A nicotine pouch is a measured dose of powder — mostly cellulose, with nicotine, a pH adjuster, a sweetener and flavourings — portioned by weight into a porous fleece bag, sealed, cut and packed into a plastic can. The powder is granulated, not grown. No tobacco leaf goes into it, and in most markets no law says how any of it must be done.
I set out to write this as a factory tour and ran into something more interesting: for a product category this large, the manufacturing record is remarkably thin. Nobody publishes the sealing step. Nobody names the company that makes the fleece. The best descriptions of what is inside a pouch come from scientists who cut the pouches open and weighed what fell out, and from one company spokesperson talking at an FDA advisory committee meeting.
If you are starting further back, nicotine pouches explained is the pillar guide. So this is what can actually be established from primary documents, and — just as usefully — what cannot. If you want the sister article on the older product, how Swedish snus is made, from leaf to can covers a process that is far better documented, for the simple reason that it has been running for two centuries.
What is actually in there
The clearest ingredient statement from a manufacturer comes from Modoral Brands, the Reynolds American subsidiary behind VELO, which publishes three separate lists. For VELO cans: “Nicotine derived from the tobacco plant, maltitol, modified cellulose, sodium carbonates, acesulfame K, and artificial flavor.” For VELO PLUS: “Non-tobacco derived synthetic nicotine, microcrystalline cellulose, sodium carbonates, sucralose, salt, water, and artificial flavor.” (Modoral Brands, Science and Manufacturing.)
Five functional parts, then: a bulking agent, nicotine, something to raise the pH, a sweetener, and flavour. Germany’s Federal Institute for Risk Assessment describes the same architecture in its own risk opinion: “Nicotine pouches are small pouches that contain nicotine-based powders. According to the manufacturer, nicotine salts are used, which are mixed with microcrystalline cellulose, various other salts (including sodium carbonate and hydrogen carbonate), citric acid and flavourings”, adding “These products do not contain tobacco.”
What no manufacturer’s list mentions is the bag itself. All three Modoral lists describe the contents and stop. That silence turns out to be the pattern.
The fleece: the one part nobody will name
The industry term for the pouch material is “fleece”, and it is used as a term of art rather than a specification. A Reynolds-commissioned toxicology study describes its own test products as “portioned by weight into the pouch using a porous material referred to as the “fleece.”” — quotation marks in the original, as though the authors did not expect the reader to know the word. (Funding: the study states it was commissioned by RAI Services Company and conducted at Labstat International; the authors were RAI Services employees at the time.)
The most precise public description I found is from the US Centers for Disease Control and Prevention, in a laboratory paper on nicotine content, explaining its own method: “For pouch products, the pouch material (organic cellulose compounds that create a non-woven fleece) was cut open and the nicotine binder/filler was weighed.” The authors declared no specific grant and no competing interests, and the paper carries the standard CDC disclaimer that its findings do not necessarily represent the agency’s official position.
A BfR-funded toxicology paper instead says viscose — “all wrapped in a pouch made of viscose fibers” — but that sentence cites two earlier papers rather than a measurement, so it tells you what the literature believes, not what was tested.
The company line is cellulose. At the FDA’s Tobacco Products Scientific Advisory Committee meeting in January 2026, Swedish Match’s US public affairs lead told the committee that “ZYN nicotine pouches are made with plant cellulose fibers and contain pharmaceutical-grade nicotine derived from real tobacco leaves, fillers to provide the appropriate mouthfeel, stabilizers to maintain the proper moisture and pH balance, and sweeteners and flavorings to ensure adult consumers find a product that encourages complete switching from other, more harmful tobacco products.” Two caveats on that one. It is a company statement, not an FDA finding. And the transcript’s own cover page says “This transcript has not been edited or corrected but appears as received from the commercial transcribing service.”
Beyond that, nothing. Searching FDA’s review documents, BfR’s opinion, Sweden’s snus regulation, four manufacturers’ own sites and the published sitemaps of the two best-known nonwoven producers turned up no named fleece supplier, no basis weight, no fibre specification and no bonding method. The only published measurement of the material itself is a microscopy study of pore size in emptied pouches, where mean void pore size ran from about 49 µm in on! and VELO to about 105 µm in Volt. I would treat the fleece as the least documented component of a product tens of millions of people put in their mouths.
