As of February 1st, 2024, Switzerland has implemented Official Collection 2023 836, a list of significant revisions to the Swiss Ordinance that governs materials and articles in contact with food (Materials and Articles Ordinance, 817.023.21). These changes, mark a collective effort to align Swiss regulations with those of the European Union.
TABLE OF CONTENTS
Scope of the Swiss Ordinance Amendments
The amendments primarily aim to harmonize Switzerland’s regulations with Regulation (EU) 2020/1245, an update to Regulation (EU) 10/2011 regarding food contact plastics. This includes the revision of the permitted lists of substances in Annexes, the integration of scientific and technical advancements and the implementation of Directive 84/500/EEC for ceramics, glass, enamels, and similar materials, and Regulation (EU) 2022/1616 for recycled plastic materials in contact with foods.
Important Changes
Several regulatory updates have been introduced across various sections, regarding different materials and substances:
- Recycled Plastics (Section 6): Article 20 clarifies that the recycling process of food contact plastics must be authorized by the Federal Office for Food Safety and Veterinary Affairs (BLV) or comply with Regulation (EU) 2022/1616.
- Packaging Inks (Section 12): Article 35 requires packaging inks to be made from substances listed in Annexes 2 and 10, or salts under Article 35b. A detection limit of 0.01 mg/kg applies to all other substances (Article 35b), unless the use of substances has a specific detection limit and they are not classified as CMR substances (carcinogenic, mutagenic or toxic to reproduction substances). Article 35a also requires packaging inks to establish a declaration of conformity (DoC).
Annex Updates
- Annex 10: Revision of the list and specifications for packaging inks to Edition 3.
- Annex 15: Introduction of a new section detailing information required for each stage of packaging inks production.
Transition Process
According to the amendment, food contact materials and articles failing to comply with DoC requirements for packaging inks have until January 31st of 2026 to adhere to the new regulations (same year as German printing ink legislation comes into force). Similarly, items not meeting other provisions may continue being sold under the previous law until January 31st, 2025, with sales permitted until their stocks are depleted.
Conclusion
These changes in regulation reflect Switzerland’s commitment in ensuring safety and integrity of materials and articles in contact with food, and also mark the harmonization of the nation’s laws with EU standards. As these amendments are set, stakeholders across industries are urged to familiarize themselves with the updated regulations to ensure compliance and maintain consumer health in food safety.
If you want to learn more on the legislation governing your plastic packaging, contact our team of experts.
