| Dimension | United States | United Kingdom |
|---|---|---|
| Regulatory Framework | FDA PMTA pre-market authorization | MHRA notification (no pre-market approval) |
| Border Enforcement | Seize and destroy at ports (FY 2026 bill) | Trading Standards seizures (post-notification only) |
| Authorized Products | 45 products from 5 brands | Thousands of notified products |
| Disposable Vape Ban | No federal ban (state-level varies) | Ban effective June 1, 2025 |
| Flavor Restrictions | State-level (8 states ban flavors) | No national flavor ban (disposable ban covers most flavored disposables) |
| Nicotine Limit | No federal limit | 20 mg/ml max (TPD) |
| Tank/Refill Limit | No federal limit | 2 ml max tank, 10 ml max bottle (TPD) |
| Tax Framework | 34+ states with excise taxes (varies) | Vaping Products Duty effective April 2027 (with seizure powers) |
| Enforcement Budget | $200M (FY 2026) | 200+ new compliance officers (HMRC) |
| Age Limit | 21+ (federal) | 18+ (Tobacco and Vapes Act 2026) |
The U.S. and UK have taken fundamentally different approaches to vape enforcement. The U.S. uses a strict pre-market authorization model — only 45 products have passed FDA review, and unauthorized products are now destroyed at the border. The UK uses a lighter notification system where manufacturers self-certify compliance with TPD standards, with enforcement handled locally by Trading Standards. The UK's disposable vape ban (effective June 1, 2025) removes an entire product category, while the U.S. allows disposables but restricts them through PMTA enforcement.
