Yes. Nicotine pouches formulated with synthetic or pharmaceutical-grade nicotine but no tobacco leaf are classified under 240491 when intended for oral intake, because the heading covers nicotine products for oral delivery regardless of whether tobacco plant material is present. However, if a product is formulated and labeled as a nicotine replacement therapy drug (e.g., nicotine polacrilex gum), it may be regulated and classified differently — a distinction that requires careful review of labeling and intended use.

Scandinavia has decades of industrial infrastructure and regulatory experience with snus and oral tobacco, and several of the world's largest oral nicotine pouch brands — including modern tobacco-free formats — are manufactured there. This heritage gives Danish and Swedish producers a significant head start in product development, quality systems, and FDA engagement relative to manufacturers in other regions.