E-Liquid Products Tax: EPT compliance guide for businesses

The E-Liquid Products Tax (EPT) is a new excise duty introduced under the Finance Act 2024 on e-liquid products such as vapes, e-cigarettes or similar inhalation devices. This tax applies to all e-liquids regardless of their nicotine content and will become effective from 1 November 2025. It is important for businesses involved in the importing and distribution of e-liquid products within Ireland to consider the EPT. It is essential for affected businesses to understand how the tax affects them, how to register, what the rates are and their responsibilities in relation to reporting.

In this article, we outline the key aspects of EPT to help businesses stay compliant.

How the EPT applies to e-liquid products

Suppliers making the first supply of e-liquid products in Ireland are liable to EPT. Trader's sourcing e-liquids only from Irish suppliers or supplying e-liquids solely outside Ireland are not liable.

To assist in determining whether a product falls within the scope of E-Liquid Products Tax (EPT), Section 57 of the Finance Act 2024 specifies the categories of products that are subject to the tax.

• Single use vapes/e-cigarettes/cartridges;
• E-liquid in refill bottles/cartridges for reusable e-cigarettes/vapes;
• DIY e-liquid kits.

E-liquid products licenced as a medicine for the purposes of nicotine replacement therapy are outside the scope of EPT. Such products are licensed or authorised by the Health Products Regulatory Authority (HPRA).

E-liquid products tax rates and reliefs

• EPT is chargeable based on the volume of the product.
• The current EPT rate applicable is €500.00 per litre.
• A relief from EPT may apply where e-liquid products on which EPT has already been paid by a registered supplier, are subsequently returned to that supplier.

EPT registration requirements

Only traders making first supplies in the State are liable for the tax and are required to register with Revenue. Those making second or subsequent supplies, in the State, do not have an EPT liability and are not required to register for EPT. Also, traders making supplies solely to a business or person outside the State are not liable for EPT. Liable suppliers of taxable e-liquid products are required to register with Revenue via (ROS) before making taxable supplies.

Filing EPT returns and making payments

Liable suppliers are required to file an E-Liquid Products Tax (EPT) return and pay any liability arising.

EPT returns and payments should be filed online via (ROS) and are due every two months, with deadlines one month after the period ends.

The first accounting period is from 1 November until 31 December 2025. The first EPT returns and payments are due by 31 January 2026.

If no supplies are made by a registered supplier, a ‘nil’ return must be submitted. Any payments made after the due date incur interest.

Record-keeping requirements under EPT

EPT does not need to be shown separately on invoices by ETP suppliers. However, suppliers must retain all relevant records for a period of six years. These records can be electronic or paper.

To find out more please reach out to our Indirect Tax team who would be happy to arrange an initial conversation with you.

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