On January 27, 2026, the Swiss State Secretariat for Economic Affairs (SECO) and the Federal Office for the Environment (FOEN) jointly published a draft amendment to the Chemical Risk Reduction Ordinance (ChemRRV). The draft imposes bans and restrictions on Persistent Organic Pollutants (POPs), mercury, per- and polyfluoroalkyl substances (PFAS), pesticides, and fertilizers.
Main Revisions
I. Persistent Organic Pollutants (POPs) (Annex 1.1)
1. Newly Controlled Substances
- Long-chain Perfluorocarboxylic Acids (PFCAs): Added control over C9-C14 and C15-C21 long-chain PFCAs and their related substances.
- Medium-Chain Chlorinated Paraffins (MCCPs): Added control over MCCPs with carbon chain lengths C14-C17 and containing three or more chlorine atoms, with a limit of 0.1% by weight in substances/preparations.
2. Control of Long-chain PFCAs C9-C21
PFCAs and their precursors are subject to the relevant provisions of Annex 1.16 (i.e., the PFAS section). Their limits, exemptions, and transitional periods are detailed in Annex 1.16 (see PFAS section below).
3. Transitional Periods for MCCPs
MCCPs benefit from extended transitional periods in specific industrial sectors, provided the articles were first placed on the market before specified dates:
|
Application Area |
Conditions |
Transition Period End Date |
|
Aerospace & Defense |
Adhesives, sealants, tapes, coatings (for ammunition marking) |
November 30, 2031 |
|
Metalworking |
Metalworking fluids as high-pressure additives (must be fully collected and professionally disposed) |
December 31, 2036 |
|
Aerospace & Defense |
Pyrotechnic articles (ammunition effects), intumescent coatings and packings, coatings for repairs |
November 30, 2041 |
|
Spare Parts Supply |
Spare parts with MCCPs in coatings/plastics (covering automobiles, agricultural machinery, medical devices, analytical instruments, etc.) |
November 30, 2041 |
Note: After the transitional period ends, use is only permitted in closed systems (ensuring complete collection and disposal).
II. Mercury (Annex 1.7)
1. Prohibition on placing the following mercury-containing products on the market:
- Switches, relays, melt pressure sensors/transmitters/transducers
- Vacuum pumps (including those using mercury)
- Wheel balancing devices and weights
- Photographic film and paper
- Satellite and spacecraft propellants
2. Exemptions:
- Switches/relays/pressure sensors used as spare parts for large-scale tools, large installations, means of transport, etc.
- Mercury vacuum pumps for analytical and research purposes
- Mercury-containing equipment destined for space
III. Per- and Polyfluoroalkyl Substances (PFAS) (Annex 1.16)
A. Core Limit Standards
|
Substance Category |
Limit for Substances/Preparations |
Limit for Articles/Article Components |
|
PFOS and related substances |
25 ppb (single substance) 1000 ppb (sum of related substances) |
25 ppb (single substance) 1000 ppb (sum of related substances) |
|
PFOA, PFCA C9–C14, PFCA C15–C21 |
25 ppb (single substance) 260 ppb (sum of related substances) |
25 ppb (single substance) 260 ppb (sum of related substances) |
B. Other Restrictions
1. PFAS in Firefighting Foam (Article 6.2)
- Definition: PFAS refers to compounds containing at least one perfluorinated methyl (CF₃) or methylene (CF₂) group and containing no hydrogen, chlorine, bromine, or iodine; controlled if total PFAS content in foam is ≥ 1 mg/kg.
- Prohibitions:
-
-
- Placing portable/mobile fire extinguishers and foam containing PFAS on the market.
- Using PFAS-containing firefighting foam in other applications.
-
- Transitional Periods:
-
-
- Fire extinguishers: Ban on market placement effective immediately, but use exempted until December 31, 2031.
- Rail/Road/Civil Airports: Use exempted until December 31, 2027.
- Military Airfields: Use exempted until December 31, 2029.
- Enterprises & Fuel Depots: Use exempted until December 31, 2036.
-
2. Food Contact Materials (Article 6.3) Prohibition on placing the following packaging materials, materials, and articles (single-use) intended for food contact on the market if they contain:
- Any single PFAS non-polymer > 25 ppb
- Sum of PFAS non-polymers > 250 ppb
- Sum of PFAS (non-polymers + polymers) > 50 ppm (0.005%)
- Exemption: Articles first placed on the market before December 31, 2027.
3. Special Restrictions for Long-chain PFCAs (PFCA C15–C21)
- Semiconductors: Exempted until December 31, 2030 (only for spare parts for electronic devices first placed on the market before December 1, 2026).
- Medical Devices: Medical devices containing PFCA C15–C21 first placed on the market before December 1, 2026 are exempted.
- Metered Dose Inhaler Coatings: Exempted until August 25, 2028.
The draft is currently in the notification stage under the EU-EFTA Technical Regulations Information System (TRIS) procedure. The deadline for submitting comments is April 28, 2026. If adopted, the new regulations will come into effect in phases starting from December 1, 2026.
