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Switzerland has officially notified the World Trade Organization (WTO) of a draft revision to the Chemical Risk Reduction Ordinance (ORRChem). The proposal introduces new restrictions on several hazardous substances, aligning with the updated EU REACH regulations and the Stockholm Convention on Persistent Organic Pollutants (POPs). 

The public comment period is open until 27 July 2025, providing stakeholders the opportunity to respond to the proposed measures. 

Objective and Rationale 

The revision aims to strengthen the protection of human health and the environment from harmful chemicals. It also supports international harmonization, the use of safer chemical alternatives, and improved recycling practices, while aligning with EU standards and fulfilling Switzerland's commitments under international treaties. 

Responsible Authorities 

• The Federal Office for the Environment (FOEN) is the Primary regulatory authority responsible for drafting and implementing chemical safety measures. 

• The State Secretariat for Economic Affairs (SECO) handles the international trade-related comments and WTO inquiries. 

Key Provisions in the Draft Ordinance 

1. Ban on Dechloran Plus and UV-328: These substances, as well as mixtures and articles containing them, will be prohibited from manufacture, use, and sale, with limited temporary exemptions. 

2. PFAS Restrictions: Based on EU Regulation (EU) 2024/2462, PFHxA and its precursors will be banned from various applications, including food contact materials, cosmetics, ski waxes, and paper-based products. 

3. Microplastic Ban: Preparations containing intentionally added microplastics will be banned, impacting industries such as cosmetics, detergents, fertilizers, pesticides, and artificial sports surfaces. The draft mirrors the phasing and exemptions set out in EU Regulation (EU) 2023/2055. 

4. Lead in PVC: There will be restrictions on the lead content of PVC products, with exemptions for recycled PVC, which is aligned with EU Regulation (EU) 2023/925. 

5. Formaldehyde Emissions: Market restrictions on articles and vehicles exceeding formaldehyde emission limits, in line with EU Regulation (EU) 2023/1464. 

6. Fluorinated Gases and Ozone-Depleting Substances: New controls on hydrofluoroolefins (HFOs), fluorinated ketones, and greenhouse gases in applications such as foams, heating ventilation and air conditioning (HVAC) systems, and aerosols, in accordance with Regulation (EU) 2024/573 and the Montreal Protocol. 

Timeline: 
 
Switzerland notified the draft regulation to the WTO on 28 May 2025. The comment period remains open until 27 July 2025, allowing 60 days for stakeholders to provide feedback. The regulation is expected to be adopted in November 2025, with an intended entry into force on 1 December 2025. 

On 14 April 2025, Switzerland notified the World Trade Organization (WTO) of two proposed amendments to its chemical safety regulations. These amendments aim to enhance public health protection by restricting the availability of certain hazardous substances to the general public and aligning Swiss regulations more closely with the European REACH and CLP frameworks.

Key Provisions of the Amendments

Restriction on CMR Substances for Consumer Use

The draft amendment to the Ordinance on the Reduction of Risks Related to the Use of Particularly Dangerous Substances, Preparations, and Articles (ORRChim) prohibits the supply of substances classified as carcinogenic, mutagenic, or toxic to reproduction (CMR) to the general public. This applies to substances listed in Annex 1 to 6 of Annex XVII of the EU REACH Regulation, as well as mixtures containing these substances when their mass concentration exceeds the threshold defined in the EU CLP Regulation.

These substances may no longer be supplied to the general public in Switzerland after 31 August 2025.

Updates to Classification, Labelling and Testing Requirements

The amendment to the Ordinance on the Protection against Dangerous Substances and Preparations (OChim) updates Annexes 2 and 3 to reflect the latest EU regulations. This includes:

• Incorporation of the 22nd and 23rd Adaptations to Technical Progress (ATPs) under the EU CLP Regulation.

• Updated references to testing methods under Regulation (EC) No 440/2008, OECD Test Guidelines (as of June 2025), and the UN Manual of Tests and Criteria, 8th revised edition with the 2025 amendment.

• Transitional periods allowing the continued supply of noncompliant substances until 30 April 2026 (for the 22nd ATP) and until a future date to be determined for the 23rd ATP.

Expanded Candidate List of Substances of Very High Concern

Following developments at EU level, seven new entries are being added to Annex 3 of ChemO, Switzerland’s list of substances of very high concern (SVHCs). In addition, one existing entry is being updated. The revised list will contain 247 substances and groups of substances, effective 1 August 2025.

Effective Date

Both amended ordinances are scheduled to enter into force on 1 August 2025.

These changes reflect Switzerland's commitment to aligning its chemical safety regulations with the EU's REACH and CLP frameworks to enhance protection for the general public against particularly hazardous substances.

For more detailed information, you can access the full notifications here and here.