereas a lot of the counterfeit tobacco produced in Belgium is destined for export, rising cigarette costs have additionally elevated home demand for cheaper illicit options.
A pack of Marlboro cigarettes in Belgium now prices round €12roughly double the worth a decade in the past, whereas unlawful cigarettes might be bought for half that quantity.
Netherlands sees surge in unlawful vapes
The Netherlands has skilled a pointy rise in unlawful vape merchandise following the introduction of strict new rules.
Dutch insurance policies embody:
- a ban on flavoured e-liquids besides tobacco flavour
- a ban on on-line gross sales of vaping merchandise
- restrictions limiting gross sales to specialist tobacco retailers
Authorities say these measures had been designed to scale back youth vaping.
Nevertheless, enforcement companies report that unlawful flavoured disposable vapes stay broadly accessibletypically imported from Asia.
Dutch police have seized tens of hundreds of unlawful vape gadgets lately, whereas the nation has additionally seen a major enhance in illicit cigarettes.
Current estimates recommend that round 17.9% of cigarette consumption within the Netherlands is now illicitroughly double the earlier yr.
Retailers warn that the rising availability of untaxed and counterfeit merchandise is making it more and more tough for reliable sellers to compete.
A rising cross-border problem
Legislation enforcement companies more and more view illicit tobacco and vaping merchandise as a pan-European legal exercise.
Underneath the EU’s EMPACT programwhich coordinates cross-border motion towards organised crime, authorities reported main enforcement exercise in 2023.
Operations led to:
- 68 unlawful cigarette factories dismantled throughout Europe
- 100 reducing and storage services found
- 790 million unlawful cigarettes seized
Authorities estimate that this amount of unlawful cigarettes alone could be enough to provide round 230,000 people who smoke for a whole yr.
Due to its geographic place, Belgium is usually recognized as a key transit hub linking provide routes from Jap Europe and Asia to client markets throughout Western Europe.
A fancy coverage debate
The emergence of unlawful vape merchandise and illicit cigarettes highlights the complexity of regulating nicotine markets in Europe.
Supporters of e-cigarettes argue that vaping merchandise can play a task in hurt discount for grownup people who smoke searching for options to conventional tobacco.
Critics, nevertheless, level to rising youth vaping, environmental considerations linked to disposable gadgets and the fast progress of unlawful markets.
The Fraunhofer research doesn’t take a place on this wider coverage debate however highlights the widening hole between regulatory frameworks and developments within the market.
Because the European Fee considers potential revisions to the EU Tobacco Merchandise Directive (TPD)policymakers face the problem of balancing public well being aims with efficient enforcement and market realities.
For regulators throughout Europe, the query is not merely how one can regulate vaping merchandise — however how one can stop unlawful markets from increasing sooner than the foundations designed to manage them.
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