Table of Contents
Fundamentals
Which Substances Are Prohibited in E-Liquids?
In Germany, the ingredients of e-liquids are subject to strict regulatory requirements. The Tobacco Products Act (TabakerzG) and the Tobacco Products Ordinance (TabakerzV) define which substances may not be used in electronic cigarettes and refill containers.
The prohibition list comprises several categories: vitamins and additives that give the impression of a health benefit, stimulating substances such as caffeine or taurine, CMR substances (substances that are carcinogenic, mutagenic or toxic to reproduction), and certain health-damaging flavouring substances such as diacetyl.
Good to Know
The legal basis is § 28 TabakerzV in conjunction with Annex 2. Additionally, the CLP Regulation (EC) No. 1272/2008 prohibits all substances classified as CMR 1A, 1B or 2. A reference draft of the BMEL also provides for a ban on menthol, cooling agents and sucralose.
Legal Framework
The Legal Framework
The regulation of e-liquid ingredients is based on several legal sources: the TabakerzG as the legal basis, the TabakerzV with the specific ban list in Annex 2, the European CLP Regulation for CMR substances, and the planned reference draft for the 5th Amending Ordinance.
Particularly important: Even substances not explicitly listed in the prohibition list may be banned under § 14(1)(3) TabakerzG if they pose a risk to human health. Each individual case should therefore be assessed separately.
Practice
Prohibited vs. Planned Prohibition – Examples
The following overview shows typical examples of prohibited and planned-to-be-prohibited ingredients in e-liquids.
| Ingredient | Status | Why? |
|---|---|---|
| Diacetyl (2,3-butanedione) | Prohibited | Health-damaging flavouring substance under Annex 2 No. 5a TabakerzV |
| Caffeine | Prohibited | Stimulating additive under Annex 2 No. 2 TabakerzV |
| Vitamin E (tocopherol) | Prohibited | Creates the impression of a health benefit (Annex 2 No. 1) |
| Menthol | Planned | Reference draft 5th AmendOrd TabakerzV – prohibition expected 2026/2027 |
| Sucralose | Planned | Reference draft 5th AmendOrd TabakerzV – prohibition expected 2026/2027 |
⚠ Caution
The e-liquid checker database covers over 1,200 substances from three different legal sources. Even if a substance is not included in the database, this does not automatically mean it is permitted. According to § 14(1)(3) TabakerzG, substances not listed can also be prohibited.
Tool
E-Liquid Ingredient Checker
Check directly whether an ingredient in e-liquids is prohibited or planned to be prohibited under TabakerzV. The search works by substance name, CAS number or category.
Please note: The check is only available in German.
E-Liquid Inhaltsstoff-Checker
Prüfen Sie, ob ein Inhaltsstoff in E-Liquids gemäß § 28 TabakerzV verboten ist.
Inhaltsstoff oder CAS-Nummer eingeben
Durchsuchen Sie 1.538 Einträge zu verbotenen und geplant verbotenen Stoffen in E-Liquids.
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Note: This overview is based on the German Tobacco Products Regulation (TabakerzV) Annex 2, the CLP Regulation (EC) No 1272/2008 and the draft amending regulation (as of 23 January 2026). It is provided solely for general guidance and without warranty. The search results do not constitute individual legal advice. Substances not listed here may also be prohibited under Section 14(1)(3) of the German Tobacco Products Act. Each case must be assessed individually.
Risks
What Breaches Can Result In
The use of prohibited ingredients in e-liquids can have significant legal consequences. Intentional placing on the market is criminal and can result in imprisonment of up to one year or a fine. Negligent use is an administrative offence.
Competitors can issue warnings under the Act Against Unfair Competition (UWG) and may also seek cessation orders in interlocutory proceedings.
When You Need a Lawyer
Problems with e-liquid ingredients?
As an attorney specialising in e-cigarette law, I advise you on the compliant composition of your products and represent you in warning procedures and administrative proceedings.
Are you unsure whether an ingredient in your e-liquid is permissible? Or have you received a warning or official notice? I am happy to advise you on compliant product composition and the prevention of regulatory risks.