A rapidly expanding illicit market for disposable e-cigarettes is undermining European regulations, fuelling youth vaping and costing governments significant tax revenues, according to a new study by the Fraunhofer Institute.
The research highlights growing concerns that Europe’s regulatory framework is struggling to keep pace with the booming popularity of disposable vaping products, many of which appear to violate existing European Union rules.
The study, commissioned by strategy consultancy SKR and presented in Brussels, suggests that a significant share of the disposable vape market now operates in what researchers describe as an “irregular market” — products sold outside the regulatory framework established by the EU’s Tobacco Products Directive (TPD).
The illicit market, valued at €6.6 billion in 2026, is projected to increase to €10.8 billion by 2030, exposing gaping holes in EU customs controls, tax enforcement, and consumer protection. These differences and gaps between member states create grey zones where illegal trade can flourish. China is the EU’s main source of imports regarding liquids, mainly.
Delivery routes for online direct orders in China
According to the report, deliveries take place mostly via rail and maritime routes. By sea freight, 30 million containers arrived at the ports of Rotterdam, Antwerp and Hamburg. Around 30,000 containers per week arrived in 2024, and Ireland and the Netherlands are the main buyers for vaping products, which supply the rest of the EU.
According to calculations by the European Commission, nearly 800 million parcels were sent from China to the European Union in 2024.
In mid-July 2025, Belgium’s Central Economic Council (Conseil central de l’économie) warned of “an uncontrollable influx of parcels from China. ” According to the CCE, up to 4 million parcels are currently being declared each day at Belgian customs.
Researchers warn that the growth of this parallel market raises concerns not only about public health but also about tax revenues, regulatory enforcement and the expansion of organised crime networks.
Disposable vape boom
Disposable e-cigarettes have become one of the fastest-growing segments of the nicotine market in Europe.
Cheap, brightly coloured and available in a wide range of flavours, these single-use devices have surged in popularity over the past few years, particularly among younger consumers.
However, researchers say the rapid growth of the market has also created opportunities for non-compliant and potentially illegal products to enter Europe through complex global supply chains.
The Fraunhofer study found widespread evidence that many products currently available across European markets fail to comply with EU regulations.
Among the most common violations identified were:
• exceeding the EU limit of 2ml of e-liquid
• nicotine concentrations above the legal limit of 20mg/ml
• missing or incomplete health warnings
• failure to notify authorities through the EU’s product registration system
Researchers warn that such products are increasingly visible across several EU member states.
Youth access raises concerns
The growing popularity of disposable vapes among teenagers has become one of the most controversial aspects of the market.
During the presentation of the study, SKR AG managing partner Rico Bak said the research was originally prompted by concerns about vaping among schoolchildren.
“I heard from my daughter that students aged 12 to 15 were already vaping,” he said during the briefing.
“That raised serious questions for me about how widespread this market actually is.”
Disposable devices are often sold in colourful packaging and sweet flavours such as fruit, candy or soft drinks — characteristics that critics argue may make them particularly appealing to young consumers.
Public health experts warn that early exposure to nicotine may increase the risk of addiction and long-term health consequences.
Enforcement challenges
Under the EU’s Tobacco Products Directive, which regulates tobacco and nicotine products across the European Union, e-cigarettes are subject to strict limits designed to protect consumers.
These include caps on nicotine strength, limits on e-liquid volumes and requirements for product notification and health warnings.
However, enforcement of these rules largely depends on national authorities and customs agencies.
Researchers say that the increasingly globalised nature of vape supply chains makes monitoring compliance difficult.
Products manufactured outside the EU can enter through multiple channels, including cross-border trade, online marketplaces and small independent retailers.
In some cases, non-compliant devices are reportedly sold openly in shops despite failing to meet EU regulatory requirements.
A wider illicit nicotine market in Europe
The emergence of illegal vape products is occurring alongside a broader expansion of illicit tobacco markets across parts of Europe.
