Pouch weight vs nicotine content: the maths
Why a pouch's nicotine figure and its weight are independent numbers, how milligrams per gram is derived, and why the same product is lawful in Finland and unlawful in Denmark depending on which number the law reads.
A pouch’s nicotine figure and its weight are two independent numbers, and dividing one by the other gives a third — milligrams per gram — which is what several countries actually regulate. A 6 mg ZYN in a 0.40 g pouch is 15 mg/g. A 17 mg VELO in a 0.70 g pouch is 24 mg/g. The smaller pouch is weaker per pouch and stronger per gram, and which of those two sentences is true depends only on which number you read.
This article is the arithmetic. If you want the units explained from scratch, mg per pouch versus mg per gram does that; if you want the legal ceilings country by country, strength caps by country covers those. What follows is why the two numbers come apart, what sits in the pouch besides nicotine, and why neither figure tells you your dose.
The two numbers, and the division between them
Start with the only products whose specifications a regulator has published in full. FDA’s technical review of the twenty ZYN products gives, for each one, “Nicotine Concentration: 3 milligrams (mg)/pouch” or “6mg/pouch”, “Portion Count: 15 pouches”, “Portion Mass: 0.40 g” and the dimensions “Portion Length: 28 millimeters (mm)”, “Portion Width: 14 mm”, “Portion Thickness: 4.5 mm”. Both strengths sit in the same 0.40 g pouch. The arithmetic is mine: 3 ÷ 0.40 = 7.5 mg/g and 6 ÷ 0.40 = 15.0 mg/g. Doubling the label doubles the concentration because nothing else moved.
The on! PLUS review gives the same fields: “Each container contains 14 pouches,” “They have a portion weight target of 0.714 g,” at 6 mg and 9 mg per pouch. My arithmetic: 8.40 and 12.61 mg/g. And an oddity worth noting because it is in FDA’s own public file rather than anywhere disreputable — 14 pouches at 0.714 g is 9.996 g, against a declared product quantity of 9 grams. The manufacturer’s three published numbers do not quite close, by about 11%. I would not read that as an error by anyone; I would read it as a reminder that declared weights are targets.
Now take ZYN ULTRA, which FDA’s authorised list shows at 9 mg and 11 mg in a 0.8 g pouch. My arithmetic: 11.25 and 13.75 mg/g. So “ULTRA” at 11 mg per pouch is less concentrated than standard ZYN at 6 mg. It delivers more nicotine because there is more pouch, not because the pouch is stronger. That single comparison is the whole article in two lines.
Where brands publish both halves
Most do not. VELO’s Swedish site is the exception and prints four fields per product — milligrams per gram, milligrams per pouch, pouch count and can weight. Bright Spearmint 14 mg lists “Nikotin (mg/g): 20 mg”, “Nikotin (mg/prilla): 14 mg”, “Antal påsar: 20”, “Vikt (g/dosa): 14”. Fourteen grams over twenty pouches is 0.70 g each, and 14 ÷ 0.70 = 20 mg/g, which is exactly what VELO prints. Across much of that range the two figures reconcile at 0.70 g precisely.
Across the rest they do not. Several variants pair 8 mg per pouch with 8 mg/g, which implies a 1.00 g pouch; others pair figures implying 0.50 g. Same brand, same site, same day, and the printed pair is internally inconsistent for roughly a third of the range. I am not going to guess which number is wrong. What it establishes is that the two figures are published independently and are not always checked against each other.
Nordic Spirit is the only brand I found that prints both bases side by side and names the problem while doing it: “The strength of a nicotine pouch can be shown in 2 ways, either as the milligrams (mgs) of nicotine per pouch or as the mgs of nicotine per gram.” Its tiers run “Mellow — Mini pouch size: 4mg of nicotine per pouch / 9mg of nicotine per gram”, “Regular — Standard pouch size: 6mg of nicotine per pouch / 9mg of nicotine per gram”, up to “Max — Standard pouch size: 17mg per pouch / 24mg of nicotine per gram.” Note what that first pair does: the Mellow mini and the Regular standard are identical at 9 mg/g and differ by half in nicotine per pouch. Under a per-gram rule they are the same product. Under a per-pouch rule they are not remotely the same product.
