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Switzerland reports draft restrictions on substances such as PFAS and POPs, involving multiple fields such as food contact materials

Time：

2026-03-18

Switzerland has submitted a draft regulation on reducing the risks associated with the use of certain particularly hazardous substances, preparations, and items, proposing the prohibition and restriction of persistent organic pollutants (POPs), mercury, perfluorinated and polyfluoroalkyl substances (PFAS), pesticides, and fertilizers in various applications, including food contact materials, consumer goods, chemicals, and other fields.

On January 27, 2026, Switzerland submitted a draft law to the World Trade Organization (WTO) to revise its Regulation on the Reduction of Risks from the Use of Certain Specially Hazardous Substances, Preparations, and Articles (ORRChem, Federal Law No. SR 814.81). The draft proposes to prohibit and restrict persistent organic pollutants (POPs), mercury, perfluorinated and polyfluoroalkyl substances (PFAS), insecticides, and fertilizers in various applications.

This revision aims to align Swiss regulations with the latest standards of the European Union and the Stockholm Convention, and strengthen the protection of human health and the environment. Enterprises involved in food contact materials, consumer goods, chemicals and other fields need to closely monitor and prepare for compliance in advance.

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Core content of the draft

1、Update on Persistent Organic Pollutants (POPs) Control

The draft explicitly adds the following substances as controlled substances:

Material Category	Specific Scope	Control Requirements
Medium chain chlorinated paraffins (MCCPs)	C14-C17 chlorinated alkanes with ≥ 3 chlorine atoms	Prohibited from being placed on the market if the content in a substance, mixture, or item exceeds 0.1%
Long chain perfluorocarboxylic acids (LC-PFCAs)	C9-C14 PFCAs and C15-C21 PFCAs and related substances	Include in control
chlorpyrifos	-	Added as a prohibited substance

2、Strict restrictions on perfluorinated and polyfluoroalkyl substances (PFAS)

This is the focus of this revision, as the draft sets extremely strict limit standards for PFAS:

Limit values for food contact packaging and disposable consumer goods (in homogeneous materials):

Limit Type	Limit Type	Exceeding the standard is prohibited from being put on the market
Single non aggregated PFAS	>25ppb (0.0000025%)	√
Total non aggregated PFAS (including precursor conversion)	>250ppb (0.000025%)	√
Total sum of aggregated and non aggregated PFAS	>50ppm (0.005%)	√

Other PFAS related requirements:

Material/Application	Limit Requirement
PFOS and its related substances	PFOS≤25ppb； Total PFOS related substances ≤ 1000ppb
PFOA, C9-C21 PFCAs and related substances	PFOA/LC-PFCAs≤25ppb； The total amount of related substances is ≤ 260ppb
Fire foam	All PFAS total<1mg/L

3、Expansion of mercury ban scope

The draft expands the scope of the ban on mercury containing products, adding new prohibited products including:

Photographic film and paper

Wheel balance counterweight device and counterweight block

4、Adjustment of pesticide and fertilizer management

The draft has adjusted the usage standards and approval requirements for plant protection products and fertilizers, with a focus on the ban on microplastics

Prohibition of placing formulations containing microplastics on the market, directly affecting the pesticide and fertilizer industries

Consistent with EU Regulation (EU) 2023/255

Definition of Microplastics: Solid, ≤ 5mm, polymer content ≥ 1%

The deadline for soliciting opinions on the draft is March 28, 2026. If approved, the new measures will be implemented in stages starting from December 1, 2026. It is recommended that relevant enterprises conduct a comprehensive review of product compliance, with a focus on investigating whether there are newly added POPs substances (such as MCCPs, LC-PFCAs, and chlorpyrifos), evaluating whether the PFAS content exceeds the limit, paying attention to the transition period arrangement, finding alternative solutions for PFAS applications that exceed the limit (such as food contact materials), and communicating with suppliers to ensure that the raw materials meet the new regulations.

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