Countries with high tobacco taxes and strict regulatory regimes have seen a growing trade in illegal cigarettes and counterfeit tobacco products.
France currently has the largest illicit cigarette market in Europe.
Recent estimates suggest that 18.7 billion illicit cigarettes were consumed in France in 2024, representing approximately 37.6% of total cigarette consumption. In practical terms, that means more than one in three cigarettes smoked in France may be illegal.
High retail prices — often €11 to €13 per pack — have created strong incentives for smuggling networks and counterfeit producers.
Authorities report that organised criminal groups play a significant role in this trade, using smuggling routes, hidden factories and online sales channels to distribute illegal products.
French authorities have dismantled seven illegal cigarette factories since 2021, highlighting the scale and sophistication of these operations.
Belgium is emerging as a production hub
Belgium has also emerged as a significant hub for illegal tobacco production and distribution.
Customs authorities dismantled twelve illegal cigarette factories in 2024, followed by ten more closures in 2025.
Belgium’s central location and extensive transport infrastructure make it attractive for organised crime groups involved in cross-border trafficking.
During a parliamentary discussion last year, Belgian Interior Minister Bernard Quintin cited federal police findings suggesting that workers are sometimes recruited through online advertisements offering well-paid jobs abroad.
In some cases, workers are reportedly transported across Europe and forced to work in illegal cigarette factories.
While much of the counterfeit tobacco produced in Belgium is destined for export, rising cigarette prices have also increased domestic demand for cheaper illicit alternatives.
A pack of Marlboro cigarettes in Belgium now costs around €12, roughly double the price a decade ago, while illegal cigarettes can be sold for half that amount.
Netherlands sees surge in illegal vapes
The Netherlands has experienced a sharp rise in illegal vape products following the introduction of strict new regulations.
Dutch policies include:
- a ban on flavoured e-liquids except tobacco flavour
- a ban on online sales of vaping products
- restrictions limiting sales to specialist tobacco retailers
Authorities say these measures were designed to reduce youth vaping.
However, enforcement agencies report that illegal flavoured disposable vapes remain widely available, often imported from Asia.
Dutch police have seized tens of thousands of illegal vape devices in recent years, while the country has also seen a significant increase in illicit cigarettes.
Recent estimates suggest that around 17.9% of cigarette consumption in the Netherlands is now illicit, roughly double the previous year.
Retailers warn that the growing availability of untaxed and counterfeit products is making it increasingly difficult for legitimate sellers to compete.
A growing cross-border challenge
Law enforcement agencies increasingly view illicit tobacco and vaping products as a pan-European criminal activity.
Under the EU’s EMPACT programme, which coordinates cross-border action against organised crime, authorities reported major enforcement activity in 2023.
Operations led to:
- 68 illegal cigarette factories dismantled across Europe
- 100 cutting and storage facilities discovered
- 790 million illegal cigarettes seized
Authorities estimate that this quantity of illegal cigarettes alone would be sufficient to supply around 230,000 smokers for an entire year.
Because of its geographic position, Belgium is often identified as a key transit hub linking supply routes from Eastern Europe and Asia to consumer markets across Western Europe.
A complex policy debate
The emergence of illegal vape products and illicit cigarettes highlights the complexity of regulating nicotine markets in Europe.
Supporters of e-cigarettes argue that vaping products can play a role in harm reduction for adult smokers seeking alternatives to traditional tobacco.
Critics, however, point to rising youth vaping, environmental concerns linked to disposable devices and the rapid growth of illegal markets.
The Fraunhofer study does not take a position in this wider policy debate but highlights the widening gap between regulatory frameworks and developments in the marketplace.
As the European Commission considers potential revisions to the EU Tobacco Products Directive (TPD), policymakers face the challenge of balancing public health objectives with effective enforcement and market realities.
For regulators across Europe, the question is no longer simply how to regulate vaping products — but how to prevent illegal markets from expanding faster than the rules designed to control them.
