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As emphasized on Monday by Pr B. Dautzenberg during the First Vape Summit in Paris: “The FR version of the directive 2014/40 does not limit the volume of tanks but only the volume of cartridges to 2 ml. The EN version is ambiguous.

Explanations

TPD provisions on tank capacity, in French version, do not seem to apply to ALL types of e-cigarettes as they do in the English version, but only focus on DISPOSABLE ELECTRONIC CIGARETTES or SINGLE USE CARTRIDGES.

This interpretation comes from a difference that was introduced when the text has been translated from English into French.

The English version reads:

  • nicotine-containing liquid is only placed on the market in dedicated refill containers not exceeding a volume of 10 ml, in disposable electronic cigarettes or in single use cartridges and that the cartridges or tanks do not exceed a volume of 2 ml;

The French version translated in English reads:

  • nicotine-containing liquid is only placed on the market in dedicated refill containers not exceeding a volume of 10 ml; in disposable electronic cigarettes or in single use cartridges, the cartridges or tanks do not exceed a volume of 2 ml;

“and that the cartridges or tanks” [EN] -> “the cartridges or tanks” [FR]

Can a small difference in the text play role in authorized tank capacity?