Why “4 dots” can mean 6 mg or 39 mg — and how nicotine pouch strength could be standardized
Two cans with four dots can contain 6 and 39 mg of nicotine per pouch. That is what Snuskampen’s data on 1,403 active white nicotine pouches in Sweden shows (October 2026). The word “Strong” spans 7.5–32.5 mg. The industry has three ways of expressing strength — mg per gram, mg per pouch, and dots or words — but no common scale. The WHO says the lack of standardized labeling “probably confuses consumers.” This article shows how big the problem is and what a standard could look like.
Three ways to state strength — and none of them is enough
- mg per gram describes the concentration in the filling. It says nothing about how much nicotine one pouch contains, because pouches weigh anywhere from about 0.5 to over 1 gram.
- mg per pouch is what actually determines the dose. It is the most useful number, but it is often in small print.
- Dots and words such as “Strong,” “Extra Strong” or “Ultra” are the brands’ own communication. The scale isn’t fixed: some use five steps, others six, and the same word means different things at different manufacturers.
More on the difference between mg per gram and mg per pouch in our analysis of the strength race.
How big is the gap? Dots versus actual nicotine
| Dots | White products | Nicotine per pouch | Median |
|---|---|---|---|
| 1 | 109 | 1.6–5 mg | 3.2 mg |
| 2 | 266 | 2.8–13.2 mg | 6 mg |
| 3 | 302 | 4–21 mg | 8.9 mg |
| 4 | 374 | 6–39.05 mg | 10.9 mg |
| 5 | 251 | 10–43 mg | 15 mg |
| 6 | 54 | 15.6–35 mg | 20 mg |
The spread is wide at every step. A pouch with four dots can contain less nicotine than one with three, and a five-dot pouch can contain more than a six-dot one. In the database, four brands use the label “Strong” for products between 7.5 and 32.5 mg per pouch — a fourfold range. German research shows the same pattern: the Federal Institute for Risk Assessment (BfR) measured 44 nicotine products and found that only about a third stated nicotine in mg, and that products with the same strength descriptor from different manufacturers could differ roughly twofold.
ZYN and VELO strengths on one scale
Comparing ZYN strengths with VELO strengths is a common question, and it shows why a shared scale helps. ZYN in the US comes in 3 and 6 mg, and ZYN Ultra in 9 and 11 mg. VELO uses dots, and in the UK its dots run from 4 mg at one dot to 17 mg at six. On the scale described below, they line up like this:
| Product | mg per pouch | Nicotine Index |
|---|---|---|
| ZYN (US) | 3 mg / 6 mg | NI 1 / NI 2 |
| ZYN Ultra (US) | 9 mg / 11 mg | NI 3 / NI 4 |
| VELO Crispy Peppermint Mini | 8 mg | NI 3 |
| VELO Crispy Peppermint | 10 mg | NI 4 |
| Median white pouch | 10 mg | NI 4 |
| Strongest white pouch (FEDRS Black) | 48.75 mg | NI 6 |
Read more about ZYN Ultra and VELO Crispy Peppermint.
What the law requires today
In Sweden, the content declaration must state nicotine content and the amount of nicotine per dose under Ordinance 2022:1263, and the Public Health Agency sets the size of the declaration and the warning. That helps — but the law says nothing about how strength symbols and words may be used, nothing about measurement method, and nothing about tolerance between declared and measured values. In the US, only a warning statement is required; nicotine content doesn’t have to be stated at all.
Limits across Europe also pull in different directions, and they use different units:
| Country | Rule | Status |
|---|---|---|
| Denmark | Max 9 mg per pouch | In force since July 1, 2025 |
| Spain | Max 0.99 mg per pouch | Draft, notified to the EU January 2025 |
| Poland | Max 20 mg per gram | Proposal, notified to the EU 2025 |
| Finland | Max 16.6 mg per gram | According to Global Tobacco Control |
| Sweden | No cap; 12 mg per gram proposed | SOU 2024:23 |
| United States | No cap and no nicotine declaration required | Warning statement only |
A brand selling in several countries therefore has to work in both mg per pouch and mg per gram. The European Commission’s April 2026 evaluation of the tobacco rules notes that nicotine pouches fall outside the Tobacco Products Directive and that divergent national rules create obstacles to the free movement of goods. See our analysis of Europe’s regulatory fragmentation and of eight EU countries’ demands ahead of TPD3.
Measurement wasn’t standardized either — until now
When CORESTA, the industry’s international research body, had 17 laboratories analyze the same pouches in 2021, the report noted that there were no standardized methods for analyzing nicotine pouches. A German study from 2024 found that measured nicotine in some products was only 80–90 percent of the declared amount.
That is changing. On October 1, 2026, ISO 21114:2026 was published — the first international standard for determining nicotine content in nicotine pouches. In December 2025, CORESTA issued a voluntary technical guide on pouch safety and quality, and in the UK there is the 2022 specification PAS 8877, which sets a maximum of 20 mg per pouch. It was sponsored by BAT, which is worth knowing. So there is now a common method for measuring nicotine — but still no common scale for communicating it.
Manufacturer strength words are not a shared scale
Words such as Strong, Extra Strong, Ultra and Max are brand-specific labels. They may be useful within one range, but they cannot be compared directly between manufacturers. The number of steps also varies. A 3-of-6 label therefore describes a manufacturer's placement within its own range; NI 3 describes a fixed interval based on verified nicotine per pouch.
| Statement | What it tells you | What it does not tell you |
|---|---|---|
| Manufacturer word or dots | The product's relative position in that brand's range | That the same word or dot count means the same dose in another brand |
| mg/g | Nicotine concentration in the filling | How much nicotine the whole pouch contains |
| mg/pouch | Declared nicotine in one pouch | How quickly all of it is released or absorbed |
| Nicotine Index | A fixed comparison interval based on mg/pouch | Sensory intensity, pH, release speed or absorption |
Why mint, pH and moisture can change the experience
Two pouches with the same declared milligrams can feel different. pH affects the fraction of nicotine in its free form, and laboratory studies show that higher pH can increase permeability across buccal tissue. Formulation, moisture and release rate also matter. This makes mg per pouch the strongest simple comparison of content, but not a complete prediction of absorption or sensation.
