WHO’s Report on Nicotine Pouches: Why Youth Protection and Adult Access Are Not Competing Goals

This week, the World Health Organization (WHO) is releasing its first global report focused specifically on nicotine pouches, raising concerns about marketing practices, youth exposure, and regulatory gaps in many countries. Protecting young people from nicotine use is a priority everyone can agree on. Where the conversation becomes more complicated is how to do that without cutting off regulated access for adults who already use nicotine and are seeking alternatives to cigarettes.

As the global debate ramps up ahead of World No Tobacco Day on May 31, it is worth looking closely at what effective regulation actually looks like in practice. Recent regulatory decisions in the United States provide a clear example of how governments can take youth protection seriously while still relying on scientific review rather than prohibition.

Let’s be clear: nicotine products are not for youth. Any marketing tactics that appeal to adolescents or young people—through youth-oriented imagery, product designs, or platforms—deserve scrutiny and enforcement. Strong age restrictions, marketing controls, and penalties for non compliance are essential.

The question is not whether governments should act, but how they should act. Blank bans or poorly designed regulations risk leaving adults with fewer legal alternatives while failing to eliminate illicit markets that operate entirely outside regulatory oversight.

Recent developments in the US illustrate a more nuanced approach—one that aligns youth protection with evidence-based regulation.

In January 2025, the US Food and Drug Administration (FDA) authorized the marketing of 20 ZYN nicotine pouch products after an extensive premarket scientific review. This marked the first time nicotine pouches received marketing authorization under the FDA’s Premarket Tobacco Product Application (PMTA) pathway. The FDA concluded that these specific products met the legal standard of being “appropriate for the protection of public health,” based on evidence showing substantially lower levels of harmful constituents compared to cigarettes and most smokeless tobacco products, and data indicating that adults switched away from higher-risk products. 

Later in 2025, the FDA also authorized six on! PLUS nicotine pouch products through the same PMTA process, completing scientific review under a pilot designed to improve the efficiency of nicotine pouch evaluations.

These decisions did not declare nicotine pouches “safe,” nor did they remove restrictions. Instead, they placed legally binding conditions on how these products may be marketed and sold—explicitly including requirements tied to youth risk mitigation.

Earlier this month, the FDA issued new guidance clarifying its enforcement priorities for unauthorized ENDS and nicotine pouch products. The agency reaffirmed that all new tobacco products still require premarket authorization, but explained that enforcement resources will be focused on products that pose the greatest risks—particularly those that appear designed to appeal to youth.

 
According to the guidance, FDA will continue to prioritize enforcement against products that:

• Use cartoon-like or youth-oriented imagery
• Disguise their nature or resemble toys or gadgets
• Lack child-resistant packaging
• Raise significant safety or public health concerns

At the same time, the agency stated it does not intend to prioritize enforcement against nicotine pouch products that have properly filed and accepted applications under scientific review—unless they contain youth appealing elements.

This distinction matters. It reflects a regulatory system that differentiates between products that ignore the rules and products that follow them.

The WHO is right to call attention to youth protection and regulatory gaps. But a global conversation that treats all nicotine pouches as the same—regardless of whether they are regulated, reviewed, or marketed responsibly—risks oversimplifying the issue.

The U.S. experience shows that science-based authorization and youth protection are not mutually exclusive. In fact, they reinforce each other. When governments set clear, evidence-driven standards and enforce them consistently, they create both incentives for responsible behavior and consequences for those who target young people.

Preventing youth nicotine use is non-negotiable. So should be evidence-based regulation that recognizes adult reality. Millions of adults already use nicotine, and many are looking for alternatives to smoking that come with lower risks. Denying them regulated options does not eliminate demand; it simply shifts it into unregulated spaces where youth protections are weakest.

As countries consider how to respond to the growing popularity of nicotine pouches, the goal should not be to choose between protecting youth and respecting adult choice. It’s a false choice. Both can be done seriously, credibly, and based on science.