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Excise Tax on Vapes and E-Cigarettes in the UAE: The 100% Rule Explained
UAE excise tax on vapes and e-cigarettes under Cabinet Decision No. 197 of 2025 — the 100% rate, excise price rules and registration within 30 days.
Key takeaways
- Vapes, e-cigarettes and e-liquids are excise goods taxed at 100% of the excise price under Cabinet Decision No. 197 of 2025
- Cabinet Decision No. 197 of 2025, effective 1 January 2026, repealed Cabinet Decision No. 52 of 2019 — the 100% vape rate did not change
- Article 5(1) of Federal Decree-Law No. 7 of 2017 prohibits the activity before registration; Article 5(2) sets a 30-day application window
- The excise price is the higher of the FTA's published standard price and the designated retail sales price less the tax included in it
- 5% VAT is then charged at retail on the excise-inclusive price, so the two taxes stack
- Ministerial Decision No. 1 of 2025 fixes the HS codes for devices; e-liquids follow Chapter 24 of the GCC tariff
Electronic smoking devices, the tools that go with them, and the liquids used in them are UAE excise goods taxed at 100% of the excise price under Article 10(1) of Cabinet Decision No. 197 of 2025, effective 1 January 2026. Registration is mandatory before the first import, and 5% VAT is then charged at retail on the excise-inclusive price.
The excise tax on vapes catches new importers off guard more than any other UAE tax, because the headline is so simple and the arithmetic underneath it is so unforgiving. A shipment you priced on a comfortable retail margin arrives at the border carrying a tax equal to the value the tax is calculated on, and then VAT is charged again on top of the excise-inclusive figure.
This guide walks through what the 100% rate actually attaches to, who has to register and by when, how the excise price is built, how excise and VAT stack, what the 2026 rule change did and did not do, and what all of it means for your pricing and your stock records.
What changed on 1 January 2026
Cabinet Decision No. 197 of 2025 was issued on 27 November 2025 and took effect on 1 January 2026. Article 14 repealed Cabinet Decision No. 52 of 2019 and all conflicting provisions.
For a vape business, the important point is what it did not change. Article 2 keeps liquids used in electronic smoking devices and tools, and the devices and tools themselves, in the list of excise goods. Article 10(1) keeps both at 100%. The substantive change in the 2025 decision was to sweetened drinks, which moved from a flat percentage to a tiered volumetric model in items 5 to 8 of that table.
| Excise good (CD 197/2025 Art 10(1)) | Rate or amount |
|---|---|
| 1. Tobacco and tobacco products | 100% |
| 2. Liquids used in electronic smoking devices and tools | 100% |
| 3. Electronic smoking devices and tools | 100% |
| 4. Energy drinks | 100% |
| 5. Sweetened drinks, 5g to under 8g sugar per 100ml | AED 0.79 per litre |
| 6. Sweetened drinks, 8g or more sugar per 100ml | AED 1.09 per litre |
| 7. Sweetened drinks, under 5g sugar per 100ml | AED 0 per litre |
| 8. Sweetened drinks with only artificial sweeteners, or artificial plus under 5g sugar | AED 0 per litre |
Every row above was read against the English text of Cabinet Decision No. 197 of 2025 as published by the Federal Tax Authority, on 4 August 2026.
Why vapes are treated as excise goods
Excise tax exists to make certain goods more expensive on purpose. Article 2(1) of Federal Decree-Law No. 7 of 2017 applies the law to excise goods specified by Cabinet Decision, and Article 2(2) imposes the tax on four activities: production in the UAE in the course of doing business, import, release from a Designated Zone, and stockpiling in the course of doing business.
So a vape is not treated as a gadget or a consumer-electronics item for tax purposes. It sits alongside cigarettes. Article 5 of Cabinet Decision No. 197 of 2025 defines electronic smoking devices and tools as all such devices and tools and the like, whether or not containing nicotine or tobacco. Article 4 uses the same breadth for the liquids.
That breadth matters. An importer bringing in hardware, coils, pods and liquids is dealing with excise across the whole product range, not just the nicotine-bearing consumables.
