Five possible scenarios for the future regulation of nicotine pouches in the EU



  • 1. Executive summary
  • 2. The EU and member states’ current position
    • 2.1. The EU’s position
    • 2.2. Member states
  • 3. Future scenarios: will TPD3 regulate nicotine products?
  • 4. Pouches regulated in the TPD
    • 4.1. Scenario 1: Nicotine pouches are regulated as tobacco-containing oral products and banned across the EU
    • 4.2. Scenario 2: Nicotine products are considered a tobacco-related product
  • 5. Pouches not regulated in the TPD
    • 5.1. Scenario 3: No common EU position or regulation for nicotine pouches emerges
    • 5.2. Scenario 4: pouches are considered to be a medicinal product
    • 5.3. Scenario 5: pouches are regarded as a food product


Tobacco-free snus is made up of a sachet filled with various ingredients and nicotine. The sachet is intended to be placed under the lip in order to deliver nicotine that will be absorbed via the user’s gums. The main difference between tobacco-free and classic snus is that the latter contains tobacco. Tobacco pouches (snus) are banned throughout the EU except in Sweden. However, there is no EU-level regulation of pouches that contain nicotine but not tobacco – and they are the subject of this report. It will cover the EUs current position on this type of product, and then cover possible future scenarios for regulation.

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