Switzerland is preparing to update its Chemical Risk Reduction Ordinance (ORRChem) to introduce tighter controls and new bans on PFAS—including their use in food contact materials and firefighting foams—as well as restrictions on MCCPs, selected persistent organic pollutants (POPs), and mercury-containing products. The initiative aims to bring Swiss legislation in line with recent developments in the European Union and under the Stockholm Convention.
On January 27, 2026, the Federal Office for the Environment notified the World Trade Organization of a draft amendment to the Ordinance on the Reduction of Risks relating to the Use of Certain Particularly Dangerous Substances, Preparations and Articles (ORRChem). The proposal introduces stricter regulatory measures and new prohibitions targeting various hazardous substances, with particular emphasis on per- and polyfluoroalkyl substances (PFAS), medium-chain chlorinated paraffins (MCCPs), and mercury. The revised provisions are expected to take effect on December 1, 2026.
Regulatory Background
ORRChem (SR 814.81) is Switzerland’s primary legal instrument for limiting the use of substances that pose significant risks to human health and the environment. The proposed revision seeks to ensure consistency with international obligations, including updates to the Stockholm Convention on POPs and evolving EU requirements, especially in relation to fluorinated greenhouse gases and food safety materials.
Key Regulatory Updates
1. PFAS Restrictions in Food Contact Materials and Firefighting Foams
The draft introduces a new section (Annex 1.16, Chapter 6.3) specifically addressing PFAS in packaging and other materials intended for food contact. It also proposes a ban on the marketing and use of firefighting foams containing PFAS where total PFAS levels exceed 1 mg/L.
For food contact packaging and single-use products, the proposal sets maximum concentration thresholds in homogeneous materials as follows:
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Individual non-polymeric PFAS: 25 ppb
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Total non-polymeric PFAS (including precursors): 250 ppb
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Total PFAS (polymeric and non-polymeric): 50 ppm
In addition, stricter limits are proposed for PFOS and PFOA, with a threshold of 25 ppb for individual substances and 260–1000 ppb for related compounds in mixtures or finished products.
2. Updates on Persistent Organic Pollutants (POPs)
The draft revises Annex 1.1 to explicitly prohibit certain substances, including:
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Medium-chain chlorinated paraffins (C14–C17 with three or more chlorine atoms)
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Long-chain perfluorocarboxylic acids (C9–C21) and related compounds
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Chlorpyrifos, newly added to the list of banned mono-aromatic halogenated substances
The proposed restriction on MCCPs would apply where concentrations exceed 0.1% by mass in substances, mixtures, or articles.
3. Expansion of Mercury Restrictions
The amendment to Annex 1.7 extends the ban on mercury-added products to include photographic films and papers, as well as wheel-balancing weights and related devices.
4. Harmonization on Fluorinated Greenhouse Gases
New packaging and labeling provisions are introduced for unsaturated hydrofluorocarbons (HFOs) listed in Annex II of EU Regulation 2024/573, ensuring alignment with EU regulatory requirements for fluorinated greenhouse gases.
Implementation Timeline and Transitional Measures
The general implementation date is scheduled for December 1, 2026. However, certain measures will include transitional periods to facilitate industry compliance:
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Mercury-added products: Restrictions will take effect on June 1, 2027.
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PFAS in food packaging: Products placed on the market for the first time before December 31, 2027, will be exempt from the new rules.
