Key takeaway
What This Development Means
Switzerland is consulting on changes to the ChemRRV that would tighten limits for PFOS and long-chain PFCA, define PFAS for certain uses and restrict PFAS in firefighting foams and some food-contact packaging.
What PFAS-related measures are included in the draft ChemRRV amendment?
The draft sets or updates concentration thresholds for PFOS and its precursors, and for PFOA and longer-chain PFCA and their precursors, applying to substances, mixtures and articles. It also introduces provisions on PFAS in certain uses, including prohibitions on placing PFAS-containing foam extinguishers and foam agents on the market and restricting PFAS above defined levels in certain food-contact packaging and single-use articles.
What should companies do now if they supply foams, packaging or treated goods into Switzerland?
Map where PFAS may be present in products, mixtures or components, including legacy formulations and impurities, and confirm whether any exemptions apply to specific use cases. For firefighting equipment and foam stocks, plan transitions to non-fluorinated alternatives and ensure procedures exist to fully capture and dispose of PFAS-containing foam where permitted for tests. For packaging, engage suppliers early to validate material composition against the draft thresholds.
Switzerland is proposing a wide-ranging update to its Chemicals Risk Reduction Ordinance (ChemRRV) that would tighten controls on several persistent and hazardous substance groups, including PFOS and longer-chain perfluorocarboxylic acids (PFCA), and add new restrictions for PFAS-containing firefighting foams and certain packaging.
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.
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