Denmark changed its pouch label order — and added a line nobody prints

If you look up Denmark’s labelling rules for nicotine pouches, the order you will probably find is BEK nr 462 af 18. marts 2021. It is no longer law. BEK nr 251 af 4. marts 2025 repealed it by its own § 13, stk. 2 and has applied since 1 July 2025.

The reason the wrong order is easy to land on is that the act does not contain the rules. § 19 a of lov om tobaksvarer m.v. (LBK nr 1161 af 4. november 2024) only empowers the minister to set the wording, form and placement. The duty lives in the bekendtgørelse — and there are two of them, because standardised packaging sits in its own order.

The part that catches people: a new mandatory line

§ 3 of the new order requires every unit pack and any outer packaging to carry smoking-cessation details, and the provision prints them in full. There was no equivalent in the 2021 order.

That is the quiet one. A can built to the old rules carries a correct warning, a correct ingredient list and a correct nicotine figure — and is still non-compliant, because a line that did not exist when the artwork was signed off is now required. Nothing about the pack looks wrong.

Three more places the 2025 order moved

• The nicotine figure has a unit. § 2 names our product directly and requires the content per pouch. A per-gram or per-can figure does not discharge it.
• There is a coverage rule, and it is not where you would look for it. The 2021 order was often summarised as setting no percentage. The 2025 order sets one, and it is tied to the number of surfaces a pack has — which means a round can is treated differently from a box. We had this wrong ourselves until we opened the order.
• Flavour wording is a closed list. Two phrases are permitted and nothing else, and the standardised-packaging order governs how even those may be printed.

The trap in the standardised-packaging order

Danish plain packaging works as a closed list: a pack may carry only the marking the law requires. That turns an ordinary habit into a breach — a best-before date in English is not merely untranslated, it is marking the law does not require, and that alone is non-compliant.

What to check on your Danish artwork

• Was the artwork approved before July 2025? If so, assume the new mandatory line is missing.
• Is the nicotine figure stated per pouch?
• Is there a batch number?
• Is the warning on enough surfaces — and does it reach the required share of each?
• Is every other word on the can something a Danish rule actually requires?

The verbatim Danish strings, the exact coverage figure and surface rule, the typography the order prescribes and the full on-pack element list are in the Denmark label spec, or upload your artwork and have it checked against all of it.