The way vape flavors are made is changing, and cooling ingredients are becoming an increasingly important part of that conversation. For years, compounds such as WS-23 have helped flavor developers create the cold sensation associated with everything from berry blends to tropical fruit and beverage-inspired recipes.
Now, regulatory scrutiny is forcing the industry to reconsider some of those familiar tools. For companies developing products for Germany and other European markets, finding an alternative isn't simply about replacing one ingredient with another. The replacement needs to deliver the right sensory effect while fitting into an increasingly complicated compliance environment.
Mylor says its RE-cool cooling blend was developed with that challenge in mind.
From One Ingredient to a More Complicated Problem
WS-23 has been popular among flavor formulators for a reason. It can deliver pronounced cooling without necessarily introducing a strong flavor of its own.
That neutrality makes it especially useful when creating fruit-and-ice profiles. A flavor developer can build a recipe around watermelon, blueberry, peach, mango, or another fruit and then add cooling without dramatically changing the identity of the recipe.
The problem is that alternatives don't always behave the same way.
A substitute may not provide enough cooling to achieve the intended effect. Another may contribute herbal or camphor-like characteristics. Others can create bitterness or astringency that becomes increasingly noticeable during extended use.
That means a successful replacement needs to solve several problems at once.

Germany's Cooling-Agent Debate
The issue has received increased attention in Germany following assessments from the Federal Institute for Risk Assessment, or BfR.
In 2025, BfR published an opinion concerning WS-23, WS-3, and WS-5, noting that these cooling agents are used in e-cigarette products and that important information about their inhalation toxicity remains limited. In January 2026, another BfR opinion examined nine additional cooling agents, including menthol, menthyl acetate, and eucalyptol.
Those scientific assessments are part of a broader regulatory discussion, and manufacturers need to distinguish between scientific opinions, proposed measures, and requirements that have actually entered into force.
For product developers, however, the direction of the discussion is already influencing formulation strategy.
Mylor's RE-cool Approach
Mylor says it approached the problem from a different direction.
Instead of trying to identify one replacement molecule that behaves exactly like WS-23, the company's R&D team developed RE-cool as a cooling blend. Mylor says the formulation went through hundreds of trials and sensory evaluations before being introduced to the market.
The company describes the technology as being based on sensory signal interaction rather than straightforward ingredient substitution.
According to Mylor, RE-cool is formulated without WS-23, WS-3, WS-5, or menthol. The company also reports that its testing found cooling intensity comparable to WS-23 while maintaining a cleaner overall sensory profile.
Those are manufacturer-reported results, so individual formulators would still need to test RE-cool in their own applications.

Keeping Fruit Flavors Front and Center
One of the most important aspects of a cooling ingredient is what happens to the flavor surrounding it.
A good cooling component should enhance the perception of freshness without overwhelming the recipe. If an alternative brings too much herbal, medicinal, or camphor-like character, it can quickly change the profile of the finished product.
Mylor says RE-cool was designed to remain highly neutral in the formulation. The company's stated objective is to let the primary flavor remain in control while the cooling effect operates in the background.
For fruit recipes, that could be significant. A peach flavor should still taste like peach. A watermelon profile should retain its juicy character. Berry blends should continue to deliver their intended combination of sweetness and tartness.
Looking at What Happens After the Draw
Mylor is also highlighting the finish of the sensory experience.
Cooling isn't only about the initial sensation. Formulators also have to consider what happens after the draw, particularly when a product is used repeatedly.
The company says RE-cool was designed to reduce bitterness and astringency within its effective dosage range. Mylor reports that its testing showed a smoother and more consistent cooling effect without the progressive bitter character it associates with some alternatives.
Again, the results are based on Mylor's own testing and should be evaluated independently when incorporated into a commercial formula.
Why InterTabac Was an Important Showcase
Mylor presented RE-cool at InterTabac 2026 in Dortmund, giving manufacturers, distributors, and flavor professionals an opportunity to experience the product directly.
The international trade show took place September 15–17 and brought hundreds of companies to Dortmund. The event's broader program included discussions surrounding regulation, market access, innovation, and developments across the industry.
Mylor's booth provided an opportunity to compare RE-cool with established cooling solutions and discuss how the blend could be incorporated into different formulations.
That hands-on component is particularly relevant because no cooling ingredient exists in isolation. The final sensory result depends on the entire recipe.

What RE-cool Says About the Future of Cooling
The development of RE-cool reflects a larger change in how flavor companies are approaching cooling technology.
The industry is moving away from the idea that a cooling ingredient only needs to produce a strong cold sensation. Today's formulation challenges require a much broader approach.
Cooling needs to work with the flavor rather than against it. It needs to deliver consistent sensory performance. It needs to avoid unwanted aftertastes. And, perhaps most importantly, it needs to fit the regulatory requirements of the market where the finished product will be sold.
Mylor's RE-cool is designed around those objectives. Its success will ultimately depend on regulatory developments, independent testing, and how well it performs across different commercial formulas.
But the need for new cooling technologies is clear. As Germany and other European markets continue examining the substances used to create icy vape profiles, companies developing flavors will increasingly have to treat cooling as a technical discipline in its own right—not simply another ingredient added to a recipe.