They Taxed Every Millilitre I Vape. They Never Worked Out How Many I Use.

On 1 October 2026, every 10ml of e-liquid sold in this country picks up £2.20 of duty. That's 22p a millilitre, and VAT goes on top of it. Flat rate. Same on 20mg, same on 0mg.

So here's a fair question. How many millilitres does a vaper actually get through in a day?

The government doesn't know. I've been through everything they published, the consultation, the response, the impact note, their own survey of vapers, and there is no answer in any of it. They never established it. They never measured it. They taxed it anyway.

I'll tell you what I get through, because somebody should. I'm a heavy vaper. Around 15ml a day on 5mg or 10mg nic salts, depending on what I'm doing, where I am and the situation I'm in. Back when I was sub-ohming on 3mg it was closer to 30ml. I've been vaping since 2012 and I founded a vape company, so I've watched a lot of people vape, and I have never once met the person this tax was designed around.

What follows is my opinion. Every fact underneath it is the government's own, and I've read the documents rather than the headlines about them.

The whole thing rests on one pod. And a tobacco company supplied the number.

What the government did publish is an equivalence. Not a consumption figure, an equivalence: roughly 1ml of e-liquid to 10 cigarettes. Everything anybody has ever said about what this tax costs a real vaper is derived from that one line.

So where did it come from? Here it is, word for word, from the Vaping Products Duty consultation, paragraph 3.20:

"We identified a product which established puffs based on laboratory testing and the international standard for puffing regimes (ISO 20768). It established that their Vuse ePen pods containing 2ml provide 200 puffs based on these tests. Therefore, it is estimated that vaping products contain, on average, 100 cigarette puffs per 1ml."

One product. One pod. A Vuse ePen.

Now go and look at the footnote for where that puff count came from. It says: British American Tobacco, Vuse puff count.

Read that again, because I had to. The evidence base for taxing five million British vapers is a puff count published by a tobacco company, about a tobacco company's own product.

I'm not going to call that a conspiracy. I don't need to. It's just staggeringly thin. Nobody vapes a Vuse ePen and calls it representative of anything. I've got customers on rebuildables, customers on 25,000-puff pods, customers on sub-ohm tanks pushing serious wattage, customers on zero nicotine going through shortfills like water. They are not the same animal as a closed tobacco-industry pod, and they never were.

Setting the tax base for an entire industry off that one product is like setting fuel duty by measuring a moped.

And here's the kicker. By the time the government published its final response, the Vuse citation was gone. The 1ml equals 10 cigarettes line survived, but the working that produced it, the pod, the puff count, the tobacco company, quietly vanished from the document. The assumption carried on. The evidence for it didn't.

What their own maths says about me

Take their equivalence seriously for a second, because it's worth doing.

1ml equals 10 cigarettes. So a 10ml bottle is 100 cigarettes. I get through about 15ml a day.

By the government's own arithmetic, I smoke 150 cigarettes a day.

A hundred and fifty. Seven and a half packs, every day, for years. I'd be dead. That's not a rhetorical flourish, it's just what their number produces when you put a real vaper into it. And I'm not some freak outlier. I'm a bloke who vapes custard flavours at 5mg and 10mg and does a lot of hours.

Now here's the part that should really worry them. I'm on nic salts in a pod these days, because it's convenient. Before that I was a sub-ohm and rebuildables vaper on 3mg, and on that setup I was getting through more like 30ml a day.

Double the liquid. On a fraction of the nicotine. Their model has that version of me smoking 300 cigarettes a day.

When a model spits out an answer that absurd, the model is wrong. You don't get to keep the model and tax people on it anyway.

They never asked anyone how much they vape

This is the part I keep coming back to.

HMRC ran a survey. They did the work. And the question they asked vapers was how much they spend. The answer came back at around £8.60 a week. They did not ask how many millilitres people get through. They had a room full of actual vapers and they asked about the wallet, not the bottle.

You cannot build a per-millilitre tax on a survey that never mentions millilitres. That's not a technicality. That's the whole thing.

And the data was sitting there for the taking. Every legitimate retailer in this country knows to the bottle what their customers buy. We do. It's in our order history. They never asked us. They never asked any of us.

So we measured it ourselves

The government never asked a retailer how much liquid people actually get through. We are a retailer. We have the answer sitting in our order history. So we went and got it.

We looked at every e-liquid purchase made by almost 18,000 customers across four separate periods spread over nine months, from July 2025 to April 2026. That's 89 days of trading, sampled at four points across the year so nobody can accuse us of picking a good month.

Then we did the thing the Treasury didn't. For every customer who came back, we worked out how much liquid they bought and how long it lasted them before they needed more. That gives you a genuine consumption rate rather than a guess. We measured over 4,300 complete purchase cycles that way.

Here is what British vapers actually get through.