LOOP publishes can weight, nicotine per pouch and nicotine per can: “Pouches: 20 / Weight: 12,5 g / Nicotine/pouch: 8,9 mg / Nicotine/can: 177,00 mg”. Its Mini Hyper range keeps 20 pouches and drops the can to 9 g, at 10,5 mg per pouch. My arithmetic: 12.5 ÷ 20 = 0.625 g, so the Strong is 14.24 mg/g; 9 ÷ 20 = 0.45 g, so the Mini is 23.33 mg/g and carries more nicotine per pouch than the Strong does. “Mini” describes the pouch, not the dose.
And Oden’s publishes the cleanest demonstration of all, because it holds concentration constant and varies the pouch. Siberia All White is listed at 33 mg/g in five formats: regular 15 g with “Appr. 15 portions/can”, slim 15 g with ~20, super slim 13 g with ~20, ultra slim 11 g with ~22, mini 10 g with ~16. My arithmetic on those approximate counts gives pouch weights from roughly 1.00 g down to 0.50 g — so about 33 mg of nicotine per pouch at the top and about 16.5 mg at the bottom, a twofold spread in dose across a product line whose printed strength never changes. The counts are prefixed “Appr.” and the derived weights are mine, so treat them as indicative.
What is in the pouch, since it is almost all not nicotine
FDA’s reviews describe the formula and withhold the substances. ZYN’s contains “tobacco-derived nicotine, flavor ingredients, an artificial sweetener, stabilizers, fillers, and pH adjusters,” and the identities of the fillers, the sweetener, the humectants and the pouch fleece are redacted as confidential throughout. No percentages appear in either FDA review.
A published patent does give a full breakdown summing to 100. For a 0.60 g pouch at 3 wt% nicotine — “The weight of nicotine is 3 wt % at the most or 18 mg per pouch” — it lists microcellulose at 53.4%, potato fibres 14.2%, xylitol 10.7%, sodium bicarbonate 10.7%, xanthan gum 3.6%, pure nicotine 2.85%, nicotine salt 4.27% and essential oil 0.36%. Read that against the per-pouch figure: the pH adjuster alone is nearly four times the mass of the nicotine base. It is a patent example rather than a measurement of a product on sale, and the same document quotes a 350 mg pouch elsewhere, so I would not treat the numbers as a product specification.
The ingredient order on a real can corroborates the shape of it, and does so under legal compulsion: Swedish law requires the list “i fallande viktordning” — descending order by weight. VELO Bright Peppermint reads “Fyllnadsmedel (E460), vatten, smakförstärkare (koksalt), xylitol (E967), nikotin, förtjockningsmedel (E401), aromer, sötningsmedel (E955), surhetsreglerande medel (E500).” Cellulose first, nicotine fifth, behind water, salt and xylitol. Germany’s BfR, weighing the category rather than one brand, found pouches “wiesen ein Gewicht von 0,38 bis 1,1 g/Beutel auf” with nicotine of “3,04 – 17,90 mg/Portionsbeutel” — so by mass, nicotine is in the low single-digit percentage of what you are holding. What is inside a nicotine pouch besides nicotine goes through the rest.
Content is not dose, and a legislature says so
This is the part that most changes how you should read either number, and the best statement of it comes from the Finnish government’s own bill — the one that set a nicotine content cap. On the question of whether that cap determines how much nicotine a user gets, the bill says: “nikotiinipussin nikotiinipitoisuudesta ei jatkossakaan olisi selvästi pääteltävissä, paljonko tuotteesta imeytyy nikotiinia, vaan nikotiini voi imeytyä kahdesta yhtä paljon nikotiinia sisältävästä tuotteesta eri tavoin riippuen siitä, paljonko niissä on nikotiinin imeytymistä lisääviä lisäaineita.” In English, and this translation is mine: the nicotine content of a pouch will still not clearly show how much nicotine is absorbed from it, because absorption can differ between two products containing the same amount of nicotine, depending on how much absorption-enhancing additive each contains. A government, in the instrument imposing a content limit, writing that its own limit does not determine dose.