100%
Excise rate on electronic smoking devices, tools and the liquids used in them under items 2 and 3 of Article 10(1), Cabinet Decision No. 197 of 2025
What the 100% actually attaches to
This is where most of the confusion lives. The 100% is not applied to your cost price, and it is not applied to your intended margin. It is applied to the excise price, and Articles 11 and 12 of Cabinet Decision No. 197 of 2025 define exactly how that is built.
| Provision | Rule |
|---|---|
| Art 11(1)(a) | The price published by the FTA for the excise good in a standard price list, if available |
| Art 11(1)(b) | The designated retail sales price for the good, less the tax included in it |
| Art 11(1) | The excise price is the higher of (a) and (b) |
| Art 11(2) | For goods taxed at 100%, the tax included in the designated retail sales price equals half of that price |
| Art 12(1)(a) | The recommended retail selling price identified, declared and affixed by the importer or producer, after deducting VAT |
| Art 12(1)(b) | The average retail selling price of the goods in the market, after deducting VAT |
| Art 12(1) | The designated retail sales price is the higher of (a) and (b) |
Article 12(1)(a) adds a detail that trips up hospitality suppliers. The recommended retail selling price means the price achieved when the good is sold at retail directly to the consumer, and it excludes cases where the price is increased because the good is sold in a hotel, restaurant or similar establishment for consumption on the premises.
Article 10(4) then handles rounding. Where the calculation produces fractions of a fils, the tax is rounded to the nearest four decimal places of the dirham on registration with the FTA, and the tax due for the purposes of periodic returns is rounded to the nearest fils using ordinary arithmetic rounding.
A worked example in AED
Take a single disposable device that a Dubai importer intends to retail at AED 63.00 including VAT. Assume the FTA has not published a standard price for that product, so Article 11(1)(b) governs.
| Step | Calculation | Amount |
|---|---|---|
| Recommended retail selling price, VAT inclusive | Given | AED 63.00 |
| Less 5% VAT (Art 12(1)(a)) | 63.00 ÷ 1.05 | AED 60.00 |
| Designated retail sales price | Higher of recommended and market price | AED 60.00 |
| Tax included in that price (Art 11(2)) | Half of AED 60.00 | AED 30.00 |
| Excise price (Art 11(1)(b)) | 60.00 − 30.00 | AED 30.00 |
| Excise due at 100% (Art 10(1) item 3) | 100% of AED 30.00 | AED 30.00 |
| VAT at retail (5% of AED 60.00) | AED 3.00 | |
| Shelf price | 30.00 + 30.00 + 3.00 | AED 63.00 |
Now suppose the same importer bought that device for AED 9.00 landed. The pre-tax margin looks generous at first glance: AED 30.00 of excise price against AED 9.00 of cost. But the AED 30.00 of excise is a cash cost paid at import, so the importer funds AED 39.00 per unit before a single sale, and recovers AED 60.00 net of VAT. The gross margin is AED 21.00, not AED 51.00.
Get the excise price wrong and the arithmetic inverts. An importer who calculates 100% on the AED 9.00 landed cost declares AED 9.00 instead of AED 30.00 — an under-declaration of AED 21.00 per unit. On a container of 40,000 units that is AED 840,000 of unpaid excise, before penalties.
Who must register, and by when
Excise registration is activity-based, not threshold-based. Article 5(1) of Federal Decree-Law No. 7 of 2017 prohibits a person from conducting any of the Article 2(2) activities before registering.
| Trigger | Deadline |
|---|---|
| Production, import, release from a Designated Zone or stockpiling (Art 4(1)(a) and (c)) | Apply within 30 days of the end of any month in which the person carried out or intended to carry out the activity, or from the effective date of the law, whichever is later (Art 5(2)) |
| Person liable because the primary person failed to pay (Art 4(1)(b)) | Apply within 30 days of becoming aware, or the date they should have become aware, of that failure (Art 5(3)) |
| Warehouse keeper operating a Designated Zone | Separate registration under Art 8 |
| No longer liable for the tax | Apply for deregistration within the timeframe in the Executive Regulation (Art 7) |
Article 6 provides the only exceptions. Article 6(1) lets the FTA except a person where tax is due on import or release from a Designated Zone and it appears the person will not import regularly. Article 6(3) excepts a person importing for purposes other than conducting business. Article 6(4) then makes clear that neither exception removes the obligation to settle the due tax.
The application itself is submitted through EmaraTax, and the documents the FTA asks for at that stage are set out in our step-by-step guide to excise tax registration in the UAE. Getting the activity classification right on the application matters more than it looks, because it determines which returns and declarations the portal then opens for you.
