Six wintergreen nicotine pouches are authorised for legal sale in the United States, and two of them — ZYN Wintergreen 3 mg and 6 mg — are the only wintergreen pouches in the world cleared to carry an FDA-reviewed reduced-risk claim. Nothing on this site has been tasted, so this is not a flavour ranking. It is a ranking on four things you can check in a public document: whether the product may lawfully be sold, what regulator has reviewed it, what is published about what is inside it, and where it is banned by name.
I want to be exact about what this page is, because “best wintergreen pouches” normally means somebody’s palate and this is not that. I have not used any of these products. There are no scores here and there will not be any until there are scored reviews to put in them. What there is instead is a set of documents — an FDA authorisation list dated 30 October 2026, two state statutes that name wintergreen in their own text, a laboratory measurement of methyl salicylate in named pouches, and the makers’ own websites — and a ranking those documents can actually support. It sits under the master ranking and alongside the best mint pouches, which was built the same way. The flavour chemistry it turns on is methyl salicylate, and the only comparable question about an ingredient nobody checks is what ‘sun-cured’ means on a snus can.
That turns out to be more useful than it sounds. Wintergreen is the one flavour category where the paperwork is unusually decisive: it is written into two state flavour bans by name, it has only two authorised suppliers in the US, and the one product anyone has chemically measured may not lawfully be sold.
What “best” can honestly mean before anyone has tasted anything
One: whether the product may lawfully be sold in the United States. FDA maintains a list of authorised nicotine pouch products and is blunt about its status. As of the page’s own currency date of 30 October 2026, it reads: “There are 67 nicotine pouch products authorized by the FDA. These are the only nicotine pouch products that may be lawfully sold in the United States.” Six of those 67 are wintergreen. Everything else on an American shelf with a wintergreen label is outside that set. That is not a taste judgement, it is a fact about the product’s legal position, and it is the single most consequential thing about any pouch you can buy in the US.
Two: what a regulator has actually reviewed and concluded. Authorisation under a premarket tobacco product application and a modified risk granted order are different things with different evidence behind them. Two wintergreen products have both. Four have only the first.
Three: what is published about what is in it. This splits the field in a way I did not expect. For ZYN Wintergreen, FDA’s own 48-page decision summary publishes the pouch mass, the dimensions, the can size, the portion count and the nicotine source. For every other wintergreen pouch, the best available document is a product page.
Four: where it is prohibited by name. Wintergreen is one of the few flavour words written into statute. It appears verbatim in both the Massachusetts and the California characterising-flavour definitions, which means that unlike most flavour categories there is no interpretive question about whether a wintergreen pouch is caught.
The ranking
Two of these positions are ties, and the ties are real rather than a dodge: the documents behind the paired products are the same documents.
1= ZYN Wintergreen 3 mg and ZYN Wintergreen 6 mg. The only wintergreen pouches with both a marketing authorisation and a modified risk granted order, and the only ones whose physical specification is published by a regulator rather than by a marketing department. Both have their own first looks on this site: ZYN Wintergreen 3 mg and ZYN Wintergreen 6 mg.
3= ZYN ULTRA Wintergreen 9 mg and ZYN ULTRA Wintergreen Chill 9 mg. Authorised on 21 August 2026 under FDA’s nicotine pouch pilot programme; no reduced-risk order, and the Chill variant’s cooling addition is not documented anywhere I could reach.
5= on! PLUS Wintergreen 6 mg and on! PLUS Wintergreen 9 mg. Authorised — they are on the list — but I could not find FDA’s announcement for them, and Helix Innovations publishes nothing retrievable about them. Lower only because less is documented, not because anything negative is.
Unranked: everything else, including the only wintergreen pouch anyone has measured. Rogue sells Wintergreen at 3 mg and 6 mg and Rogue Max Wintergreen at 9, 12 and 15 mg from its own site. None of them is on FDA’s list. Nor are LUCY, BRIDGE, White Fox, NIC-S, FRĒ or Juice Head, whose wintergreen products appear in the laboratory literature. I am not ranking a product above an authorised one on the strength of a chemistry paper when FDA’s own sentence says the 67 are the only ones that may lawfully be sold. There is a first look at Rogue Wintergreen 6 mg on this site, and a side-by-side with ZYN; both say the same thing about its legal position.
