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Liquid Nicotine Packaging Business Guidance

Enacted in 2016, the Child Nicotine Poisoning Prevention Act (CNPPA) requires “any nicotine provided in a liquid nicotine container sold, offered for sale, manufactured for sale, distributed in commerce, or imported into the United States” to utilize a packaging that meets all of the requirements of 16 CFR § 1700.15. See 15 U.S.C. § 1472a(a). The requirements of the CNPPA became effective on July 26, 2016, and means that any products manufactured, imported, or sold on or after July 26, 2016, must meet the requirements of the CNPPA.

Section 14(a) of the Consumer Product Safety Act (CPSA), 15 U.S.C. § 2063(a), requires manufacturers of consumer products subject to a regulation, standard, or ban enforced by the CPSC to certify that those products meet the requirements of all applicable regulations, standards, or bans by issuing a certificate of compliance (General Certificate of Compliance or GCC). For more information on GCCs, please visit our GCC business guidance page.

Please note that although CPSC regulates special packaging of liquid nicotine containers, it does NOT regulate liquid nicotine itself, nor does it regulate tobacco and tobacco products per section 3(a)(5)(B) of the CPSA, 15 U.S.C. § 2052(a)(5)(B), and section 2(f)(2) of the Federal Hazardous Substances Act, 15 U.S.C. § 1261(f)(2). For regulatory information related to liquid nicotine and tobacco products, visit the U.S. Food and Drug Administration’s Center for Tobacco Products guidance page.

For more information on the requirements of 16 CFR § 1700.15 and special packaging, visit our Poison Prevention Packaging Act (PPPA) business guidance page.

For additional guidance and frequently asked questions on liquid nicotine packaging requirements under the CNPPA, please visit our FAQs page.

Guidance for Industry

Additional Information


For more information, please contact the Small Business Ombudsman (SBO) team:

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