The PHF Science Study Unveiling Persistent Labelling Issues

A groundbreaking study conducted by the New Zealand Institute for Public Health and Forensic Science (PHF Science), published on March 22, 2026, in the Journal of Drug and Alcohol Dependence, has revealed ongoing inaccuracies in vape product labelling even after significant regulatory changes. Researchers analysed over 300 vaping substances purchased from online New Zealand retailers across three key periods: December 2020 (pre-regulations), December 2021 (post-initial reforms), and October 2022 (following further updates). The findings highlight discrepancies in nicotine concentrations and undisclosed ethanol (alcohol) content, raising concerns about consumer safety and regulatory effectiveness.

Evolution of Vaping Regulations in New Zealand

New Zealand's vaping landscape has undergone substantial transformation since 2020. The Smokefree Environments and Regulated Products Act was amended in August 2020 to include vaping products, introducing an 18-year age limit for purchases in November 2020 and distinguishing specialist vape retailers from general stores. By May 2021, colours were banned in e-liquids, and August 2021 saw the implementation of comprehensive regulations covering ingredients, labelling, retail, import, manufacturing, distribution. Key labelling mandates included listing alcohol in ingredients if present and explicit 'contains alcohol' warnings for products exceeding three per cent alcohol by volume. Subsequent updates in 2025 capped nicotine at 20mg/mL for disposables (banned from June 2025) and 28.5mg/mL for substances, alongside flavour restrictions to curb youth appeal.

These reforms aimed to ensure accurate labelling, including nicotine concentration in mg/mL, PG:VG ratios, batch numbers, expiry dates, and safety instructions. Despite this, the PHF study demonstrates that compliance lagged behind intentions.

Methodology: A Rigorous Examination of Online Vape Products

The PHF Science team, led by researchers Robyn Somerville, Rachel Fleming, Janet Stacey, and Jared Doncliff, procured vaping liquids from popular online NZ stores during the specified periods. Each sample underwent laboratory testing for nicotine (freebase) and ethanol concentrations using validated analytical methods. Labels were reviewed for compliance with contemporaneous regulations, focusing on whether stated nicotine levels matched measured values (within ±10 per cent tolerance) and if ethanol was declared. This longitudinal approach provided a unique snapshot of market evolution amid policy shifts, funded by the government's Strategic Science Investment Fund.

Key Findings on Nicotine Label Accuracy

Nearly half of all tested e-liquids exhibited nicotine concentrations deviating by more than 10 per cent from label claims. In the pre-regulation batch (Dec 2020), fewer than 50 per cent were accurate. Following the August 2021 regulations, accuracy improved modestly to just over 50 per cent in both the 2021 and 2022 batches. Some 'zero nicotine' products from early batches contained trace amounts, though none did in 2022. These discrepancies could mislead users seeking specific strengths for smoking cessation or recreational use, potentially leading to under-dosing (ineffective quitting aid) or over-dosing (acute nicotine poisoning symptoms like nausea, dizziness).

• Pre-2021: <50% accurate nicotine labelling
• Post-2021: >50% accurate, modest gain
• ~50% overall inaccuracy rate across 300+ samples

Undisclosed Ethanol: A Pervasive Labelling Failure

Every single sample contained ethanol, yet none listed it in ingredients. Approximately five per cent exceeded three per cent alcohol, requiring explicit warnings—one sample reached 23 per cent. Ethanol in vapes poses risks via inhalation, ingestion (accidental spills), or skin absorption, potentially causing irritation, intoxication, or exacerbating toxicity when combined with nicotine. This universal non-compliance underscores a critical gap in labelling transparency, unaffected by regulations.

Health Implications of Labelling Inaccuracies

Inaccurate nicotine can heighten addiction risks, especially among youth, whose developing brains are highly susceptible. Higher-than-labelled nicotine accelerates dependence, while undisclosed alcohol adds unknown toxicity—ethanol vapors may irritate airways, and high levels risk systemic absorption. For smokers switching to vapes as harm reduction, unreliable dosing undermines quit success. Vulnerable groups, including pregnant individuals or those with respiratory conditions, face amplified dangers from unlabelled hazards. Recent NZ Health Survey data shows adult daily vaping at 11.7 per cent (2024/25), with youth rates declining to 7.1 per cent daily among Year 10s, yet inaccuracies persist as a public health threat.

Comparison with Prior Research

Echoing a June 2025 New Zealand Medical Journal analysis of 574 ESR (predecessor to PHF) samples, where 48.3 per cent showed nicotine discrepancies, the PHF study confirms persistence. Earlier audits found vape shops with poor compliance on child-safety and nicotine caps. Internationally, similar issues plague markets, but NZ's online focus highlights enforcement challenges in e-commerce.

Stakeholder Perspectives and Expert Commentary

PHF's Jared Doncliff noted, “There was limited measurable change in label accuracy... more work to be done.” Ministry of Health collaborates with PHF for ongoing testing, investing more recently. Health advocates like Hāpai Te Hauora criticise industry mislabelling, calling for stricter oversight. Vape retailers argue compliance burdens online imports from lax jurisdictions. Academics at University of Auckland, partnering with PHF on forensics, emphasise evidence-based policy refinement.

For full study, see the Journal of Drug and Alcohol Dependence publication.

Challenges in Enforcement and Online Sales

Online sales evade physical inspections, with imports from unregulated markets flooding NZ. Product notification is required, but verification relies on self-reporting. Recent disposable bans and flavour limits (March 2025) aim to tighten control, yet labelling persists as a weak link. PHF continues supporting Ministry testing amid rising enforcement needs.

Future Outlook: Towards Compliant Vaping Markets

With youth vaping halving since 2022 peaks, regulations show partial success, but labelling fixes demand enhanced lab surveillance, importer penalties, and consumer education. Potential steps include mandatory third-party testing, digital tracking, and public dashboards on compliance. PHF's work informs ongoing Smokefree Aotearoa 2025 goals. For regulations details, visit Ministry of Health guidelines.

Photo by Brett Jordan on Unsplash

Actionable Insights for Consumers and Policymakers

• Verify specialist retailers; avoid unverified online sellers.
• Report suspected mislabelling to Ministry of Health.
• Policymakers: Boost PHF funding for routine audits, harmonise with international standards.
• Researchers: Expand to contaminants beyond nicotine/ethanol.

PHF Science exemplifies rigorous public health research driving policy, underscoring NZ's commitment to evidence-led vaping control.