Every figure is a range because we measured it twice, using two different methods. One of them is generous to the government's number. The other isn't. Neither of them gets anywhere near 2ml.

Read the bottom two rows together, because that is the whole argument. The typical vaper we measured gets through somewhere between 5.7 and 10.3ml a day. The Treasury built a tax on 2ml. 91% of every purchase cycle we measured is above it.

Three reasons these numbers are too low

We'd rather tell you what's wrong with our own study than have somebody else do it.

These are our customers, not the country. Ecigone's customers lean towards refillables and open systems more than the average corner shop's do. That pushes our overall figure up, and we're saying so before anyone else does. It's exactly why the table is broken down by device: judge us on the row that matches you.

We threw away our most dramatic number. Open-system vapers came out at 16 to 30ml a day. We are not leading with that, because shortfill buyers can keep a stash on a shelf and we cannot see the shelf. It's in the table for completeness and we don't rely on it. The two rows we'd stake our name on are the pod rows, and they still come in at two to four times the Treasury's figure.

Nobody buys everything from one shop. This is the big one, and it runs entirely in one direction. We can only see what a customer bought from us. Every vaper in this country also picks up a bottle in a corner shop, grabs one at the garage, or shops around online. Whatever they bought elsewhere, we haven't counted it. Every single number in that table is a floor. The real figure is higher, and we have no way of knowing by how much.

Which brings us to the point.

We are one retailer, working from one order book, and we have measured almost 18,000 vapers and over 4,300 purchase cycles. HM Treasury had the entire industry to ask, and a legal power to demand the data, and they taxed five million people on the puff count of a single pod published by a tobacco company.

They could have done this. They just didn't.

The zero-nicotine problem nobody wants to talk about

The tax is flat. £2.20 per 10ml, whatever's in it. So 0mg pays exactly what 20mg pays.

Now, I've been a loud advocate for zero-nicotine vaping for years. My view has always been the same: start at 20, work your way down, and one day walk away from the whole thing. That's the journey. That's what it's for. I've got a lot of customers at 0mg and 3mg who are at the far end of quitting, doing exactly what every public health body in the country told them to do.

Those people are about to be taxed at the same rate as someone on 20mg nic salts.

And here's what makes it worse, and this is the part I'd put in front of a minister.

The original consultation had six objectives. Two of them were about nicotine: encouraging people onto lower-strength and nicotine-free liquid, and encouraging manufacturers to cut the nicotine in their products. The design followed from that. It was going to be a tiered tax, more duty on stronger liquid.

And the consultation said this, in terms, at paragraph 3.10:

"A flat rate structure was considered, which would mean one rate for all liquid regardless of nicotine content, however a progressive structure will better meet these objectives."

They wrote down that a flat rate would not meet the health objectives. They considered it and rejected it, on the record.

Then came the response. The six objectives became four. Both of the nicotine ones were gone. And the structure they'd said couldn't meet the objectives, the flat rate, is the one we're getting.

They didn't change the tax to fit the objectives. They changed the objectives to fit the tax.

If this was really about nicotine, it would be a tax on nicotine. It isn't. It's a tax on liquid. And that tells you exactly what it's for.

I'll be straight with you: the tiered version, more on the strong stuff, less on the weak, I could have lived with. When it was first floated I didn't think it was a bad job at all. I'd still rather my customers weren't taxed for getting off cigarettes. But at least it pointed people somewhere. This points nowhere.

"The heaviest vapers." They think they mean ex-smokers.

The government's own impact note says the quiet part out loud:

"We expect the heaviest vapers to carry the largest burden, encouraging them to reduce their consumption and eventually quit."

Fine. Now, who are the heaviest vapers?

The Treasury seems to picture a former smoker chuffing away on a pod. And 84% of the five million people this tax hits did come from smoking, 53% are ex-smokers, 31% still smoke as well. That's from the government's own numbers, and it's remarkable how little it comes up in their impact assessment. The section on the impact on individuals doesn't mention smoking status at all. Five million people, most of them ex-smokers, and the document that assesses the impact on them doesn't think that's worth a line.

But from where I sit, serving these people every day, the heaviest vapers aren't the pod crowd at all. They're the hobbyists. Sub-ohm tanks, rebuildables, big airflow, big clouds, and very often 3mg or below, because when you're moving that much liquid you physically cannot be on 20mg. It would floor you.

I know this because I was one of them. Rebuildables, sub-ohm, 3mg, and roughly double the liquid I get through today on a pod at 10mg.

Sit with that for a second. The lower my nicotine went, the more liquid I used. That is how vaping actually works, and it is the exact opposite of what a per-millilitre tax assumes.

So the tax lands hardest on the vapers who took the most nicotine out of their vaping. The ones furthest along. Read that back, because that's the actual design.