And one correction to a thing you will see asserted: Velo has no wintergreen pouch at all. All 24 Velo products authorised on 30 October 2026 are Velo Mini Pouch lines, and “wintergreen” does not appear on that announcement or on velo.com. Any “best wintergreen” list with a Velo entry has invented it.
The authorised wintergreen set, in full
These are the six, with the product strings exactly as FDA writes them.
| Product, as FDA lists it | Manufacturer | Authorised | Reduced-risk order |
|---|---|---|---|
| ZYN Wintergreen 3 mg | Swedish Match USA, Inc. | 16 January 2025 (PMTA) | Yes — 30 June 2026 |
| ZYN Wintergreen 6 mg | Swedish Match USA, Inc. | 16 January 2025 (PMTA) | Yes — 30 June 2026 |
| ZYN ULTRA Wintergreen 9 mg | Swedish Match USA, Inc. | 21 August 2026 (PMTA) | No |
| ZYN ULTRA Wintergreen Chill 9 mg | Swedish Match USA, Inc. | 21 August 2026 (PMTA) | No |
| on! PLUS nicotine pouches 6 mg Wintergreen | Helix Innovations LLC | On the list; announcement not located | No |
| on! PLUS nicotine pouches 9 mg Wintergreen | Helix Innovations LLC | On the list; announcement not located | No |
For context on how small that set is: the whole authorised list is 67 products from three companies — Helix Innovations with 12, Modoral Brands with 24 and Swedish Match USA with 31 — across strengths of 2, 3, 4, 6, 9 and 11 mg. Wintergreen accounts for six of the 67, and the strongest authorised wintergreen in the country is 9 mg.
FDA attaches a standing caveat to the whole list, and it belongs on this page too: “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.” All tobacco products are harmful and potentially addictive. Those who do not use tobacco products shouldn’t start.”
The claim only two of them can make, and exactly what it says
On 30 June 2026 FDA issued modified risk granted orders covering 20 ZYN products at two strengths each, ZYN Wintergreen among them. The authorised claim is a closed list of named conditions, and the wording matters: “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 claim is not. It is not a finding that the product is safe. It is not an endorsement of use by anyone who does not already smoke. And it is conditional on substitution for cigarettes — the comparator is written into the sentence. The orders also run for five years and carry postmarket surveillance obligations, and FDA says it may withdraw them.
It is also worth knowing what the claim does not reach. Reading FDA’s own decision summary for this order, the six named conditions contain nothing dental — gingiv, periodont, enamel, caries and oral health all return zero occurrences across its 48 pages. Anyone telling you FDA has concluded something about pouches and your gums is not quoting this order.
What wintergreen actually is, and the one time anyone measured it in a pouch
Wintergreen flavour is methyl salicylate. In the plant it is almost the entire volatile fraction: a 2024 review of Gaultheria procumbens reports that “over 130 volatile compounds have been detected in wintergreen oil with dominating methyl salicylate (96.9–100%)”. That review was funded by the Medical University of Lodz and its authors declare no conflicts of interest.
In pouches, there is exactly one published measurement set, and it is the most interesting document on this page. A 2026 study in Nicotine & Tobacco Research from Roswell Park Comprehensive Cancer Center compared 10 tobacco-free pouch brands against 7 tobacco-containing ones and quantified 33 flavouring chemicals. Its wintergreen finding: “Expectedly, methyl salicylate, which gives a characteristic wintergreen taste, was identified in all ONP and OTP wintergreen flavors.” The concentrations are real numbers. Methyl salicylate in Rogue Wintergreen was measured at 14.9 ± 0.5 mg per pouch, the most concentrated flavouring found in any tobacco-free pouch in the study. In the tobacco-containing arm, Copenhagen Wintergreen came in at 26.8 ± 0.2 mg per pouch.
