PLI Online Sales: What Changes in 2025 (ADM/PLI)
From January 1, 2025, there has been a substantial change in the scope of what a retailer can offer remotely in the inhalation liquid products sector. The change was introduced by Legislative Decree September 26, 2024 no. 141, which updated Art. 21 of Legislative Decree January 12, 2016 no. 6. In summary, online sales to consumers of nicotine-containing liquids are no longer permitted; the e-commerce channel remains possible for nicotine-free products, provided it is managed by authorized entities as required by ADM. The regulatory intervention is published in the Official Gazette and also clarified by legal analyses and sector circulars.
What the Law Says, in Practice
The regulatory text reformulates the discipline of distance selling: the part that allows e-commerce expressly refers to products “not containing nicotine,” while the ban concerns those with nicotine intended for consumers purchasing in Italy. In other terms, the online shop can continue to sell only what falls within the nicotine-free category, in compliance with ADM requirements (warehouse/authorizations) and the additional information obligations typical of e-commerce. For nicotine references, sales are only permitted in authorized physical retail locations. This reading is consistent both with the publication in the Gazette and with the explanatory notes and legal analyses following the reform.
Operational Implications for E-Commerce Managers
If you have a mixed catalog (with and without nicotine), the first step is to clearly separate the lines and remove or deactivate all nicotine variants from the online channel, including pre-loaded pods and nicotine disposables. Keep in e-commerce only the nicotine-free families and permitted flavors/ingredients, verifying in the back-office that SKUs, descriptions, and images do not mislead the user. In parallel, check the ADM/PLI authorization status: the Authority has launched a digitalization process with the PLI/Flavor Retail Portal for managing applications and authorization procedures; keeping documentation aligned is an integral part of compliance.
On the communication front, remember that a restrictive framework also applies to advertising and that the Agency maintains a list of sites blocked for irregularities: it is advisable to review banners, copy, and editorial materials to avoid non-compliant claims or messages. Age-gate 18+, clear warnings, and consistency across channels (website, social media, Google Business Profile listing) remain essential requirements.
What Can Still Be Sold Online and What Cannot
Today the dividing line is simple to explain even to your team: everything containing nicotine cannot be sold online to consumers; what does not contain nicotine can remain in the catalog only if the operator complies with the authorization conditions set by ADM. This distinction is widely confirmed by institutional sources and consumer communications circulated in the first months of 2025, following the reform’s entry into force.
How to Update Catalog, UX, and Policies in a Compliant Way
The review starts with a complete SKU inventory: for each product family, you need to verify nicotine presence, texts, and images. Nicotine product pages must be hidden from e-commerce and made available only through the physical channel; for the remaining “0 mg/ml” pages, check for neutral descriptions (no claims), warnings, and metadata. Then align terms and conditions, privacy/cookie policy, legal notices, and customer care flows, so that every touchpoint consistently states what can be purchased online and what cannot. For those also operating as franchises or retail networks, it is advisable to prepare an operational manual that reduces local variability and centralizes templates, texts, and procedures.
Process Updates: Authorizations and ADM Portal
In 2025, ADM announced the evolution toward digital management of authorizations related to PLIs and flavors, with a dedicated portal for retail locations. It is the piece that completes the regulatory change: less “paper” bureaucracy, more digital traceability, and faster checks. If you intend to open or update your position, plan the process in advance because document alignment is a prerequisite for selling permitted products (nicotine-free) online.
Enforcement and Responsibility
ADM maintains and updates the list of blocked domains when it detects legal violations; industry publications have documented increases in inspections in 2025. This context requires discipline in the catalog and periodic monitoring: better a cautious policy that exposes less to sanctioning and reputational risks.
Come aggiornare catalogo, UX e policy in modo conforme
La revisione parte da un inventario completo degli SKU: per ogni famiglia prodotto occorre verificare presenza di nicotina, testi e immagini. Le schede con nicotina vanno oscurate dall’e-commerce e rese disponibili solo nel canale fisico; per le rimanenti schede “0 mg/ml” occorre controllare descrizioni neutrali (niente claim), avvertenze e metadati. Allinea poi termini e condizioni, privacy/cookie policy, informative legali e flussi di customer care, così che ogni touchpoint ripeta in modo coerente cosa è possibile acquistare online e cosa no. Per chi opera anche come franchising o rete di punti vendita, conviene predisporre un manuale operativo che riduca la variabilità locale e centralizzi template, testi e procedure.
Frequently Asked Questions
Can I sell nicotine liquids online to foreign customers?
The ban refers to distance selling to consumers purchasing in Italian territory. Cross-border cases require maximum caution: in addition to Italian law, the rules of the destination country and platform obligations apply. In the absence of specific legal oversight, it is recommended to exclude nicotine variants from the e-commerce channel aimed at the Italian public.
For nicotine-free products, is it enough to remove nicotine from the descriptions?
No: adequate authorization requirements and ADM procedures are needed. Furthermore, texts, images, and metadata must not create confusion with nicotine variants. Periodically verify that the site layout, cart, and categories do not expose to ambiguities or non-compliant purchase paths.
Is there a single portal for applications?
Yes: ADM has announced the PLI/Flavor Retail Portal to start and manage authorization procedures online. Update your internal processes to take advantage of it and keep logs and receipts.