ZYN Wintergreen 6mg vs Rogue Wintergreen 6mg
A specifications and regulatory head-to-head with no scores: one of these is documented by its regulator to the millimetre, the other by a product page.
On the published evidence, ZYN Wintergreen 6 mg wins, and it is not close — but neither of these has been in my mouth, so there are no scores on this page. ZYN is documented down to the millimetre by its own regulator and is one of only 43 pouches that may lawfully be sold in the United States. Rogue publishes a can weight and a marketing page.
What this comparison is, and what it is not
This is a specification and regulatory head-to-head, built from FDA orders, state statutes, an independent laboratory study and each maker’s own published material. Neither has been tested here, so there is no verdict on taste and no six-score breakdown — the same basis as our first looks at ZYN Wintergreen 6 mg and Rogue Wintergreen 6 mg. What that leaves is a sharper comparison than most: same flavour, same declared strength, and a gap in documentation wide enough to be the story.
The specifications, side by side
“Not published” below means exactly that: I looked and the figure does not exist in any primary source. Nothing in this table is estimated except where marked.
| Specification | ZYN Wintergreen 6 mg | Rogue Wintergreen 6 mg |
|---|---|---|
| Maker | Swedish Match USA, Inc. | Rogue Holdings, LLC — “a wholly owned subsidiary of Swisher International, Inc.” |
| Nicotine per pouch | 6 mg (“Nicotine Concentration: 6 mg/pouch”, FDA) | 6 mg (maker’s product page) |
| Pouches per can | 15 | 20 |
| Pouch mass | 0.40 g (FDA) | Not published. ~0.675 g by my arithmetic from the can weight |
| Can net weight | 6 g (FDA) | 13.5 g / 0.48 oz (maker) |
| Pouch dimensions | 28 × 14 × 4.5 mm (FDA) | Not published |
| Nicotine by mass | 15 mg/g (my arithmetic) | ~8.9 mg/g (my arithmetic, from a derived mass) |
| Nicotine source | Tobacco (stated by FDA) | Not published. “Tobacco-free” describes the leaf, not the nicotine’s origin |
| Nicotine chemistry | Nicotine salt (bitartrate dihydrate, maker) | Nicotine polacrilex — nicotine “bound to a polymer resin” (maker) |
| Full ingredient list | By function on the maker’s site; redacted in FDA’s review | Not published — “flavors and other food grade ingredients” |
| pH | Not published by anyone | Not published by anyone |
| FDA marketing authorisation | Granted 16 January 2025, STN PM0000600.PD1 | None |
| FDA modified-risk order | Granted 30 June 2026, STN MR0000268.PD8, five-year term | None |
| Marketing denial order | None | None |
| FDA warning letter | None | None to the pouch maker |
| Wintergreen strengths offered | 3 mg, 6 mg; ZYN ULTRA Wintergreen 9 mg | 3 mg, 6 mg; Rogue MAX Wintergreen 9, 12, 15 mg |
| Maker-published price | Not published | $26.99 per five-can pack — $0.27 a pouch (my arithmetic) |
One footnote FDA adds about its own figures, worth knowing: “In addition to portion mass, the applicant submitted two of the three dimensions (i.e., portion length, portion width, portion thickness) which allowed for calculation of the third dimension.” One of those three millimetre figures is arithmetic, not measurement.
Axis one: the legal position, which is the whole ballgame in the US
FDA’s list of authorised nicotine pouches says, in its own words: “There are 43 nicotine pouch products authorized by the FDA. These are the only nicotine pouch products that may be lawfully sold in the United States.” ZYN Wintergreen 6 mg is on that list. Searching the page for “Rogue” in any capitalisation returns nothing; the only two companies on it are Swedish Match USA and Helix Innovations.
Be careful what that means. Absent from the list is not the same as rejected. FDA’s marketing-orders page carries no denial order naming Rogue, Rogue Holdings or Swisher, and the warning-letter database — current to 13 October 2026 — returns three unrelated companies with “Rogue” in the name, two of them e-liquid makers, and nothing for “Swisher”. FDA does not publish pending applications. The accurate statement is: no authorisation, and no adverse action either.
And FDA attaches the same caveat to the winner: authorisation “does not mean these products are safe, nor are they ‘FDA approved.’ All tobacco products are harmful and potentially addictive.”
Axis two: the reduced-risk claim only one of them can make
On 30 June 2026 FDA granted Swedish Match a modified-risk order covering exactly twenty ZYN products — ten flavours at 3 mg and 6 mg. ZYN Wintergreen 6 mg is in it, as MR0000268.PD8. The authorised wording is one sentence and FDA’s own stray space is part of it:
” Using ZYN instead of cigarettes puts you at a lower risk of mouth cancer, heart disease, lung cancer, stroke, emphysema, and chronic bronchitis.”
Three things that sentence does not say. It says nothing about safety — the same order states it “does not mean we ‘approved’ the tobacco products”. It says nothing about vaping; I searched all twenty-four pages for e-cigarette, vape, vaping, vapor and ENDS and every term returns zero. And it is expressly not a cessation claim: FDA warns that any statement that these products are “intended to be used for the treatment or mitigation of tobacco dependence, including as smoking or tobacco cessation aids” would strip them of modified-risk status. The order runs five years from issue.
