CGHA research in the UK and US | October 28 2026
Illustrative image generated with AI; not a photograph of the sampled products.
CGHA research in the UK and US shows a substantial decline in the share of US nicotine products classified as unauthorized or illicit from the high levels recorded in 2024 for vapes and 2025 for pouches. Repeated Montgomery County sampling in 2026 continues that downward pattern. Cambridge vape illegality rose from 15% in 2024 to 57% in October 2026. Within 2026, Cambridge vapes rose from 43% in April to 52% in June, eased to 50% in August, and reached 57% in October. Cambridge pouches initially declined, then rebounded in October. Expanded legal authorizations and enforcement are plausible contributors to the US improvement, although the sampling cannot quantify their separate effects.
Figure 1. Philadelphia and suburbs (blue) and Cambridge UK (orange). Dashed segments bridge historical studies; solid lines connect 2026 sampling rounds. The 2024 US sample covered a broader area than later Montgomery County sampling. Cambridge’s 2024 sampling month is unspecified. The original 2025 pouch figure was 88%; a later follow-up used 82%.
The local results
| Sampling round | US vapes* | US pouches† | Cambridge vapes | Cambridge pouches |
|---|---|---|---|---|
| 2024 baseline | 99.35%* | — | 15%‡ | — |
| October 2025 | — | 88%† | — | — |
| April 2026 | 79% | 60% | 43% | 33% |
| June 2026 | 76% | 57% | 52% | 32% |
| Aug / Sept 2026 | 74% | 56% | 50% | 29% |
| October 2026 | 71% | 54% | 57% | 32% |
* Philadelphia and suburbs, 2024: 456 of 459 identified vape products unauthorized. † Original October 2025 pouch figure; the later follow-up used 82%. Dashes indicate no comparable figure included. The 2026 US rounds cover Montgomery County. ‡ Cambridge illicit vapes in 2024: 15%, supplied by the investigators; sampling month unspecified.
Between April and October, the Montgomery County vape figure fell eight percentage points, from 79% to 71%. Pouches fell six points, from 60% to 54%. Cambridge vapes rose 14 points, from 43% to 57%, while pouches finished one point lower at 32%. From August to October, Cambridge vapes rose seven points and pouches three points.
Where the earlier research fits
The 2024 paper Schrödinger’s Vapes examined 14 Philadelphia area gas stations between December 2023 and June 2024. Only three of 459 identified vape products were FDA authorized, and more than 99% of recorded vape sales volume involved unauthorized products. That establishes the severity of the earlier problem. The chart uses the 2024 product count—456 unauthorized products out of 459, or 99.35%—rather than the separate sales-volume result. The earlier sample covered a broader area than the later Montgomery County rounds, so dashed lines distinguish the historical comparison.
The original October 2025 Montgomery County pouch paper reported 88% of observed products as nonauthorized. By October 2026, the supplied summary was 54%, a decline of 34 percentage points. The April 2026 follow-up instead cited an October baseline of 82%; against that version, the decline is 28 points. The figure now shows the original published 88% and retains the discrepancy in its note. Either baseline points to a substantial decline; the exact change requires reconciliation of the underlying counts.
Enforcement and the shrinking British assortment
Cambridge’s illicit vape rate rose from 15% in 2024 to 57% in October 2026, an increase of 42 percentage points. That longer rise contrasts with the US decline. Within 2026, the rate rose from 43% in April to 52% in June, slipped to 50% in August, and reached 57% in October. The Cambridge observations also show markedly fewer product types available following crackdowns. This matters when interpreting the October rise. An illicit percentage is a ratio: it can rise even if the number of illicit products falls, provided the legal assortment falls faster. Without comparable product counts and sales volumes, the rebound cannot establish that the absolute illicit market has grown.
The US decline is welcome and is consistent with two developments working together: a broader legal product range and pressure on unauthorized supply. FDA first authorized 20 ZYN pouch products in January 2025 and reported 43 authorized pouch products by August 2026. Its vape authorizations also expanded, including four Glas pods in May 2026 and the JUUL2 device and two pods in August. By October, FDA listed 48 authorized e-cigarette products and devices. More authorizations can reduce measured illegality through substitution toward legal products and, where an existing stocked product gains authorization, through a change in its legal status.
Enforcement supplies the other part of the explanation. FDA reported about 120 retailer warning letters and 20 civil money penalty complaints concerning unauthorized products in fiscal 2025, alongside increased import refusals. The earlier store follow-up also described removal of unauthorized products after warning letters. These observations support a role for enforcement, but do not establish how much of the local decline comes from removals, new authorizations, product substitution or displacement to other sellers. Identifying those shares would require item-level records linking each change to its cause. The practical lesson is to combine credible enforcement with a workable legal supply of alternatives for adults who smoke.
Continuing research
CGHA continually reviews its data and methods and looks for ways to improve both. The figures presented here reflect the evidence currently available to CGHA from its research in the UK and US. Further sampling and methodological refinements will inform future updates.
