Switzerland Consults Over Revision to Law on Dangerous Chemicals

SafeGuardSAutomotive, Cosmetics & Personal Care, Electrical & Electronics, Hardgoods, Personal and Protective Equipment, Softlines, Toys and Juvenile ProductsFebruary 10, 2026

SG 018/26

Switzerland plans to update the nation’s Chemical Risk Reduction Ordinance (ORRChem).

On January 27, 2026, the World Trade Organization (WTO) announced a draft law from Switzerland to revise the nation’s Ordinance on the reduction of risks relating to the use of certain particularly dangerous substances, preparations and articles (Chemical Risk Reduction Ordinance, ORRChem, RS/SR 814.81, version 01.01.2026 in French, German and Italian).

The draft ordinance, provided in French, contains important changes to ORRChem by revising, inter alia, the requirements for mercury and per- and polyfluoroalkyl substances (PFASs).

Key changes in the draft ordinance are summarized in Table 1.

Section to ORRChem	Highlights of change
Annex 1.1 ‘Persistent organic pollutants (POPs)’, Chapter 1 ‘Prohibitions’, point 3	Emphasizes that Annex 1.16 applies to: Perfluorooctane sulfonic acid (PFOS) and related substances Long-chain perfluorocarboxylic acids (PFCAs, C₉-C₁₄ PFCAs and C₁₅-C₂₁ PFCAs) and related substances
Annex 1.1, Chapter 2 ‘Exceptions’	Introduces derogations for medium-chain chlorinated paraffins (MCCPs, C₁₄-C₁₇ chloroalkanes with at least three chlorine atoms)
Annex 1.1, Chapter 3 ‘List of prohibited POPs’	Includes a) LC-PFCAs and related substances, b) MCCPs and c) chlorpyrifos
Annex 1.1, Chapter 4 ‘Transitional provisions’	Adds several derogations for the prohibition of MCCPs in specified applications
Annex 1.7 ‘Mercury’ Chapter 1.1 ‘Placing on the market: Prohibitions’	Expands the scope of prohibition to include, inter alia, a) photographic films and paper and b) wheel balancing devices and weights
Annex 1.16 ‘Per- and polyfluoroalkyl substances (PFAS)’ Chapter 1.1 ‘PFOS and its derivatives: Definitions’	Updates the term ‘PFOS and its derivatives’ to ‘PFOS and their related substances’, with definition
Annex 1.16, Chapter 1.2 ‘PFOS and its derivatives: Prohibitions’	Prohibits the manufacture, placing on the market and use of PFOS and their related substances: ≤ 25 ppb PFOS in substances, mixtures or articles ≤ 1,000 ppb sum of PFOS-related substances in substances, mixtures or articles
Annex 1.16, Chapter 3.2 ‘PFOA, LC-PFCAs and related substances: Prohibitions’	Prohibits the manufacture, placing on the market and use of PFOA, C₉-C₁₄ PFCAs, C₁₅-C₂₁ PFCAs, and their respective related substances: ≤ 25 ppb PFOA, C₉-C₁₄ PFCAs and C₁₅-C₂₁PFCAs in substances, mixtures or articles ≤ 260 ppb sum of C₉-C₁₄ PFCA-related substances and C₁₅-C₂₁PFCA-related substances in substances, mixtures or articles
Annex 1.16, Chapter 3.3 ‘PFOA, LC-PFCAs and related substances: Exceptions’	Introduces derogations for fluoropolymers and non-invasive and non-implantable medical devices, subject to certain conditions
Annex 1.16, Chapter 6.1 ‘PFAS in certain uses: Special packaging and labeling for partially halogenated unsaturated hydrofluorocarbons’*	Sets criteria for the use of substances listed in Annex II to Regulation (EU) 2024/573 (current consolidated version to February 2024) on fluorinated greenhouse gases
Annex 1.16, Chapter 6.2 ‘PFAS in firefighting foams’*	< 1 mg/L sum of all PFASs
Annex 1.16, Chapter 6.3 ‘PFAS in packaging, materials and articles in contact with food’*	Sets requirements for food packaging and single-use food contact materials and articles: < 25 ppb individual non-polymeric PFASs* < 250 ppb sum of individual non-polymeric PFASs, including those transformed from related substances* < 50 ppm sum of polymeric and non-polymeric PFASs*
*Present Chapter 6 will become Chapter 7

Table 1

Comments will be accepted until March 28, 2026.

If approved, the new measures will be phased in starting December 1, 2026.

We are committed to providing information about regulatory developments for consumer products as a complimentary service. Through our global network of experts and laboratories, we provide a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.

^{© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.}