Regulation · 29 October 2026 · Stefan Bensmo

Sweden Rules ZYN’s Ingredient Labels Non-Compliant – What the Order Means for Every Brand

Short answer: the Public Health Agency of Sweden has ordered Swedish Match to list each ingredient on ZYN packaging, in descending order by weight, instead of grouping flavourings under the word “aromer” (aromas). The order applies to products made after it becomes final and carries a conditional fine of SEK 2 million per month. It targets one company, but the rule applies to everyone.

What happened?

The details come from case documents (ref. 00913-2026) obtained by trade outlet 2Firsts (2Firsts). Swedish business daily Dagens industri first reported the case on October 21.

What the agency found

Swedish Match has notified more than 160 tobacco-free nicotine products to the Public Health Agency. The notifications list between 11 and 42 ingredients per product, but the packaging showed only 10 to 13 ingredients or categories. Flavourings were grouped under the word “aromer” (2Firsts).

According to the agency, this breaches Section 11 of the Ordinance on tobacco-free nicotine products, which requires all ingredients to be listed in descending order by weight (Ordinance 2022:1263). The company must therefore list ingredients individually. No recall of products already on the market is required, and the order applies only to products made after it becomes legally effective. The company has been given 60 days to comply (2Firsts).

Swedish Match’s objections

Swedish Match considers its packaging compliant with Swedish law and has said it intends to appeal. The company has pointed to the trade-secret protection in the ordinance, the limited space on a can, and EU rules including the CLP Regulation on chemical labelling (2Firsts).

The agency responds that the rules for tobacco-free nicotine products are not harmonised at EU level and that the Section 11 requirement has no trade-secret exemption. An appeal must first be lodged with the agency within three weeks and is then heard by the Administrative Court in Stockholm. We have not been able to confirm whether the company has appealed.

Why the order matters beyond ZYN

Our read Grouping flavourings under a collective term is common in the industry. It is simple, saves space and protects recipes. If the order stands, the Public Health Agency and municipalities can apply the same reading to every brand sold in Sweden. The packaging would then need to show essentially the same ingredient list as the notification.

• Compare your packaging with your notifications now. Differences between notification and pack are exactly what the agency looked for.
• Plan for longer ingredient lists. With 20–40 ingredients, the text can be hard to fit on a lid. That affects pack design and printing.
• Do not assume the recipe is protected. According to the agency, the labelling requirement has no trade-secret exemption.
• Watch the appeal. If the court sides with the company, current practice holds. If not, the requirement becomes the industry standard.

See also nicotine pouch regulation in Sweden, why nicotine strength needs a standard and who owns ZYN.