The measurements agree. FDA’s reviewers use “nicotine extraction” as a quantity distinct from nicotine content throughout the ZYN file, and they were sceptical of the applicant’s own method for measuring release: “The chemistry consult concluded that it is unclear whether the nicotine dissolution method used by the applicant can precisely measure nicotine release from the new products,” and the behavioural review “did not rely on the applicant’s nicotine dissolution study to determine nicotine exposure.” The same file records product characterisation data in which “nicotine quantity in half of the samples of the new products was lower than the target quantity of nicotine (approximately 4.5 mg rather than the 6.0 mg target specification).”
How much actually leaves the pouch has been measured, by a laboratory that discloses its funding fully. An Altria-funded study of seven named products reported the percentage of nicotine released from content as 98% for on!, 96% for Zyn, 90% for Dryft, 89% for Volt, 88% for Velo, 72% for Rogue and 38% for Loop — a range wide enough that two pouches of identical labelled content can differ by more than twofold in what comes out. The disclosure matters and I am printing it: the study “was funded by Altria Client Services LLC, an affiliate of Helix Innovations LLC, the manufacturer of on! nicotine pouches,” and the same statement records a pending Altria ownership interest in the owner of the Loop brand — which is the worst performer in the paper.
Independent in-vivo work from Germany’s federal risk assessment institute found the same variability in people. Fifteen smokers used pouches declared at 6, 20 and 30 mg; the paper reports that “Extraction rate of nicotine differed between pouches,” that a 30 mg pouch produced higher nicotine uptake than a cigarette, and concludes that “A limit of nicotine content is warranted. The nicotine release rate varies across products and needs to be known to estimate the nicotine delivery.” That study declares no commercial relationships and was funded by the institute itself.
And the mechanism behind the variation is not nicotine content at all. Across 37 pouch brands, CDC’s laboratory found products varying in “pouch content mass, moisture content (1.12%‒47.2%), alkalinity (pH 6.86‒10.1), and % free nicotine (7.7%‒99.2%),” with “Total nicotine content ranged from 1.29 to 6.11 mg/pouch, whereas free nicotine ranged from 0.166 to 6.07 mg/pouch.” The free fraction — the part most readily absorbed — spans from under a tenth of the content to essentially all of it. A later CDC study of 70 tobacco-free products reported both bases in one sentence: total nicotine “0.822 to 31.5 mg/g,” pouch levels “1.41-8.11 mg/product,” freebase “2.15-16.8 mg/g,” with pH from 4.68 to 9.49. An industry-funded permeation study puts it bluntly: “While nicotine concentration did not affect the apparent permeability coefficient (P app) within the tested range, higher pH resulted in a higher P app value.” Both CDC studies declare no competing interests; the permeation paper carries no funding or conflict statement in its indexed record, and all four authors are employed by Altria.
Why the regulators chose different denominators
Finland’s bill explains its own figure completely, and the explanation is the reason the unit is per gram. The cap was set “16,6 milligrammaan nikotiinia grammassa tuotetta. Näin CLP-asetuksen mukainen akuutin myrkyllisyyden raja (16,7 milligrammaa grammassa tuotetta) ei ylittyisi” — one tenth of a milligram below the acute-toxicity classification threshold in EU chemicals law. Chemicals law classifies by concentration, so the denominator was handed to Finland rather than chosen by it.
