Switzerland has officially submitted Draft Ordinance 2026/9003/CH to the EU under the Technical Regulations Information System (TRIS) procedure. The draft, prepared by the Swiss State Secretariat for Economic Affairs (SECO) and the Federal Office for the Environment (FOEN), proposes amendments to the Ordinance on the Reduction of Risks relating to the Use of Particularly Dangerous Substances, Preparations, and Articles.

The notification was received by the EU Commission on 27 January 2026, and the standstill period for stakeholder comments runs until 28 April 2026. This allows EU Member States, industry representatives, and civil society to review and provide feedback before the ordinance is adopted.

Key Regulatory Highlights

The draft ordinance primarily targets hazardous chemicals, including PFAS, in consumer products and food contact materials:

  • Scope: Packaging, single-use consumer goods, and articles in contact with food.
  • Prohibition thresholds for PFAS:
  • Non-polymeric PFAS ≥ 0.0000025 % (25 ppb)
  • Sum of non-polymeric PFAS ≥ 0.000025 % (250 ppb)
  • Total PFAS content ≥ 0.005 % (50 ppm)

These limits align with EU chemical management approaches and reflect growing global regulatory pressure to reduce PFAS exposure. Manufacturers placing products on the Swiss or EU market will need to ensure compliance through testing, declarations, and supply chain verification.

Regulatory Context

The TRIS procedure under Directive (EU) 2015/1535 serves to prevent trade barriers by notifying EU authorities of draft technical regulations in other countries. This process allows:

  • Early identification of potential trade impacts
  • Feedback from EU Member States, industry, and civil society
  • Alignment of Swiss rules with EU chemicals regulations

The TRIS system helps ensure that regulations affecting consumer safety and chemical use are transparent and harmonized across borders.

Implications for Industry

  • Compliance Requirements: Companies producing or importing packaging or food-contact products into Switzerland and the EU must assess PFAS content and ensure it does not exceed threshold levels.
  • Supply Chain Verification: Tier-1 and Tier-2 suppliers may need to provide detailed chemical declarations and testing data.
  • Testing & Reporting: Analytical testing for PFAS will be critical, especially for non-polymeric PFAS that are often present in trace amounts.
  • Market Access: Non-compliant products could face restrictions or bans under the new ordinance.

Next Steps & Stakeholder Action

  • Stakeholders can submit comments and feedback to the Swiss authorities during the standstill period until 28 April 2026.
  • Monitoring updates via the EU TRIS notification portal is recommended for manufacturers, importers, and regulatory compliance teams.

Conclusion:

The Swiss draft ordinance 2026/9003/CH represents a significant tightening of PFAS regulations in consumer goods and food contact materials, reflecting global trends toward safer chemical management. EU and international stakeholders should proactively review the thresholds, evaluate supply chains, and prepare for regulatory alignment to ensure smooth market access.

Source: Switzerland PFAS Rules 2026

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