SG 099/26
Switzerland has revised its legislation on food contact materials (FCMs) and articles.
On July 8, 2026, Switzerland’s Federal Food Safety and Veterinary Office (FSVO) issued RO 2026 374 (available in French, German and Italian), amending Ordinance of the Federal Department of Home Affairs (FDHA) on Materials and Articles Intended to Come into Contact with Food (RS/SR 817.023.21, version in French, German and Italian, including Annexes 2 ‘Positive list for plastics’ and 10 ‘Positive list for inks’ (Edition 3.4 of January 1, 2026, which are referenced in RO 2025 812).
What does this regulation require?
Key changes in the amendment include:
- Specifying that a) FCMs and articles not complying with this amendment may remain on the market until August 1, 2027 and b) repeat use final articles manufactured with BPA, as provided for in the amendments of November 13, 2024, as well as such products not complying with the requirements of Annex 13, Chapter 2, or Annex 14 of the amendment of June 2, 2025, may be placed on the market until July 20, 2026, and remain on the market until July 20, 2027
- Updating Table 1 of Annex 2 concerning the list of permitted substances for plastics, including:
- Revising the chemical name and specifications for substance no. 4658 (amines, di-C14-C20-alkyl oxidized, from hydrogenated tallow)
- Adding several entries, including substance nos. 5345 (waxes and waxy substances, rice bran, oxidized), 5360 (2, 2′-oxydiethylamine) and 5361 (wax, rice bran, oxidized, calcium salt)
- Introducing entry 31 to Table 5 of Annex 2 ‘Notes relating to compliance control’, specifying that water must be used for compliance control purposes instead of food simulants listed in Table 1 of Annex 4 (c.f. Regulation (EU) 2026/245, SafeGuardS 20/26)
- Amending Annex 10 on the permitted substances for inks
- Modifying Annex 4, including:
- Revising language and food simulants for ‘cheeses’ (Chapter 1.3, Table 2)
- Updating the conformity testing criteria for migration in plastics
- Replacing the provisions on a) the expression of migration test results based on the surface area to volume ratio under actual or intended conditions of use, b) criteria for assessing overall migration in reusable materials and articles and c) criteria for assessing specific migration in reusable items
- Updating quality assurance system requirements for recyclers of food contact plastics (Annex 5)
- Amending Annex 13 ‘Specific requirements for varnishes and coatings’, including:
- Adding Regulation (EU) 2026/250 to the footnote of Chapter 2.1
- Repositioning the statement, ‘An extraction method is used to verify that a material or article does not contain BPA. The detection limit of the method must be 1 µg/kg’, from Chapter 2.3 to Chapter 2.2
Who is impacted?
The amendment affects stakeholders across the FCMs and articles supply chain, including manufacturers, importers, retailers and other intermediaries operating in the Switzerland market.
When does it apply?
The new law will become effective on August 1, 2026.
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