ELFBAR Statement on Underage Protection: Position and Measures

Our Position

ELFBAR is committed to preventing underage access to vaping products. In line with this commitment, the brand launched Lighthouse, its dedicated guardian protection program, in January 2023.

Our products are intended for adult users and should never be marketed or sold to anyone below the legal purchasing age. As a leading global brand, we support measures aimed at protecting underage individuals, enforcing age restrictions and age verification requirements, and strengthening access-control.

This Statement covers all ELFBAR products and relevant business activities across our value chain. We are committed to working with all our business partners to uphold the principles set out in this Statement and fulfill our shared goal of protecting the underage through effective safeguards and responsible practices.

How We Put Our Commitment into Practice

Our approach to preventing underage access to vaping products is centered on three key pillars – Product Design, Regulatory Compliance, and Marketing, Retail and Stakeholder Engagement.

1. Product Design

We routinely assess product and packaging designs and flavor names for elements that could appeal to individuals below the applicable legal age, and implement appropriate safeguards where needed.

• Flavor Name and Descriptors: We are phasing out flavor names that could unduly appeal to underage individuals, and avoid any names intended to target them. In many markets, including Germany and the UK, we phase out flavor names associated with confectionery or desserts. We prioritize descriptors that accurately reflect the flavor profile of the product.
• Product Appearance and Packaging Design: We avoid visual styles or elements that could have particular appeal to underage individuals, including designs that are influenced by trends among underage audiences. We have also adjusted our product and packaging colors. In line with applicable local requirements, our product packaging includes age restriction markings and warnings, such as “KEEP OUT OF REACH OF CHILDREN”, in the relevant local languages. Our product instructions also provide safety and usage information, including statements that products should not be used by women who are pregnant or breastfeeding, and that it is forbidden to sell the products to individuals below the applicable legal age.

2. Regulatory Compliance

We apply technical and operational safeguards in accordance with the regulatory requirements of each market and continuously update our practices, boosted by innovative technologies still under development and ready to scale up.

• Child-Resistant and Access-Prevention Features
  • Child-Resistant Devices: We have introduced devices with physical child-resistant features in multiple markets, including mechanisms that require a specific sequence of activations or button presses before use. Markets including Germany have now achieved full coverage, and we continue to expand these features in line with applicable requirements in individual markets. Certain Bluetooth-enabled products also allow users to set a password via the mobile app to activate the built-in lock and help prevent underage access.
  • Pod Safety Design: This includes open-system pods incorporating physical silicone barriers to prevent leaks and restrict access by children.
  • E-liquid Bottle Safety Design: This includes 10ml bottled e-liquids which use push-and-turn caps requiring an additional action to open, helping prevent children from easily accessing the contents.
  • More Age-Gating Technologies: Various age-gating and age verification solutions are currently under development, with plans for phased implementation across different product lines once they are sufficiently mature and scalable.
• Age Verification
  • Age Verification on Brand-Operated Websites: Brand-operated websites implement age verification measures, which require purchasers to complete a proof of age check at checkout or present valid identification for verification upon delivery.
  • Device Function Restrictions: Certain products can connect to a mobile app, where additional product features only unlock after completing the required age verification process.
  • Access Controls: Official brand websites and registered user platforms feature age verification prompts requiring visitors to confirm they are of legal age, before registering or gaining access.

3. Marketing, Retail and Stakeholder Engagement

Our commitment extends to responsible marketing, retail practices and engagement with industry and other relevant stakeholders.

• Responsible Online and Offline Marketing
  • For Adult Consumers Only: Products are intended for adult smokers, and we do not market to underage individuals.
  • Marketing Principles: We uphold standards designed to protect underage individuals and implement the requirements set out in the Company’s Sales and Marketing Principles.
  • Social Media Guidelines: We do not promote on social media channels likely to attract a younger audience, such as TikTok, in line with the Company’s Social Media Guidelines. We have also set many social media accounts to private mode so that relevant product content is not visible to underage audiences.
• Supporting Responsible Retailing
  • Retail Licensing: We support the introduction of a retail licensing scheme to ensure that retailers selling vaping products meet relevant qualifications and compliance requirements.
  • Point-of-Sale Practices: We advocate for responsible retail practices that help prevent underage sales, including robust age verification procedures and appropriate checks at the points of sale to ensure compliance in each market. We call for effective enforcement of age restrictions by the relevant authorities, including adequate resources and appropriate penalties for non-compliance. We also call for appropriate retail display and access controls, including keeping vaping products behind the counter or otherwise positioned out of reach.
• Industry and Stakeholder Collaboration
  • Sector and Retailer Association Membership: We actively engage with vaping industry and retailer trade associations and participate in related events, supporting and contributing to the development of responsible industry standards and best practices.
  • Supporting Legislative Measures: We believe the vape market should be properly regulated, and support proportionate, evidence-based legislation, including prohibitions on inappropriate imagery (such as cartoon characters) and flavor descriptors intended to appeal to underage audiences, closing loopholes relating to free samples, increased penalties for sales to individuals below the applicable legal age, and appropriate excise taxation.
  • Tackling the Illicit Market: We work with regulators and retail organizations to help tackle the illicit market and reduce underage access to vaping products.

Continuous Improvement

This Statement is maintained and reviewed by ELFBAR’s Global Government Affairs, Communications and Stakeholder Engagement Department. We update the Statement as appropriate to reflect new initiatives, developments in applicable laws and regulations, market shifts, and evolving business practices.

We welcome feedback and suggestions on this Statement from all interested parties, including our partners, regulators, associations and the public: 📧public-affairs@heavengifts.com

ELFBAR

October 2026