After following a link from here to the Wargames Factory Viking sampler set as a potential army builder for Dunlendings, I've been checking out a lot of their other stuff online.

I'm wondering if the scale of their figures is LOTR-28mm, or if they are
"heroic 28-32mm" - aka Warhammer scale?

thanks,

I believe they are more into 28mm true-scale than heroic. That said, I never really saw a picture side-by-side with a Lotr miniature and don't actually own any either.

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The best I can offer is that I just held up one of WGF's Celt Warband to a LOTR Galadhrim Warrior and the stood pretty much shoulder to shoulder without a height difference. The WGF figs were a little bulkier, but not taller.