Excise has no small-business exemption. Article 5(1) does not merely require registration — it prohibits the activity until you have registered. The moment you import, produce or stockpile a single case of vapes for business purposes, you are inside the regime.
Customs codes: how a product is actually classified
Article 4 of Cabinet Decision No. 197 of 2025 defers the classification of e-liquids to customs codes specified by the Minister, and Article 5 does the same for devices. Ministerial Decision No. 1 of 2025, issued 3 January 2025, supplies them.
| Source | Classification |
|---|---|
| MD 1/2025 Art 1 | Liquids used in electronic smoking devices: the HS codes in Chapter 24 of the GCC common schedule |
| MD 1/2025 Art 2 — 8543 40 10 | Electronic cigarette devices for reusable use |
| MD 1/2025 Art 2 — 8543 40 20 | Electronic water pipe “shisha” |
| MD 1/2025 Art 2 — 8543 40 30 | Electrically heated devices for cigarettes |
| MD 1/2025 Art 2 — 8543 40 90 | Other electronic smoking devices |
| MD 1/2025 Art 2 — 8543 90 91 | Parts for electronic cigarettes, excluding batteries under heading 8507 |
| MD 1/2025 Art 2 — 8543 90 92 | Parts for electronic water pipe shisha, excluding batteries under 8507 |
| MD 1/2025 Art 2 — 8543 90 93 | Parts for electrically heated devices for cigarettes, excluding batteries under 8507 |
| MD 1/2025 Art 2 — 8543 90 98 | Parts for other smoking electronic devices |
The battery carve-out is worth noting. A standalone battery classified under heading 8507 is not swept into the device codes, which changes the excise position for a spares importer bringing in cells separately.
Article 3(1) of Cabinet Decision No. 197 of 2025 also confirms that electrically-heated cigarettes fall inside tobacco and tobacco products under Chapter 24, rather than under the electronic device codes.
Smoking cessation products are excluded
Article 3(2) of Cabinet Decision No. 197 of 2025 excludes Chapter 24 products that are exclusively intended to assist in smoking cessation, according to customs codes specified by the Minister. Ministerial Decision No. 249 of 2025, issued 22 September 2025 and effective 1 October 2025, lists them.
| HS code | Item |
|---|---|
| 2404 91 10 | Chewing gum containing nicotine to assist tobacco use cessation |
| 2404 91 20 | Tablet form to assist cessation |
| 2404 92 10 | Patches to assist cessation |
| 2404 99 10 | Spray to assist cessation |
| 2404 99 20 | Nose drops to assist cessation |
| 2404 99 30 | Injections to assist cessation |
The word doing the work is exclusively. A product marketed for both cessation and recreational use does not fall inside the exclusion, and the classification has to be defensible at import rather than argued afterwards.
How excise and VAT stack
Excise and VAT are separate taxes, and the order in which they apply reshapes your pricing. Excise comes first, on import or production, at 100% of the excise price. VAT comes later, at the point of sale, at 5% — and it is charged on the excise-inclusive price.
Work through it as a chain. Start with the excise price. Add 100% excise, which doubles the base. Then at retail add 5% VAT calculated on the combined excise-inclusive figure. Both taxes end up embedded in the shelf price, and because VAT sits on top of excise rather than beside it, the effective tax load is higher than a simple reading of “100% plus 5%” suggests.
Article 9 of Cabinet Decision No. 197 of 2025 handles one narrow relief, though it does not reach vapes. Where an energy drink or sweetened drink has already borne excise, a beverage made by combining it with other products at the selling point for a non-taxable person is not itself an excise good — but Article 9(2) blocks the tax paid on that good from being treated as deductible under Article 16 of the excise law.
What the 100% rate does to landed cost and pricing
Shoppers ask why vapes cost what they do, and the answer is almost entirely tax rather than retail greed. The e-cigarette tax in the UAE is charged at 100% of the excise price, so before a device has covered a single dirham of freight, marketing or shop rent, the state has already taken an amount equal to the value the tax is calculated on. The e-liquid tax works the same way — a bottle of refill liquid carries 100% excise on its own excise price, and Article 4 makes no exception for small volumes or zero-nicotine flavours.
Compare that with an ordinary consumer-electronics import, which carries customs duty and 5% VAT and nothing else, and the gap is obvious. Two products with the same factory cost land at very different shelf prices purely because one is an excise good.
