Issue link: https://read.dmtmag.com/i/1545684
20 tobaccoasia Issue 4, 2026 July / August Erwin Henriquez, Euromonitor International. Credit: Euromonitor Barnaby Page, Tamarind Intelligence. Credit: Tamarind Intelligence Shane MacGuill, Euromonitor International. Credit: Euromonitor Brazil and Australia likewise stand out as markets with huge illicit vaping sectors, driven by outright bans or near- total prohibitions. These cases further re- inforce the link between restrictive regu- latory frameworks and the proliferation of illicit trade. Europe: lower averages, persistent outliers In the European Union (EU), the over- all incidence of illicit vaping products is comparatively lower, estimated at around 36% of retail volume in 2025. However, this average masks significant variations between individual member states. Es- tonia and Belgium, for instance, exhibit notably high levels of illicit activity, at ap- proximately 89% and 84% respectively. In Estonia, strict flavor bans and display restrictions have constrained the legal market, while demand for flavored disposable products remains strong. Lim- ited enforcement capacity and the ease of cross-border sourcing within the EU further exacerbate the problem. Belgium, meanwhile, has seen illicit trade driven by successive regulatory tightening, includ- ing excise taxes on e-liquids and a ban on disposable vapes. The UK: regulation, adaptation, and the illicit response The UK provides one of the clearest real-world case studies of how regula- tory intervention can reshape—and in some cases expand—the illicit vaping landscape. As of June 1, 2025, the UK implemented a nationwide ban on the sale and supply of single-use, or dispos- able, vaping devices, making it illegal for businesses to sell such products across all channels, including online and retail outlets. The policy was introduced to ad- dress two primary concerns: a sharp rise in youth vaping and the environmental impact of millions of discarded devices each week. However, while the ban suc- cessfully removed disposable vapes from the legal retail environment, it also cre- ated a significant regulatory vacuum that illicit operators were quick to exploit. Euromonitor's Shane McGuill not- ed that the immediate aftermath of the ban saw consumers migrate toward alter- native, legal vaping formats. Yet this shift was neither complete nor stable. Over time, the market adapted in ways that blurred regulatory boundaries, with prod- ucts emerging that sit in legal grey areas, while a portion of consumers reverted to disposable devices through cross-border purchases and online channels. Barnaby Page of Tamarind Intel- ligence offered a more direct assessment. According to him, by reclassifying an en- tire category of widely used products as il- legal overnight, "it has inevitably increased the prevalence of illicit products." This view is supported by early market indica- tors. Data compiled by talysis.co.uk dur- ing the very first week of the ban already showed over £1 million in illegal vape sales persisting in convenience channels, even as legal sales declined sharply. Further evidence suggests that con- sumer behavior has adapted in ways that sustain illicit demand. Consumer surveys conducted ahead of the ban indicated that a majority of disposable vape users would consider turning to illicit sources if legal access were removed. Subsequent reporting by The Times indicated that a substantial share of users have indeed continued to access banned products through informal retail, online vendors, and social networks, highlighting the re- silience of illicit supply chains. At the same time, enforcement challenges remain significant. While the UK has implemented strict penalties for non-compliance, in- cluding fines and potential imprison- ment, the scale of the illicit market and the adaptability of suppliers continue to test regulatory capacity. The UK experi- ence underscores a broader lesson: when a popular product category is removed from the legal market without fully elimi- nating demand, illicit trade can expand rapidly, often in more opaque and less controllable forms. Supply chains without borders: the role of China When it comes to the origins of illicit vap- ing products, both Euromonitor Interna- tional and Tamarind Intelligence point to China as a central player. McGuill noted that "the illicit supply chain of e-vapor products relies heavily on products manu- factured in China, regardless of the [des- tination] market." This reflects China's