Reference source : Federal Office for the Environment (FOEN), Switzerland
PFAS Restriction Proposal PFAS in Consumer Products Food Contact Materials FCM Regulatory Consultation
On 27 January 2026, Switzerland notified the World Trade Organization (WTO) of a draft amendment to the Chemical Risk Reduction Ordinance (ORRChem, Fedlaw No. SR 814.81) proposing new restrictions on the use of per- and polyfluoroalkyl substances (PFAS) in food contact materials and single-use consumer goods.
The draft would introduce quantitative PFAS concentration limits in homogeneous materials and prohibit the placing of products exceeding these limits on the Swiss market. The measure aims to protect human health and the environment.
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.
Scope of the Draft Ordinance
According to the notification, the proposed restrictions would apply to:
The assessment is based on PFAS content in homogeneous materials.
Proposed PFAS Concentration Limits:
The placing on the Swiss market would be prohibited if the following limits are exceeded:
1) Individual non-polymeric PFAS ≥ 25 ppb (0.0000025%)
2) Sum of non-polymeric PFAS, including PFAS formed from precursor substances using a state-of-the-art conversion process ≥ 250 ppb (0.000025%)
3) Total PFAS content (non-polymeric and polymeric PFAS combined) ≥ 50 ppm (0.005%) Exceeding any one of these thresholds would result in non-compliance.
Objective and Rationale:
As stated in the notification, the draft amendment aims to strengthen the protection of human health and the environment by limiting exposure to persistent per- and polyfluoroalkyl substances (PFAS). Due to given their high persistence, potential for bioaccumulation, and long-term environmental impact, PFAS require enhanced regulatory control. The amendment also supports the transition toward safer alternatives and improved environmental protection measures.
The proposal may be particularly relevant for:
Timeline:
Switzerland has notified the draft regulation to the WTO. The comment period is open until 28 March 2026, allowing 60 days from the date of notification for stakeholders to submit comments. Comments should be submitted via the Swiss State Secretariat for Economic Affairs (SECO). The regulation is proposed to be adopted on 1 November 2026, with an intended entry into force on 1 December 2026.
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