Germany’s Proposed Disposable Vape Ban

1. Why the Definition of Disposable Matters

The German government has expressed its intention to pursue a ban on disposable e-cigarettes. Discussions have focused primarily on the protection of minors, resource waste and the fire risks associated with batteries in discarded devices. The specific scope of the proposed ban will depend on the product definitions in the final legislation.

Uncertainty remains over the implementation date, transitional arrangements and specific products that a future ban would cover. Research has previously forecast that Germany could introduce a draft by the end of 2026 and advance legislation in 2027. These milestones should not be treated as confirmed legal arrangements.

Future regulation may focus on whether a device can be refilled with e-liquid, whether it can be recharged and whether its battery unit can continue to be used after the e-liquid runs out. Under the approach suggested by some research, even a rechargeable device could face regulatory risks relating to disposable products if it cannot be refilled or fitted with a replacement pod once its e-liquid is depleted.

For e-cigarette brands, a key question is therefore whether the device can continue to be used by replacing consumables or refilling it after the e-liquid runs out or the atomizing component needs replacement.

This question connects policy changes with replaceable pods, refilling and reusable device structures. Whether a specific product meets Germany’s future regulatory requirements will still need to be assessed against the final legislation.

2. Market Shares and Pod Users

German e-cigarette market data offer another perspective: the market share of disposable products has gradually declined since reaching a relatively high level in 2023, while the proportion of users of open and closed pod systems has continued to rise.

Disposable e-cigarettes’ share of sales value fell from 44% in 2023 to 21% in 2025, while their share of users declined from 30% to 15% over the same period. These two measures describe changes in sales composition and user composition, respectively.

Existing forecasts project that Germany’s e-cigarette market will grow from US$1.497 billion in 2025 to approximately US$1.582 billion in 2026 and around US$1.625 billion in 2027. Over the same period, user numbers are forecast to rise from 3 million to 3.2 million and then 3.35 million.

These forecasts show continued growth in the overall market alongside a decline in the relative share of disposable products.

By 2027, open and closed pod systems are each forecast to account for 35% of users. Pod products are projected to reach 39% of sales value, while bottled e-liquid is expected to retain a share of around 36%. This suggests that several types of reusable system may continue to coexist in Germany, rather than the market shifting entirely to a single device type.

For e-cigarette brands, these changes suggest that product portfolios may need to extend from disposable devices to reusable devices and their associated consumables.

For replaceable-pod products in particular, brands need to consider pod specifications, atomizing systems, e-liquid compatibility and ongoing consumable supply, alongside device design and performance, to build a more complete product range.

The 2026–2027 figures above are market forecasts. The charts do not state whether the proposed ban has already been incorporated into the forecast scenario, so they cannot establish the ban’s specific effect on market shares. Future market composition may also be influenced by policy, consumer demand, product innovation and sales channels.

3. Product Structures and Current Requirements

Several brands already offer products with different pod-replacement and refilling structures. DOJO BLAST10K, GRABIT MAX, PIXL XFILL and MEGABAR GT 15000 illustrate different combinations of battery units and consumables. Their technical approaches vary, showing that reusable systems do not have a single product format.

The four products below illustrate different structural design approaches.

Their specifications come from publicly available brand or product websites and do not mean that every configuration meets current German regulatory requirements.

Four Product Structures Compared

These examples show that brands can enable reuse of the battery unit through different structures. However, there are clear differences in pod connections, liquid storage, atomizing components and refilling mechanisms.

Capacity Labels and Current Requirements

Under Section 14 of Germany’s Tobacco Products Act, nicotine-containing refill containers must not exceed 10 ml, nicotine-containing disposable e-cigarettes or disposable cartridges must not exceed 2 ml, and nicotine concentration must not exceed 20 mg/ml.

For advertised capacities such as 10 ml or 12 ml, it is therefore necessary to establish whether the figure refers to a separate refill container, a pod or the combined capacity of different components. A stated total capacity alone does not determine whether a product complies with German law.

4. Product Trends and Development Conditions

Taken together, market data and existing product examples suggest that open and closed pod systems may continue to coexist in Germany, with reusable battery units developing alongside replaceable consumables.

The declining share of disposable e-cigarettes and the increasing share of pod products provide reference points for brands reviewing their product portfolios. Bottled e-liquid’s continued substantial share also suggests that refillable systems are expected to retain a place in the market.

From a design perspective, reusable systems may develop further toward modular structures, replaceable pods and refilling. Separating the battery unit from consumables allows brands to select different pod, refilling and atomizing approaches according to their target users’ habits.

