Whole Melt 2ml — EU/UK vs US Label Boundaries Explained
A practical guide for distributors and licensed fillers using 2 ml Whole Melt empty devices—what “2 ml” means in EU/UK rules, where US practice differs, and how to label hardware correctly when no nicotine or cannabinoids are included.
Quick basics
“2 ml” is commonly used for device capacity. In the EU/UK, 2 ml has a specific regulatory meaning for nicotine e-cigarette tanks. In the US, there is no federal tank-size cap; labeling focuses instead on whether the product is a regulated tobacco product (nicotine) versus a general consumer electronic.
Browse the product family first to align terminology and dielines: see wholemelt (category overview) and the more specific listing page Whole Melt Disposable Vape Pens.
EU/UK: what the 2 ml limit actually covers
Scope. Under the EU Tobacco Products Directive (TPD) and the UK TRPR, nicotine-containing e-cigarettes are subject to a 2 ml maximum tank capacity and strict packaging/label rules. If your unit is supplied empty (no nicotine), the tank-size cap doesn’t apply, but once marketed/filled with nicotine for retail, those rules switch on.
- 2 ml maximum for e-cigarette tanks (UK TRPR guidance). Plan your artwork and spec sheets accordingly.
- Health warnings for nicotine products: standardized text and size requirements on the pack; for EU markets, warnings typically occupy large portions of principal display areas.
- General product duties still apply to empty hardware: manufacturer name/contact, traceable identifiers, and safety information under the EU General Product Safety Regulation (GPSR).
For pan-EU packaging when shipping only empty hardware, avoid nicotine claims and keep device copy factual (materials, capacity, charging). Link your technical files and COA via a QR code to simplify customs and distributor checks. You can cross-link back to wholemelt for SKU references.
US: how labels differ (and when warnings apply)
In the US, the FDA regulates tobacco products, including e-cigarettes and their “components or parts,” when they are intended for nicotine use. If your Whole Melt device is shipped empty and marketed as hardware only, do not include nicotine claims or imagery; treat labeling as consumer electronics + battery safety. If supplied as a nicotine product, FDA tobacco labeling and warning-statement requirements apply; also consider state analogues and advertising rules (e.g., age gating, placement).
Empty hardware: baseline label elements
When shipping 2 ml Whole Melt devices as empty hardware (no nicotine/cannabinoids), use a neutral, cross-border label set:
- Product ID & capacity: model, lot/serial, “capacity 2 ml (empty device)”.
- Responsible economic operator: legal name, postal address, and contact (EU GPSR/UK consumer product norms).
- Materials & conformity: RoHS/REACH statements for electronics and wetted parts; keep the full declarations in your technical file and surface a short claim on-pack.
- Battery & charging: cell type, rated capacity/voltage, recycling mark, and a pointer to the UN 38.3 test summary (QR to PDF).
- Safety icons: age-restricted sale icons (where used by channel policy), keep-dry, do-not-incinerate, WEEE bin, CE/UKCA if applicable to accompanying charger/cable.
Need a quick product reference for content writers? Use the PDP index at Whole Melt Disposable Vape Pens to standardize specs across campaigns.
Cross-border checklist (EU/UK ⇄ US)
- Confirm sales configuration: empty hardware vs. nicotine product; mirror this in copy and carton codes.
- EU/UK retail with nicotine → apply 2 ml tank limit + required warnings; US retail with nicotine → FDA tobacco warnings and marketing authorization rules.
- For empty devices: keep labels to hardware facts; maintain RoHS/REACH documentation and make a brief on-pack claim.
- Battery logistics: attach (or QR-link) the UN 38.3 test summary for the cell/battery design shipped.
- Origin statements: qualify “Made in …” claims per FTC rules (US) and local fair-trading laws.
FAQ
Does the EU/UK 2 ml rule apply to empty 2 ml devices?
Not while shipped as empty hardware. The 2 ml cap is enforced for nicotine e-cigarettes marketed for consumer sale. Once filled/marketed with nicotine, the cap and warning rules apply.
Do I need a nicotine warning if the device is zero-nicotine?
If the product is not a tobacco product (no nicotine and not intended for nicotine use), do not place nicotine warnings. Keep copy clean and factual to avoid implying tobacco product status.
What internal links should our buyers read first?
Start with wholemelt and then jump to Whole Melt Disposable Vape Pens for specific 2 ml enclosures.

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