First look, based on manufacturer specifications and the FDA record. I have not tested this product, so there are no scores and no tasting notes on this page. ZYN Wintergreen 3mg is a 0.40 g pouch carrying 3 mg of tobacco-derived nicotine, 15 to a 6 g can. It is one of 43 nicotine pouch products FDA has authorised for sale in the United States, and one of 20 covered by the modified-risk order Swedish Match received on 30 June 2026. It cannot lawfully be sold in California or Massachusetts, both of which name wintergreen as a banned characterizing flavour.
Every figure below comes from Swedish Match’s own product pages or from FDA’s own documents, and each is attributed. Where a specification is not published anywhere I could reach, I say so rather than filling the gap.
What this is
ZYN is a tobacco-free oral nicotine pouch made by Swedish Match USA, Inc. — the US arm of the Swedish Match group, whose consumer site carries the footer © 2026 Swedish Match North America LLC.
The pouch contains no tobacco leaf; the nicotine is extracted from tobacco, which is why it is regulated as a tobacco product.
Wintergreen is one of ten flavours Swedish Match lists as available nationwide. Its own description of the flavour is a single line: ZYN Wintergreen offers mint refreshment with a hint of sweetness
. That is the same copy the brand uses for the 6 mg version, so by the manufacturer’s own account the only difference between ZYN Wintergreen 3mg and ZYN Wintergreen 6mg is nicotine.
One note on the flavour itself. Wintergreen as a flavour is characteristically methyl salicylate, which FDA lists among the synthetic flavouring substances permitted in food at 21 CFR 172.515. But ZYN’s flavour ingredients are redacted throughout FDA’s own review of the product, so I cannot tell you that methyl salicylate is in this pouch — only that wintergreen flavour generally is built on it.
Specifications
The physical specification here is unusually complete, and not because the manufacturer published it. FDA’s modified-risk order letter lists the dimensions of every covered product in its Appendix A, which is a better source than a shop page.
| Product name (manufacturer) | ZYN Wintergreen 3mg |
|---|---|
| Product name (FDA) | ZYN Wintergreen 3 mg |
| Manufacturer | Swedish Match USA, Inc. |
| Nicotine | 3 mg per pouch, tobacco-derived |
| Pouch mass | 0.40 g |
| Concentration | 7.5 mg/g — my arithmetic from the two figures above, not a published figure |
| Pouch dimensions | 28 mm × 14 mm × 4.5 mm |
| Pouches per can | 15 |
| Can contents | 6 g; polypropylene can and lid |
| Format name | Not published. Swedish Match uses no format name for this product on its US pages, and the format is redacted in FDA’s review |
| Flavour category (FDA) | Flavored — “Wintergreen” |
| FDA marketing authorisation | Authorised. On FDA’s list of authorised nicotine pouch products, content current 21 August 2026 |
| FDA modified-risk order | Yes — STN MR0000268.PD7, granted 30 June 2026 |
| Sold in California / Massachusetts | Prohibited in both. Wintergreen is a named characterizing flavour under each state’s ban |
| Measured nicotine content | No published measurement exists for any 3 mg ZYN |
Swedish Match publishes its ingredients by function rather than as a formulation: In addition to nicotine salt, ZYN contains only food-grade ingredients.
It names nicotine bitartrate dihydrate as the nicotine salt, hydroxypropyl cellulose as a stabiliser, microcrystalline cellulose, maltitol and gum arabic as fillers, sodium carbonate and sodium bicarbonate as pH adjusters, and acesulfame K as the sweetener.
What the FDA record says about this specific product
This is where a first look can do something a taste test cannot. FDA’s technical project lead review of the ZYN application, signed 14 January 2025, discusses Wintergreen by name and by its own application number, PM0000599.PD1.
On delivery: FDA found that nicotine exposure from the mint-flavored new products in PM0000595.PD1 (Peppermint 3 mg), PM0000597.PD1 (Spearmint 3 mg), and PM0000599.PD1 (Wintergreen 3 mg) are bioequivalent
, and more generally that Nicotine exposure from mint-flavored products are bioequivalent even though these products have different flavor ingredients.