This trend does not mean that every rechargeable or replaceable-pod product will meet Germany’s future regulatory requirements. How the proposed ban ultimately defines disposable products, and what changes existing products may need, will depend on the final regulations.

Future product planning requires brands to balance regulatory requirements, product performance, development costs and time to market.

Large brands may build differentiation through dedicated product design and technical development. For smaller brands that are new to the industry, have limited research and development resources or want to control upfront investment, existing technology platforms and supply chain resources may also be options to consider.

5. Development Models and Product Assessment

Developing a new device from scratch is not the only option for smaller brands, businesses new to the industry or brands planning to expand into Germany.

Dedicated custom tooling typically involves investment in product design, mold manufacturing, prototype testing and production validation. For brands still testing the market, facing uncertain sales volumes or lacking a complete development team, a new product development project may involve higher upfront costs and development risks.

Using shared tooling or customizing an existing technology platform can reduce some duplicated development work and may shorten time to market. Actual investment and timelines still depend on the scope of customization, testing requirements and supply conditions.

Shared Tooling and Cooperation Models

Through White Label and Private Label arrangements, brands can adapt logos, colors, packaging and certain configurations on existing devices. Clients seeking greater differentiation may choose ODM development, while brands with complete product designs can use OEM arrangements to access external manufacturing and supply chain resources.

These models differ in development investment, the extent of customization and responsibility for design. Brands should choose an approach that matches their requirements.

Related reading: What Are OEM, ODM, White Label & Private Label?

Technical Assessment of Shared-Tooling Products

Shared tooling can reduce some development costs, but technical maturity and manufacturing quality still need to be assessed for each product.

Compatibility between the device and e-liquid is particularly important for replaceable-pod and refillable e-cigarettes. Coil structure, output power, e-liquid formulation, airflow and liquid storage design all affect actual product performance.

Leakage, condensation, battery performance, material compatibility and consistency in volume production also need to be evaluated through appropriate performance testing and quality management.

Smaller brands’ product assessments should cover appearance, purchase price, specifications, device reliability, e-liquid compatibility, supplier capabilities and the target market’s compliance requirements.

Working with a partner experienced in product development, technical assessment and supply chain management can help brands evaluate different options more comprehensively and reduce uncertainty in product selection and project execution.

6. Milsons Vape Development and Sourcing Support

As Germany’s e-cigarette market develops toward a more diverse mix of reusable products, brands need to choose devices and cooperation models that fit market demand, development budgets and the scale of their business.

As a professional e-cigarette product solutions provider, Milsons Vape brings together device, industrial design, hardware engineering, e-liquid development and supply chain resources. We support brands at different stages with product selection, customized development, quality management, compliance coordination and logistics.

Product Selection and Supplier Resources

For brands considering shared-tooling products, Milsons draws on resources across China’s e-cigarette supply chain rather than relying on a small, fixed group of manufacturers. We identify devices and suppliers according to the client’s target market, product positioning and budget.

By assessing device structures, manufacturing quality, technical maturity and supply conditions, we help clients make product selection more efficient.

Coordinated Device and E-Liquid Development

Actual e-cigarette performance depends on hardware as well as e-liquid formulation, coils and power design.

Milsons combines device and e-liquid development resources, focusing on the match between atomizing systems and formulations. We help clients improve atomization, taste and product stability, providing more coordinated solutions for replaceable-pod, refillable and other e-cigarette products.

Customization and Design Support

For clients seeking brand differentiation, Milsons can support industrial design, CMF, structural development and technical solution optimization according to project requirements.

Brands can customize appearance and configurations on an existing technology platform or undertake more extensive development based on their product positioning. Clients without a complete hardware development and design team can also use external expertise to advance product development.

Quality and Supply Chain Management

Milsons combines product performance assessment, reliability testing, supplier screening and production quality management to help clients identify potential quality issues, while addressing manufacturing consistency and supply stability.

By coordinating sourcing, quality control and supply chain resources, we help brands improve development and procurement efficiency and reduce project execution risks.

Compliance and International Logistics Support

For different overseas regulatory environments, Milsons can support product testing, technical documentation, packaging labels and logistics delivery according to the target market and product type.

For Germany and other European markets, these services can help clients assess compliance requirements and coordinate development, manufacturing and delivery. Whether a final product meets market-entry requirements must still be confirmed against the applicable regulations and its actual configuration.

Whether you want to establish a product line using shared tooling or develop distinctive replaceable-pod or refillable e-cigarettes, Milsons can provide solutions according to your business scale, budget and target market requirements.

Contact us at info@milsonsvape.com to learn more about e-cigarette product solutions for Germany and other overseas markets, and to discuss your product selection, customized development and sourcing requirements.