Switzerland Amends Chemicals Ordinance on Substances and Mixtures

SG 129/25

Switzerland has further aligned the country’s Chemicals Ordinance (ChemO) with European Union (EU) requirements.

On August 14, 2025, Switzerland issued Official Collection 2025 506 (RO 2025 506, available in French, German, and Italian) to amend two Annexes under the nation’s Ordinance on Protection against dangerous substances and preparations (Chemicals Ordinance, ChemO, RS/SR 813.11, versions in French, German and Italian):

• Annex 2 (Technical requirements for the classification, labeling and packaging (CLP) of substances and preparations) – by listing amendments to the EU-CLP Regulation that are applicable to Switzerland’s ChemO
• Annex 3 (Candidate List of substances of very high concern (SVHC)) – by adding seven substances/groups of substances and updating the entry for tris (4-nonylphenyl, branched and linear) phosphite (TNPP). This inclusion expands the number of substances/groups of substances on the Candidate List from 240 (RO 2024 404, SafeGuardS 130/24) to 247

Highlights of the seven SVHCs added to Annex 3 of ChemO in the amendment are summarized in table 1.

Table 1

It is important to note that Article 71 to ChemO, ‘Articles Containing SVHC’, requires suppliers of articles containing an SVHC on the Candidate List in a concentration greater than 0.1% to provide professional users or traders of the article with sufficient information, available to the supplier, to allow the safe use of the article. At minimum, this should include the name of the substance. Equivalent information must be provided to consumers (general public) free of charge within 45 days of a request.

Additionally, ChemO outlines a manufacturer’s obligation to establish and provide a safety data sheet (SDS) for substances and mixtures.

RO 2025 506 will enter into force on September 1, 2025.

The amendment provides transitional provisions for the CLP of substances and mixtures:

• Classification and labeling of substances that do not meet the requirements of Delegated Regulation (EU) 2024/2564 (22^nd Adaptation to Technical Progress (ATP-22) to the CLP Regulation) may be supplied until April 30, 2026
• Substances that do not meet the classification and labeling requirements of Delegated Regulation (EU) 2025/1222 (ATP-23) may be supplied until January 31, 2027

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