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Switzerland to Align CMR Substance Requirements with REACH

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 10, 2021

Switzerland is intending to further align with EU REACH by adapting CMR substances from ATPs-15 and 17 of the CLP Regulation to its Chemical Risk Reduction Ordinance. These are proposed to be implemented in phases, starting March 1, 2022.

In the European Union (EU), entries 28 to 30 of Annex XVII of Regulation (EC) 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (Annex XVII of REACH, consolidated version to October 2021) regulate carcinogenic, mutagenic and reprotoxic category 1A or 1B substances (CMR category 1A or 1B substances). These CMR substances are prohibited to be placed on the market, or used, as substances, as constituents of other substances or in mixtures for the general public when their individual concentration in the substance or mixture is equal to or greater than their specific concentration limit (SCL), or in the absence of an SCL, their generic concentration limit (GCL), under Regulation (EC) 1272/2008 ‘Classification, Labeling and Packaging of Substances and Mixtures (CLP Regulation, consolidated version to October 2021).

 In Switzerland, Annex 1.10 to the Chemical Risk Reduction Ordinance (ORRChem, SR 814.81, in French, German or Italian) regulates CMR category 1A or 1B substances with provisions similar to those falling under entries 28 to 30 of Annex XVII of REACH. In the event of amendments to Appendixes 1 to 6 under entries 28 to 30 of Annex XVII of REACH, Switzerland’s Federal Office of Public Health (FOPH), in agreement with the Federal Office for the Environment (FOEN) and State Secretariate for Economic Affairs (SECO), adapts those amendments to its national law. 

 In October 2021, Switzerland’s FOPH announced its intention to add 26 CMR substances to Annex 1.10 of its ORRChem – 18 substances are adopted from Regulation (EU) 2020/1182 (ATP-15 to the CLP Regulation, SafeGuardS 122/20) and 8 substances are adopted from Regulation (EU) 2021/849 (ATP-17 to the CLP Regulation, SafeGuardS 76/21). These 26 CMR substances consist of: 

  • 8 carcinogenic category 1B substances, including dibenzo[def,p]chrysene (CAS 191-30-0) - a polycyclic aromatic hydrocarbon (PAH)
  • 2 substances that are both carcinogenic category 1B and mutagenic category1B
  • 16 reprotoxic category 1B substances, including diisooctyl phthalate (CAS 27554-26-3) – a phthalate

There are two effective dates:

  • March 1, 2022 for substances adopted from ATP-15 to the CLP Regulation
  • December 17, 2022 for substances adopted from ATP-17 to the CLP Regulation

Both of the aforementioned effective dates are consistent with those in ATPs-15 and 17 to the CLP Regulation.

SGS keeps interested parties informed about the latest developments relating to the REACH regulation. Our expertise, combined with consultancy services and experience in consumer product supply chains, provides a central point of contact for global solutions. In the end, it’s only trusted because it’s tested. Discover more on our website, read our brochure and contact us if you would like to learn more about how SGS can support your REACH compliance activities. 

For inquiries, please contact:

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

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