The filler, measured
Here the record is much better, because someone has run the analysis. A January 2026 paper in Scientific Reports characterised seven mint and spearmint pouches physically and chemically, and states plainly: “Microcrystalline cellulose (MCC) is a major component of the crystalline structure of nicotine pouch fillers.” Its elemental analysis also found silicon in two of the seven, which the authors suggest “could be due to the presence of an ingredient such as Talc” — worth noting as a hypothesis and not more.
The funding here matters and the paper discloses it fully: “This research was funded by Altria Client Services LLC, an affiliate of Helix Innovations LLC, the manufacturer of” on! pouches, and several authors were Altria Client Services employees. Two of the seven products tested are the funder’s own or soon to be partly owned, and on! is the reference product the others are compared against. That does not make the measurements wrong — they are the only ones of their kind — but it is the sort of thing a reader should be told.
How general is cellulose? A 2026 paper in Nicotine & Tobacco Research, funded by the National Cancer Institute, surveyed 50 tobacco-free pouches from ten brands and reported that “Product packaging and content analysis on manufacturer websites revealed that most ONP brands contained cellulose-based filler material” — 80% of brands — against tobacco pouches, where “The primary filler material reported in all OTPs was tobacco.” That one sentence is the whole difference between a pouch and a portion of snus: swap leaf for wood pulp.
The nicotine: a salt, a resin, or neither
Three routes are in commercial use, and they are distinguishable.
The commonest is a nicotine salt. FDA’s own review of the ZYN modified-risk applications describes the applicant’s products as “the proposed MRTPs as 400 mg sealed pouches containing tobacco-derived nicotine in a salt formulation, along with flavor ingredients, an artificial sweetener, stabilizers, fillers, and pH” “adjusters, and without any whole, cut, or ground tobacco.” The NCI-funded survey goes further on the chemistry: “ZYN specifically disclosed the use of nicotine bitartrate dihydrate.”
The second route is an ion-exchange resin, the same technology as nicotine gum. The same survey: “ONP brands LUCY, NIC-S, and Rogue disclosed nicotine polacrilex, where nicotine is bound to an ion exchange resin and delivered via an aqueous extraction, similar to therapeutic nicotine gums.” Rogue says so itself: “Rogue Pouches contain quality nicotine bound to a polymer resin to create nicotine polacrilex.” and “Nicotine polacrilex is combined with flavors and other food grade ingredients resulting in a flavorful, quality pouch.”
The third is synthetic nicotine, and it is rarer than the marketing suggests. Because tobacco-derived nicotine is a single mirror image of the molecule and the cheap synthetic route gives a 50/50 mixture, you can test the claim. The NCI-funded team did: “Several ONP brands claimed to use tobacco-free nicotine; however, only BRIDGE and FRĒ pouches contained racemic nicotine” and “The remaining ONPs and all OTPs contained 100% S-nicotine.” They add the honest caveat: “While purified synthetic S-nicotine is possible, the cost is reportedly much higher than that of producing racemic synthetic nicotine.” So two of the brands in that sample were demonstrably synthetic and most of the rest, label notwithstanding, were not. If that distinction interests you, tobacco-free vs synthetic nicotine takes it apart properly.
One point of law, since people get it backwards: since 2022 the source makes no difference to whether FDA has jurisdiction. The statutory definition reaches “The term "tobacco product" means any product made or derived from tobacco, or containing nicotine from any source, that is intended for human consumption”. Synthetic nicotine is not a loophole.
The rest of the powder: pH, sweetness, cold
Raising the pH raises the share of nicotine in its free-base form, which is the form that crosses the mouth lining fastest. Nearly every maker does it, and says so: “Nearly all ONP manufacturers acknowledged using chemicals to modify pouch pH, most commonly sodium bicarbonate and sodium carbonate”. Measured pH of aqueous extracts in the Altria-funded work ran 7.6 to 9.0 across the seven; the CDC’s wider sample ran 7.64 to 9.49, corresponding to a free-base fraction from about 31% to about 97%. Our piece on snus pH and why it changes the nicotine hit explains the mechanism; it is the same chemistry here.
Sweeteners are declared on labels — acesulfame K, sucralose, sodium saccharin, maltitol — and we cover them separately in sweeteners in nicotine pouches explained.
