Illustration of five rising bars in blue, amber and red representing escalating nicotine strength tiers

What ‘extra strong’ actually means on a can

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Nothing. “Extra strong” has no legal definition anywhere I could find, no fixed milligram threshold, and no agreed scale behind it. It is a marketing word, chosen by whoever printed the can, and two pouches carrying it can differ by a factor of three in nicotine content — and further still in how much of that nicotine your mouth can actually absorb.

I went looking for a rule. I read the EU Tobacco Products Directive, the Swedish and Polish statutes that govern tobacco-free nicotine products, Finland’s and Denmark’s caps, and the United States Code provision that bans descriptors on tobacco packaging. Not one of them defines “strong”, “extra strong”, “super strong”, “X-strong” or any numeric strength ladder for an oral nicotine product. Several of them regulate what number must appear on the pack. None of them regulates the adjective printed above it.

That gap is the whole subject of this article, and it has three layers: there is no law behind the word, the brands that do publish a scale each invented their own, and the number the word is supposedly summarising is itself measured to be wrong more often than not.

Layer one: there is no law behind the word

Start with the EU, because most people assume the TPD covers this. It does not — and for a reason that is worth understanding rather than memorising.

The Directive’s scope hook is in Article 2(4): “‘tobacco products’ means products that can be consumed and consist, even partly, of tobacco”. A tobacco-free nicotine pouch does not consist, even partly, of tobacco. So it is not a tobacco product for TPD purposes, and the Directive’s labelling rules in Article 13 simply do not reach it. The Commission says so itself. In a parliamentary answer of 25 October 2023, Commissioner Kyriakides wrote that “tobacco-free nicotine pouches are currently outside the scope of the Tobacco Products Directive 2014/40/EU (TPD)”. The Commission’s own evaluation of the Directive, SWD(2026) 111 final of 2 April 2026, confirms that “Nicotine products other than e-cigarettes and refill containers (nicotine pouches, nicotine gums, nicotine nasal sprays and other nicotine products)” fall outside its scope, and that “EU Member States have adopted various regulatory approaches to addressing these novel products in areas not covered by the tobacco control framework.”

There is a nice irony here. For actual tobacco products the TPD is stricter than anything the pouch category faces: Article 13(1)(a) says that “labels shall not include any information about the nicotine, tar or carbon monoxide content of the tobacco product”. A cigarette pack may not tell you its nicotine content. A nicotine pouch can print any adjective it likes.

National law fills some of the gap, and it is instructive how. Sweden requires a content declaration under 7 § of Lag (2022:1257) om tobaksfria nikotinprodukter, and the implementing regulation, 11 § of Förordning (2022:1263), says what must be in it: a list of all ingredients in descending order of weight, information on the nicotine content in the product “och fördelning per dos” — and its distribution per dose — and a recommendation to keep the product away from children. Note what is missing: the regulation fixes neither the unit nor the format of the number, only that it be given per dose. On descriptors, 8 § bans two things: labelling may not “antyda att en viss tobaksfri nikotinprodukt är mindre skadlig än andra sådana produkter” — imply that one product is less harmful than others — or resemble a food or cosmetic. There is no misleading-strength clause at all.

Poland is the nearest thing to an answer, and it proves the point by exception. Art. 11hb, inserted into the tobacco-protection act by the amending law published on 20 June 2025 (Dz.U. 2025 poz. 799), caps pouches at 20 mg/g, mandates the health warning, and then imports the TPD-style misleading-presentation prohibitions by cross-reference — with express carve-outs permitting information about nicotine content and about flavourings. Polish law, in other words, decided which presentational rules should apply and then specifically allowed the strength figure through. It still says nothing about the adjective.

Finland regulates the thing the adjective is supposed to be about, and does it better than anyone: a cap of 16.6 mg of nicotine per gram of product, plus a portion-weight window. The government’s own statement of 22 May 2025 puts it in one line — a smokeless nicotine product may not be sold “valmiina annosyksikkönä, jonka paino on vähemmän kuin 0,5 grammaa tai enemmän kuin yksi gramma”, a finished dose unit weighing less than 0.5 g or more than 1 g — and then does the arithmetic for you: “Melko tyypillisessä 0,7 gramman pussissa nikotiinia saa olla enintään hieman alle 12 milligrammaa.” In a fairly typical 0.7 g pouch, at most just under 12 mg. Finland also standardised retail pack appearance from 1 February 2026. Denmark takes the other route, capping per pouch: order no. 249 of 4 March 2025 says “Nikotinposer må maksimalt indeholde 9,0 mg nikotin pr. pose”, in force 1 July 2025. Neither country defines a strength word.

