The 2 ml cap on cartridges: Only affecting HUGE cig-a-likes?

EU regulators, stay away from my dripper! :)

There has of course been a lot of talk about the TPD the last days, naturally, and a lot of it has been about the 2 ml cap on refillable cartridges. Such a limit on the tank or cartridge size would favour the cig-a-likes that the Tobacco companies are investing heavily in, as these would almost be the only e-cigarettes allowed. Add the advertising ban, that big Tobacco is already used to dealing with, and it would be a pain for others to compete in such a market. Another concern is of course that these (1st generation) e-cigarettes are not as effective as the more advanced ones as shown in this study by Dr. Farsalinos and others: http://goo.gl/VT61k2. There is 2 problems with this alone:

1. Less effective e-cigarettes of course means lower chance of successfully managing to quit smoking. And the heavier the smoker, the more severe this effect will be, as these are also the ones that are the most addicted. So this, along with the 20ml/mg cap on nicotine in e-liquids, affects the people that could have benefited the most from switching... in all possible ways.
2. You would need to carry more e-liquid around. Less effective cigarettes would make vapers use more liquid, and refill more often. Low capacity and low efficiency means more nicotine bottles of e-liquid being carried around, which means less safety. Quite the opposite of what I think was the intention.

So will this cap mean that all the mods and atties we're used to are effectively banned and we'll all end up having to smoke cig-a-likes in 2 years from now? To be honest I don't really think so. For one thing there will be markets selling these, call them what you like... grey or black. But there is also another thing. Have a look at article 20, point 3 a.: http://goo.gl/ROfRpE. This is the only place the 2 ml limit is mentioned in the directive from what I can see. Here is what it reads:

"nicotine-containing liquid is only placed on the market in dedicated refill containers not exceeding a volume of 10 ml, in disposable electronic cigarettes or in single use cartridges and that the cartridges or tanks do not exceed a volume of 2 ml;"

Well, this only says how nicotine-containing liquid is allowed to be sold, doesn't it? So cartridges, tanks and re-buildables with larger capacities can be sold freely as long as they are empty? To me it sure looks like it, but I got to admit I am afraid that there is something in there that I've missed. But then again, have a look at the European Commissions own "E-cigarettes myth buster": http://goo.gl/7fzTVs

“Why regulate a product that doesn’t even contain nicotine?”
The Directive only covers e-cigarettes which contain nicotine.

Well, most, if not all advanced e-cigarettes are sold empty, not containing a drop of nicotine e-liquid. Actually almost only cig-a-likes are sold pre-filled. So... this 2 ml cap... is it really just banning HUGE cig-a-likes? As I said ... I'm afraid I have missed something, or that the directive will be altered to take care of this, but I'm still going to make sure I get to try some of those Havanas from House of Liquid before 2016.