Finland also explains what the gram is a gram of, which nobody else does: “Tuotteen painoon laskettaisiin mukaan myös pussin paino, sillä nikotiiniseoksesta imeytyy nikotiinia pussiin, ja jos pussin painoa ei laskettaisi mukaan tuotteen painoon, sääntelyä voitaisiin kiertää lisäämällä pussimateriaaliin nikotiinia.” The fleece counts, because nicotine migrates into it and excluding it would let the rule be evaded by dosing the pouch material.
And Finland is the only jurisdiction I have found that separates the two jobs a weight rule can do. Its minimum of 0.5 g exists so there would not be “hyvin pieniä ja huomaamattomia nikotiinipusseja, joita esimerkiksi pikkulapset voisivat helpommin saada nieltyä” — very small, inconspicuous pouches that small children could more easily swallow. Its maximum of 1 g exists purely to convert the concentration cap into a per-pouch cap, and the bill does the arithmetic itself: a 1 g pouch may hold at most 16.6 mg, and a 0.7 g pouch — “painoltaan melko tyypillinen”, fairly typical by weight — at most “hieman yli 11,6 milligrammaa”.
Poland, by contrast, set 20 mg/g with no weight rule at all, and its notification to the Commission gives no derivation of the figure and never mentions pouch weight. Denmark set 9.0 mg per pouch and its regulation — about 1,100 characters over three chapters — contains no derivation either. Austria’s notified draft takes Finland’s exact 16.6 mg/g and attaches it to a 1.6 g ceiling rather than 1.0 g, which on my arithmetic would permit up to 26.56 mg in a pouch; its notification summary meanwhile describes the rule as “16.6 milligrams of nicotine per 1.6 grams of a consumption unit,” while the draft text says “a maximum of 16.6 milligrams of nicotine per gram.” The two readings differ by about 60% in the per-pouch outcome. The unit confusion this article is about has reached the EU’s own notification register. Austria’s draft is not enacted and I am not calling it law.
The same product, legal and illegal, on the same facts
The four live tests are: Finland, at most 16.6 mg/g and a dose unit of 0.5–1.0 g; Poland, at most 20 mg/g with no weight rule; Denmark, at most 9.0 mg per pouch; Czechia, at most 12 mg per dose, at most 240 mg per unit pack, at least 20 doses. Inputs below are sourced above; the mg/g column and the readings are my arithmetic.
| Product | Per pouch | Pouch weight | mg/g | Where it passes |
|---|---|---|---|---|
| ZYN Cool Mint 6 mg | 6 mg | 0.40 g (FDA) | 15.0 | Poland and Denmark. Fails Finland — not on nicotine, but because 0.40 g is below the 0.5 g floor. Fails Czechia’s 20-dose minimum at 15 pouches |
| ZYN ULTRA 11 mg | 11 mg | 0.8 g | 13.75 | Finland on both limbs. Fails Denmark (11 > 9) |
| on! PLUS 9 mg | 9 mg | 0.714 g (FDA) | 12.61 | Finland and Poland. Fails Czechia’s 20-dose minimum at 14 pouches |
| VELO Bright Spearmint 14 mg | 14 mg | 0.70 g | 20.0 (VELO’s own figure) | Exactly at Poland’s ceiling. Fails Finland, Denmark and Czechia |
| LOOP Strong | 8.9 mg | 0.625 g | 14.24 | All four |
| LOOP Mini Hyper | 10.5 mg | 0.45 g | 23.33 | None. Fails Finland twice — on concentration and below the weight floor |
| Siberia -80 ULTRA Slim | ~16.5 mg (derived) | ~0.50 g (derived) | 33 (maker’s own) | None. Its per-pouch content is almost exactly Finland’s per-gram number |
| Nordic Spirit Regular, standard vs mini | 6 mg vs 3 mg | not published | 9 for both (maker’s own) | Identical under Finland and Poland; a twofold difference in dose and no difference at all in the regulated quantity |
The cleanest line in that table is the first two rows together: under Finland’s rule a 6 mg ZYN is unlawful and an 11 mg ZYN ULTRA is lawful, and under Denmark’s rule it is the other way round. Nothing about either product changed except which number the law reads.