ZYN ULTRA is not in it — the string “ULTRA” appears nowhere in the order — so a ZYN ULTRA Wintergreen 9 mg may be sold but may not carry the claim, while this 6 mg may.
Axis three: what an independent laboratory measured
There is a published same-strength measurement of both brands — with one caveat I have to flag immediately. The study tested mint variants, not wintergreen: “To be consistent, all products were mint flavored with nicotine levels between 6 and 9.4 mg per pouch based on the can label.” So these are brand-level figures at the right dose, not these exact SKUs.
| Measured | ZYN Cool Mint 6 mg | Rogue Spearmint 6 mg |
|---|---|---|
| Pouch weight | 0.38 ± 0.002 g | 0.69 ± 0.043 g |
| Nicotine found (label 6 mg) | 5.4 ± 0.03 mg — 90% of label | 6.2 ± 0.01 mg — 103% of label |
| Nicotine released in 60 min | 96 ± 2% | 72 ± 5% |
| pH of the filler | 7.62 ± 0.01 | 7.43 ± 0.17 |
| Moisture | 3.52 ± 0.08% | 14.70 ± 0.14% |
| Soluble content | 78.26 ± 0.77% | 41.21 ± 0.35% |
Three results matter. Rogue over-delivered against the number on its can and ZYN under-delivered. Rogue’s pouch is 1.8 times the mass at the same dose — Swisher’s own “Bolder Flavor. Bigger Pouches.” turning out to be literally true. And ZYN released nearly all its nicotine within the hour against Rogue’s under three quarters, with both reaching about 97% on the fitted model: the difference is pace, not capacity. ZYN’s measured 0.38 g sits within 5% of FDA’s published 0.40 g — an independent lab confirming the regulator’s spec sheet.
Disclose this properly. The study “was funded by Altria Client Services LLC, an affiliate of Helix Innovations LLC, the manufacturer of on! nicotine pouches”, and all eight authors were Altria employees at the time. The funder makes ZYN’s only authorised competitor, and that competitor scored best of the seven on release. I would still use the numbers — the methods are published and the measurements are internally consistent — but not without that sentence attached.
Axis four: how much each regulator knows about the product
This is where the two diverge most, and it is the part that would actually decide it for me.
FDA’s technical review of the ZYN applications states that the products “are not smokeless tobacco products because they do not consist of cut, ground, powdered, or leaf tobacco”, that “among the 42 HPHCs analyzed in the new products, levels of 36 were too low to be quantified”, and that they do not contain measurable quantities of the tobacco-specific nitrosamines NNN and NNK or the carcinogen B[a]P. FDA’s footnote to that last point must travel with it: “Levels are not above the limit of quantitation (LOQ) of the analytical methods used in these PMTAs, though the applicant did not demonstrate that the new products are free from these chemicals.”
Reading the review closely gives a figure specific to this SKU that I have not seen printed. FDA names six HPHCs as quantifiable in at least one product, then attributes coumarin to the Cinnamon products and naphthalene to the Citrus products only. Neither is Wintergreen. So for ZYN Wintergreen 6 mg, four of the 42 constituents are quantifiable: acetaldehyde, formaldehyde, nicotine and nornicotine. Acetaldehyde runs “78%-89% lower” than General Snus and nornicotine “98%-100% lower” — but formaldehyde is “24%-52% higher”. That is the one constituent that goes the wrong way, and it should be on the page.
There is also something unusual about this exact product. FDA bridges data across ZYN flavours, but Wintergreen 6 mg is not a bridged product — it is a reference one. From the review: the bioequivalence analyses “were performed using the nicotine PK profiles for the 6 mg Wintergreen and Smooth (PM0000600.PD1, PM0000608.PD1)”. Of ten 6 mg ZYN flavours, Wintergreen is one of only two with its own clinical pharmacokinetic data. And the contrast is pointed: for 6 mg Menthol, FDA concluded the abuse liability “cannot be bridged to other new products with a known abuse liability profile because the applicant did not provide sufficient data and bridging rationale.”
For Rogue Wintergreen 6 mg there is no equivalent of any of this. No HPHC data, no pH, no dimensions, no moisture figure, and no statement anywhere of where its nicotine comes from. The asymmetry is the finding: the authorised product is characterised by its regulator in detail, and the unauthorised one is characterised by a product page.
Axis five: both are banned in the same states, and wintergreen is named in the statutes
This is the axis where the FDA order buys nothing at all.
Massachusetts defines a “characterizing flavor” to include “a taste or aroma relating to any fruit, chocolate, vanilla, honey, candy, cocoa, dessert, alcoholic beverage, menthol, mint, wintergreen, herb or spice”, and a tobacco product as “a product containing or made or derived from tobacco or nicotine”. The prohibition binds “No person, retailer or manufacturer” and covers sales “in any retail establishment, online or through any other means to any consumer in the commonwealth”. It also makes each maker’s own packaging the evidence against it: a manufacturer’s public claim that a product has a characterizing flavour “shall constitute presumptive evidence that the tobacco product is a flavored tobacco product”. Both cans say Wintergreen.
