Subject: Request for clarification regarding TPD notification requirements for device modifications
From: "Vjaceslavs Levinoks" <[email-masked]>
To: <[email-masked]>
Cc: Jūlija Kačanovska <[email-masked]>
Date: Wed, 15 Apr 2026 22:11:05 +0300

Tähelepanu! Tegemist on väljastpoolt asutust saabunud kirjaga. Tundmatu 
saatja korral palume linke ja faile mitte avada.

Dear Sir or Madam,

Our company places electronic cigarette devices on the Estonian market under 
its own brand and has submitted the relevant notifications via the EU-CEG 
system in accordance with the Tobacco Products Directive 2014/40/EU.

In light of the upcoming requirements under the Regulation (EU) 2023/1542, 
we are currently assessing certain technical modifications to ensure future 
compliance. These may include:

*	minor dimensional changes (approximately 1 mm),
*	introduction of a removable or service-replaceable battery,
*	a limited increase in battery capacity (approximately 150 mAh),

while maintaining the same e-liquid composition, nicotine strength, intended 
use and overall product category.

From a technical perspective, these changes are not expected to 
significantly affect emissions, nicotine delivery or user exposure.

We would appreciate your guidance on the following:

1.	Would such modifications be considered a “substantial modification” 
requiring a new notification via EU-CEG in Estonia?
2.	Does a change in battery capacity and/or battery accessibility 
(non-removable vs removable or service-replaceable) automatically trigger a 
re-notification requirement?
3.	Is it acceptable to consider such changes as non-substantial if it can be 
demonstrated that emissions and nicotine delivery remain unchanged?

Thank you in advance for your guidance.

Vjaceslavs Levinoks

SIA Latliq

Tomu iela 4, Riga, LV-1003