The same paper found something about wintergreen that no marketing copy will tell you: within a single brand, the wintergreen version behaved differently from the mints. “A delayed release was observed from Rogue pouches, where spearmint 6-mg pouches released 72.3% of their nicotine content and wintergreen 3-mg pouches released <1% at 5 minutes”. And on pH: “Inconsistencies in pH between BRIDGE pouches of different flavors were observed, where spearmint and cool mint flavors were more alkaline compared to wintergreen-flavored pouches (pH 9.0 vs. 6.0).” Two wintergreen pouches, two brands, and in both cases the wintergreen variant sat apart from its own range. That is a genuinely new reason to treat flavour as more than flavour.
The study was supported by the National Cancer Institute under awards U54 CA228110, P01 CA200512 and P30 CA016056. Its senior author’s declaration of interests includes a past research grant from Pfizer, advisory board service to Johnson & Johnson and consulting for FDA, the World Health Organization and the Campaign for Tobacco-Free Kids; the paper says so and so do I.
Now the reason this is not a ranking column. Every wintergreen pouch with a published methyl salicylate measurement is a product that is not on FDA’s authorised list. Rogue is absent from it. So are LUCY and BRIDGE. Copenhagen Wintergreen is a tobacco-containing product, not a nicotine pouch at all. There is no measured flavour chemistry for any of the six authorised wintergreen pouches, and the per-product tables in the Roswell Park paper are in supplementary files I could not retrieve. A column that scored products on their measured methyl salicylate would rank an unauthorised product first on data that exists for one entry out of seven.
One piece of arithmetic, which is mine and not either paper’s. A 2023 Archives of Toxicology screening study by BfR scientists detected methyl salicylate in 2 of 48 nicotine pouch packages bought in Germany, and derived per-pouch limits for flavourings from food acceptable daily intakes — for the group containing methyl salicylate, 3.5 mg per pouch on an average five-a-day scenario and 0.88 mg on a twenty-a-day worst case, for a 70 kg adult, using half the ADI to leave room for other exposure. Rogue Wintergreen’s measured 14.9 mg per pouch is several times the first figure and more than ten times the second. No published source makes that comparison, and the BfR figures are a toxicological derivation from food law applied to pouches by the authors, not a sales limit anywhere. I print it because the gap is large enough to be worth knowing about, and I print the caveat because the gap is not a legal finding. That study was funded by BfR’s own intramural programme and its authors declare no conflict of interest.
The “FDA GRAS” line about wintergreen flavouring is wrong, including where this site has used it
This needs a correction rather than a hedge, and it applies to pages on this site as much as anywhere else. Methyl salicylate is not FDA GRAS. It is not listed in 21 CFR 172.515, the synthetic flavouring substances section — which does list five other salicylate esters, benzyl, ethyl, isoamyl, isobutyl and phenethyl, and conspicuously not this one. Searching the whole of 21 CFR part 172 returns no occurrence of methyl salicylate. Nor does it appear anywhere in part 182 or part 184, the two GRAS parts, or in part 189, the prohibited-in-food part. FDA’s own Substances Added to Food inventory record for methyl salicylate lists only two food-additive sections against it, 175.105 and 177.1010, and both are indirect additives about adhesives and polymer components — food contact, not food.
What the record does give is FEMA No. 2745 and JECFA flavour No. 899. FEMA is not FDA, and FDA says so in its own words: “The trade association, Flavor and Extract Manufacturers Association (FEMA), has established expert panels that evaluate and make independent conclusions on the GRAS status of flavoring substances.” and “Inclusion in this inventory of information from non-FDA entities does not indicate an FDA approval or evaluation of this use.” In the EU the correct instrument is the Union list of flavouring substances, where methyl salicylate sits as FL 09.749 with no restriction entered on its row.
