Key takeaway
What This Development Means
Switzerland has notified a draft ORRChem amendment that would impose strict PFAS thresholds on food contact packaging and other single-use goods. The proposal reflects wider global movement toward group-based PFAS controls and will push packaging and chemicals suppliers to review formulations, documentation and market access risk before the expected December 2026 entry into force.
What PFAS limits does Switzerland propose for food contact packaging?
The draft ORRChem amendment would ban food contact packaging exceeding 25 ppb for a single non-polymeric PFAS, 250 ppb for the total of non-polymeric PFAS, and 50 ppm for the combined total of polymeric and non-polymeric PFAS in the homogeneous material.
When will Switzerland’s PFAS packaging restrictions take effect?
The Swiss Federal Council proposes adoption on 1 November 2026, with the amended ORRChem expected to enter into force on 1 December 2026 following the consultation process and review of stakeholder comments.
Source basis: WTO TBT Notification G/TBT/N/CHE/301
Switzerland Targets PFAS In Food Contact Materials
Switzerland has notified the World Trade Organization (WTO) of a draft amendment to its Chemical Risk Reduction Ordinance (ORRChem) that would introduce strict limits on PFAS in food contact packaging. The proposal, issued by the Federal Office for the Environment (FOEN), aims to restrict the placing on the market of packaging and single-use consumer goods containing per- and polyfluoroalkyl substances above defined thresholds. If adopted, the revised ordinance is expected to enter into force on 1 December 2026.
The measure is designed to protect both human health and the environment by reducing exposure to PFAS, a group of highly persistent chemicals widely used for oil, grease, and water resistance in packaging materials. The proposal forms part of a broader update to Switzerland’s ORRChem framework governing hazardous substances.
Under the draft rules, food contact materials and other single-use items would be prohibited from entering the Swiss market if PFAS levels exceed specific thresholds in the homogeneous material. The limits include:
- 25 parts per billion (ppb) for any single non-polymeric PFAS
- 250 ppb for the sum of non-polymeric PFAS, including those formed from precursor substances
- 50 parts per million (ppm) for the combined total of polymeric and non-polymeric PFAS
These restrictions would apply to packaging intended to come into contact with food as well as other single-use consumer goods.
Alignment With Global PFAS Regulation Trends
PFAS are often described as “forever chemicals” due to their extreme environmental persistence and resistance to degradation. They have been widely used in food packaging coatings, firefighting foams, textiles, and electronics. However, mounting evidence linking PFAS exposure to health risks such as endocrine disruption, immune effects, and certain cancers has prompted regulators worldwide to tighten controls.
The Swiss proposal reflects a growing international policy shift toward group-based PFAS restrictions. Similar regulatory initiatives are currently underway in the European Union, several US states, and other jurisdictions. For manufacturers and importers supplying the Swiss market, this means increasing scrutiny of material formulations and supply chain transparency.
The revised ORRChem amendment also introduces detailed provisions covering other substances and applications, including limits on PFAS in firefighting foams and restrictions on specific persistent organic pollutants.
Implications For The Packaging And Chemicals Supply Chain
For packaging producers, converters, food manufacturers, and chemical suppliers, the proposed PFAS limits will require careful assessment of raw materials and coatings used in food contact products. Companies may need to reformulate barrier coatings, validate alternative fluorine-free technologies, and update compliance documentation.
The consultation period for stakeholder comments runs until 28 March 2026, after which Swiss authorities will consider feedback before final adoption.
Businesses supplying food contact materials to Switzerland should monitor the legislative process closely and begin evaluating PFAS content in their products to avoid potential market access risks.
Summary
Switzerland’s proposed ORRChem amendment introduces strict PFAS limits for food contact packaging and single-use goods. With adoption expected in 2026, the measure reflects global momentum to restrict persistent chemicals and will require packaging producers and supply chains to assess materials, reformulate products, and ensure compliance with new thresholds.
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