The thing I'm genuinely worried about

It isn't the price. It's what people do about the price.

Because the tax is per millilitre, the cheapest way to keep your nicotine and cut your bill is to use less liquid and put more nicotine in it. Go up from 10mg to 20mg and use half the juice. That's the rational response. That's what the tax is pushing.

I've tried it. It doesn't work like that. You go up in strength and for a bit you vape less, then you drift back to vaping the same amount anyway, only now you're on double the nicotine. And when you eventually try to come back down, you vape even more than you did to start with. I've watched it happen to me and I've watched it happen to customers.

A tax that nudges an ex-smoker's nicotine intake up is a strange thing for a health policy to do.

The government heard this sort of thing during the consultation. They wrote the objections down, which I'll give them credit for. Respondents pointed to the 70% drop in legal vape sales in Italy after their vaping duty came in. A vaping business submitted US research showing vape tax rises correlating with more people smoking. And the industry warned that compliance costs could make some small businesses unviable.

On the US evidence they did answer, after a fashion: they're putting tobacco duty up on the same day, to keep the gap. Fine, that's a response.

On Italy's 70% collapse, and on the small businesses going under, the response says nothing at all. The objections are printed in the document. The replies aren't.

What it costs me. What it'll cost you.

Let's do the actual money, because the "44p a day" line that got repeated everywhere is doing a lot of heavy lifting.

The duty is £2.20 per 10ml. Add VAT on top of the duty and you're at £2.64 per 10ml before anyone's made a penny of margin.

Fourteen hundred and forty-five pounds a year, for me, in duty alone. And if I'd stayed on sub-ohm at 3mg, where I was for years, it'd be nearly three grand. On a fraction of the nicotine.

That's before you count what the tax does to the price, which is a different and bigger question.

Because the duty isn't the only cost arriving. Manufacturers have to buy machinery to apply duty stamps. They need bonded warehousing. There's extra logistics, extra compliance, extra admin, and on top of all that there are import cost increases coming out of China. All of that has to land somewhere, and it lands on the shelf.

Anyone telling you they know exactly where prices settle in October is guessing. I run a vape company and I don't know. What I do know is it won't just be £2.20 plus VAT.

Shortfills are the ones that really get hurt. A 100ml shortfill picks up £22 of duty before VAT. That format, as we know it, largely doesn't survive that. Some brands will hang on. Most won't.

The bit that should worry the Treasury

If you're going to tax five million people, you'd want your homework to be solid. Theirs isn't, and you don't have to take my word for it.

Start with the bill for collecting it. HMRC's own impact note says delivering this duty will cost them £140m: £20m to build the IT system, £120m in staffing through to 2030. In its first year, the duty is forecast to raise £135m.

I'll be fair, because I want this to stand up: that first year is only half a year, the duty starts in October, and by 2027 to 2028 it's forecast to bring in £400m. So it isn't true that it costs more than it raises forever. But it is true, from their own document, that the machine costs more to build than the tax collects in its first year. That's the price of the plumbing.

Then there's the forecast itself, and this one is worth your time.

The Office for Budget Responsibility had to estimate how much people would cut back when the price rose. The academic evidence gave them a number: an elasticity of about -1.15, meaning demand falls sharply. Here is what they did with it, in their own words:

"Using such a high elasticity would lead to a very sharp fall in demand which we judged unlikely. We therefore made a judgement to reduce the own-price elasticity by 25 per cent to -0.9."

Not because new evidence arrived. Because the answer the evidence gave them looked too big. So they shaved a quarter off it and moved on.

They also promised: "We will continue to review these elasticity assumptions as more evidence on consumer behaviour becomes available." That was July 2025. As of today they haven't published an update.

And when the OBR first certified this duty, back at Spring Budget 2024, they gave the costing their highest uncertainty rating: very high. The single biggest source of that uncertainty, in their own scoring, was the data.

The data. The pod. The tobacco company's puff count. Even the forecasters flagged it.

The grey market, and the black one. They are not the same thing.

People are going to react to this. Let's be honest about how.

Start with what's already true. The UK caps nicotine in e-liquid at 20mg. Right now, today, you can go online and buy nicotine at 72mg. The cap has been there for years and it has not stopped that. Bear that in mind when anyone tells you a rule will hold the line.

So here's what I think happens. There'll be a grey market: not criminals, just ordinary vapers working round the edges of a tax they think is unfair. Stockpiling before October and storing it properly. A big move to longfills. And people buying PG, VG and flavour concentrates from other industries, where they're just chemicals and food ingredients rather than vaping products, and mixing their own.

I don't condone any of that. But I understand exactly why people will do it.

And here is where I have to stop and warn you about something, because I don't think one vaper in a hundred knows it.

Mixing your own becomes a criminal offence on 1 October 2026

Not taxed. Not frowned upon. Against the law.

