Switzerland Proposes ChemRRV Update Tightening PFAS Limits And Restricting PFAS Foams

The draft amendment is structured as changes to multiple ChemRRV annexes and includes a staged implementation approach. It states an entry into force of 1 December 2026, with specific annex changes following later in 2027.

Tighter PFOS And Long-Chain PFCA Thresholds

The proposal sets out prohibitions on manufacturing, placing on the market and use of PFOS and its precursor substances, and applies concentration limits to substances, preparations and articles. It also extends controls across other PFAS families, including PFOA as well as C9–C14 PFCA and C15–C21 PFCA and their precursor substances, using low concentration thresholds expressed in parts per billion for key categories.

In practice, these provisions increase the importance of robust material declarations and analytical verification across supply chains, particularly for imported articles where PFAS may be present as unintended contaminants or as performance additives in coatings and polymers.

Restrictions On PFAS In Firefighting Foams

One of the more operationally significant elements is the section on PFAS in foam extinguishing media. The draft defines PFAS for this purpose and introduces prohibitions on placing PFAS-containing foam fire extinguishers and PFAS-containing foam agents intended for such extinguishers on the market. It also prohibits the use of PFAS-containing foam agents in foam extinguishers and in other applications, with limited exceptions for activities such as exercises and functional tests where foam is fully collected and properly disposed of.

For industrial sites and logistics operators holding legacy stocks, the proposal signals that foam transition planning, containment procedures and waste handling capabilities will be scrutinised more closely.

Packaging And Other Risk-Reduction Measures

The draft also introduces restrictions targeting PFAS in packaging and certain single-use food-contact articles, using a combination of per-substance and summed thresholds. Alongside the PFAS-focused measures, the amendment package includes other risk-reduction updates, such as changes relevant to pesticide and biocide use permissions in certain environments.

Summary

The ChemRRV proposal would broaden Switzerland’s PFAS compliance expectations beyond a narrow set of substances, extending to specific product uses and low concentration thresholds. Companies supplying firefighting foams, packaging materials or PFAS-affected articles into Switzerland should assess product composition, identify transition timelines and prepare evidence to demonstrate compliance as the draft moves through consultation and implementation.