Registration process
Germany vape product registration
Germany follows the core EU-CEG product notification process, but with additional legal requirements and options for faster market access. Below is the full workflow and special considerations based on German law.
Step 1: Prepare the Submission
Use TPD PRO to:
Add Submitter and Manufacturer information
Build compositions with full toxicological data
Attach required PDF files (e.g., emissions, leaflet, packaging)
Generate validated XML files
Step 2: Submit via eTrustEx
Submit the following via the eTrustEx platform:
Submitter XML
Attachments
Product Submission XML
Files must be submitted in the correct order and receive a “Success” response for each.
German-Specific Legal Requirement
According to the German Tobacco Products Act (TabakerzG §3 para. 1):
If the manufacturer is based within the EU and sells directly to Germany - they may submit the notification.
If the manufacturer is outside the EU (e.g., in China) - their submission is not valid in Germany. Instead, a European entity (distributor, importer, or authorized representative) must submit the product.
Waiting Period
Germany enforces the standard 6-month waiting period after submission before a product can be legally sold. After approval, products are published in the German government database:
Distribution Strategy Options
If you don’t yet have a local distributor in Germany, there are two common approaches:
Option 1: Submit via EU Representative
An authorized EU company (such as a compliance partner) submits on your behalf.
Once you find a German distributor, they can:
File a follow-up notification
Reference your existing EC-IDs
Get listed immediately
Summary
Germany requires more than just EU-CEG compliance - legal responsibility for the notification must lie with the actual market entrant. However, with strategic planning, fast-track listing is possible using referenced EC-IDs and local partners.