This is HMRC, in their own published guidance, word for word:

"From 1 October 2026 it will be against the law to manufacture vaping products in places that have not been checked and approved by HMRC. This includes the mixing of non-duty paid liquids to produce a liquid to be used in a vape, even if not produced for commercial sale."

Read that last clause again. Even if not produced for commercial sale. Your kitchen table counts. And the same guidance opens by telling you who has to read it: manufacturers of vaping products, "including products made at home".

To do it lawfully you would need HMRC approval. That means passing a fit and proper person test, having a fixed place of business, submitting a premises plan with the fire exits marked in red, submitting a business plan, and providing a financial guarantee from a bank. For your spare room.

I went looking for a hobbyist exemption. There isn't one. HMRC's line is that there will be no exemptions at all "except in circumstances required by law, such as supplies to diplomatic missions". Unless you're an embassy, you're not getting a pass.

There is exactly one thing they've left open, and it matters:

"It will not include the mixing of multiple duty-paid liquids, for example a duty-paid 'shortfill' (nicotine-free liquid) and duty-paid 'nicotine-shot'."

So shortfill plus nic shot, both bought duty-paid from a legitimate shop, stays completely legal. That's the survival route, and it's why longfills and shortfills will matter more after October than they do now, not less. Germany taxed vaping and their longfill market didn't die, it grew.

But the DIY route, mixing from raw PG, VG, concentrate and nicotine you bought as ingredients? Come October that isn't a grey area. It's an offence, carrying civil and criminal sanctions and, in HMRC's own words, "potentially leading to prison sentences".

I'm telling you this precisely because I don't want anyone reading this to sleepwalk into it thinking it's a clever bit of tax planning. It isn't. Nobody is talking about this, and they should be.

Then there's the actual black market

That's a different animal entirely, and it's the one that keeps me up.

Unregulated vapes sold on street corners and out of shops that just want to make a quick buck. No testing, no safety, no idea what's in the bottle. You can already buy illegal disposables in corner shops the length of this country. Everybody can see it. Now give people a financial reason to go looking, and watch what grows.

TPD gets a kicking, and some of it is fair, but the honest truth is it cleaned this industry up. It weeded that rubbish out. My genuine fear is that this tax reopens the door, and that the harm from one bad bottle of unregulated liquid dwarfs anything the duty was ever meant to prevent.

I honestly don't know how all this plays out. Anyone who tells you they do is guessing. But I know this much: the vast majority of vape companies in this country are responsible retailers. They'll follow the rules, they'll pay the duty, and they'll do everything they can to keep the cost down for the person at the end of it. We will, at Ecigone. That's not a marketing line, it's just the job.

And most vapers will stay with us, for one simple reason. They want to know what they're putting in their body.

What I'd have told them, if anyone had asked

I want to be clear about something first, because it would be easy to read all this as a bloke moaning about a tax on his own business.

I'm not against regulation. Regulation has been good for vaping. It drove out a lot of cowboys and it made this a safer thing to do, and there are still bad actors in this industry I'd happily see gone. And I'm not going to pretend I don't understand the concern about kids, because I do. I smoked as a kid. Kids do kid things. I don't condone it for a second.

But let's be honest about what this is. It's a sin tax. Same as alcohol, same as tobacco, same as sugar. The vaping industry got big and the Treasury noticed. That's the whole story, and the kids are the cover.

If I'd been in that room, here's the only thing I'd have said:

Ask the retailers. Go to the legitimate shops, the ones with tills and order histories and years of data on what real customers actually buy, and ask them how much people genuinely get through. Run a proper consumption survey. Then set the tax on the answer.

It would have cost them nothing. We'd have handed it over. Every serious retailer in the country would have handed it over.

They didn't ask. So we're doing it ourselves. We're going through our own order data to work out what UK vapers genuinely consume, and we'll publish it. It's the study the Treasury should have run before they wrote the number down.

Where this leaves us

I'll pay it. Most people will. It's still miles cheaper than smoking, and I would hate to put a cigarette back in my mouth. My mum died of lung cancer in 2018. That's the reason I do this at all.

Some people will stockpile, which is entirely legal before October and something I'll be doing myself. Some will move to longfills. Some, I'm afraid, will go looking for a cheaper bottle from someone who shouldn't be selling it.

And a few will go back to cigarettes. I don't know how many. Neither does anybody else, and that is precisely the problem. But every single one of them is a person this government said it wanted to help.

The maddening thing is that none of this had to be a fight. Tax it if you must. But tax it on something real.

Because right now, the number underneath all of this came from a tobacco company, and nobody ever checked it against a single British vaper.

Shane Margereson is the founder of Ecigone. He's vaped since 2012 and gets through around 15ml a day. By the government's own cigarette equivalence, that makes him a 150-a-day smoker.