The United States regulates descriptors, but in one direction only. 21 U.S.C. 387k makes a product a “modified risk tobacco product” — needing an FDA order before sale — if its label “uses the descriptors ‘light’, ‘mild’, or ‘low’ or similar descriptors”, or otherwise represents that it is less harmful or lower in exposure. FDA’s position is that such claims without an order are “health fraud”. Read the statute and the direction is obvious: the bar is on words that imply less. “Extra strong” implies more, makes no reduced-risk claim, and on the face of the text is not caught. FDA has never published a definition of “similar descriptors” — I checked its descriptors page and its June 2010 guidance, and neither gives an example beyond the three named words. So the law that does police adjectives is aimed at the opposite kind of adjective.

One wrinkle worth noticing: ZYN’s UK site sells a tier it calls “Low”. That is the same word the US statute names. Different jurisdiction, and a strength tier is not a health claim — but it shows how little thought the descriptor layer has had.

Layer two: every brand invented its own scale

Because nobody defines the words, brands define themselves. Here is what the brand owners actually publish on their own sites, which is not always what retailers print.

Brand System published on the brand’s own site Numbers attached?
ZYN (UK) Three tiers: “Low”, “Medium”, “Strong” Yes — Low 1.5–3 mg, Medium 6–9 mg, Strong 11–16.5 mg
VELO (UK) Three tiers: “Mellow”, “Original”, “Intense” No mapping published; mg listed per flavour (4–17 mg)
Nordic Spirit (UK) Dots on the can, 1 to 6 No mg figures in the readable guide
Skruf “Styrka” score out of 5, plus mg/g and mg per portion Yes, both bases — the most transparent I found
Siberia / White Fox No scale; bare milligram figures Yes, but with no stated basis
on! / on! PLUS No scale; a strength filter, 2–12 mg Yes, no basis stated
Pablo No scale; “strengths … ranging from 3-24mg” Yes, no basis stated
Loop Nothing at all — “a large variety of flavours and strengths” No

Two of those rows deserve pulling out.

ZYN’s UK tiers are tied to user experience, not to a scale. The site’s own words: “Shop ZYN Low. New to nicotine pouches? Shop our 1.5mg & 3mg ranges”; “Shop ZYN Medium. Already a nicotine pouch user? Shop our 6mg & 9mg ranges”; “Shop ZYN Strong. Experienced nicotine pouch user? Shop our 11mg, 13.5mg & 16.5mg ranges.” That is a sensible piece of consumer guidance and I would rather have it than not. But notice the top of the ladder is the word “Strong” and the range is 11–16.5 mg, while Pablo sells 24 mg and Siberia’s original portion is listed at 25 mg with no adjective at all. One brand’s “Strong” is under half another brand’s unlabelled top product.

Skruf shows why a single scale cannot work. Its tobacco-free Super White Slim Fresh #4 page publishes “Nikotinhalt mg/g: 18 mg/g” and “Nikotinhalt / påse: 13 mg/portion”, with a 0.72 g portion and a “Styrka” of 4 out of 5. Its tobacco snus product actually named “Xtra Stark” publishes 17 mg/g, 15 mg per portion — and a Styrka of 4 out of 4. The word “Xtra Stark” sits on the lower mg/g figure. The two scores are on different scales, for different product families, and are not comparable, even within one company. (Incidentally, Skruf publishing mg/g on its own product pages is itself notable: most brand owners do not, which is a large part of why the mg-per-pouch versus mg-per-gram confusion persists.)

And there is the format multiplier underneath it all. A 16 mg/g figure means about 8 mg in a 0.5 g mini and about 16 mg in a 1 g regular portion — the same “strength”, twice the dose. That is why Finland caps the portion weight as well as the concentration, and why I would not read a strength word without knowing the format.

Layer three: the number itself is often wrong

Suppose you ignore the adjective and trust the milligrams. Independent measurement says you should not trust them very far either.

The best regulator data comes from the Bavarian Health and Food Safety Authority, whose staff published their market survey as Reimann et al., Toxicology Reports 13 (December 2024) 101779 (doi 10.1016/j.toxrep.2024.101779). They analysed 31 pouch samples collected between 2019 and 2023. Two findings matter here. First, on labelling: “Nicotine content was labeled on 48 % of the products only and ranged from 2.58 to 36.9 mg per pouch.” Less than half the products told you anything. Second, on accuracy: “Regarding the 15 samples with labeled nicotine content, we usually analyzed lower nicotine levels in the pouches with median deviation of 14.7 %.” The authors declare no competing financial interests; no funding statement appeared in what I could read, and the authors are staff of a state authority.

Germany’s federal risk-assessment institute found the same direction. Mallock-Ohnesorg et al., Frontiers in Pharmacology, 22 May 2024 (doi 10.3389/fphar.2024.1392027): measured contents of “4.8 ± 0.4 mg, 16.3 ± 3.1 mg, and 27.1 ± 0.2 mg” for pouches declared at 6, 20 and 30 mg — “the pouches only contained between 80% and 90% of the declared nicotine content.” That study was funded by the BfR itself (grant BfR-CPS-08-60-0102-02.P606) and declares no commercial relationships.

