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Switzerland Proposes to Revise its Chemical Risk Reduction Ordinance

SafeGuardSAutomotive, Home Furnishings and Houseware, HG Restricted Substances, Sports and Leisure, Stationery and Office Supplies, Footwear and Leather Products, Home Textiles, Jewelry Bags and Accessories, Personal and Protective EquipmentDecember 07, 2021

Switzerland is proposing to align its chemical restrictions under ORRChem with those of REACH and the POP Recast Regulation in the European Union. If approved, the new measures will be implemented in phases, starting April 1, 2022.

In November 2021, the World Trade Organization (WTO) circulated a notification from Switzerland’s 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 (RS 814.81, Chemical Risk Reduction Ordinance, ORRChem, in French, German or Italian). The draft Ordinance, in German and attached to WTO document number 21-8805), would align the Swiss Ordinance with some of the recently adopted restrictions from Annex XVII of Regulation (EC) 1907/2006 Registration, Evaluation, Authorization and Restriction of Chemicals (Annex XVII of REACH) and Regulation (EU) 2019/1021 on persistent organic pollutants (POP Recast Regulation). 

The draft Ordinance contains important changes to several sections under Annex 1 of ORRChem in relation to ‘Provisions Concerning Specific Substances:’

  • Persistent organic pollutants (Annex 1.1)
  • Halogenated organic substances (Annex 1.2)
  • Ozone depleting substances (Annexes 1.4 and 2.9)
  • Substances stable in the atmosphere (Annex 1.5)
  • Asbestos (Annex 1.6)
  • Carcinogenic, mutagenic and reprotoxic substances (CMR substances, Annex 1.10)
  • Per- and polyfluoroalkyl substances (PFAS, Annexes 1.16 and 2.11)
  • Plastics, their monomers and additives (Annex 2.9)
  • Extinguishing agents (Annex 2.11 – this is in relation to PFAS in Annex 1.16) 

It is interesting to note that the draft Ordinance regulates perfluorohexane sulfonic acid, its salts (PFHxS) and PFHxS-related substances, a measure that is under consideration in the EU

The draft Ordinance also amends the nation’s Plant Protection Products Ordinance of May 12, 2010.

Highlights of certain provisions in the draft Ordinance are summarized in Table 1. 

WTO Document Number 21-8805, November 22, 2021
Draft Ordinance to Chemical Risk Reduction Ordinance, ORRChem

Annex 1 to ORRChem Section No.


1.1 ‘Persistent organic pollutants (POP)’

  • Inclusion of perfluorooctanoic acid (PFOA) and its precursors to Annex 1.16 ‘Per and polyfluoroalkyl substances’

  • Expands the list of banned POP by including PFOA, its salts and PFOA-related substances

  • Repositions pentachlorophenol (PCP, CAS 87-86-5), its salts and esters, and dicofol (CAS 115-32-2) from Annex 1.2 ‘Halogenated organic substances’

1.6 ‘Asbestos’

  • Clarifying that the prohibition of asbestos does not apply to asbestos-containing mixtures and articles if these have been authorized

1.16 ‘Per- and polyfluoroalkyl substances’1

  • Section is replaced with new language and new provisions:

    • It adds PFHxS and PFHxS-related substances:

      • Prohibited as substances on their own

      • ≤ 25 ppb PFHxS as a constituent of other substances, in mixtures or articles

      • ≤ 1,000 ppb PFHxS-related substances as a constituent of other substances, in mixtures or articles

    • It adds perfluorocarboxylic acids containing 9 to 14 carbon atoms in the chain (C9-C14 PFCA), their salts and C9-C14 PFCA-related substances

      • Prohibited as substances on their own

      • ≤ 25 ppb C9-C14 PFCA as a constituent of other substances, in mixtures or articles (sum of C9-C14 PFCA-related substances)

      • 260 ppb C9-C14 PFCA-related substances as a constituent of other substances, in mixtures or articles (sum of C9-C14 PFCA-related substances)

2.9 ‘Plastics, their monomers and additives’

  • ≤ 20 mg/kg (sum of 8 polycyclic aromatic hydrocarbon (PAHs)2 and marked with a unique identification number of the batch) for granules or mulches: 1) as infill material in synthetic tur pitches, or 2) in loose form on playgrounds or in sport applications

  • Prohibits oxo-degradable plastics

2.11 “Extinguishing agents’

  • Clarifies that Annex 1.16 applies to extinguishing agents containing PFOS, PFOA, C9-C14 PFCA and C9-C14 PFCA-related substances 

1Certain derogations apply
2Benzo[a]pyrene (BaP), Benzo[e]pyrene (BeP), Benzo[a]anthracene (BaA), Chrysen (CHR), Benzo[b]fluoranthene (BbFA), Benzo[j]fluoranthene (BjFA), Benzo[k]fluoranthene (BkFA) and Dibenzo[a,h]anthracene (DBAhA)

Table 1

According to the draft Ordinance, there are several effective dates:

  •  April 1, 2022 for provisions other than those indicated below
  • October 1, 2022 for Annex 1.16 ‘Per- and polyfluoroalkyl substances’
  • April 1, 2023 for the Plant Protection Products Ordinance of May 12, 2010

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