Your true landed cost for an excise product is the purchase price, plus freight and duties, plus the 100% excise on the excise price. If you built your buy price and your retail price off pre-excise numbers, the excise alone can wipe out the margin you thought you had. The businesses that get this right calculate backwards from a defensible retail selling price: they fix the price the consumer will pay, derive the designated retail sales price under Article 12, compute the excise price under Article 11, confirm VAT sits on top, and only then judge whether the remaining margin justifies the import.
Records, stock control and the FTA’s evidence expectations
Stock records carry as much weight as the pricing. Article 24(1) of Federal Decree-Law No. 7 of 2017 sets out exactly what has to exist.
| Art 24(1) | Record |
|---|---|
| (a) | Records of all produced, imported or stockpiled excise goods |
| (b) | Records of exported excise goods and the evidence of export |
| (c) | Records of stock levels, including details of lost or destroyed items |
| (d)(1) | Tax record: due tax on imported excise goods |
| (d)(2) | Tax record: due tax on produced excise goods |
| (d)(3) | Tax record: due tax on stockpiled excise goods |
| (d)(4) | Tax record: deductible tax under Article 16 |
Article 13 of Cabinet Decision No. 197 of 2025 adds the classification evidence. The FTA may determine the procedures required to prove a product’s classification and may request documents, laboratory tests or other evidence. Article 13(3) is the sharp end: where a person fails to provide those documents within the FTA’s timeframe, the authority may treat the product as an excise good until proven otherwise.
Excise goods should therefore be tracked separately, with the excise value visible in the inventory records, so physical stock reconciles to the excise declared and paid. Sound accounting and bookkeeping is what makes that reconciliation routine rather than a scramble, and the periodic filings those records feed are covered in our guide to the UAE excise stock declaration.
Getting the compliance cycle right
Excise is a recurring rhythm, not an annual event. Article 18 of Federal Decree-Law No. 7 of 2017 requires a tax return at the end of each tax period, and Article 17 leaves the length of the tax period to the Executive Regulation, Cabinet Decision No. 37 of 2017 and its amendments.
A workable cycle looks like this. At import or production, the excise is calculated on the Article 11 excise price and recorded against the specific stock. Through the period, excise stock movements are tracked against the excise ledger so that what physically moved matches what was declared. At period end, the return is prepared, the declared figures are reconciled to the stock records, and any variance is investigated before filing rather than after.
Article 19 then governs payment. Article 19(2) requires a person excepted from registration under Article 6(1) or 6(3) to settle the due tax at the point of import. Article 20 lets a taxable person carry forward excess refundable tax to subsequent periods and offset it against payable tax.
The value of running it monthly is that errors surface while they are still small. A misclassified product or a wrong excise price caught in the first period’s reconciliation is a quick correction. The same error left to compound across a year of imports becomes a material exposure — and where it does, the correction route is a voluntary disclosure, which we cover in our guide to the VAT voluntary disclosure Form 211 process that applies equally under the Tax Procedures Law to excise.
Designated Zones and where the tax point actually falls
One structural feature separates excise from VAT and it decides your cash flow. Article 2(2)(c) of Federal Decree-Law No. 7 of 2017 makes the release of excise goods from a Designated Zone a taxable activity in its own right. Goods can therefore sit in a Designated Zone in the UAE without the excise having crystallised.
Article 13 of the same law provides for Designated Zones, and Article 14 governs the transfer of excise goods between them. Article 4(1)(c) then puts the due tax on the warehouse keeper where goods are released from a Designated Zone and the payable tax has not previously been paid — a liability that sits with the operator, not only with the owner of the stock.
For a vape importer this is the difference between funding AED 30.00 of excise per unit at the border and funding it as stock is released to the UAE market. On a container of 40,000 units the timing difference is AED 1,200,000 of working capital, which is rarely a rounding item for an SME in Dubai or Sharjah.
The trade-off is control. A Designated Zone brings warehouse-keeper registration under Article 8, stricter stock records under Article 24(1)(c), and the FTA’s evidential expectations on every movement. Businesses that take the cash-flow benefit without building the stock discipline to match usually find the two meet at the first reconciliation. Our guide to excise designated zones in the UAE sets out the warehouse-keeper conditions and the financial-guarantee position in full.