There is a commercial consequence, documented by the manufacturer. VELO’s Danish site explains that “Det maksimale nikotinniveau i nikotinposer må ikke være højere end 9mg per pose, og produkter, som førhen var over 9mg er reduceret til 9mg,” and that for some products this “kan være med til at påvirke oplevelsen” — it may affect the experience. A per-pouch cap forced a reformulation down to the cap. A per-gram cap would have allowed the dose to stay and the pouch to shrink instead.
What the pack has to tell you
Only one jurisdiction requires both halves of the fraction. Finland’s new labelling section requires “maininta tuotteen nikotiinipitoisuudesta ja annostuksesta” — concentration and dosage — and the bill’s commentary on that section spells out what it means: the pack must state how many milligrams of nicotine there are per gram of product, and additionally the dosage, that is, how much nicotine one pouch contains. The statutory words are concentration and dosage; the mg/g reading comes from the commentary, and that distinction is worth keeping.
Austria’s notified draft would go further still and put the pouch weight itself on the pack: “the weight of each individual consumption unit” and “the indication of the nicotine content in milligrams per gram of a consumption unit.” That would let a consumer compute either unit from either. It is a draft.
Everyone else gives you one half. Sweden requires “uppgift om innehåll av nikotin i produkten och fördelning per dos” — content and its distribution per dose — and requires neither milligrams per gram nor the weight, so a Swedish pack can carry 8 mg per pouch with no way to derive a concentration. That VELO volunteers mg/g anyway is a choice, not compliance. Czechia requires “obsah nikotinu v mg na jednu dávku nikotinového sáčku” and the number of doses, from which the pack total follows, but not mg/g and not the weight. Denmark requires “Nikotinindhold pr. enhed. For nikotinposer er det pr. pose”. And in the United States, the quantity statement may be given “in terms of weight, measure, or numerical count” — a disjunction, so printing grams discharges the duty, and that provision requires no nicotine figure at all.
FAQ
Which number should I compare products on? Milligrams per pouch, if you are deciding what to buy, because that is closer to a dose than a concentration is. Milligrams per gram if you are checking what is legal where you are.
Does a mini pouch mean less nicotine? Not reliably. LOOP’s mini carries more nicotine per pouch than its Strong. VELO’s minis keep 20 pouches and shrink the can from 14 g to as little as 8.4 g, so the pouch gets smaller while the printed strength may not change at all.
Can I work out mg/g myself? Only if you have the pouch weight, and almost no brand publishes it. Can weight divided by pouch count is the usual route, and it worked on VELO’s and LOOP’s own figures here — but on a third of VELO’s Swedish range the result disagreed with VELO’s own printed mg/g, so treat your answer as approximate.
Is a 20 mg/g pouch twice as strong as a 10 mg/g one? Per gram, yes. Per pouch, only if the pouches weigh the same. And in terms of what reaches you, not necessarily at all: release ranged from 38% to 98% of content across seven products, and the readily absorbed free fraction ranged from 7.7% to 99.2% across 37.
Why is there no accuracy requirement on the printed figure? As far as I can establish there is not one in the EU, UK, US or Sweden — unlike cigarettes, where the EU imposes an accuracy standard. FDA accepted samples measuring about 4.5 mg against a 6.0 mg target, and Italy’s national health institute reported “substantial discrepancies between declared and measured nicotine contents, largely attributable to product variability rather than analytical limitations.”
Is a pouch mostly nicotine? No, and a peer-reviewed review published this year says otherwise — that pouches are “comprised primarily of nicotine” — which every compositional source above contradicts. On a patent’s own breakdown nicotine base is 2.85% by weight, and on a Swedish ingredient list required to run in descending weight order, nicotine comes fifth.
