Vape sale prices and RRPs: the 6 August CAP pricing checklist retailers should run before advertising discounts

Adult UK vape retailers can show factual prices on their own websites. The harder question is how those prices are evidenced and presented. An RRP comparison, was/now claim, save £X line or up-to saving may be accurate in one narrow sense, yet still create a compliance problem if the reference price is weak or the presentation pushes the saving too hard.

This 18+ retailer checklist is not legal advice. It is a practical audit framework for vape website price displays, based on CAP pricing guidance, CAP Code rules and GOV.UK guidance on Article 20(5) advertising restrictions for electronic cigarettes. The short version: prove the price first, then ask whether the way you show it remains factual rather than promotional.

CAP's 6 August 2026 advice on recommended retail prices is general pricing guidance, not vape-only guidance. It still matters for adult vape retailers because RRPs and savings claims are common on product pages, category pages and clearance areas. CAP says RRP comparisons are likely to mislead if the quoted RRP differs significantly from the price at which the product is generally sold, and that a manufacturer's recommended price is not enough on its own if the product was not actually generally sold at that price: https://www.asa.org.uk/advice-online/recommended-retail-prices-rrp.html.

For nicotine-containing e-cigarettes that are not licensed as medicines, the pricing question sits inside a stricter advertising environment. CAP Code rule 22.12 restricts marketing communications with the direct or indirect effect of promoting unlicensed nicotine-containing e-cigarettes in online media, while allowing factual product claims on marketers' own websites in certain circumstances: https://www.asa.org.uk/type/non_broadcast/code_section/22.html.

That is why this topic belongs inside a wider compliance audit, not just a merchandising review. Our broader UK Vape Marketing Audit Checklist for 2026 covers channel, audience and claims controls; this article zooms in on price presentation.

Before publishing a vape discount claim, run two separate tests.

First, can you prove the objective pricing claim? CAP Code rule 3.7 requires marketers to hold documentary evidence before publication for objective claims that consumers are likely to regard as capable of substantiation: https://www.asa.org.uk/type/non_broadcast/code_section/03.html. CAP Code rules on price statements and comparisons also require clear, non-misleading presentation, including rule 3.39 for RRP comparisons and rule 3.22 for from and up-to claims.

Second, can you present the price factually in the vape context? GOV.UK's Article 20(5) guidance says retailer websites may provide factual product information, including price, where the consumer has sought that information. The same guidance states that advertising about price promotions is prohibited and gives highlighting price promotion as an example of promotion rather than information: https://www.gov.uk/government/publications/proposals-for-uk-law-on-the-advertising-of-e-cigarettes/publishing-20-may-not-yet-complete.

Passing one test does not automatically pass the other. A retailer might have price-history data for a previous price, yet still create risk by making the saving the loudest element on the page. Equally, a plainly presented price can still mislead if the RRP or previous price cannot be substantiated.

An RRP comparison needs more than a supplier's spreadsheet or a manufacturer's recommended number. CAP's RRP advice says marketers may quote genuine RRPs, but complaints are likely to be upheld where the advertiser cannot demonstrate that the product was actually generally sold at that price: https://www.asa.org.uk/advice-online/recommended-retail-prices-rrp.html.

For a vape retailer, the audit questions should be specific:

Be careful with sole-seller or pre-launch products. CAP advises against using an RRP where the advertiser is the only seller of the product, and against using RRPs for products that have not yet launched. In vape retail, that should make retailers cautious about white-label lines, exclusive bundles, new device launches and retailer-created starter packs.

Keep examples generic and in GBP. A claim such as RRP £14.99, now £9.99 should not go live unless the retailer can show why £14.99 is a genuine market reference point for that same product. Do not rely on a number just because it came from the supplier catalogue.

A was/now claim is not the same as an RRP claim. It usually points to the retailer's own previous selling price. CAP's savings guidance says reference prices should represent a genuine established usual selling price, and that the ASA is likely to look at the relevant pricing history, sales data, recency and channel context when assessing whether a savings claim is misleading: https://www.asa.org.uk/advice-online/promotional-savings-claims.html.

