Switzerland is proposing to align its chemical restrictions under ORRChem with those of EU REACH. If approved, the new restrictions will be implemented in phases starting December 1, 2019.

SAFEGUARDS | Consumer Products NO. 072/19

SafeGuardS plastic toys

On May 1, 2019, the World Trade Organization (WTO) circulated a notification from the Swiss Federal Office for the Environment (FOEN) announcing a proposal to revise its Ordinance on the Reduction of Risks relating to the Use of Certain Particularly Dangerous Substances, Preparations and Articles (Chemical Risk Reduction Ordinance, ORRChem). The draft amendment (the ‘Order’), in French, German or Italian and attached to WTO document number 19-2977, would align the Swiss Ordinance with many of the recently adopted restrictions from Annex XVII of Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) in the European Union (EU).

The draft amendment contains, inter alia, the following restrictions:

  • BBP, DBP, DEHP and DIBP – less than 0.1% in plasticized materials of an article (Annex 1.18, Art. 3)
  • Decabromodiphenyl ether (Deca-BDE) – prohibited in articles or parts thereof unless its presence is an unavoidable impurity (Annex 1.9, Art. 3)
  • Methanol – no more than 0.6% in windscreen washing or deicing fluids (Annex 2.3, Art. 3)
  • Nonylphenol ethoxylates (NPEs) – no more than 0.01% in textile articles that can be cleaned with water (Annex 1.8, Art. 3)
  • Octamethylcyclotetrasiloxane (D4) or decamethylcyclopentasiloxane (D5) – no more than 0.1% in rinse-off cosmetics (Annex 2.2, Art. 3)
  • Perfluorooctanoic acid (PFOA), its salts and related substances

Interestingly, entry 67 to Annex XVII of EU REACH restricts Deca-BDE to less than 0.1% in articles or parts thereof (Regulation (EU) 2017/227, Safeguard 27/17) without the exemption of unavoidable impurities.

The proposal also amends the existing Swiss regulation on fluorinated greenhouse gases to fulfill the requirements of the Kigali Amendment to the Montreal Protocol on Ozone Depleting Substances (ODSs).

Please see the draft amendment for full details of the proposal.

According to the draft amendment, the ‘Order’ enters into force on June 1, 2019. Certain amended provisions/restrictions to ORRChem will become effective during December 1, 2019 to June 1, 2024.


Entry Acronym Chemical Name CAS Number 
1 BBP Benzylbutyl phthalate 85-68-7
2 DBP Dibutyl phthalate 84-74-2 
DEHP Bis(2-ethylhexyl) phthalate  117-81-7 
DIBP  Diisobutyl phthalate  84-69-5 

Table 1.

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