Flavour is where the manufacturing gets least like food and most like fine chemistry. A Yale-led analysis funded by NIDA and FDA’s Center for Tobacco Products found one product whose entire flavour was a single synthetic coolant: “Chemical analysis of the ONPs demonstrated the presence of WS-3, an odourless menthol-derived synthetic cooling agent in Zyn Chill” at 234 µg per pouch, as the only major flavourant and the only observable peak besides nicotine. The same work reported “Average total pouch mass for the Zyn pouches was 405” ± 18 mg across twelve pouches — an independent check on the 400 mg specification below.
Moisture is the quiet variable. In the Altria-funded measurements, moisture content ran from 3.5% in ZYN to 37.2% in Volt, with water activity from 0.56 to 0.92. That is not a small spread; it is the difference between a dry powder and a damp one, and it shows up in how fast a pouch releases anything at all. Humectants is the companion piece.
What seven brands actually measure
All figures below are from the Altria-funded Scientific Reports characterisation of seven mint and spearmint products, 6–9.4 mg labelled strength. I have reproduced them rather than averaged them, because the variation is the finding.
| Product | Moisture content | Water activity | pH of extract | Filler particle size (d50) | Soluble in artificial saliva |
|---|---|---|---|---|---|
| ZYN | 3.52% | 0.56 | 7.62 | 353 µm | 78.3% |
| Dryft | 3.71% | 0.56 | 8.31 | 400 µm | — |
| on! | 4.48% | 0.57 | 8.62 | 314 µm | — |
| VELO | 6.62% | 0.56 | 8.98 | 495 µm | — |
| Rogue | 14.70% | 0.65 | 7.43 | 584 µm | 41.2% |
| Loop | 26.64% | 0.87 | 8.62 | 444 µm | not measurable |
| Volt | 37.18% | 0.92 | 8.47 | 431 µm | — |
A tenfold range in moisture and a factor of nearly two in filler particle size, across products sold side by side as the same kind of thing. The paper’s own conclusion is the right one: “The production of nicotine pouches involves various manufacturers utilizing different ingredients sourced from a variety of vendors.” and “Additionally, manufacturers employ various granulation processes and use different materials for the pouches.” This is a large part of why two 6 mg pouches from different brands feel completely different.
On the line: what is documented and what is not
For dimensions and packing, FDA’s granted modified-risk order for the twenty ZYN products is the best public specification of a nicotine pouch anywhere. Across all twenty: portion mass 0.40 g, 15 pouches per can, 6 g of product per can, portion 28 mm long, 14 mm wide, 4.5 mm thick, in a polypropylene can with a polypropylene lid, nicotine source recorded as tobacco for every one. The arithmetic closes: 15 × 0.40 g is exactly the 6 g stated. Across the wider market, pouch weights run from about 0.3 g to 0.6 g, with around 18 pouches per can on average — see pouch sizes by brand and how many pouches are in a can.
For the machinery, there is one primary description of pouch forming in the public record, and it is about snus. Swedish Match, describing its own portion snus: “The portions are measured and inserted into a cellulose fiber tube.” “They are then sealed and cut apart.” “The finished portion pouches are packed into a plastic can, before being sealed with a lid.” “Finally, the cans are weighed and labeled.” Four sentences, and that is the fullest account of the pouching step from any manufacturer in this category.
Skruf’s description of its Sävsjö line adds the step that distinguishes wet from dry portions — “Skillnaden mellan vitt och brunt snus är just duschningen och vätan.” (“The difference between white and brown snus is precisely the showering and the moisture.” My translation.) For a nicotine pouch there is no tobacco to moisten, but the same wet-or-dry choice at the end of the line is visible in that moisture table above.
What is not published, anywhere I could find: the granulation step; the mixing and wetting of the powder; how the fleece is fed and bonded; whether the seal is heat, ultrasonic or adhesive; the cut; the can-filling; the check-weigh. I looked in FDA’s two ZYN review documents, FDA’s advisory-committee background paper and transcript, Swedish Match’s and Skruf’s own production pages, six GN Tobacco factory pages, Modoral’s own manufacturing page, Rogue’s FAQ, BfR’s opinion and Sweden’s snus regulation. The granulation differences in the paper above were inferred from the particle-size distributions, not described by anyone.
