Switzerland has aligned its chemical restrictions under ORRChem with many of the provisions in EU REACH. The amendment entered into force on June 1, 2019.

SAFEGUARDS | Consumer Goods NO. 091/19

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The Swiss Chemical Risk Reduction Ordinance (ORRChem) is a comprehensive piece of legislation governing the management of substances on their own, in mixtures and in articles.

First published in May 2005, the ORRChem is in part based on several pieces of EU legislation and has been revised on several occasions. These include, inter alia, the following:

  • Regulation (EC) 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)’
  • Regulation (EC) 1272/2008 ‘Classification, Labeling and Packaging of Substances and Mixtures’
  • Directive 2011/65/EU (RoHS II Directive)
  • Directive 2006/66/EC (Battery Directive)
  • Directive 94/62/EC (Packaging Directive)

The ORRChem contains four Chapters and two Annexes for the management of chemicals:

  • Chapter 1 ‘General Provisions’
  • Chapter 2 ‘Use of Substances, Preparations and Articles’
  • Chapter 3 ‘Enforcement’
  • Chapter 4 ‘Final Provisions’
  • Annex 1 ‘Provisions Relating to Specific Substances’
  • Annex 2 ‘Provisions Relating to Groups of Preparations and Articles’

The restrictions and prohibitions in Chapter 2 on the use of specific substances, preparations and articles, together with exemptions, are regulated in Annexes 1 and 2.

In May 2019, the World Trade Organization circulated a notification announcing Switzerland’s intention to amend its ORRChem (Safeguard 72/19). This was, in part, to align with many of provisions from Annex XVII of REACH.

Switzerland has published amendment of April 17, 2019 to strengthen its ORRChem. This comprehensive revision, in French, German and Italian, contains many of the provisions from the newly added restrictions to Annex XVII of REACH in the European Union (EU). Some of these provisions include:

The revision also amended the existing Swiss regulation on fluorinated greenhouse gases in relation to Ozone Depleting Substances (ODSs).

This amendment entered into force on June 1, 2019. Certain provisions/restrictions in the amendment will become effective between December 1, 2019 and June 1, 2024.

Major highlights of the amendment for restricted substances are summarized in Table 1.

Ordinance on the Reduction of Risks Associated with the use of Particularly Dangerous Substances, Preparations and Articles (ORRChem)
Amendment of April 17, 2019
Section Substance Scope Requirement Effective Date
Annex 1.8 NPEs Textile fibers, semi-finished or finished textile products that can be cleaned with water ≤ 0.01% June 1, 2022
Annex 1.9 Deca-BDE
Used in the manufacture of or placed on the market:
  • As a constituent of another substance
  • In a mixture
  • In an article
Prohibited* December 1, 2019
Annex 1.10
Thermal paper
≤ 0.02% each
June 1, 2020
Annex 1.16
PFOA, its salts and related substances
Manufacture, place on the market or use of substances
June 1, 2021
  • Constituent of another substance
  • Mixture
  • Articles or parts thereof

≤ 25 ppb for PFOA and its salts

≤ 1,000 ppb for PFOA-related substances

June 1, 2021**
Annex 1.16
silanols and their derivatives

  • Sprays
  • Mixtures for spray refills
≤ 2 ppb
December 1, 2020
Annex 1.18
Plasticized materials in articles***
≤ 0.1%
July 7, 2020
Annex 2.2
D4 and D5
Wash-off cosmetic products
≤ 0.1% each
June 1, 2021
Annex 2.3
Windscreen washing or defrosting fluids
≤ 0.6%
June 1, 2019

*Unless presence is an unavoidable impurity
** Certain articles have different effective dates
*** Certain exemptions apply

Table 1

It is interesting to note the following differences between Switzerland and Annex XVII of EU REACH:

  • ORRChem restricts both BPA and bisphenol S (BPS) in thermal paper whereas the EU restricts only BPA
  • ORRChem prohibits Deca-BDE in articles unless its presence is an unavoidable impurity whereas the EU restricts the same substance in articles to less than 0.1% without the exemption of unavoidable impurities

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides 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. Please do not hesitate to contact us for further information.


Stakeholders are advised to comply with the latest requirements in ORRChem for the Swiss market.

For enquiries, please contact:

Hingwo Tsang
Global Information and Innovation Manager
t: (+852) 2774 7420

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