Mint and menthol also produce cooling and sometimes irritation through sensory receptors. A study of nicotine pouches sold after California's flavour ban found that pouches containing the cooling agent WS-3 produced a stronger cooling sensation even though that does not change the declared nicotine dose. A stronger mint “sting” is therefore not evidence that a pouch contains more nicotine than, for example, a berry- or fruit-flavoured pouch.
Important nuance The relationship is not as simple as “higher pH always feels stronger”. A double-blind 2026 trial found greater harshness at higher nicotine concentration, while pH had a non-linear association with palatability and no simple linear effect on sensory measures. Sensation and nicotine content should therefore be reported as separate product characteristics.
What a nicotine strength standard needs
- mg per pouch as the primary unit. It is the number that determines the dose and that consumers can compare.
- Fixed levels with fixed boundaries. The same level should mean the same amount of nicotine regardless of brand and country.
- A measurement method and a tolerance. ISO 21114 provides the method. The industry needs to agree on what deviation is acceptable.
- Separation from marketing. Brands can keep “Strong” and “Ultra” as names, but the comparable level has to stand on its own.
A proposal: the Nicotine Index (NI 0–6)
The Nicotine Index is an open scale built on exactly those principles. The level is calculated only from verified mg of nicotine per pouch. If only mg per gram is known, the product gets no level until pouch weight or mg per pouch can be verified. This is how today’s Swedish range is distributed:
| Level | mg nicotine per pouch | White pouches | Tobacco snus |
|---|---|---|---|
| NI 0 | 0 | – | – |
| NI 1 | 0.1–3 | 57 | 0 |
| NI 2 | 3.1–6 | 290 | 8 |
| NI 3 | 6.1–9 | 293 | 65 |
| NI 4 | 9.1–13 | 460 | 60 |
| NI 5 | 13.1–20 | 194 | 45 |
| NI 6 | > 20 | 109 | 8 |
NI measures only the amount of nicotine per pouch. It says nothing about absorption, pH, release speed or perceived intensity, and it should not be read as a measure of dependence risk. The methodology (version 1.0) is published openly. The Nicotine Index was initiated by Stefan Bensmo, who also runs NicotinePouches.se, Snuskampen and SnusBattle.
What does this mean for manufacturers and brands?
Our read A nicotine strength standard is coming — the question is who sets it. If the industry doesn’t agree on how to communicate strength, regulators will do it country by country, in different units. Denmark counts per pouch and Poland per gram. Brands that already state clear mg per pouch and use fixed strength levels across their range will be best placed, both for enforcement and for consumers comparing across brands. Four concrete steps:
- Make mg per pouch the most visible number on the can, not just a line in the content declaration.
- Tie your dots to fixed ranges, and use the same ranges across your whole range and in every country.
- Measure according to ISO 21114 and document the deviation from the declared value, so the label holds up in an inspection.
- Keep your brand names, but show a comparable level next to them. It reduces the risk of misunderstanding without removing your own identity.
Want to review labeling and strength communication ahead of new rules? See regulatory and marketing.
Sources
- Characterization of Total and Unprotonated (Free) Nicotine Content of Nicotine Pouch Products — Nicotine & Tobacco Research (2021)
- Evaluation of Factors Impacting Nicotine Permeation in Oral Nicotine Pouch Products — ACS (2025)
- Effects of nicotine concentration and pH on nicotine pouch appeal and sensory experience — Addiction (2026)
- Preflavour and postflavour ban oral nicotine pouches: chemical and sensory analysis — Tobacco Control (2026)
- WHO Technical Report Series 1047: WHO study group on tobacco product regulation, ninth report (2023) — WHO
- WHO warns nicotine pouch brands targeting youth as sales surge, 15 May 2026 — WHO
- Förordning (2022:1263) om tobaksfria nikotinprodukter — lagen.nu
- HSLF-FS 2023:24, märkning av tobaksfria nikotinprodukter (PDF) — Folkhälsomyndigheten
- ISO 21114:2026 Nicotine pouches — Determination of nicotine content using LC-UV — ISO
- Nicotine pouches 2021 collaborative study, TTPA-284-1-CTR (PDF) — CORESTA
- Technical Guide No. 35: Nicotine Pouch Safety and Quality (December 2025) — CORESTA
- PAS 8877:2022 Tobacco-free oral nicotine pouches — BSI
- Health risk assessment of nicotine pouches, opinion 023/2022 (PDF) — BfR
- Mallock-Ohnesorg et al., nicotine pouches: declared and measured nicotine, Frontiers in Pharmacology 2024
- Evaluation of the tobacco control legislative framework, SWD(2026) 111 (PDF) — European Commission
- Bekendtgørelse nr. 249 af 4. marts 2025 (PDF) — Retsinformation
- Draft Royal Decree, TRIS 2025/0044/ES — European Commission
- Draft act, TRIS 2025/0055/PL — European Commission
- Global regulatory scenario of nicotine pouches (PDF, October 2025) — Global Tobacco Control
- 21 CFR 1143.3 Required warning statement — Cornell LII
- Nicotine Index methodology, version 1.0 — Nicotine Index
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