Ahead of InterTabac 2026, which runs in Dortmund from 15 to 17 September, manufacturer YTOO has published an overview of the regulatory developments currently shaping the German vapor market — covering an additive review, an e-liquid tax already in force, and parallel EU-level policy tracks.
For white label e-liquid and private label vape juice programmes serving European accounts, the company argues, the cumulative effect is that product feasibility has to be recalculated rather than assumed.
Additives: scope under review
The most discussed item is the fifth amendment to the German Tobacco Products Ordinance (Tabakerzeugnisverordnung). According to Bundestag Lobbyregister disclosures, a draft dated 23 January 2026 proposes expanding the additive scope under Annex 2 by 13 substances, with menthol, sucralose and several cooling agents attracting the most industry attention.
YTOO is careful to distinguish this from a flavour ban. The draft targets specified substances, not flavour categories; liquids formulated without the listed additives — including fruit, dessert and tobacco profiles — fall outside its scope. The company also stresses that the draft remains at revision stage: which substances are ultimately restricted, the effective date and any transition period will depend on the final legal text, with an EU notification procedure still to follow and industry estimates pointing to late 2026 or 2027 at the earliest.
The practical consequence, the manufacturer notes, is at formulation level. Menthol and certain cooling agents build the cooling sensation, throat character and much of the overall sensory structure; sucralose is widely used to tune sweetness and flavour fullness. A change to the permitted boundary is therefore not a matter of deleting one ingredient, but of rebuilding a sensory result — replacement-material screening, formula reconstruction, sensory rebalancing and stability verification.
Tax: €0.32/ml, already in force
Under the current Tobacco Tax Act, substitutes for tobacco products have been taxed at €0.32 per millilitre since 1 January 2026, applying to all vaporisable liquids including nicotine-free products. A 10 ml bottle carries €3.20; 100 ml carries €32.
The staged path to date runs €0.16 (2022), €0.20 (2024), €0.26 (2025) and €0.32 (2026). Germany's Ministry of Finance has proposed further increases to €0.33 (2027), €0.34 (2028), €0.35 (2029) and €0.36 (2030), though these remain proposals rather than enacted law.
YTOO notes that a per-millilitre structure converts capacity from a packaging decision into a commercial one, with capacity, cost, tax, target retail price and channel margin needing to be solved together in a single product model.
EU tracks
In July 2025 the European Commission tabled a revision of the Tobacco Taxation Directive (TED) that would bring e-liquids, heated tobacco and nicotine pouches further into the EU minimum excise framework. In April 2026 the Commission completed its evaluation of the Tobacco Products Directive (TPD), signalling that novel product development has outpaced the existing rulebook.
The manufacturer's read is that brands operating across Europe will increasingly manage two layers — EU-level rules and member-state policy — and that a single product version covering multiple markets may give way to more country-specific variants.
YTOO supplies white label e-liquid and private label vape juice programmes across Europe, North America, the Middle East and Southeast Asia, with TPD, UFI, MSDS and ISO-certified production.
Full overview: https://www.ytoojuice.com/germany-e-liquid-tax-intertabac-2026-regulatory-outlook/
