Switzerland Notifies WTO on Draft Ordinance for Packaging to Promote Circular Economy

Switzerland has officially notified the World Trade Organization (WTO) of a draft Ordinance on Packaging aimed at reinforcing sustainable packaging practices and advancing the circular economy. The proposed regulation introduces environmental measures that impact the production, design, disposal, and reporting of packaging across all sectors.

The WTO notification was submitted on 10^th July 2025, and the public comment period is open until 8^th September 2025, allowing stakeholders 60 days to provide feedback on the draft.

Objective and Rationale

The draft ordinance is designed to:

• Prevent the unsustainable use of resources
• Promote the circular economy
• Strengthen environmental protection through improved packaging systems

Responsible Authorities

• The Federal Office for the Environment (FOEN) is the lead authority responsible for drafting and implementing the proposed regulation.
• The State Secretariat for Economic Affairs (SECO) is tasked with managing international trade inquiries and WTO-related comments.

Key Provisions in the Draft Ordinance

• Sustainable Packaging Design: Producers and distributors must, where technically and economically feasible, reduce material use, improve recyclability, and increase the use of secondary raw materials.
• Extended Take-Back System: A subsidiary take-back obligation will be introduced for non-refillable plastic packaging and beverage cartons, supporting the development of a nationwide separate collection and recycling system.
• Prepaid Disposal Fees Expansion: The current disposal fee system for glass beverage containers will be extended to cover glass packaging for food and cosmetic products, ensuring the proper financing of waste disposal.
• Expanded Reporting Requirements: Mandatory reporting obligations will be applied to packaging beyond beverage containers, enabling accurate calculation of recycling rates and fostering transparency in the packaging market.
• PVC Packaging Regulation Repeal: Existing rules on PVC beverage packaging will be repealed due to its minimal use in the market.
• Deposit System Simplification: Exceptions to the mandatory deposit scheme on refillable beverage containers will be introduced to streamline usage and encourage reuse.

Timeline

Switzerland submitted the notification to the WTO on 10 July 2025.
The public comment period closes on 8 September 2025.
The regulation is expected to be formally adopted in 2026, with its entry into force scheduled for 1 January 2027.

• Transition period until 1 January 2028 for take-back obligations
• Transition period until 1 January 2029 for reporting requirements