FDA does hold the detail. Its 2026 review notes that the underlying premarket applications “contain sufficient information to characterize the product design and composition, manufacturing, product stability, and product analyses”, and that the earlier technical review covers the engineering and the results of FDA inspections of the manufacturing sites. That earlier document is not reachable: the links FDA itself publishes to it return a 404. And the manufacturer’s own manufacturing module, released under FDA’s disclosure, is a single page with every word redacted.
Does any law say how a pouch must be made?
I expected the answer to be no everywhere. It is no in three of the four places that matter, and a clear yes in the fourth.
Sweden regulates it. Since an amendment that took effect in 2024, the Swedish Food Act equates “snus, snusliknande produkter och tuggtobak” — snus, snus-like products and chewing tobacco — with food. The National Food Agency is careful about what that means: “Snus, snusliknande produkter och tuggtobak är inte livsmedel enligt definitionen av livsmedel i artikel 2 i” Regulation 178/2002, and they have been “jämställts med livsmedel som en lagteknisk lösning” — equated with food as a legislative-technical device — precisely so that parts of food law can reach them. The regulation that follows, LIVSFS 2024:2, binds pouch makers to drinking-water quality for process water, limits on lead, aflatoxins and benzo(a)pyrene, EU food-hygiene rules for premises, equipment and staff, a documented HACCP plan, traceability one step back and one step forward, and registration of every manufacturing plant with the municipality. It also, uniquely, reaches the bag: “Material och produkter som kommer i kontakt med snus, snusliknande produkter och tuggtobak ska uppfylla de krav” that apply to food-contact materials. A separate Swedish ordinance bans vitamins, caffeine, taurine and stimulants associated with energy in tobacco-free nicotine products, requires ingredients of high purity, and requires the product notification to include a description of the manufacturing process.
The EU does not. The Tobacco Products Directive covers products that “‘tobacco products’ means products that can be consumed and consist, even partly, of tobacco, whether genetically modified or not”, and its oral-tobacco ban reaches “‘tobacco for oral use’ means all tobacco products for oral use, except those intended to be inhaled or chewed, made wholly or partly of tobacco, in powder or in particulate form”. A tobacco-free pouch is neither. It is outside the Directive altogether — not banned by it, and not subject to its ingredient rules. (The ban itself, and Sweden’s exemption, are in why snus is banned across the EU but legal in Sweden.)
The UK has the power and has not used it. The Tobacco and Vapes Act 2026 lets the Secretary of State regulate “the substances that may be included in a relevant product or the amount of any given substance that may be included;” and “the flavour of relevant products;”, with nicotine products expressly in scope, and those powers have been live since Royal Assent in April 2026. As at today no regulation has been made under them touching the contents, flavour, materials or dimensions of a nicotine pouch. That is a title-based search of the statute book rather than an exhaustive index of enabling powers, so take it as strong rather than conclusive.
The US regulates the sale, not the recipe. A pouch is a tobacco product whatever the nicotine source, and is excluded from the definition of food, so the food-additive regime does not apply to a flavouring used in one. Congress did instruct FDA to write manufacturing-practice rules for tobacco products — the statute requires regulations “requiring that the methods used in, and the facilities and controls used for, the manufacture, preproduction design validation” and so on to conform to good manufacturing practice. FDA has not written them: the tobacco subchapter of 21 CFR contains eight parts, none of them a manufacturing-practice or product-standard part. The only US rule that touches the pouch itself is a label: “WARNING: This product contains nicotine. Nicotine is an addictive chemical.”, on at least 30% of each principal display panel. The CDC laboratory paper puts it in one sentence: “However, there are no FDA regulations defining standards for the ingredients used in TFN products.”
What nobody has published
- Who makes the fleece, and what it is specified as. No supplier, basis weight, fibre type or bonding method appears in any primary document I could reach.
- How the seal is made. Heat, ultrasound and adhesive are all plausible and none is documented.
- The granulation recipe. Its existence is inferred from particle-size data; no description exists.
- Brand-by-brand ingredient tables. The one survey that assembled them put them in a supplementary file that is not retrievable.
- Any comparison of nicotine pouch lines across factories. Nobody has measured whether the same brand made in two plants comes out the same.
FAQ
Is there tobacco in a nicotine pouch? Not leaf. BfR states flatly that these products do not contain tobacco, and FDA’s description of the ZYN products says they contain no whole, cut or ground tobacco. The nicotine in most of them is still extracted from tobacco plants.
