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Switzerland has taken further steps to align its Chemicals Ordinance (ChemO) with European Union (EU) requirements, specifically concerning the Classification, Labelling and Packaging (CLP) of substances and mixtures, and the Candidate List of Substances of Very High Concern (SVHC). These amendments, detailed in Official Collection 2025 506 (RO 2025 506), came into force on September 1, 2025.
Key Amendments
The amendments primarily focus on two annexes of the ChemO (RS/SR 813.11):
Annex 2 (Technical requirements for CLP): This annex has been updated to reflect amendments to the EU-CLP Regulation that are now applicable to Switzerland's ChemO.
Annex 3 (Candidate List of SVHC): Seven new substances/groups of substances have been added to this list, and the entry for tris (4-nonylphenyl, branched and linear) phosphite (TNPP) has been updated. This expansion increases the Candidate List from 240 to 247 substances/groups of substances.
Newly Added SVHCs
The seven SVHCs added to Annex 3 include substances with various hazardous properties as follows:
| Entry | Substance | EC No. | CAS No. | Reason for inclusion |
| 1 | Bis(α,α-dimethylbenzyl) peroxide | 201-279-3 | 80-43-3 | Toxic for reproduction |
| 2 | Triphenyl phosphate | 204-112-2 | 115-86-6 | Endocrine disrupting properties |
| 3 | 6-[(C10-C13)-alkyl-(branched, unsaturated)-2,5-dioxopyrrolidin-1-yl]hexanoic acid | 701-118-1 | 2156592-54-8 | Toxic for reproduction |
| 4 | O,O,O-triphenyl phosphorothioate | 209-909-9 | 597-82-0 | PBT |
| 5 | Octamethyltrisiloxane | 203-497-4 | 107-51-7 | vPvB |
| 6 | Perfluamine | 206-420-2 | 338-83-0 | vPvB |
| 7 | Reaction mass of: triphenylthiophosphate and tertiary butylated phenyl derivatives | 421-820-9 | 192268-65-8 | PBT |
Obligations for Articles Containing SVHC
Article 71 of ChemO mandates that suppliers of articles containing an SVHC from the Candidate List in a concentration greater than 0.1% must provide certain information spontaneously to the professional user and the trader. These information include:
Name of the substance
All the necessary information at its disposal to allow the safe use of the article
Consumers (general public) are also entitled to receive equivalent information free of charge within 45 days of a request.
Furthermore, manufacturers are obligated to establish and provide a safety data sheet (SDS) for substances and mixtures.
Transitional Provisions
The amendment includes transitional provisions for the CLP of substances and mixtures:
Substances not meeting the requirements of Delegated Regulation (EU) 2024/2564 (22nd Adaptation to Technical Progress (ATP-22) to the CLP Regulation) may be supplied until April 30, 2026.
Substances not meeting the classification and labeling requirements of Delegated Regulation (EU) 2025/1222 (ATP-23) may be supplied until January 31, 2027.
