Switzerland Proposes Strict PFAS Limits for Food Contact Packaging and Single-Use Articles

Switzerland has proposed amendments to the Chemical Risk Reduction Ordinance (ORRChem) to prohibit placing on the market food-contact packaging and single-use consumer goods containing PFAS above very low concentration limits from December 1, 2026, with transitional measures until the end of 2027.

On January 27, 2026, Switzerland's Federal Office for the Environment (FOEN) notified the WTO of a draft amendment to the Ordinance on the Reduction of Risks relating to the Use of Certain Particularly Dangerous Substances, Preparations and Articles (Chemical Risk Reduction Ordinance, ORRChem). Under notification G/TBT/N/CHE/301, the Swiss authorities have proposed a prohibition on the placing on the market of food packaging and single-use consumer goods that contain Per- and Polyfluoroalkyl Substances (PFAS) exceeding specific threshold limits. The proposed amendments are scheduled to enter into force on December 1, 2026.

Scope and Definitions

The draft ordinance introduces a new section (Annex 1.16, Section 6.3) specifically targeting PFAS in packaging, materials, and articles intended to come into contact with foodstuffs. The regulation applies to packaging intended for food contact as well as other single-use materials and articles defined under Article 48 of the Ordinance on Foodstuffs and Utility Articles.

The regulatory definition of PFAS within this draft encompasses substances containing at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, without any hydrogen, chlorine, bromine, or iodine attached to it. The text provides specific structural exclusions for certain substances possessing only specific CF3-X or -CF2-X' groupings.

Compliance Thresholds

The core compliance requirement involves strict mass content limits for PFAS in homogeneous materials. The placing on the market of covered products is prohibited if they exceed any of the following values:

Individual Non-Polymeric PFAS: A mass content of 0.0000025% (25 ppb) for at least one non-polymeric PFAS.
Sum of Non-Polymeric PFAS: A mass content of 0.000025% (250 ppb) for the sum of non-polymeric PFAS, including those formed by conversion from precursor compounds.
Total PFAS Content: A mass content of 0.005% (50 ppm) for the sum of all non-polymeric and polymeric PFAS.

Implementation Timeline and Transitional Measures

The Swiss Federal Council proposes to adopt this ordinance by November 1, 2026, with an entry into force date of December 1, 2026. However, the draft text includes a transitional provision to allow industry adaptation. The prohibition under section 6.3.2 will not apply to packaging, materials, and articles placed on the market for the first time before December 31, 2027.

The consultation period for this draft regulation is open, with the final date for comments set for March 28, 2026.