The largest deviations come from a Roswell Park group, Page et al., Nicotine & Tobacco Research 28(2), February 2026 (doi 10.1093/ntr/ntaf105). Most products were fine — “For most ONPs, measured nicotine content was consistent with values provided on packages (within 20%)” — but the outliers are large: “VELO nicotine pouches available in 4 and 7-mg cans contained, on average, >60% less nicotine than labeled”, and “White Fox 12 mg contained nearly 40% less nicotine (7.8 ± 0.8 mg/pouch) than labeled.” One product, Bull Dog, ran 20 per cent higher than its online marketing claimed. I have not been able to read that paper’s funding statement — the publisher’s page truncates before the end matter and the open-access mirror is behind a challenge page — so treat those figures as unverified for funding, which is a gap I would rather flag than paper over.

Commercial laboratory work points the same way. Jablonski, Cheetham and Martin, Separations 9(3):65 (2022), doi 10.3390/separations9030065, surveyed the modern oral category and found unlabelled products measuring “from 3.1 to 8.0 mg/portion”. That study was internally funded by Enthalpy Analytical, whose authors state that the company “is a commercial testing laboratory with a focus on nicotine-containing products and provides services to a wide range of clients including tobacco manufacturers and regulatory authorities” — declared, and relevant.

The thing “extra strong” cannot tell you at all

Here is what changed my own thinking. Total nicotine content and available nicotine are different quantities, and the gap between them is enormous and unlabelled.

CDC scientists measured it. Stanfill et al., Nicotine & Tobacco Research 23(9), September 2021 (doi 10.1093/ntr/ntab030), characterised 37 pouch products and found they “varied in pouch content mass, moisture content (1.12%‒47.2%), alkalinity (pH 6.86‒10.1), and % free nicotine (7.7%‒99.2%)”. Free nicotine — the unprotonated form, the one that crosses the mucosa most readily — “ranged from 0.166 to 6.07 mg/pouch” against total nicotine of “1.29 to 6.11 mg/pouch”. Read that twice. In one product almost all the nicotine was in the readily absorbed form; in another, under a tenth of it was. The paper is US government work in the public domain, with no separate funding statement shown.

Manufacturers know this and treat it as a design variable. A Nicoventures patent application published in December 2025, EP4659596A1, claims oral products in which “an amount of nicotine present in free-base form is 15% or less based on a total content of nicotine”, on the basis that low free-base pouches “may…be advantageous in providing low levels of harshness/irritation”. So a company can deliberately build two pouches with the same milligram figure and very different kick — and nothing on either can will tell you which is which.

Then there is how much actually comes out. The BfR study extracted mean doses of “1.8 ± 0.8 mg, 4.7 ± 3.5 mg, and 14.1 ± 3.0 mg” from the 6, 20 and 30 mg products. The label number is the amount in the pouch, not the amount you get.

So how should you read a can?

My own working rules, after all of the above:

  • Ignore the adjective entirely. It carries no information that is comparable across brands, and often none within a brand.
  • Find the number and find its basis. If the pack says mg without saying per pouch or per gram, you cannot use it. If it gives mg/g, you need the portion weight before it means anything.
  • Treat the number as approximate and probably high. Independent measurement puts the median deviation around 15 per cent low, with occasional products far worse.
  • Use your own reaction as the instrument, not the label. This is the one place where the pH and free-base variation actually helps you: the pouch tells you what it is within a couple of minutes. A “mild” one that bites is a real thing.
  • Compare within a brand, not across brands. Within one range the relative ordering is likely to be honest, because it is the same maker, the same base and the same pouch weight.

Frequently asked

Is “extra strong” regulated anywhere?

Not in anything I could read. Sweden bans “less harmful” implications, Poland imports a TPD-style misleading-presentation rule with a nicotine-content carve-out, and US law bans “light”, “mild” and “low”. None of them defines a strength word or sets a threshold for one.

Is there a milligram figure at which a pouch counts as extra strong?

No. The nearest thing to a bright line is a legal cap, not a descriptor: 16.6 mg/g in Finland, 20 mg/g in Poland, 9.0 mg per pouch in Denmark. Sweden currently has no adopted cap, though SOU 2024:23 proposed 12 mg/g.

Why do the same brand’s tiers differ between countries?

Because the tiers are marketing, set market by market, and because national caps differ. A range that is lawful in Sweden may be unsellable in Denmark. Do not assume a tier name travels.

If the label is unreliable, what should I trust?

The cap in your own market tells you the ceiling, the portion weight tells you the multiplier, and your first two minutes with the pouch tell you more than the adjective ever will.

Sources

Related reading: the complete mg guide, every brand’s strength scale side by side, and mg per pouch vs mg per gram.

Nicotine is addictive. No tobacco or nicotine product is safe, and completely stopping is the lowest-risk option. This site is for adults who already use nicotine — 21+ in the United States, 18+ or your local legal age elsewhere. Nothing here is medical advice.