The relevance of this question is growing because, for Ukraine, the regulation of electronic cigarettes cannot be reduced merely to formal restrictions on sales.

In this context, Ukraine should not look to just any large markets. It should focus specifically on those where electronic cigarettes are a legal market segment, where industry associations exist, and where there are mechanisms to combat illicit trade.

Let us look at each country in more detail.

The United States is one of the world’s largest electronic cigarette markets.

It has a strict product authorisation system through the FDA, which may serve as a useful example in terms of product control.

However, despite strong regulation, a significant illicit segment remains in the US.

This means that rules alone are not enough without effective control over imports and retail trade.

The United Kingdom should be an important reference point.

It has one of the most balanced regulatory models and does not equate regulation with the full displacement of the legal market.

The European Union should be the central direction for Ukraine.

This is due to Ukraine’s European integration course, a similar regulatory model and a broadly comparable legal and institutional culture.

At the EU level, electronic cigarettes are regulated under Article 20 of Directive 2014/40/EU on tobacco products.

Cooperation with individual European countries allows Ukraine to compare different approaches and choose the most suitable model for its own market.

Within the EU, Germany is one of the most promising partners.

It is one of the largest European markets, with high purchasing power, developed retail infrastructure and clear regulatory requirements from the state.

Canada should also be mentioned separately.

Canada has a legally regulated market for vaping products, and the maximum nicotine concentration in products manufactured or imported for sale is 20 mg/ml.

However, this model also has its challenges.

The market is under significant regulatory and tax pressure, while discussions around flavours, excise duties and product accessibility remain sensitive.

China is also often mentioned.

And this is not accidental, as China is one of the world’s largest manufacturers.

At the same time, China is not an appropriate regulatory reference point for Ukraine.

The reason why focusing on the Chinese market would be inappropriate is not limited to flavour restrictions.

The Chinese model is based on state tobacco monopoly control, not on an open European regulatory system.

It significantly restricts domestic demand and encourages manufacturers to focus on exports.

It also does not create a relevant model of partnership between the state and independent legal businesses for Ukraine.

In addition, the Chinese direction carries high reputational risks.

For Ukraine, which seeks to reduce the shadow economy and bring the market into the legal field, such a model cannot serve as an example.

It is associated not with the legalisation of a civilised market, but with the risks of illicit practices and counterfeit logistics.

Recently, we signed a Memorandum with the British association IBVTA and will continue moving further towards the EU.

This will help Ukraine create not a copy of someone else’s system, but its own balanced model based on the positive experience of other countries.