Where this leaves a vape importer
If you import, produce, stockpile or release vapes, e-cigarettes or e-liquids in the UAE, the compliance picture is clear even if the arithmetic is punishing. The goods are excise goods taxed at 100% of the excise price under Cabinet Decision No. 197 of 2025. You register with the FTA before you trade, within the 30-day window in Article 5(2) of Federal Decree-Law No. 7 of 2017. You verify the customs codes against Ministerial Decision No. 1 of 2025. You file each period, and you remember that VAT stacks on top of the excise-inclusive price.
The firms that stay out of trouble treat excise as a pricing and inventory-control discipline rather than a tax-return chore. They price the 100% in before they buy, they segregate and reconcile excise stock every period, and they can show how the excise price was derived under Articles 11 and 12. Get those three habits in place and excise becomes a known, manageable cost. Skip them and the 100% rate turns a promising product line into a structural loss.
For UAE businesses building or reviewing an excise product line, we help with excise tax registration and return support and with the underlying accounting and bookkeeping that keeps excise stock reconciled and defensible. The goal is the same one we bring to every engagement: the tax should sit correctly inside your numbers, so the FTA position is clean and the commercial decision is made with eyes open.
Disclaimer: Velmont Crest is a DED-licensed accounting firm providing advisory, preparation and compliance support services. We are not the FTA, a law firm, or a licensed financial-services provider, and we do not represent clients before the FTA as a registered tax agent. Excise tax rules, product classifications, designated prices and Digital Tax Stamp phasing change over time — verify the current position with the FTA and take advice specific to your products and circumstances before importing or pricing excise goods.
References
- Cabinet Decision No. 197 of 2025 on Excise Goods, Tax Rates or Amounts, and Calculation Methods — Federal Tax Authority
- Federal Decree-Law No. 7 of 2017 on Excise Tax and its amendments — Federal Tax Authority
- Ministerial Decision No. 1 of 2025 on the Implementation of Cabinet Decision No. 52 of 2019 — Federal Tax Authority
- Ministerial Decision No. 249 of 2025 on Smoking Cessation Products — Federal Tax Authority
- UAE Federal Tax Authority — Excise Tax Legislation
- UAE Government portal (u.ae) — Excise Tax
Frequently asked questions
- Why are vapes and e-liquids so expensive in the UAE?
- Tax, mostly. The e-cigarette tax is excise at 100% of the excise price under item 3 of the table in Article 10(1) of Cabinet Decision No. 197 of 2025, so before freight, marketing or shop rent the charge already equals the value it is calculated on. The e-liquid tax works identically under item 2, with no lower band for small volumes or zero-nicotine flavours. Then 5% VAT is charged at retail on the excise-inclusive figure, so the buyer effectively pays tax on tax. Why it is expensive comes down to that stacking, and it is the intended effect of the policy.
- What is the excise tax rate on vapes and e-cigarettes in the UAE?
- How much is charged is set by Article 10(1) of Cabinet Decision No. 197 of 2025, effective 1 January 2026. Item 2 of that table taxes liquids used in electronic smoking devices and tools at 100%. Item 3 taxes electronic smoking devices and tools themselves at 100%. Item 1 taxes tobacco and tobacco products at 100%. Those rates are unchanged from Cabinet Decision No. 52 of 2019, which the new decision repealed. The rate applies to the excise price, not to your landed cost.
- What exactly is the excise price for a vape product?
- Article 11(1) of Cabinet Decision No. 197 of 2025 defines the excise price as the higher of two figures: the price published by the FTA for that excise good in a standard price list, where one is available, and the designated retail sales price for the good less the tax included in it. Article 11(2) then says that for goods taxed at 100%, the tax included in the designated retail sales price is equivalent to half of that price. Article 12(1) defines the designated retail sales price as the higher of the recommended retail selling price after deducting VAT, and the average market retail selling price after deducting VAT.
- Who has to register for excise tax on vape products in the UAE?
- Article 5(1) of Federal Decree-Law No. 7 of 2017 prohibits a person from conducting any of the activities in Article 2(2) before registering. Those activities are production in the UAE in the course of business, import, release from a Designated Zone, and stockpiling in the course of business. Article 5(2) requires the application within 30 days of the end of any month in which the person carried out or intended to carry out such an activity. There is no turnover threshold of the kind VAT has.
- Are there any exceptions to excise registration?
