Key Points | 2Firsts in Conversation with VdeH

• Market slowing, large black market: Germany’s vaping market is still expanding, but growth has decelerated. The black market may approach half of total share and is linked to organized crime.

• Disposables reshape channels: Disposables have expanded into convenience stores and supermarkets, but have pressured traditional vape specialty shops and created new challenges in logistics, tax stamps, and retail enforcement.

• Clear opposition to bans: VdeH opposes flavor and disposable bans, warning they would push demand underground and drive consumers back to cigarettes, undermining harm-reduction goals.

• Policy coherence needed: With rising tax pressure and a strong black market, TPD III should not sacrifice flavors and the vaping category; policy must balance fiscal aims and public health.

• Three entry essentials: Overseas firms must ensure end-to-end compliance, strictly observe youth-protection red lines, and compete on quality and technology to gain a foothold in Germany.

2Firsts, September 19, 2025, Dortmund, Germany — InterTabac 2025 is being held from September 18 to 20. During the show, 2Firsts toured the halls, focusing on new product launches and developments across the novel-nicotine space to provide first-hand on-site reporting and trend insights.

On day two, 2Firsts sat down with Horst Winkler, President of the German Vaping Trade Association (Verband des eZigarettenhandels e. V. (VdeH), and Oliver Pohland, Managing Director, to discuss regulatory dynamics and market trends in Germany’s novel-nicotine sector.

Market & Channels: Slower Growth, Black-Market Squeeze, and the Disposable Shift

VdeH observes that the German vaping market remains on an upward trajectory but the pace has clearly slowed. Pohland pointed to the black market as the main “ceiling,” estimating it to be “close to half of the overall market.” More concerning, the illicit trade shows links with organized crime—“those who once smuggled drugs now smuggle vapes”—directly pressuring compliant companies on price and access while distorting tax collection and market order. If the black market were effectively contained, “growth potential in the legal market would be significantly higher.”

In terms of product and channel structure, disposables—“ready to use, discard when finished”—have dramatically lowered the barrier to entry for consumers and multiplied points of sale, driving rapid growth in convenience stores, supermarkets, and shisha outlets. Meanwhile, specialty vape shops built around refillable/open systems have come under pressure. According to Winkler, this structural shift is redrawing the retail map and raising the bar for compliance: tracking for disposable logistics, tax-stamp and labeling standards, as well as the frequency and training of retail-site inspections all need to adjust.

Regulation & Policy: Opposing Flavor and Disposable Bans, Calling for Coherent Policy Mix

Asked about flavor bans and disposable bans, VdeH set out a clear position of opposition. Pohland stressed that flavors are a key driver helping smokers switch from cigarettes to vaping and achieve harm reduction. In a context where the black market already holds a large share, imposing a flavor ban or an outright disposable ban risks two spillovers: first, demand migrates underground, further fueling illicit trade; second, some users revert to cigarettes, weakening public-health goals. Winkler added that experiences in other countries have shown the risk of “post-ban black-market expansion and smoker relapse,” arguing that policy must account for real-world enforceability and market substitution pathways.

At a broader rules level, VdeH views the EU’s forthcoming TPD III and Germany’s evolving tax regime as core agenda items. Winkler noted that increasing tax burdens while simultaneously tightening supply via bans is unlikely to achieve fiscal and health objectives in a high-illicit environment. A coherent policy mix is needed—one that both cracks down on illegal flows and provides a stable, predictable, and enforceable pathway for compliant products. Pohland said the association will actively engage at the European level to ensure TPD III does not come “at the expense of vaping and flavors.”

Association & Business Guidance: Membership, Youth-Protection Red Lines, and Market Entry

Winkler introduced VdeH as founded around 2012, with roughly 100 German member companies spanning manufacturers, distributors, and other links in the chain. The association does not lobby for any single firm; rather, it identifies and represents members’ “common interests,” translating industry facts and data into policy dialogue and regulatory proposals to help build “fair and enforceable” rules. Membership criteria include three basics: involvement in the vaping industry, no illicit/black-market background, and a clear, robust financial structure. Dues are tiered by company size or sales. VdeH currently serves German-based companies.

On corporate responsibility and compliance, the interviewees repeatedly emphasized that youth protection is a non-negotiable red line. Companies should avoid any “child-appealing” product design and marketing—e.g., cartoon imagery, overt “candy/toy-like” visuals, or extreme “pink/dessert” stylings—and use restrained naming, packaging, and messaging to reduce misinterpretation risk. Pohland cautioned that politics and public opinion are highly sensitive to child appeal; ignoring this often results in dual setbacks in both regulatory and reputational arenas.

For overseas entrants (including Chinese firms), the interviewees outlined several “hard requirements”:

• Play by the rules — Germany is a highly regulated market; companies must ensure end-to-end compliance in product safety, warnings/labeling, tax reporting, supply-chain traceability, and channel management.

• Respect youth-protection red lines — keep product design and communications clearly adult-oriented.

• Compete on quality and technology — build long-term strategies to stay resilient amid policy uncertainty and intense competition.

Both emphasized that as long as companies operate compliantly, “there are still viable business opportunities” in Germany.

For more on-the-ground coverage, visit the 2Firsts InterTabac Special Section.