Electronic Cigarette Shops in Bahrain: Licensing, Sales Rules and Regulatory Oversight

The legal framework and the importance of classification

Law No. 8 of 2009 concerning the control of smoking and tobacco of all kinds sets out rules on licensing, sales, promotion, display and enforcement. Electronic nicotine products are also addressed by a national technical regulation dealing with the products themselves and their entry into the market. Retailers and importers need to read the applicable requirements together, rather than treating compliance with a product specification as permission to disregard licensing or sales restrictions.

Commercial registration and health approvals

Article 10 of the tobacco-control law requires authorisation from the competent authorities for the import, distribution or retail sale of tobacco, subject to the prescribed conditions and fees. The source article describes the role of the Ministry of Industry and Commerce in commercial registration and the Ministry of Health in health licensing and supervision. Applicants should establish which approvals their exact commercial activity requires before fitting out a shop or importing stock.

The supporting documents and premises arrangements discussed in the article include the lease, relevant approvals, an undertaking to comply with the governing rules and photographs of the shopfront and display area. The applicable health requirements may also regulate access to displayed products and the posting of warnings. A shop's actual approval conditions should be checked directly with the competent authority; requirements for a smoking venue should not automatically be applied to every retail-only premises.

Protecting under-18s and controlling promotion

The tobacco-control framework prohibits selling or supplying the covered tobacco products to people under eighteen, requires a clear notice at the point of sale and calls for proof of age where there is doubt. It also prohibits employing under-18s in tobacco sales. Retail procedures should make age checks a routine part of the transaction and apply the corresponding restrictions governing electronic nicotine products.

The article also examines restrictions on tobacco advertising, promotional sponsorship, free distribution and promotional gifts under Articles 6, 7 and 15. Articles 12 and 13 address display, individual cigarettes, packaging and point-of-sale warnings. Businesses should review how these rules and the product-specific technical requirements apply to shop displays, online material and campaigns before launching promotional activity.

Product standards, inspection and prohibited substitutes

Product compliance requires attention to the applicable technical specification, import checks, packaging and labelling. The tobacco law addresses examination of consignments and the required information on packs. The national electronic-nicotine regulation adds product-specific requirements. The separate restriction in Article 11 on substances used as smoking substitutes must also be assessed in light of the relevant ministerial decisions; a nicotine-free label alone does not establish that a product may lawfully be traded.

Penalties depend on the provision breached

Law No. 15 of 2025 amended Article 20 of the tobacco-control law. It sets different sanctions for different contraventions, including a fine of at least BHD 100 for breaches of Articles 5, 8 and 13, and fines of BHD 1,000 to BHD 3,000 for breaches of Articles 7 and 12. The statutory penalty for an Article 11 breach can include imprisonment of up to one year and a fine of BHD 1,000 to BHD 100,000. On conviction, the court may also order closure for up to three months or confiscation of the materials used. These are sanctions attached to identified statutory offences, rather than a single automatic penalty for every vaping-shop violation.

Tax and customs obligations need a separate review

The article distinguishes VAT, excise and customs obligations. Whether a particular electronic device, liquid or tobacco-containing product attracts a specific excise or customs treatment depends on its classification and the applicable rules. Retailers should confirm their VAT registration and reporting position with the National Bureau for Revenue, and importers should confirm product classification and the corresponding taxes before bringing goods into Bahrain. Purchasing stock from a local supplier does not remove a retailer's own VAT obligations where those obligations arise.

For an operator, a practical compliance review should connect the licensed activity, approved premises, product records, age-verification procedures, marketing controls and tax documentation. Keeping those elements aligned helps identify a problem before it becomes a licensing dispute or an enforcement case.

Official legislation: Law No. 15 of 2025 amending Article 20 of the tobacco-control law