In plain terms: at the same strength, FDA could not separate the mint family on nicotine delivery. If you are choosing between 3 mg Wintergreen, Peppermint and Spearmint, the regulator’s view is that you are choosing a flavour, not a dose.
On constituents, FDA reports that Levels of 36 of the 42 HPHCs reported for the new products are too low to be quantified
, that the quantifiable ones are acetaldehyde, coumarin, formaldehyde, naphthalene, nicotine, and nornicotine
, and that the products do not contain measurable quantities of carcinogenic tobacco-specific nitrosamines, including NNN and NNK
. Against Swedish Match’s own snus, Acetaldehyde levels are 78%-89% lower
. Every numeric value in the review is redacted, so those are FDA’s conclusions, not figures I can show you.
On abuse liability: abuse liability is expected to be lower than that of combusted cigarettes and lower than some smokeless tobacco products
, and for the 3 mg line specifically, abuse liability is not expected to exceed that of General Snus or moist snuff
.
And on the flavour question that hangs over every mint pouch, FDA’s reasoning is worth quoting because it is unusually direct: the majority of the new products include characterizing flavors that are common in smokeless tobacco products (e.g., Cool Mint, Peppermint, Spearmint, and Wintergreen) and are not novel flavors
. Wintergreen was treated as a heritage smokeless flavour rather than a novelty one.
Regulatory status in the United States
ZYN Wintergreen 3 mg appears by name on FDA’s list of authorised nicotine pouch products, under Swedish Match USA, Inc. The page states There are 43 nicotine pouch products authorized by the FDA.
and that These are the only nicotine pouch products that may be lawfully sold in the United States.
It also carries the caveat that has to travel with it: While these products are authorized to be sold in the United States, it does not mean these products are safe, nor are they ‘FDA approved.’
Separately, on 30 June 2026 FDA granted Swedish Match a modified-risk order covering 20 ZYN products, Wintergreen 3 mg among them. The authorised claim reads: Using ZYN instead of cigarettes puts you at a lower risk of mouth cancer, heart disease, lung
cancer, stroke, emphysema, and chronic bronchitis.
The order states that These modified risk orders are effective for 5 years from the issue date of this letter.
— which by my arithmetic is 30 June 2031, though FDA does not print that date.
Two things about that claim deserve attention. It is a closed list of six named conditions, and it is conditional on substitution for cigarettes — it says nothing to anyone who does not currently smoke. And it is word-for-word the same claim scope FDA granted traditional Swedish snus in 2019 and renewed in 2024, with only the brand name changed. A tobacco-free pouch was given the same six-condition latitude as a tobacco product. That is a notable regulatory judgement and I have not seen it remarked on much.
The order also comes with conditions: Swedish Match must run postmarket surveillance that must be designed to monitor use of ZYN among youth under the age of 18
, must give FDA at least 30 days’ notice before disseminating advertising, and must maintain independent age- and identity-verification.
Where you cannot buy it
Both of the big state flavour bans reach this product, and neither needs an argument about whether wintergreen counts as menthol — both statutes name wintergreen outright.
California’s Health & Safety Code § 104559.5 defines a characterizing flavor to include tastes or odours relating to alcoholic beverage, menthol, mint, wintergreen, herb, or spice, or a cooling sensation distinguishable by
an ordinary consumer. Its definition of “tobacco product” reaches A product containing, made, or derived from tobacco or
nicotine that is intended for human consumption
, so a tobacco-free nicotine pouch is inside it. The prohibition binds retailers.
Massachusetts goes further. M.G.L. c. 270 § 28 uses the same flavour list, including mint, wintergreen, herb or spice
, and the same nicotine-reaching definition of “tobacco product” — but its prohibition binds manufacturers too and expressly covers remote sales: No person, retailer or manufacturer shall sell, distribute, cause to be sold or distributed, offer for
sale any flavored tobacco product or tobacco product flavor enhancer in any retail establishment,
online or through any other means to any consumer in the commonwealth
.