Sources
- FDA, Technical Project Lead review of the ZYN PMTAs, PM0000593–PM0000612, signed 14 January 2025 — portion mass, count, dimensions and nicotine per pouch in Appendix A, Table 5.
- FDA, Technical Project Lead review of the Helix Innovations PMTAs, on! PLUS, discipline reviews dated 12 December 2025.
- FDA, Nicotine Pouch Products Authorized by FDA — content current as of 21 August 2026.
- Finland: Laki tupakkalain muuttamisesta 251/2025, 25 a § and 39 a §, and the government bill as notified to the Commission, notification 2024/0643/FI.
- Austria: notified draft and notification form, notification 2025/0793/AT, received 29 December 2025. Not enacted.
- Poland: notification 2025/0055/PL; the cap is in Dz. U. 2025 poz. 799, art. 11hb.
- Czechia: vyhláška č. 141/2023 Sb., §§ 2(4)–(5) and 4(4).
- Sweden: Förordning (2022:1263) § 11.
- Denmark: Bekendtgørelse nr. 251 af 4. marts 2025 § 2; the 9 mg cap is in Bekendtgørelse nr. 249 af 4. marts 2025 § 2.
- 21 U.S.C. § 387c(a)(2)(B), via Cornell LII.
- Platt SP et al., “Dissolution and physical characterization of oral nicotine pouch products,” Scientific Reports 2026;16(1):4406, PMID 41495155 — funded by Altria Client Services LLC, an affiliate of the manufacturer of on!, with a disclosed pending ownership interest in the owner of Loop.
- Mallock-Ohnesorg N et al., “Small pouches, but high nicotine doses,” Frontiers in Pharmacology 2024;15:1392027, PMID 38841367 — funded by the German Federal Institute for Risk Assessment; no commercial relationships declared.
- Stanfill S et al., “Characterization of Total and Unprotonated (Free) Nicotine Content of Nicotine Pouch Products,” Nicotine & Tobacco Research 2021;23(9):1590-1596, PMID 34233354 — CDC; funding recorded as CDC HHS, no conflict statement in the indexed record.
- Tran H et al., “Total and unprotonated (freebase) nicotine content in new types of oral ‘tobacco-free’ nicotine products,” Tobacco Control 2026;35(2):161-167, PMID 39542719 — intramural CDC; “Competing interests: None declared.”
- Li XS et al., “Evaluation of Factors Impacting Nicotine Permeation in Oral Nicotine Pouch Products,” ACS Omega 2025;10(39):45644-45655, PMID 41078756 — no funding or conflict statement in the indexed record; all four authors employed by Altria Client Services LLC.
- Majorani C et al., “GC-MS determination of nicotine in heterogeneous tobacco-free products,” Analytical Methods 2026, PMID 42827026 — Istituto Superiore di Sanità; no funding or conflict statement in the indexed record.
- Besaratinia A, “Oral nicotine pouches,” Public Health 2026;258:106412, PMID 42431029 — cited only for the “comprised primarily of nicotine” claim that the compositional sources contradict; author declares no conflicts.
- US 11,801,219 B2, “Pouch product suitable for application in an oral cavity,” published 31 October 2023, Table 1 and claim 1; and US 12,295,412 B2 (Altria Client Services), published 13 May 2025, on component weight ranges.
- Bundesinstitut für Risikobewertung, Stellungnahme 027/2021, pouch weights and measured nicotine.
- Manufacturer figures as cited: VELO Sweden, VELO Denmark, LOOP, Nordic Spirit, Oden’s (which is both a manufacturer site and a direct-sale shop).
Last verified 20 October 2026. Every mg/g figure attributed to a regulator or a manufacturer above is printed by that source; every mg/g figure derived by division is labelled as my arithmetic. Pouch weights for Siberia and Nordic Spirit are derived rather than published, and the Siberia counts are prefixed “Appr.” by the maker. Latvia’s pack-mass labelling requirement and the ZYN ULTRA per-pouch wording rest on earlier research rather than on documents re-read for this article.