The file should exist before the banner goes live. For a was £12.99, now £9.99 claim, the retailer should be able to show when the higher price applied, how long it applied, whether the product was actually available at that price, and whether customers bought at that price. If the higher price was brief, stale, unavailable, or barely used, the saving may create an impression the evidence does not support.

The CTSI Business Companion pricing guidance is useful operationally because it tells traders to retain evidence of promotional communications, terms, stock and availability, price histories and sales volumes at promotional and non-promotional prices: https://www.businesscompanion.info/en/guidance-for-traders-on-pricing-practices. Treat that as an audit habit, not as a guaranteed safe harbour.

Also check compulsory charges. CAP's general pricing advice and CMA price-transparency guidance both point retailers towards clear total-price presentation where non-optional charges apply: https://www.asa.org.uk/advice-online/prices-general.html and https://www.gov.uk/government/publications/price-transparency-cma209. A discount claim can be undermined if mandatory charges are hidden until later in the checkout journey.

Range claims are risky because the headline can be technically true but unrepresentative. CAP's promotional savings guidance says from and up-to claims should not exaggerate the saving available, that a significant proportion of items should be available at the maximum saving, and that less than 10% is unlikely to be considered significant by the ASA: https://www.asa.org.uk/advice-online/promotional-savings-claims.html.

For adult vape retailers, there is an extra presentation point. If the claim is attached to nicotine-containing vape products, a large up-to saving can do more than mislead on price. It can also shift the page towards promotional advertising if the saving becomes the selling hook.

The CAP/MHRA enforcement notice on promotional pricing of e-cigarettes says advertisers may present factual information about unlicensed nicotine-containing e-cigarettes on their websites, including prices, but that undue emphasis on savings and discounts is likely to go beyond what is allowed and breach the CAP Code: https://www.asa.org.uk/resource/enforcement-notice-promotion-pricing-of-e-cigarettes-websites.html.

That means the visual treatment matters. Large sale banners, heavy strikethroughs, countdown timers, limited-time urgency, clearance language, aggressive colours and homepage-wide discount panels can all increase risk because they encourage purchase rather than simply inform the adult visitor of the price.

A more restrained approach is to keep price information close to product information, state the current price clearly, and avoid making the discount the main reason to act. Our Vape Website Product Information After 2027: Factual Copy vs Promotion explains that wider factual-copy boundary in more detail.

Age-appeal controls still apply. CAP Code rules 22.9 to 22.11 cover under-18 appeal, people who are or seem under 25, and media directed at under-18s: https://www.asa.org.uk/type/non_broadcast/code_section/22.html. Retailers reviewing pricing graphics should check the visual treatment alongside the audience and imagery checks covered in CAP's June 2026 vape ad guidance.

The checklist is deliberately conservative. It does not say every discount claim is prohibited, and it does not guarantee that a claim is compliant. It gives the retail team a way to catch weak evidence and high-pressure presentation before a page is published.

One useful habit is to save the final screenshot, not just the spreadsheet. A claim can look restrained in a product database but become high-pressure once it appears inside a homepage hero, sticky banner or category tile. The screenshot also helps reviewers see whether the price was shown as product information or as a purchase incentive.

For adult UK vape retailers, the safest editorial discipline is evidence first and restrained presentation second. CAP's pricing guidance asks whether the price claim can be substantiated and whether the comparison is likely to mislead. GOV.UK and CAP's e-cigarette advertising guidance add the separate question of whether price information is being presented non-promotionally.

That is the practical takeaway. Before publishing an RRP, was/now, save £X, from or up-to claim, build the file, test the claim against the whole range, and look at the finished webpage with fresh eyes. If the discount has become the loudest message on a nicotine-containing vape page, the risk is no longer just pricing substantiation. It is also the factual-versus-promotional boundary.