Cooling has become one of the most recognizable characteristics of modern vape flavors, particularly in fruit, beverage, candy, and “ice” profiles. But as European regulators take a closer look at cooling agents, formulators are being pushed to think beyond simply creating the coldest possible sensation.
That changing environment is where Mylor is positioning its RE-cool cooling blend solution. The company showcased RE-cool at InterTabac 2026 in Dortmund, Germany, where brand owners, formulators, and distributors could sample the product and compare its sensory profile with WS-23 and other cooling alternatives.
InterTabac itself brought around 750 companies from 64 countries to Dortmund from September 15–17, highlighting just how international the conversation around new regulations and product development has become.
Why Cooling Agents Are Under Greater Scrutiny
Germany's regulatory discussion around cooling agents has gained momentum following assessments from the Federal Institute for Risk Assessment, or BfR. In April 2025, BfR published Opinion 010/2025 examining WS-23, WS-3, and WS-5. The agency said these substances are widely used in e-cigarettes and noted that important data on inhalation toxicity remains limited.
BfR followed that work in January 2026 with Opinion 003/2026, which examined nine additional cooling agents, including menthol, menthyl acetate, and eucalyptol. The agency again highlighted gaps in publicly available health data for cooling agents used in e-cigarette liquids.
For manufacturers and flavor houses, the issue creates a complicated development challenge. Cooling is not simply an ingredient added at the end of a formula. It can influence how fruit, sweetness, acidity, and other flavor components are perceived.
WS-23 Has Been Difficult to Replace
WS-23 has become a familiar tool for formulators because it can provide a strong cooling sensation without dramatically changing the underlying flavor profile. That makes it particularly useful in fruit-forward recipes where the goal is to make a watermelon, berry, peach, or tropical profile feel colder without introducing another dominant flavor.
Finding alternatives isn't necessarily as simple as replacing one ingredient with another.
Some cooling materials can bring their own sensory characteristics into a formula. Herbal, camphor-like, bitter, or otherwise noticeable notes can change the intended character of a recipe, especially when higher levels of cooling are required.
For formulators, the challenge is therefore about more than matching temperature perception. The replacement also needs to work alongside the flavor system.
Mylor Takes a Different Approach With RE-cool
Mylor says it developed RE-cool after extensive formulation and sensory testing, with the goal of creating a cooling solution that addresses both regulatory considerations and flavor performance.
Rather than presenting the product simply as a one-for-one raw-material replacement, the company describes RE-cool as a cooling blend built around sensory signal interaction.
According to Mylor, RE-cool is formulated without WS-23, WS-3, WS-5, and menthol. The company also says its internal testing indicates that the cooling sensation can reach a level comparable with WS-23 while maintaining a clean sensory profile.
Those performance claims come from Mylor and should be understood as company-reported testing rather than an independent regulatory determination.
Keeping the Fruit Profile in Focus
One of the biggest challenges with cooling substitutions is maintaining the original flavor concept.
A strong fruit recipe needs its primary ingredients to remain recognizable. If the cooling component introduces too much character of its own, it can shift the balance of the finished product.
Mylor says RE-cool is designed to have a highly neutral flavor character within a formulation. The company's stated goal is to provide cooling without competing with sweet or fruity notes and without introducing the camphor-like or herbal characteristics that can appear with some alternatives.
For a peach-and-ice or berry-and-ice recipe, that could be particularly important. The cooling effect should complement the fruit rather than becoming the flavor itself.
The Aftertaste Is Another Part of the Equation
Cooling intensity is only one piece of the sensory experience. What happens at the end of the draw can be just as important.
Mylor says RE-cool was developed to minimize bitterness and astringency within its effective dosage range. According to the company, its testing showed a more consistent cooling sensation from the beginning through the end of a session.
That's an important consideration for formulators working with higher-intensity cooling profiles. A blend that performs well initially but develops an undesirable aftertaste can require additional formulation work.
What Comes Next for Vape Formulators?
The regulatory environment remains an important consideration for companies selling vape products in Germany and elsewhere in Europe. InterTabac's 2026 programming itself placed significant attention on regulation, market access, and innovation, reflecting the broader changes facing manufacturers and suppliers.
At the same time, regulatory discussions should not be confused with completed rules. BfR's assessments provide scientific risk analysis, while the eventual legal requirements depend on the applicable regulatory process.
That distinction matters for companies planning formulas, because compliance decisions need to be based on the rules that actually apply to their products and market at the relevant time.
RE-cool Represents a Larger Shift in Flavor Development
Mylor's RE-cool launch highlights a broader issue facing the flavor industry: replacing a familiar ingredient isn't necessarily enough. Manufacturers also have to preserve the sensory characteristics that made the original ingredient useful.
For cooling-heavy vape flavors, that means balancing intensity, neutrality, aftertaste, and compatibility with the rest of the recipe.
RE-cool is Mylor's answer to that challenge. Whether its reported performance translates across different formulations and applications will ultimately depend on independent evaluation and real-world formulation work, but the product illustrates where cooling technology is heading as European regulation continues to evolve.
The conversation is no longer simply about making a flavor colder. Increasingly, it's about achieving the desired sensory effect while adapting to a regulatory environment that is placing greater attention on the ingredients used to create that experience.