- Yes, but they are narrow. Article 6(1) of Federal Decree-Law No. 7 of 2017 lets the FTA except a person from registration where tax is due on import or release from a Designated Zone and it appears the person will not regularly import excise goods. Article 6(3) excepts a person importing for purposes other than conducting business. Article 6(4) makes clear that an exception from registration does not remove the obligation to settle the due tax or any administrative penalty.
- How is VAT different from excise tax on e-cigarettes?
- They are two separate taxes applying at different points. Excise is charged once, on production, import, release from a Designated Zone or stockpiling under Article 2(2) of Federal Decree-Law No. 7 of 2017, at 100% of the excise price. VAT is charged at 5% at the point of sale under Federal Decree-Law No. 8 of 2017, and it applies to the excise-inclusive price. Both taxes end up in the shelf price: the cost of the product, plus 100% excise, plus 5% VAT on that combined figure.
- Do e-liquids with zero nicotine still count as excise goods?
- Yes. Article 4 of Cabinet Decision No. 197 of 2025 states that liquids used in electronic smoking devices and tools include all liquids used in such devices and tools and the like, whether or not containing nicotine, pursuant to the customs codes specified by a decision issued by the Minister. Article 5 uses the same formula for the devices, extending it to devices whether or not containing nicotine or tobacco. Nicotine content is not the test.
- Which customs codes apply to vape devices and liquids?
- Ministerial Decision No. 1 of 2025, issued 3 January 2025, sets them. Article 1 applies the harmonized system codes in Chapter 24 of the GCC common schedule to liquids used in electronic smoking devices. Article 2 lists the Chapter 85 codes for the devices themselves: 8543 40 10 for reusable electronic cigarette devices, 8543 40 20 for electronic water pipe shisha, 8543 40 30 for electrically heated devices for cigarettes, 8543 40 90 for other, and the 8543 90 series for parts excluding batteries under heading 8507.
- Are smoking cessation products subject to UAE excise tax?
- Not as tobacco products. Article 3(2) of Cabinet Decision No. 197 of 2025 excludes products listed within Chapter 24 of the GCC Common Customs Tariff that are exclusively intended to assist in smoking cessation, according to customs codes specified by a Ministerial Decision. Ministerial Decision No. 249 of 2025, effective 1 October 2025, lists those codes — nicotine chewing gum, tablets, patches, sprays, nose drops and injections intended to assist cessation.
- What are the Digital Tax Stamp rules for these products?
- Article 24(2) of Federal Decree-Law No. 7 of 2017 gives the Council of Ministers the power, at the Minister's suggestion, to specify which excise goods must be marked to indicate that tax has been paid, together with the relevant conditions and procedures. The Digital Tax Stamp scheme operates under that power and has been rolled out in phases across tobacco products. Because product coverage and phasing evolve, verify whether a specific product requires a stamp under the current FTA rules rather than assuming it is outside the scheme.
- What records must a UAE excise registrant keep?
- Article 24(1) of Federal Decree-Law No. 7 of 2017 lists four categories: records of all produced, imported or stockpiled excise goods; records of exported excise goods and evidence of export; records of stock levels including details of lost or destroyed items; and a tax record covering due tax on imported, produced and stockpiled goods plus deductible tax under Article 16. Article 24(3) leaves the retention timeframes, conditions and controls to the Executive Regulation.
- Can the UAE excise rate on vapes go higher than 100%?
- It could, within limits. Article 3(1) of Federal Decree-Law No. 7 of 2017, as amended by Federal Decree-Law No. 7 of 2025, lets a Cabinet Decision set rates as a percentage of the excise price provided the rate does not exceed 200%. Article 3(2) allows rates set as a specific amount per unit of measurement, capped at AED 100 per unit. The current setting for vapes and e-liquids is 100% ad valorem, and Cabinet Decision No. 197 of 2025 kept it there when it replaced the 2019 decision.
- What is the excise price for a concentrate or powder?
- Article 11(3) of Cabinet Decision No. 197 of 2025 carves concentrates, powders, gels and extracts out of the ordinary designated retail sales price route and refers the calculation to a mechanism specified by the Minister. Article 3 of Ministerial Decision No. 1 of 2025 sets that mechanism for goods convertible into carbonated, energy or sweetened drinks. It does not change the position for vape devices or e-liquids, which follow the ordinary Article 11(1) test.
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