Switzerland Proposes Revision to its Chemical Risk Reduction Ordinance

SafeGuardSToys and Juvenile Products, Automotive, Cosmetics & Personal Care, Electrical & Electronics, Hardgoods, Personal and Protective Equipment, SoftlinesJune 18, 2025

SG 086/25

Switzerland notifies the World Trade Organization (WTO) of draft ordinance to further align the nation’s chemical restrictions under its Chemical Risk Reduction Ordinance (ORRChem) with the EU REACH and the POP Recast Regulation.

In May 2025, the WTO announced a draft law from Switzerland’s Federal Office for the Environment (FOEN) to amend its Ordinance on the Reduction of Risks Relating to the Use of Certain Particularly Dangerous Substances, Preparations and Articles (Chemical Risk Reduction Ordinance, ORRChem, SR/RS 814.81, available in French, German and Italian). The draft ordinance, provided in French and attached to WTO document number 25-3516, would align the Swiss ordinance with several recently adopted restrictions from Annex XVII of Regulation (EC) No 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (Annex XVII of REACH, consolidated version to April 2025) and Regulation (EU) 2019/1021 on persistent organic pollutants (POP Recast Regulation, consolidated version to October 2024).

The draft ordinance plans to regulate, among other things, the following chemicals:

Dechlorane Plus (DP) and UV-328 in accordance with Decisions SC-11/10 and SC-11/11 of the Conference of the Parties to the Stockholm Convention
Lead in polyvinyl chloride (PVC) articles based on Regulation (EU) 2023/925 (SafeGuardS 55/23)
Formaldehyde emissions from articles and the interior of vehicles based on Regulation (EU) 2023/1464 (SafeGuardS 91/23)
Perfluorohexanoic acid (PFHxA) and PFHxA-related substances based on Regulation (EU) 2024/2462 (SafeGuardS 145/24)
Synthetic polymer microparticles (SPM, aka ‘microplastics’) based on Regulation (EU) 2023/925 (SafeGuardS 57/25 and references therein)

Highlights of several changes in the draft ordinance are summarized in Table 1

Section to ORRChem	Highlights of change
Annex 1.1 ‘Persistent organic pollutants (POPs)’	Updates list of prohibited POPs to include 1) perfluorohexane sulfonic acid (PFHxS) and PFHxS-related compounds, 2) dechlorane plus (DP), 3) methoxychlor and 4) UV-328 Adds time-limited derogations for DP and UV-328
Annex 1.2 ‘Halogenated organic substances (HOSs)’	Removes methoxychlor from the list of HOSs (Clause 3b ‘Compounds similar o DDT’)
Annex 1.5 ‘Substances stable in air’	Updates exemptions under prohibition, as well as authorization requirements for imports and exports Updates references from Regulation (EU) No 517/2014 to Regulation (EU) 2024/573 in relation to management of fluorinated greenhouse gases (F-gases)
Annex 1.16 ‘Per- and polyfluoroalkyl substances (PFAS)’	Replaces existing Chapter 4 ‘Fluoroaklysilanols and their derivatives’ with ‘PFAS’ Introduces definitions, requirements and derogations for perfluorohexanoic acid (PFHxA) and PFHxA-related compounds, including but not limited to: ≤ 25 ppb (sum of PFHxA) and ≤ 1,000 ppb (sum of PFHxA-related compounds) for 1) cosmetics, 2) food contact materials and articles, 3) textiles, leather, furs and hides for the general public and 4) mixtures for the general public
Annex 2.9 ‘Plastics, their monomers and additives’	Renews section with a new structure: Introduces and aligns requirements for synthetic polymer microparticles (SPM, microplastics) with the EU < 0.1% lead in mixtures containing PVC or articles containing PVC, with certain exemptions
Annex 2.17 ‘Wood-based articles and other articles containing resin’	Adds formaldehyde emission requirements with several derogations: ≤ 0.062 mg/m³ formaldehyde emission from 1) furniture and wood-based articles and 2) interior of vehicles ≤ 0.08 mg/m³ formaldehyde emission from other articles

Table 1

Additionally, the draft ordinance amends the following sections of the ORRChem:

Annex 1.4 ‘Ozone-depleting substances’
Annex 2.1 ‘Detergents’
Annex 2.2 ‘Cleaning products, air fresheners and cosmetics’
Annex 2.3 ‘Solvents’
Annex 2.10 ‘Refrigerants
Annex 2.11 ‘Extinguishing agents
Annex 2.12 ‘Aerosol generators’
Annex 2.19 ‘Insulating gases in electrical appliances and installations’

If approved, the new measures will be phased in starting December 1, 2025.

We are committed to providing information about regulatory developments for consumer products as a complimentary service. Through our global network of experts and laboratories, we provide a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.

^{© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.}