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On January 27, 2026, Switzerland's Federal Office for the Environment (FOEN) notified the World Trade Organization (WTO) a draft revision to the Ordinance on the Reduction of Risks relating to the Use of Certain Particularly Dangerous Substances, Preparations and Articles (ORRChem). The proposed amendment introduces stricter controls and new prohibitions on a range of hazardous substances, with a primary focus on per- and polyfluoroalkyl substances (PFAS), medium-chain chlorinated paraffins (MCCPs), and mercury. The amendments proposed to enter into force on December 1, 2026.
Regulatory Background
The Chemical Risk Reduction Ordinance (ORRChem, SR 814.81) serves as Switzerland's primary legal framework for restricting substances that pose high risks to health and the environment. This revision aims to align Swiss legislation with recent international developments, including updates to the Stockholm Convention on Persistent Organic Pollutants (POPs) and evolving standards within the European Union, particularly regarding fluorinated greenhouse gases and food safety materials.
Key Regulatory Changes
The draft ordinance outlines significant amendments across several annexes of the existing regulation:
1. Restrictions on PFAS in Food Contact Materials and Firefighting Foams
The revision introduces a new section (Annex 1.16, Chapter 6.3) specifically regulating PFAS in packaging and materials intended to come into contact with foodstuffs. Additionally, the draft prohibits the placing on the market and use of firefighting foams containing PFAS if the total PFAS content exceeds 1 mg per liter.
For packaging and single-use articles intended for food contact, the draft establishes the following maximum concentration limits in homogeneous materials:
Individual non-polymeric PFAS, 25 ppb;
Sum of non-polymeric PFASs (including precursors), 250 ppb;
Sum of all PFASs (polymeric and non-polymeric), 50 ppm.
In addition, the draft also tightens regulatory limits for PFOS and PFOA, which are now limited to 25 ppb for pure substances and 260–1000 ppb for related compounds in preparations or finished objects.
2. Regulation of Persistent Organic Pollutants (POPs)
The draft updates Annex 1.1 to explicitly list and prohibit the following substances:
MCCPs (Medium-chain chlorinated paraffins): Specifically chloroalkanes C14-C17 with three or more chlorine atoms.
LC-PFCAs: Long-chain perfluorocarboxylic acids (C9-C21) and related substances.
Chlorpyrifos: Added to the list of prohibited mono-aromatic halogenated compounds.
The prohibition on MCCPs (Annex 1.1) applies if the content in substances, preparations, or articles exceeds 0.1% by mass.
3. Expansion of Mercury Prohibitions
Amendments to Annex 1.7 expand the ban on mercury-containing products. New prohibitions cover photographic films and papers, as well as wheel balancing weights and devices.
4. Alignment on F-Gases
The draft introduces special packaging and labeling requirements for unsaturated hydrofluorocarbons (HFOs) listed in Annex II of EU Regulation 2024/573, ensuring consistency with European standards for fluorinated greenhouse gases.
Implementation and Transitional Periods
The general entry into force date is scheduled for December 1, 2026. However, the ordinance provides specific transitional periods and derogations for certain applications to allow industry adaptation:
Mercury Products: The prohibitions regarding specific mercury-added products (Annex 1.7) will enter into force on June 1, 2027.
PFAS in Food Packaging: Packaging and articles placed on the market for the first time before December 31, 2027, are exempt from the new prohibitions.
