On July 1, 2026, the Swiss Federal Food Safety and Veterinary Office (FSVO) notified the World Trade Organization (WTO) Committee on Sanitary and Phytosanitary Measures (G/SPS/N/CHE/103) of amendments to the Food Contact Materials and Articles Ordinance. The revision strengthens controls on bisphenol A (BPA) and other bisphenol substances, and updates quality assurance requirements for recycled plastics. The new regulations are scheduled to take effect on August 1, 2026.
Key Amendments
1. Comprehensive Upgrade of Bisphenol Substance Controls
The most notable aspect of this revision is the update to Annex 13 (Coatings and Coatings). Under the new regulations:
- Bisphenol A (BPA) and its salts: Permitted for use only in accordance with EU Regulation (EU) 2024/3190
- Testing methods: Verification methods for non-detectable BPA must have a limit of detection (LOD) of 1 μg/kg
- Definition of hazardous bisphenols/bisphenol derivatives: Substances classified as mutagenic, carcinogenic, toxic to reproduction, or endocrine disruptors (Category 1) under Article 1 of Annex 2 to the Chemicals Ordinance (ChemV)
- Other hazardous bisphenols: Permitted for use only in accordance with Article 5 and Annex II of EU Regulation (EU) 2024/3190
2. Refinement of Migration Testing Rules for Plastic Materials
Annex 4 introduces technical revisions to the rules for assessing compliance with migration limits for plastic materials:
- Analytical method requirements: The linear range of analytical methods must cover at least RL×LMS to RU×LMS (where RU = 2, RL = 0.2), with measurement uncertainty calculated using a specific reproducibility coefficient of variation (CVR) formula;
- Result expression: Migration-specific values shall be expressed using the actual surface area-to-volume ratio (S/V); for containers with a capacity of less than 500 mL or more than 10 liters, as well as films, seals, etc., simplified calculation methods may be used;
- Testing of reusable materials: Reusable materials must undergo three migration tests, with the third test result complying with migration limits, and migration levels must not increase progressively (i.e., the second test result must not exceed the first, and the third must not exceed the second). If scientifically demonstrated that migration levels will not increase, and the initial test does not exceed the limit, compliance may be assumed.
3. Updated Quality Assurance System Requirements for Recycled Plastics
Annex 5 has been completely replaced, imposing stricter requirements on the quality assurance systems implemented by enterprises producing recycled plastics for food contact:
- Recyclers must establish a systematic quality manual, clearly defining organizational structure, management responsibilities, and competency requirements;
- Develop a quality control plan covering raw material specifications, supplier qualifications, sorting, cleaning, deep cleaning, heating, and other critical processes;
- Establish monitoring procedures for critical control points (CCPs) with defined critical limits;
- Implement batch quality assessment ("quality assessment steps") to ensure each batch of recycled material complies with legal requirements, or to determine whether corrective action, rejection, or diversion to non-food contact applications is necessary.
4. New and Revised Authorized Substances
Annex 2 and Annex 10 have been updated to add several new authorized substances or modify the conditions of use for existing substances (for the specific list of substances, please refer to the full text of the regulation).
Transitional Arrangements To allow industry sufficient time to adapt, Switzerland has established differentiated transition periods:
- General products: Products not complying with the new regulations may continue to be imported, manufactured, and labeled under the old regulations until August 1, 2027, and may be sold until that date;
- Reusable finished products: Reusable finished products containing specific substances (Item 136 of Annex 2/10) or not complying with Chapter 2 of Annex 13 or Annex 14 requirements may be imported, manufactured, labeled, and placed on the market under the old regulations until July 20, 2026, and may be sold until July 20, 2027.
