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Switzerland Strengthens Regulation on Food Contact Materials and Articles

SafeGuardSFebruary 03, 2017

Switzerland has published a new regulation establishing requirements for 10 groups of food contact materials and articles as part of the nation’s new ‘Food Law 2017’. The new law on food contact materials and articles will become effective in two phases starting May 1, 2017.

In December 2016, the Swiss Federal Office for Food Safety and Veterinary Affairs (FSVO), [Bundesamt für Lebensmittelsicherheit und Veterinärwesen (BLV)], announced [1] an amendment to the legislation on food safety that includes food contact materials and articles (FCMs), toys, cosmetics and other consumer goods. The Consumer Goods Regulation of the Federal Department of Home Affairs [Bedarfsgegenständeverordnung Verordnung des Eidgenössischen Departements des Innern (EDI)] relating to Regulation of the EDI on materials and articles intended to come into contact with food establishes requirements for 10 groups of FCMs. These are active and intelligent materials, ceramics, glass, enamels and similar articles, metals and alloys, paper and cardboards, paraffins, waxes and dyes, plastics (which also includes epoxy resins), printing inks, recycled plastics, regenerated cellulose films and silicones.

Under the law, FCMs are to be manufactured using good manufacturing practices so that they do not transfer their constituents to food in quantities which could endanger:

  • Human health, or
  • Bring about an unacceptable change in the composition of the food, or
  • Bring about a deterioration in the organoleptic characteristics of the food

The Swiss law on FCMs contains a number of important provisions, which includes:

  • Utilizing the migration limits for lead and cadmium in ceramics from Directive 84/500/EEC [2] for food contact ceramics, glass, enamel and similar materials
  • Adopting the specific migration limits for eight heavy metals (aluminium, barium. cobalt, copper, iron, lithium, manganese and zinc) in plastics from Regulation (EU) 2016/1416 [3], amending Regulation (EC) 10/2011
  • Adopting test conditions for overall and specific migrations for plastics from Regulation (EC) 10/2011 of January 14, 2011 [4]
  • Requirements for epoxy resins – these are under the scope of plastics
  • Prohibiting the use of bisphenol A (BPA) in polycarbonate baby bottles

The amendment contains two effective dates:

  • May 1, 2017 for the Regulation on food contact materials and articles except for the prohibition of bisphenol A (BPA) in polycarbonate baby bottles
  • May 1, 2018 for the prohibition of BPA in polycarbonate baby bottles

Highlights of the Swiss law on food contact materials and articles are summarized in Table 1.

Regulation of the EDI relating to materials and articles intended to come into contact with food (Consumer Goods Regulation)
SectionFood Contact MaterialHighlight
4Metals and metal alloys

≤ 0.05% lead (Pb)
≤ 0.01% cadmium (Cd)
≤ 0.03% arsenic (As)
≤ 10 mg/kg aluminium (Al) migration for products intended to come into contact with fruit and vegetable juices

Tin and its alloys

At least 97% tin purity and ≤ 0.05% Pb and ≤ 0.01% Cd

Tin as a coating of steel
At least 99.85% purity and ≤ 0.01% for each of Pb and Cd

  • List of authorized substances and their specific migration limits are in Annex II to the EDI Regulations on FCMs
  • CMR substances and nanomaterials are prohibited
  • Compliant with the additives regulation of 25 November 2013 (Zusatzstoffverordnung, ZuV)
  • DoC (in accordance with Appendix 3)

Overall migration
≤ 60 mg/kg for products for infants and young children otherwise ≤ 10 mg/dm²

6Recycled plastics
  • Authorization for recycling required (Article 50 of the Food and Consumers Regulation [Lebensmittel- und Gebrauchsgegenständeverordnung, LGV) and Regulation (EC) 282/2008)]
7Regenerated cellulose films
  • To be manufactured according to substances listed in Annexes 6 and 7
  • Plastic-coated regenerated cellulose films must be manufactured from substances listed in Annex 6 before the coating is applied
  • Plastic coated regenerated cellulose films must be manufactured using substances in Annex 2 and taking the requirements for plastics into consideration  
  • DoC
8Ceramics, glass, enamels and similar articles
  • Requirements for the migration of lead and cadmium are identical to those falling under Directive 84/500/EEC for ceramics
  • DoC
9Paper and cardboard articlesFood must be able to be separated from these materials
10Paraffins, waxes and dyes

Paraffins and waxes

  • Comply with European Pharmacopeia, 8th Edition
  • Substances must not be carcinogenic

According to a list of authorized substances in Article 29

11SiliconesTo be manufactured using substances in Annexes 2 and 9
12Printing inks
  • Prohibited if these are in direct contact with food or migration of color occurs
  • May only be manufactured using substances in Annexes 2 and 10
13Active and intelligent materials and articles
  • Must be manufactured using authorized substances for food
  • Substances in components that are not in direct contact with food or the food environment are to be separated by a functional barrier. These substances must not be CMRs or in nano form
  • Labeling with the words ‘DO NOT EAT’ is required if these can be perceived as edible (e.g. sachet of oxygen scavengers) and if technically feasible, together with ‘DO NOT EAT’ symbol

Example of label



  • DoC (Annex 12)

The following legislation and Annexes in German, French or Italian can be downloaded from the Consumer Goods Section (Gebrauchsgegenstände [5]) of Regulations and Explanations, Food Law 2017, in the FSVO website:

  • Ordinance on materials and articles intended to come into contact with food (Consumer Goods Regulation)
  • Annex 2 ‘Plastics’
  • Annex 9 ‘Silicones’
  • Annex 10 ‘Printing inks’


DoC: Declaration of Compliance
CMRs: Carcinogenic, Mutagenic or Reprotoxic

SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. From overall migration test to expert advices on emerging regulations and compliance issues and documentation review, SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Hing Wo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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