Our earlier piece covered Poland's own "stacking on top" case specifically. This one takes a different angle — mapping out where several major EU member states currently stand on flavor restrictions, to make it quick to gauge where a specific market sits. The TPD itself imposes no hard flavor ban — only a nicotine cap and tank/pod volume limit — so whether fruit flavors can be sold is entirely up to each country.
Already in force: France
France has banned prefilled disposable vapes since February 2025. The ban itself doesn't explicitly say "flavor ban," but since the overwhelming majority of disposables on the market are flavored, the practical effect covers most flavored product. Broader flavor legislation (covering all e-liquid, not just disposables) remains under parliamentary discussion, with no formal bill yet.
Draft complete, awaiting a vote: Spain
Spain wrapped up public consultation on an amendment to Royal Decree 579/2017 in late 2024, with the draft proposing a ban on all non-tobacco flavors. If passed as drafted, it could take effect as early as 2026 — but it's currently at "draft complete, not yet formally voted on," a different certainty tier from France's "already in force."
Expert-recommendation stage: Belgium
Belgium's Federal Public Health Service released an expert evaluation report in 2024 recommending restrictions on sweet/beverage-style flavors. That recommendation has reached parliamentary committee hearings, but remains some distance from a formal bill — relatively early-stage compared to the other cases here.
First parliamentary debate: Portugal
Portugal held its first parliamentary debate on flavor restrictions in November 2024, with the draft proposing only tobacco and menthol flavors remain permitted. It hasn't yet reached a vote.
Minister has voiced support, no formal draft yet: Greece
Greece's Health Minister publicly voiced support in 2025 for "banning all flavored e-liquid except tobacco and menthol," but as of now, that statement hasn't translated into a formal legislative draft — the earliest stage among these cases. There's a meaningful gap between a minister's personal statement and a formal legislative process; "minister supports it" shouldn't be treated as "legislation is imminent."
At a glance
| Country | Current stage | Details |
|---|---|---|
| France | In force | Full ban on prefilled disposables (since Feb 2025) |
| Spain | Draft complete, awaiting vote | Proposes banning all non-tobacco flavors, possibly effective 2026 |
| Belgium | Expert recommendation + hearings | Recommends restricting sweet/beverage flavors |
| Portugal | First parliamentary debate | Proposes tobacco + menthol only |
| Greece | Minister has voiced support | No formal draft yet |
| Poland | HTP flavor ban passed; e-cig flavor restrictions in progress | See our dedicated Poland piece |
What this map actually shows
"Being an EU member state" tells you nothing about which stage a specific country is at in flavor legislation — France has been in force for two years, while Greece may need another two or three years just to reach "draft complete." That gap can exceed five years, even though both countries are EU members following the same TPD baseline.
The structural reason is simple: the TPD sets only a floor. Rules above that floor — like flavor restrictions — are left entirely to each country's own legislative pace, with no EU-level unified timeline forcing synchronization, and no requirement that member states follow suit.
Practical guidance for sourcing and channel planning
- Don't use "it's an EU country" to predict a specific country's flavor-compliance status — verify the current stage per country (in force / draft awaiting vote / expert recommendation / minister statement); these carry very different certainty levels
- The "draft complete, awaiting vote" stage (like Spain) is worth preparing for now — based on the France, UK, and New Zealand precedents, once a draft reaches the voting stage, it often takes effect faster than expected
- The "minister's personal statement" stage (like Greece) doesn't require adjusting product lines yet, but is worth logging and tracking as a long-term planning signal, not a near-term action trigger
(General information only, not legal advice — consult a lawyer familiar with compliance in your target market before making business decisions.)