HMRC narrows ban on transitional vaping duty stamps

HMRC has narrowed the restriction on transitional vaping duty stamps in its internal manualGOV. The duty-stamps page now says a transitional stamp may not be purchased after 30 November 2026, when digital stamps become mandatory, and may not be affixed to the packaging of an eligible vaping product packaged after 1 January 2027GOV. The previous version added a second affixing trigger, covering products released for consumption in the UK after 31 March 2027GOV; that release-based limb has been deletedGOV, so the affixing ban now turns only on the packaging dateGOV.

Transitional stamps are the physical-only forerunners of the scannable digital stamp. They share the digital stamp's look, in a different colour and without the data matrix, so they cannot be scanned. They were available to purchase from 1 April 2026 until 30 November 2026, with digital stamps available from 1 September 2026, and from 1 January 2027 only digital stamps may be affixed. Stamps must be fixed to the outermost retail packaging so the pack cannot be opened without damaging the packaging or the stamp, and digital stamps are activated at affixing with metadata including the time, place, operator and product descriptors. By 1 April 2027 every vaping product outside duty suspension must carry a duty stamp.

The practical effect concerns stock packaged before the January cut-off. Under the earlier wording, a product packaged in December 2026 but released for consumption after 31 March 2027 appeared unable to carry its transitional stamp. With the release-based limb removed, the packaging date is the only test on this pageGOV: a product packaged on or before 1 January 2027 keeps a validly affixed transitional stamp even if it is released after the end of MarchGOV. That reading is consistent with the page's retained expectation that transitional stamps may still be found in retail premises after 31 March 2027, in which case caution should be exercised rather than non-compliance assumed.

One point needs care. A separate manual page dealing with scanning events still phrases the restriction in the earlier form, retaining the release-after-31-March-2027 limb alongside the packaging limb. Advisers reconciling the two pages should work from the updated duty-stamps page for affixing decisions while remaining aware that the scanning-events page has not yet been aligned.

Manufacturers, warehousekeepers and UK representatives should therefore complete transitional-stamp purchasing by 30 November 2026 within their HMRC-set rolling limits, finish affixing transitional stamps before 1 January 2027, and keep the required controls over ordering, storage, reconciliation and loss or damage. Only HMRC-approved purchasing operators may buy stamps, and digital stamps affixed from the new year must be activated with the prescribed data. The legal basis is Part 4 and Schedule 15 of the Finance (No. 2) Act 2026 with the Vaping Products (Production, Duty Stamps and Commencement) Regulations 2026 and the Vaping Stamps (Requirements, Reviews and Appeals) Regulations 2026, explained in the HMRC manual duty-stamps page VPDS156000 as amended and the published guidance on how vaping duty stamps work.