Key Points
- Sweden's Public Health Agency found ZYN nicotine pouch ingredient labels noncompliant and ordered Swedish Match North Europe to revise them.
- The products reviewed listed 10 to 13 ingredients on their packaging, compared with 11 to 42 in regulatory submissions.
- Multiple flavoring ingredients were grouped under the generic term "aromer" rather than identified individually.
- Swedish Match was given 60 days to comply and faces a conditional penalty of SEK 2 million per month for noncompliance. Previously marketed products are not subject to recall under the order.
- The company cited trade-secret protection and legislative history in defending its labeling practices and said it intends to appeal.
2Firsts
October 22, 2026
Sweden's Public Health Agency (Folkhälsomyndigheten) has found ingredient labels on ZYN nicotine pouches produced by Philip Morris International (PMI) subsidiary Swedish Match to be noncompliant because multiple flavoring ingredients are grouped under the generic term "aromer" rather than listed individually, according to an October 21 report by Swedish financial newspaper Dagens industri. The agency has ordered corrective action, warning of a conditional penalty of SEK 2 million per month for noncompliance. Swedish Match disputes the decision and plans to appeal.
The agency found that the products' packaging listed 10 to 13 ingredients, while corresponding product notifications submitted to regulators identified between 11 and 42 ingredients.
ZYN Packaging Lists 10 to 13 Ingredients, Compared With 11 to 42 in Regulatory Submissions
According to Dagens industri, Sweden's Public Health Agency purchased five cans of ZYN nicotine pouches ahead of a visit to Swedish Match's factory in Gothenburg in May 2026 and examined the ingredient declarations on their packaging.
The agency found that the products reviewed listed 10 to 13 ingredients on their packaging, compared with 11 to 42 ingredients in the corresponding product notifications. Multiple flavoring components were grouped under the Swedish term "aromer," meaning flavorings, without being identified individually.
An ingredient declaration for ZYN Cold Mint shown in the report included nicotine salts, cellulose and sweetening agents, while the specific flavoring components were presented under the generic designation "aromer."
Under Section 4 of Sweden's Ordinance (2022:1263) on Tobacco-Free Nicotine Products, manufacturers must submit a list of all ingredients and their quantities, along with toxicological information, to regulators. Section 11 requires product packaging to list all ingredients in descending order by weight and provide information on nicotine content and nicotine per dose.
The Public Health Agency concluded that Swedish Match's use of a generic flavoring designation for multiple ingredients did not meet the statutory labeling requirements.
Swedish Match Cites Trade Secrets and Plans to Appeal
Swedish Match disputes the Public Health Agency's interpretation of the labeling rules.
According to Dagens industri, the company argued that grouping flavoring ingredients under "aromer" protects confidential product formulations and complies with its interpretation of Swedish law.
Swedish Match also referred to the legislative preparatory materials for Sweden's tobacco-free nicotine product law, noting that lawmakers did not ultimately include a specific prohibition against grouping ingredients under a common designation.
The company further argued that the limited space on nicotine pouch packaging makes extensive ingredient lists difficult to accommodate.
Under the Public Health Agency's HSLF-FS 2023:24 regulations, ingredient declarations must cover 20% of one of the largest surfaces of both unit and outer packaging. They must appear in Swedish, using bold black text on a white background, and may be applied using non-removable stickers.
The Public Health Agency based its decision on the statutory requirement to list all ingredients and maintained that the individual flavoring components must be disclosed.
Swedish Match communications director Robert Noord told Dagens industri in an emailed response that the company considered its existing labels compliant with Swedish law, disagreed with the agency's assessment and intended to appeal the decision.
SEK 2 Million Monthly Penalty Threatened; Existing ZYN Products Not Subject to Recall
The Swedish Public Health Agency issued its administrative decision on September 29, 2026, directing Swedish Match North Europe to revise the ingredient declarations on the relevant ZYN products.
According to Dagens industri, the company was given 60 days to comply. Failure to meet the requirements could trigger a conditional penalty of SEK 2 million for each month of continued noncompliance.
The order applies only to products manufactured after the decision becomes legally effective and does not require the recall of ZYN products already placed on the market.
The decision may be appealed within three weeks of notification. Dagens industri reported that no appeal had been received by the agency when the newspaper contacted officials. Swedish Match subsequently confirmed that it intended to challenge the ruling.
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Cover image: ZYN products on display at a duty-free shop at Stockholm Airport, Sweden. Photo taken by 2Firsts in November 2025.
Reference
- Dagens industri — Böter hotar Swedish Match – mörkar Zyn-ingredienser, October 21, 2026
- Swedish Parliament — Ordinance (2022:1263) on Tobacco-Free Nicotine Products, Sections 4 and 11
- Swedish Parliament — Act (2022:1257) on Tobacco-Free Nicotine Products
- Swedish Public Health Agency — HSLF-FS 2023:24, Regulations on Tobacco-Free Nicotine Products
- Swedish Public Health Agency — Manufacturing and Importing Tobacco-Free Nicotine Products
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