Neither statute exempts mint, menthol or wintergreen. Outside the US, the UK currently places no flavour restriction on pouches, though from 29 October 2026 it becomes an offence to sell any nicotine product to anyone under 18.
One thing worth knowing about the rest of the range
While checking this product against FDA’s list, something else turned up. Swedish Match markets Black Cherry, Peach and Dragonberry as permanent additions to the classic lineup
available at the classic 3 mg and 6 mg strengths.
None of those three flavours appears anywhere on FDA’s authorised-product list at its content-current date of 21 August 2026.
I’m reporting that as a discrepancy, not an accusation. FDA does not publish pending applications, and a list can lag a market. But the agency’s own framing is that the listed products are the only ones that may lawfully be sold, and three marketed flavours are not on it. It does not touch Wintergreen 3 mg, which is listed.
Who this suits
On specification, this is the lower of the two ZYN strengths in a 0.40 g pouch at 7.5 mg per gram — toward the low end of the market, where the German risk assessor’s survey found a median of 9.48 mg in a 0.6 g pouch. It would suit an adult nicotine user who wants a long, flat delivery rather than a sharp one, and who wants a mint-family flavour without the peppermint or spearmint register. FDA’s bioequivalence finding means there is no delivery reason to pick Wintergreen over Peppermint or Spearmint at the same strength.
It does not suit anyone in California or Massachusetts, where it cannot lawfully be sold. And nothing here is a reason for someone who does not already use nicotine to start.
If you want more nicotine in the same flavour, the 6 mg is the same product by the manufacturer’s own description. If you want the same 3 mg strength in a different register, ZYN Cool Mint 3mg is the sibling — described by the maker as a taste of menthol with notes of peppermint
. For wintergreen from another brand, Rogue Wintergreen 6mg sits at twice the strength and, per the one published analytical study, in a much moister pouch.
What I could not establish
- Any measured nicotine value for a 3 mg ZYN. The only published analysis of ZYN measured a labelled 6 mg pouch at 5.4 mg by GC-FID, n=3. That paper’s authors are all employees of Altria Client Services LLC, and the published page carries neither a funding statement nor a competing-interests statement. Scaling that result down to 3 mg would be guesswork, so I haven’t.
- The flavour ingredients. Redacted throughout FDA’s review.
- A format name. The dimensions are published by FDA; the marketing name for the format is not published by the manufacturer on its US pages. Do not assume the UK figures apply — ZYN UK is a different legal entity with different can counts.
- Anything about taste, moisture, drip, burn or how long it lasts in use. I have not used this product. When I do, this page becomes a scored review.
Sources
- FDA, Nicotine Pouch Products Authorized by FDA, content current 21 August 2026 — fda.gov.
- FDA, ZYN modified risk granted order and Appendix A, 30 June 2026 — fda.gov.
- FDA, Modified Risk Tobacco Products — fda.gov.
- FDA, PMTA technical project lead review for ZYN, signed 14 January 2025 — accessdata.fda.gov.
- 21 CFR 172.515, synthetic flavouring substances, listing methyl salicylate — eCFR.
- California Health & Safety Code § 104559.5 — Justia.
- Massachusetts General Laws c. 270 § 28 — Justia.
- UK government guidance, Selling vaping and nicotine products, last updated 12 August 2026 — gov.uk.
- BfR, Health risk assessment of nicotine pouches, Opinion no. 023/2022, 7 October 2022 — bfr.bund.de.
- Platt SP et al., Dissolution and physical characterization of oral nicotine pouch products, Scientific Reports 16:4406, 6 January 2026 — nature.com.
- Manufacturer specifications (commercial source): ZYN Wintergreen 3mg product page and ZYN US FAQ.
Related reading on this site: the master ranking, the 3mg tier, the brand directory, and every pouch flavour ranked.