There is a deeper problem with the whole framing. A nicotine pouch is not a food. Under 21 U.S.C. 321(rr)(1) a tobacco product is “any product made or derived from tobacco, or containing nicotine from any source, that is intended for human consumption”, and 321(f) defines food as articles used for food or drink. The food-additive and GRAS machinery in 21 CFR parts 170 to 189 therefore confers nothing on a flavouring used in a pouch. Reaching for a food clearance to reassure someone about a tobacco product is a category error, not a shortcut.
And on FDA’s tobacco side, there is nothing either: methyl salicylate does not appear on FDA’s established list of harmful and potentially harmful constituents, which runs to 111 entries. BfR’s health risk assessment of nicotine pouches does not mention methyl salicylate or wintergreen at all, and says of flavourings generally that “Chemical characterisation of the flavourings used is in progress at the BfR.”
The one place in the CFR where FDA itself writes the words “wintergreen oil” is 21 CFR 201.303, a drug-labelling interpretation, and it cuts both ways: “Because methyl salicylate (wintergreen oil) manifests no toxicity in the minute amounts in which it is used as a flavoring, it is mistakenly regarded by the public as harmless even when taken in substantially larger amounts. Actually, it is quite toxic when taken in quantities of a teaspoonful or more.” Quoting only the second sentence misrepresents FDA; quoting only the first does too. The section requires a warning on any drug above 5 percent methyl salicylate, and 16 CFR 1700.14(a)(3) requires child-resistant packaging for liquids above the same threshold. Both are about teaspoonfuls of liquid. The published salicylate toxicity literature is likewise all topical or swallowed exposure at gram doses — five millilitres of oil of wintergreen is reported as roughly equivalent to 7,000 mg of salicylate. There is no published toxicology of methyl salicylate delivered by a nicotine pouch.
Wintergreen is banned by name in two states, and the statutes say so in their own words
Most flavour-ban arguments turn on whether a product has a “characterising flavour” at all. Wintergreen does not have that problem, because both statutes name it.
Massachusetts. M.G.L. c. 270 § 28 defines a characterising flavour as “a distinguishable taste or aroma, other than the taste or aroma of tobacco, imparted or detectable before or during consumption of a tobacco product, including, but not limited to, a taste or aroma relating to any fruit, chocolate, vanilla, honey, candy, cocoa, dessert, alcoholic beverage, menthol, mint, wintergreen, herb or spice”. Pouches are in scope: the same section defines a tobacco product as “a product containing or made or derived from tobacco or nicotine that is intended for human consumption”, and adds “regardless of nicotine content in the product”. The prohibition reaches online sale into the state explicitly, binding retailers and manufacturers alike, with a narrow smoking-bar exception for on-site consumption.
California. The definition enacted by SB 793 and approved by voters as Proposition 31 runs “Characterizing flavors include, but are not limited to, tastes or aromas relating to any fruit, chocolate, vanilla, honey, candy, cocoa, dessert, alcoholic” — and then, across a page break in the official text, “beverage, menthol, mint, wintergreen, herb, or spice.” The prohibition binds the retailer: “A tobacco retailer, or any of the tobacco retailer’s agents or employees, shall not sell, offer for sale, or possess with the intent to sell or offer for sale, a flavored tobacco product or a tobacco product flavor enhancer.” California’s definition of “tobacco product” reaches products containing nicotine from any source, which is why this site’s California page treats the flavour ban as covering tobacco-free pouches. I should say plainly that I read today’s text from the Secretary of State’s own official voter guide, because the Legislative Counsel’s site refused automated access, so I am citing the text as enacted rather than as amended since.
The practical consequence for a reader in either state is the same and it is not partial: there is no legal wintergreen pouch. Not a weaker one, not an authorised one, not a tobacco-free one. The flavour itself is the thing the statute names. The California page covers how that works in practice, and the on! PLUS and FRE wintergreen comparison covers the same two statutes from the product side.
If you want the flavour category in context rather than the legal position, every nicotine pouch flavour, ranked and explained is the wider map.
