The rapid emergence of recreational nicotine pouches in Pakistan presents a regulatory puzzle that policymakers can no longer afford to ignore. On one hand, the legal framework governing drugs and poisonous substances in Punjab, and indeed across Pakistan, clearly recognizes nicotine as a hazardous compound beyond defined thresholds. 

On the other hand, commercially available “Recreational Nicotine Pouches” are being openly marketed and sold with concentrations that significantly exceed those thresholds, with little to no oversight. This contradiction is not merely administrative; it has serious public health implications, particularly for young people who are increasingly being targeted by these products.

The Punjab Drug Rules, 2007, provide an explicit starting point for understanding this issue. Under these rules, nicotine is classified as a poisonous substance, and a preparation is exempt from poison control provisions only if its nicotine content remains below 0.2 percent. 

This threshold is not arbitrary; it reflects a long-standing toxicological understanding that nicotine, while therapeutically useful in controlled doses, becomes dangerous and potentially addictive when concentrations exceed minimal levels. Global smoking and use of nicotine pouches and vapes addiction has amply demonstrated this. 

The rules further imply that substances falling within the poisonous category must be regulated, restricted, and typically dispensed under professional supervision. This aligns with broader pharmaceutical governance principles, where safety, dosage, and medical necessity are paramount.

However, the nicotine content found in recreational pouches currently available in Pakistan stands in stark contrast to this regulatory benchmark. A typical pouch contains 14 mg of nicotine and weighs approximately 0.7 grams (700 mg), resulting in a concentration of about 2 percent nicotine by weight. This is ten times higher than the permissible exemption limit of 0.2 percent defined under the law of the land. From a strictly legal standpoint, this places such products squarely within the category of poisonous substances. 

Yet, surprisingly, these pouches are not being treated as regulated drugs or controlled poisons. Instead, they are being sold as Recreational Nicotine products, often in appealing packaging and flavors that attract younger users.

This discrepancy raises an important legal question: if nicotine above 0.2 percent is classified as a poison, why are products containing approximately 2 percent nicotine not subject to the same regulatory controls as other Schedule E substances? Under the existing framework, substances listed in this category are typically dispensed only on the advice of a registered medical practitioner and are available through licensed pharmacies. 

The rationale is clear, these substances carry inherent risks and require professional oversight to ensure safe use. Applying this logic consistently would mean that these recreational nicotine pouches, given their high concentration, should not be freely available over the counter, let alone marketed aggressively to the general public including youth and children.

The issue becomes even more complex when viewed in the context of Pakistan’s broader drug regulatory architecture. The Punjab Drug Rules, 2007, are not an isolated instrument; they derive their authority from the Federal Drugs Act of 1976, which itself is rooted in earlier legislation such as the Dangerous Drugs Act of 1930. This historical continuity underscores a consistent legislative intent: to control substances that pose risks of toxicity, dependence, or misuse. 

Nicontine is Poison

Nicotine’s classification as a poison beyond certain limits reflects decades of scientific and regulatory consensus. It is therefore difficult to justify the current excessive sales and marketing of Recreational Nicotine Pouches, especially when the legal foundations for control are already well established.

Moreover, other provinces in Pakistan, such as KP and Sindh, have updated their drug rules in recent years, often strengthening provisions related to controlled substances and public health safeguards. While the specifics may vary, the underlying principle remains consistent across jurisdictions: substances with known risks must be regulated in proportion to their potential harm. 

In this context, the unregulated sale of high-nicotine recreational pouches appears increasingly anomalous. It suggests either a gap in enforcement or a deliberate regulatory blind spot,both of which have serious implications for public health governance.

The contrast with Nicotine Replacement Therapy (NRT) products further highlights this inconsistency. In 2023, NRTs were included in Pakistan’s Essential Medicines List, reflecting their recognized role in smoking cessation and harm reduction. These products, such as nicotine gums, patches, and lozenges, are carefully formulated to deliver controlled, lower doses of nicotine. 

Their purpose is therapeutic: to help individuals gradually reduce dependence on tobacco. As such, they are regulated, quality-controlled, and often recommended under medical guidance. The nicotine levels in NRTs are deliberately kept within safe limits to minimize the risk of addiction while still providing relief from withdrawal symptoms.

Recreational nicotine pouches, by contrast, operate outside this therapeutic framework. They deliver significantly higher doses of nicotine, 14 mg per pouch, without any clear medical justification. When a single pouch contains ten times the nicotine concentration allowed under the exemption threshold, it is difficult to argue that such a product is harmless. 

In fact, from a pharmacological perspective, higher nicotine concentrations increase the likelihood of rapid absorption, stronger physiological effects, and greater addiction potential. This is particularly concerning for young users, whose developing brains are more susceptible to nicotine dependence.

Finetuning Public Health Policy

The marketing strategies employed for these pouches further exacerbate the problem. Unlike NRTs, which are positioned as medical aids, recreational nicotine pouches are often branded as lifestyle products. More recently on World Women's Day, the tobacco industry associated and promoted the sale of these pouches as “freedom for women”. They come in a variety of flavors, sleek packaging, and are promoted through channels that appeal to younger demographics. This creates a perception of safety and modernity, masking the underlying pharmacological risks. In effect, a substance legally recognized as a poison beyond certain limits is being repackaged as a harmless consumer good.

From a policy perspective, this situation demands urgent attention strongly leaning towards an outright ban. The existing legal framework already provides a basis for regulation; what is lacking is its consistent application. If nicotine above 0.2 percent is to be treated as a poison under the law, then products exceeding this threshold must be banned under the ambit of drug regulation. This could involve classifying high-nicotine pouches as controlled substances, restricting their sale to licensed pharmacies, and requiring medical oversight for their use. At a minimum, clear labeling, age restrictions, and advertising controls should be enforced to mitigate the risks.

Equally important is the role of the Ministry of Health and relevant regulatory authorities, including Drugs Regulatory Authority of Pakistan (DRAP). The absence of formal approval or oversight for these products raises questions about accountability and governance. 

Public health policy cannot remain reactive in the face of rapidly evolving nicotine delivery systems only for economic/profit reasons. Instead, it must anticipate and address emerging risks, particularly those that disproportionately affect young people.

Upholding Legal Integrity

Ultimately, the issue of recreational nicotine pouches is not just about regulatory technicalities; it is about safeguarding public health and upholding the integrity of the legal framework. When laws clearly define a substance as hazardous beyond certain limits, allowing products that exceed those limits to circulate freely undermines both the letter and the spirit of the law. It sends a mixed message to consumers, weakens regulatory credibility, and creates an environment where commercial interests can override public health considerations.

The way forward requires clarity, consistency, and political will. Pakistan already has the legal tools needed to address this issue. What remains is the commitment to apply them effectively. If nicotine is indeed a poison beyond 0.2 percent, as the law unequivocally states, then it must be treated as such in practice. 

Anything less risks normalizing exposure to a highly addictive substance and compromising the health of future generations.

(The authors are tobacco control advocates at the  Centre for Health Policy & Innovation,   Sustainable Development Policy Institute (SDPI), Islamabad, Pakistan. The views expressed are personal. They can be contacted at wasif@sdpi.org )