The draft prepared by the Ministry of Social Affairs and Ministry of Justice would limit nicotine pouches, strips and sprays to a maximum of 4 mg/g of nicotine. The Prosecutor's Office noted in a letter to the Justice Ministry that it is unclear whether compliant alternative products will reach the market in time. They cautioned that this could push consumers toward illegal or unregulated nicotine products that may pose greater health risks.

There is also concern that young people might turn to other addictive substances — cigarettes, alcohol, cannabis or black‑market drugs — if nicotine products become harder to obtain. The Ministry of Social Affairs responded that such "substitution effects" are not supported by research. According to the ministry, youth risk behavior is more strongly influenced by peers, family, mental health, socioeconomic conditions, product availability and marketing.

Studies also show that when a nicotine product becomes less accessible or disappears from the market, its use often declines, especially among youth who do not consume nicotine regularly.

Difficult to curb black-market reselling

The Interior Ministry warned that if individuals buy large quantities of nicotine products abroad and resell them in Estonia, detecting such activity will be difficult. Products can be moved through parcel lockers, making violations hard to trace — a situation that could encourage black‑market growth.

Another issue involves foreign sellers. If an online shop in another country ships products to Estonian consumers, it is unclear how Estonia could take action against that seller. Estonian misdemeanor procedures generally cannot be applied to individuals or companies operating abroad.

The Consumer Protection and Technical Regulatory Authority noted in its feedback that the market already offers a workaround to e‑cigarette flavor restrictions: water‑pipe vapor‑stone flavorings. These products contain the same base components as e‑liquids and can be used as e‑cigarette liquid or liquid additives. The flavorings include substances that would not be permitted in e‑liquids under current law — yet they are not legally classified as e‑cigarette liquids.

Aive Telling, head of environmental health policy at the Ministry of Social Affairs, acknowledged that new restrictions could lead to black‑market growth, but said it is not inevitable. "The black market requires constant active attention," she said.

Nicotine reaching younger children 

Telling said young people are starting to use nicotine products at increasingly early ages. Whereas experimentation used to begin around age 15–16, it now starts at about age 11. The most common entry products are nicotine pouches and e‑cigarettes. Manufacturers make their products more attractive, she said, which helps them reach more children.

Currently, just over 20 percent of nicotine products on the market meet the new requirements. About 60 percent would need their composition changed, and nearly one‑fifth would have to be removed from sale. The new rules are planned to take effect in 2028, with the exact date determined during legislative review.

Several European countries have tightened nicotine‑product regulations in recent years. Belgium, the Netherlands, Ireland and Finland aim to reduce the number of nicotine users, and the Netherlands is already seeing a decline in youth e‑cigarette use. Latvia raised the minimum purchase age for tobacco and nicotine products to 20 two years ago. Estonia is not currently considering such a change.

The Ministry of Social Affairs and Ministry of Justice have drafted a new plan to better protect the health of Estonian children and youth and reduce nicotine use. The bill recently sent for approval would ban ordering nicotine products by mail or courier, restrict flavors in e‑cigarettes and other nicotine products, and require disclosure of tobacco‑industry lobbying meetings.

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