Switzerland Revises Food Contact Materials Ordinance

SafeGuardSHardgoodsJuly 01, 2025

SG 094/25

Switzerland has further aligned the nation’s chemical requirements for certain food contact materials (FCMs) and articles with those in the EU. The new measures will become effective on July 1, 2025.

On June 2, 2025, Switzerland’s Federal Food Safety and Veterinary Office (FSVO) issued RO 2025 395 (version in French, German and Italian) to amend the nation’s ordinance on FCMs and articles (RS/SR 817.023.21, available in French, German and Italian).

This amendment aims to harmonize the nation’s safety requirements for, among other things, bisphenol A (BPA) and other bisphenols and bisphenol derivatives in certain FCMs and articles with those in the EU. (SafeGuardS 5/25)

Highlights of RO 2025 395 are summarized in Table 1.

Section to Food Contact Material Ordinance RS/SR 817.023.21	Highlight of amendment
Article 43c (Art. 43c) ‘Transitional provisions’	Provides several transitional provisions for single-use and repeat-use FCMs and articles, including but not limited to: Repeat-use FCMs and articles manufactured with BPA that are compliant with applicable rules before July 1, 2025, may be imported, manufactured, labeled and placed on the market until July 20, 2026 (January 20, 2028, for food production professional equipment), and remain on the market until January 20, 2029
Annex 2 ‘List of substances permitted for the manufacture of plastic materials and articles and related requirements, Edition 3.3’	Modifies positive list: Amends specifications for bisphenol A (BPA, substance no. 136): Permitted to be used as a monomer or starting substance in the manufacture of polysulfone filtration membrane assemblies < 1 µg/kg for BPA migration into food Requires finished goods to be cleaned and rinsed prior to first contact with food Extractable BPA must be not detected (ND) (detection limit = 1 µg/kg) Adds tris(2-ethylhexyl) benzene-1,2,4- tricarboxylate (entry no. 1492) Deletes 1) wood flour and fibers, untreated (5103) and 2) phosphoric acid, mixed esters with 2-hydroxyethyl methacrylate (5350) Redesignates benzophenone-3,3',4,4'- tetracarboxylic dianhydride (BTDA, from entry no. 5351 to 1338)
Annex 10 ‘List of substances permitted for the manufacture of packaging inks and related requirements, Edition 3.3’	Removes BPA (entry no. 136) Revises chemical name and specifications for 1,1,1-trimethylolpropane, ethoxylated (n = 6 – 8), ester with 2-benzoyl-benzoic acid (4956) Modifies specification for neodecanoic acid (5018)
Annex 13, Section 2 Special requirements for varnishes and coatings - ‘Bisphenol A’	Amends BPA requirements: Prohibits BPA and its salts in the manufacture of varnishes and coatings and in the placing on the market of materials and articles coated with a varnish or coating made with BPA Permits BPA as a monomer or starting substance in the manufacture of liquid epoxy resins to be applied on self-supporting materials and articles with a capacity of > 1,000 liters Extractable BPA must be ND (DL = 1 µg/kg)
Annex 13, Section 3 Special requirements for varnishes and coatings - ‘Bisphenols and bisphenol derivatives’	New sub-section on bisphenols and bisphenol derivatives: Details the chemical structures for ‘bisphenol’ and ‘bisphenol derivative’ Defines ‘hazardous bisphenol or hazardous bisphenol derivative’ as a bisphenol or bisphenol derivative with harmonized classification as carcinogenic, mutagenic or toxic to reproduction (CMR) Category 1A or 1B or endocrine disruptor for human health (ED HH) Category 1 (RS/SR 813.11, Chemical Products Ordinance, Annex 2) Prohibits residual BPA if another bisphenol or bisphenol derivative is used in the manufacture of varnished and coated FCMs and articles Prohibits hazardous bisphenols other than BPA, or hazardous bisphenol derivatives, in the manufacture of varnishes and coatings, and items coated with a varnish or coating made from hazardous bisphenols other than BPA or hazardous BPA derivatives Extractable hazardous bisphenol or hazardous bisphenol derivative must be ND (DL = 1 µg/kg)
Annex 14 ‘Declaration of conformity (DoC) for varnishes and coatings’	Revises information requirements for a DoC, such as disclosing the list of bisphenols or bisphenol derivatives used in the manufacture of the FCM or article

Table 1

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