Tobacco Asia

July/August 2026 - Volume 30 Number 4

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18 tobaccoasia Issue 4, 2026 July / August By Thomas Schmid The global market for vaping products is increasingly defined not only by innovation and regulation but also by the rapid expansion of the illicit trade. Across continents, non-compliant e-vapor prod- ucts have infiltrated supply chains, retail environments, and con- sumer habits, often outpacing the ability of regulators to respond effectively. While the drivers vary—from strict regulatory regimes to price disparities and enforcement gaps—the outcome is strikingly consistent: a growing share of global vaping consumption is taking place outside the bounds of legality. According to insights gathered from Euromonitor International and Tamarind Intelligence, illicit products now account for a substantial proportion of global vape product volume, presenting complex challenges for policymakers, public health authorities, and legitimate industry players alike. Defining "illicit": a moving target across jurisdictions Any meaningful discussion of illicit vape products must begin with the difficulty of defining them. As Erwin Henriquez, global insight manager nicotine, and Shane MacGuill, global lead, stimulation, intoxication, and emerging substances at Euromonitor International, explained to Tobacco Asia, "illicit vape products" or "non-compliant e-vapor products" encompasses "products that are manufactured, imported, distributed, or sold in breach of applicable laws or regula- tions in each market." Global Shadow Market: Illicit Vapes Mapping the rise of illicit vape products is a fickle undertaking, but it also reveals that the problem is far from being a petty issue. Customs officials seizing and cataloguing illegal vaping devices and accessories. Credit: ChatGPT These breaches can take multiple forms, including the absence of required authorizations (licensing), non-compliance with ingredient or nicotine limits, and evasion of taxes or duties. Cru- cially, Henriquez and McGuill emphasized that "the exact classification therefore depends on the regulatory framework of each market," underscor- ing the fragmented nature of the global landscape. Barnaby Page, editorial director at Tamarind Intelligence, echoed this complexity during his in- terview with Tobacco Asia, noting that illicit sta- tus can arise from failures in any of several areas: product compliance, retail licensing, administrative approval, or tax payment. "Failing to fully comply in any one of these areas would thus define a prod- uct as illicit," he explained. This multi-dimensional definition highlights how a product may be per- fectly legal in one jurisdiction yet illicit in another, or even within the same market depending on how it is sold or taxed. The invisible market: measuring what cannot be seen Researching illicit markets presents inherent meth- odological challenges. By their very nature, such activities evade formal reporting channels, making precise measurement difficult, if not impossible. Euromonitor International employs what Hen- riquez described as a "mixed-method, triangulated approach," combining trade and expert inter- views, retail and online observations, open-source intelligence, seizure data, and comparative regula- tory analysis. In many cases, Henriquez pointed out, researchers rely on proxy indicators, such as discrepancies between legal sales and estimated consumption, to infer the scale of illicit activity.

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