What is the bag made of? Cellulose, on the evidence: CDC describes a non-woven fleece of organic cellulose compounds, and the maker of ZYN told FDA’s advisory committee it uses plant cellulose fibres. One regulator-funded paper says viscose, citing others. No manufacturer specifies it.
Why do some pouches feel wet and others bone dry? Because they are. Measured moisture content across seven products ran from 3.5% to 37.2%. That is a formulation choice, not a storage accident.
Is a pouch made like snus? The packing end looks similar — portion, seal, cut, can, weigh, label. The front end is completely different: snus starts with ground tobacco that is salted, watered and heat-treated, which Swedish Match calls pasteurisation. A pouch starts with a granulated powder. Where law has forced the two formats together, the result is odd: Norwegian-market pouches have tobacco added back in so they qualify as snus.
Does anyone inspect these factories? In Sweden, yes: municipal food-control authorities, under food-hygiene rules, with every plant registered. In the US, FDA says it has inspected manufacturing sites, but the review containing the findings is not publicly reachable. Elsewhere, there is no pouch-specific manufacturing regime to inspect against.
Are pouches made in the same factories as snus? Sometimes. Swedish Match’s Kungälv plant lists snus and nicotine pouches; GN Tobacco’s Enköping plant makes both. We go through the corporate map in who actually makes nicotine pouches.
Sources
- FDA, Center for Tobacco Products, Modified Risk Granted Orders letter to Swedish Match USA, Inc., 30 June 2026 (Appendix A product specifications; nicotine source).
- FDA, Center for Tobacco Products, Technical Project Lead review of the ZYN modified-risk applications, July 2026.
- FDA, Center for Tobacco Products, January 2026 TPSAC meeting background material on the ZYN MRTPAs.
- FDA, Center for Tobacco Products, TPSAC meeting transcript, 22 January 2026 (uncorrected transcript, as its cover states).
- Centers for Disease Control and Prevention, Total and unprotonated (freebase) nicotine content in new types of oral ‘tobacco-free’ nicotine products, Tobacco Control, PMC12075619. No specific grant declared; no competing interests declared.
- Dissolution and physical characterization of oral nicotine pouch products, Scientific Reports, 6 January 2026, PMC12864968. Funded by Altria Client Services LLC, an affiliate of the manufacturer of on!; several authors were Altria Client Services employees.
- Comparison of Nicotine and Selected Flavoring Contents Between Tobacco-Free and Tobacco-Containing Oral Pouches, Nicotine & Tobacco Research, PMC12824957. Funded by the National Cancer Institute (U54 CA228110, P01 CA200512); one author discloses industry and regulator consultancies.
- Synthetic cooling agent in oral nicotine pouch products marketed as “flavor-ban approved”, Tobacco Control, PMC10753027. Funded by NIDA and FDA’s Center for Tobacco Products; disclosures in the paper.
- In vitro toxicological evaluation of pouched portioned oral nicotine products, Frontiers in Toxicology, PMC11634830. Commissioned by RAI Services Company; authors were RAI Services employees.
- Oral nicotine pouches with an aftertaste? Part 2, Archives of Toxicology, PMC10404181. BfR intramural funding; no conflict declared.
- Bundesinstitut für Risikobewertung, Health risk assessment of nicotine pouches, updated BfR Opinion no. 023/2022, 7 October 2022. The German text is the legally binding version.
- Livsmedelsverket, LIVSFS 2024:2, in force 1 April 2024; and Kontrollwiki article 887 (guidance, non-binding, last updated 13 August 2026).
- Livsmedelslag (2006:804) 3 §, as amended by Lag (2024:23), and Förordning (2022:1263) om tobaksfria nikotinprodukter, via Riksdagen.
- Directive 2014/40/EU, Articles 2(4), 2(8) and 17, consolidated OJ text.
- Tobacco and Vapes Act 2026 (c. 18), sections 94–96 and 117, legislation.gov.uk.
- 21 U.S.C. § 321(f), (s) and (rr) and § 387f(e), via govinfo; 21 CFR 1143.3 via the eCFR versioner API, 1 November 2026.
- Modoral Brands, Science and Manufacturing; Rogue, FAQs; Swedish Match, Snus production; Skruf, Produktionen.
Last verified 11 November 2026. Translations from Swedish are mine.
