HMRC: How to Submit UK Vaping Products Duty Return Monthly

• Approved UK vaping product manufacturers must submit a monthly Vaping Products Duty return by the 7th day of each month, with the first return due on 7 November 2026.
• The return covers activity from the previous calendar month, and a nil return is required even if there is nothing to declare.
• Duty suspension allows deferral of duty payment for products stored in approved locations, with duty becoming payable upon release for consumption.
• VAT for duty-suspended products is paid via Form W50, not the standard VAT return, once products are released from suspension and duty is paid.
• Non-compliance with submission or payment deadlines can result in late payment interest and additional penalties.

Significantly, this specific VAT payment must be made using Form W50, rather than being included in the manufacturer's regular VAT return.

Approved manufacturers of vaping products in the United Kingdom are required to submit a monthly return detailing all finished vaping products released for consumption within the UK. This mandatory submission must be completed using the dedicated "Manage your Vaping Products Duty" online service. The obligation applies to all UK-approved entities, ensuring comprehensive oversight of products entering the domestic market.

The Vaping Products Duty came into force on 1 October 2026. The deadline for submitting this online Vaping Products Duty return is the 7th day of each month. The first return was due on 7 November 2026, covering activity from the preceding calendar month (October 2026), which is designated as the accounting period. Even if a manufacturer has no finished vaping products to declare for a particular period, a return, known as a nil return, must still be submitted to HMRC, underscoring the strict compliance requirements. Before a manufacturer can complete their initial return, they must first gain access to the Vaping Products Duty online service.

The regulatory framework for vaping products includes provisions for duty suspension, an arrangement with HMRC that allows for the deferral of Vaping Products Duty payments. This applies when products are stored in specific approved locations. The duty becomes payable only when these products are removed from their approved storage facility for sale or supply within the UK. To utilize this suspension mechanism, manufacturers must secure prior approval from HMRC.

Manufacturers must also account for various adjustments in their returns. These include "spoilt goods," which are duty-paid items returned for destruction, such as products deemed unfit for consumption. "Under-declared" situations arise when a manufacturer reports a lower quantity of products leaving their premises than were actually released, perhaps due to an overlooked dispatch record. Conversely, "over-declared" instances occur when the reported quantity exceeds the actual amount released, possibly from double-counting a dispatch or reporting it in the incorrect accounting period.

A crucial aspect for manufacturers involves the distinct Value Added Tax (VAT) treatment for vaping products held under duty suspension. When these products are sold while still at the manufacturing premises and remain under excise duty suspension, VAT is not immediately due at the point of sale. Instead, VAT becomes payable only when the vaping products are released from duty suspension and the corresponding excise duty is settled.

Significantly, this specific VAT payment must be made using Form W50, rather than being included in the manufacturer's regular VAT return. Manufacturers needing this form should request it by emailing vapingenquiries@hmrc.gov.uk. Failure to adhere to the established deadlines for both submission and payment carries serious consequences. Non-payment by the due date will incur late payment interest, and manufacturers may also face additional penalties for non-compliance.

Lawyers advising clients in the UK vaping manufacturing sector must ensure they are aware of the mandatory monthly Vaping Products Duty return submission requirements, including specific deadlines (7th of each month), nil return obligations, and the distinct VAT payment process (Form W50) for products under duty suspension, to avoid penalties for non-compliance.

Source: Original reporting via GOV.UK guidance.