Who tells you what: the disclosure ranking
This is the axis that surprised me most, and it inverts the usual expectation.
For ZYN Wintergreen, the best public specification is FDA’s. Its decision summary describes the products 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”, and its appendix records, for each of the two wintergreen entries, a polypropylene can, 6 g of product, 15 pouches, a 0.40 g portion measuring 28 by 14 by 4.5 mm, nicotine source tobacco, and 3 or 6 mg per pouch. Meanwhile zyn.com’s US site serves no product data at all to anything but a browser — “wintergreen” appears zero times in what the server returns — and publishes no US sitemap. FDA publishes more about ZYN Wintergreen than ZYN does.
Rogue is the only maker whose own site served real wintergreen product data: Wintergreen at 3 and 6 mg, Rogue Max Wintergreen at 9, 12 and 15 mg. Its ingredient statement is a sentence in an FAQ — the product’s actual ingredients panel is published as an image, so there is no machine-readable ingredient list. Modoral Brands, velo.com and swedishmatch.com return nothing about wintergreen; us.velo.com and the on! consumer domain do not resolve at all.
The Roswell Park authors ran the same audit from the other side and found the disclosure gradient is real: “ZYN and on! further indicated that nicotine in these products was salt-based. ZYN specifically disclosed the use of nicotine bitartrate dihydrate.” while “ONP brands LUCY, NIC-S, and Rogue disclosed nicotine polacrilex”. So some disclosure exists; a retrievable ingredient list for a wintergreen pouch does not.
Outside the United States, “best wintergreen” has a different answer, and it may be none
A British reader cannot buy ZYN Wintergreen from the maker. ZYN’s UK product sitemap lists 76 products and wintergreen is not among them; the UK mint range runs cool mint, spearmint, peppermint, menthol ice and various frost and ice variants, from 1.5 mg up to 16.5 mg.
That is a commercial decision, not a legal one. The Tobacco and Vapes Act 2026 brings pouches into scope — section 117(1) defines a nicotine product to include “nicotine, or any substance containing nicotine, which is intended to be delivered into the human body” — and section 96 takes a power to make regulations about “the flavour of relevant products”. The power is delegated and unused: wintergreen appears zero times in the Act and zero times in the 2016 tobacco and related products regulations. The UK has taken the power to restrict pouch flavours and has not named one.
In the EU, flavour rules do not reach these products at all. The Tobacco Products Directive’s characterising-flavour prohibition is narrowed by Article 7(12), exempting tobacco products other than cigarettes and roll-your-own, and by Article 7(15), disapplying the article to tobacco for oral use — and tobacco-free pouches are not tobacco products under the Directive in the first place. Flavour and availability are national questions across the EU.
And one thing a ranking built on documents keeps running into: nicotine pouches and dry mouth is a whole page about a question where the measurement people assume exists simply does not.
What this ranking cannot tell you
It cannot tell you which one tastes better, which runs longer, which burns, or which has the cleaner mint-to-sweet balance, because I have not used any of them. It cannot tell you the measured nicotine of any wintergreen pouch, because the per-product tables are in supplementary files I could not get and the main text reports only release percentages. It cannot tell you how ZYN ULTRA Wintergreen Chill differs from plain ZYN ULTRA Wintergreen, because no document I reached says. It cannot date the on! PLUS wintergreen authorisation, because I could not find the announcement. And it cannot tell you whether California’s text has been amended since the 2022 vote, because the state’s own legislative site refuses automated requests.
When scored reviews of these products publish, they will replace the entries above and the order will change. Until then, what you have is a documents ranking that says so on its face.
Frequently asked questions
Is there a legal wintergreen pouch in California or Massachusetts? No. Wintergreen is named in the characterising-flavour definition in both statutes, so the flavour itself is what is prohibited. There is no tobacco-free workaround, because both states’ definitions of a tobacco product reach products containing nicotine from any source.