Massachusetts does carry an FDA carve-out — and it is worth knowing why it rescues neither product, because “but ZYN is FDA-authorised” is the commonest objection here. The exemption requires a product that “has been approved by the United States Food and Drug Administration for the sale of or use as a tobacco cessation product or for other medical purposes and is marketed and sold or prescribed exclusively for the approved purpose”. ZYN fails the first limb because FDA says in both its orders that it has not approved anything, and the second because the modified-risk order forbids cessation positioning. Rogue fails the first limb outright.
California names the same flavours, in a statute enacted as SB 793 and approved on 28 August 2020, and has no FDA carve-out at all. Its prohibition binds retailers directly, with manufacturers reached by a rebuttable presumption triggered by their own labelling. Since AB 3218 the state has also built an “Unflavored Tobacco List”: per the Attorney General’s own rulemaking, “Products not appearing on the list will be subject to seizure”, and the Attorney General “may also seek civil penalties against distributors, wholesalers, and delivery sellers”. Neither product is on that list.
Rogue, to its credit, says all this itself. Its own FAQ lists twelve states plus Washington D.C. it cannot ship to — California and Massachusetts among them — and states that under San Francisco’s health code “flavored tobacco products including nicotine pouches may not be sold to any person or entity in San Francisco”. ZYN’s US site publishes no equivalent list. On candour about where you cannot buy it, Rogue wins the one axis it wins.
Wintergreen itself: a complete blank
I expected to find something on methyl salicylate, the compound that makes wintergreen taste of wintergreen. There is nothing. FDA’s ZYN review never names a single flavour ingredient — every identity is redacted — and methyl salicylate is not among the 42 constituents analysed. Both BfR reports and both RIVM reports return zero hits for it, and RIVM’s flavour screen covered eleven named compounds of which it was not one, so the only European per-product screen could not have detected it. Neither maker names it. For a flavour two states single out by name in statute, that is a remarkable hole in the record.
Who should pick which
If you are in the United States and care whether what you are buying is legal, the answer is ZYN — it is on the authorised list and Rogue is not, and that is a question of fact rather than preference. The same choice gets you a published pouch mass, published dimensions, a published nicotine source, a constituent analysis, and the only reduced-risk claim FDA has granted in this category.
If what you want is more material in your mouth per pouch, Rogue is measurably the bigger product — 1.8 times the mass at the same declared dose, four times the moisture, and a dose that arrives more slowly. A pouch with the same milligrams spread over nearly twice the mass is a lower concentration against your gum, which some people prefer and which the can does not tell you. You are also buying a product whose maker has not published where its nicotine comes from.
If you are in California or Massachusetts, neither. Both are flavoured, both are wintergreen, wintergreen is named in both statutes, and no FDA order changes that.
I will put scores on this page when I have used both. Until then the honest answer is that one of these products is documented and one is not, and that is a real difference even before anything reaches your lip.
Sources
- FDA, marketing granted order to Swedish Match USA Inc., 16 January 2025, STNs PM0000593.PD1–PM0000612.PD1 — Appendix A specifications for ZYN Wintergreen 6 mg.
- FDA, modified risk granted orders, 30 June 2026, STNs MR0000268.PD1–PD20 — the authorised claim, the five-year term and the cessation prohibition.
- FDA CTP, Technical Project Lead review of PMTAs, signed 14–16 January 2025 — HPHC findings, footnote 5, and the SM18-01 bioequivalence analysis.
- FDA, Nicotine pouch products authorized by the FDA, content current as of 21 August 2026.
- Platt SP et al., Dissolution and physical characterization of oral nicotine pouch products, Scientific Reports 16:4406, 6 January 2026, tables 1, 2 and 8. Funded by Altria Client Services LLC; all eight authors Altria employees at the time.
- M.G.L. c. 270 § 28 — sale of flavored tobacco products.
- California SB 793, chapter 34 of 2020, approved 28 August 2020, adding Health & Safety Code § 104559.5.
- California Department of Justice, Unflavored Tobacco List rulemaking, initial statement of reasons, 7 November 2025 — the AB 3218 amendments, the seizure remedy and the renumbered definitions.
- Rogue, Wintergreen product page and FAQ; Rogue’s help centre article “Who is Rogue Holdings, LLC”, 24 March 2025 (that host blocks automated requests, so it is cited without a link); Swisher brand page — manufacturer sources, read 15 October 2026.
- BfR, Health risk assessment of nicotine pouches, 023/2022; RIVM, briefrapport 2020-0152 — both checked for methyl salicylate and wintergreen, zero hits in each.
One figure I could not re-verify: a 2026 paper in Nicotine & Tobacco Research reports a methyl salicylate content for Rogue Wintergreen specifically, but its publisher serves no readable text, so I have not printed the number. The current text of California’s § 104559.5 is also unread — the state legislature’s own site blocks automated access, so the renumbering above is taken from the Attorney General’s rulemaking rather than the code. Last verified 15 October 2026.