| Dimension | United States | United Kingdom |
|---|---|---|
| Regulator | FDA (CTP) | MHRA (TPD compliance) |
| Product authorization | PMTA (48 products authorized) | TPD notification (no authorization required) |
| Nicotine limit | No federal limit | 20mg/ml max |
| Tank/refill limit | No federal limit | 2ml tank, 10ml refill bottle |
| Health authority stance | AHA calls for more research | PHE/NHS: "less harmful than smoking" for adult smokers |
| Flavor restrictions | 6 states ban flavors, 17 have PMTA directories | Disposable vape ban (June 2025) |
| Blood pressure research | VapeScan Study (2026) | UK studies ongoing; COT scheme monitoring |
The UK takes a more permissive stance on vaping for adult smokers switching from cigarettes, with Public Health England's "less harmful than smoking" position. However, the VapeScan findings about cardiovascular risk in never-smokers raise questions that are relevant to both markets — particularly as the UK disposable ban pushes users toward refillable devices that may deliver higher nicotine doses.