What is the strongest authorised wintergreen pouch in the US? 9 mg — ZYN ULTRA Wintergreen and ZYN ULTRA Wintergreen Chill, both authorised on 21 August 2026. The 12 mg and 15 mg wintergreen products sold by Rogue under the Max line are not on FDA’s authorised list.
Does FDA say wintergreen pouches are safe? No, and it says the opposite in terms: authorisation “does not mean these products are safe, nor are they “FDA approved.”” The modified risk order for ZYN is a comparative claim about substituting for cigarettes, limited to six named conditions, none of them dental.
Is the wintergreen flavouring itself a problem? Nobody has published a toxicology of methyl salicylate delivered by a pouch. What exists is a measurement of how much is in two named wintergreen products, a set of derived per-pouch limits from food intake values that those measurements exceed, and a body of poisoning literature about swallowed or topically applied wintergreen oil at gram doses. Those are three different things and this page keeps them apart.
Why is Rogue not ranked when its wintergreen is the one that has been measured? Because FDA’s list says the 67 authorised products are the only ones that may lawfully be sold, and Rogue is not among them. Ranking it first on a chemistry paper would be recommending a purchase that the regulator says is not lawful.
Sources
- FDA, Nicotine Pouch Products Authorized by the FDA — page currency 30 October 2026; 67 products, three companies, six wintergreen entries.
- FDA, FDA Authorizes Marketing of 20 ZYN Nicotine Pouch Products, 16 January 2025.
- FDA, FDA Authorizes 20 ZYN Nicotine Pouches to Be Marketed with a Specific Modified Risk Claim, 30 June 2026.
- FDA, FDA Authorizes 11 New Nicotine Pouches, 21 August 2026 — ZYN ULTRA Wintergreen and Wintergreen Chill.
- FDA, FDA Authorizes Marketing of 24 Velo Nicotine Pouches, 30 October 2026 — no wintergreen product.
- FDA, ZYN modified risk tobacco product decision summary (PDF) — product specification and the absence of dental endpoints.
- FDA, Substances Added to Food inventory — methyl salicylate, and FDA’s explanation of FEMA’s role.
- 21 CFR 172.515, part 182, part 184 and 21 CFR 201.303; 16 CFR 1700.14.
- 21 U.S.C. 321 — definitions of food, food additive and tobacco product.
- FDA, established list of harmful and potentially harmful constituents — 111 entries, no salicylates.
- M.G.L. c. 270 § 28 — Massachusetts flavoured tobacco prohibition.
- California Secretary of State, Text of Proposed Laws, November 2022 (PDF) — SB 793 / Proposition 31 as approved, adding Health and Safety Code § 104559.5.
- Page et al., Comparison of Nicotine and Selected Flavoring Contents Between Tobacco-Free and Tobacco-Containing Oral Pouches, Nicotine & Tobacco Research, 2026 — NCI-funded; methyl salicylate in named wintergreen products.
- Pieper et al., Oral nicotine pouches with an aftertaste? Part 1, Archives of Toxicology, 2023 — BfR-funded screening of 48 packages and the derived per-pouch limits.
- Michel & Olszewska, Phytochemistry and Biological Profile of Gaultheria procumbens L. and Wintergreen Essential Oil, International Journal of Molecular Sciences, 2024.
- Chan et al., Salicylate Toxicity from Genital Exposure to a Methylsalicylate-Containing Rubefacient, Western Journal of Emergency Medicine, 2016.
- BfR, Health risk assessment of nicotine pouches (PDF) — no mention of wintergreen or methyl salicylate; flavouring characterisation still in progress.
- Commission Implementing Regulation (EU) No 872/2012 (PDF) — Union list of flavourings, methyl salicylate FL 09.749; and Directive 2014/40/EU (PDF), Articles 7 and 17.
- Tobacco and Vapes Act 2026, sections 96 and 117.
- Rogue, Wintergreen product page and Rogue Max Wintergreen; ZYN UK product sitemap; velo.com.
Last verified 10 November 2026 against the documents listed above. The FDA authorisation list changes; the page’s own currency date is the one to check.
