Switzerland is strengthening its chemical safety rules for food contact materials (FCMs) and articles to match stricter European Union standards. On June 2, 2025, the Federal Food Safety and Veterinary Office (FSVO) issued RO 2025 395 to amend the nation’s Food Contact Materials Ordinance (RS/SR 817.023.21). The updated measures took effect on July 1, 2025.
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Switzerland Aligns with EU Standards
Switzerland’s regulatory trend of aligning its food packaging and material safety framework with the EU continues, following previous steps discussed in related updates, including Switzerland’s regulations on food contact plastics and previous amendments on food contact materials.
Stricter Limits on Bisphenol A and Similar Chemicals
Key focus of the amendment is bisphenol A (BPA) and its derivatives. According to the new ordinance:
- By way of derogation from section 2.1, BPA may be used as a monomer or starting substance in the manufacture of liquid epoxy resins for application to self-supporting materials or objects with a capacity exceeding 1000 litres.
- Migration into foodstuffs must not be detectable.
- The detection limit is set at 1 µg/kg in food contact. Finished objects coming into contact with foodstuffs must be cleaned and rinsed before being brought into contact with foodstuffs for the first time.
- Extractable BPA must not be detected (ND) at or above a detection limit of 1 µg/kg.
- BPA is now banned entirely in varnishes and coatings for FCMs and articles, except when used as a monomer or starting substance in liquid epoxy resins for large-capacity containers over 1,000 liters.
- ‘Hazardous bisphenols’ are defined as those classified as carcinogenic, mutagenic, toxic to reproduction (CMR) Category 1A or 1B, or endocrine disruptors for human health (ED HH) Category 1. Also, similar prohibitions as the previous are included for ‘hazardous bisphenols’.
Changes to Approved Substance Lists
The ordinance also updates Switzerland’s ‘positive lists’:
- BPA stays permitted for specific uses like polysulfone filtration membranes but under the tight new migration limits.
- Certain substances have been added, revised, or deleted from the permitted lists for plastics and packaging inks. For example, tris(2-ethylhexyl) benzene-1,2,4-tricarboxylate is now allowed, while untreated wood flour and specific mixed esters have been removed.
New Transitional Periods and Documentation Rules
Manufacturers and importers get some time to adapt:
- BPA-based repeat-use FCMs compliant before July 1, 2025, can stay on the market under transitional deadlines extending to January 20, 2029, for some products.
- Updated rules for the Declaration of Conformity (DoC) require detailed disclosure of any bisphenols or derivatives used.
Conclusion
Switzerland’s latest amendment brings its food packaging safety rules closer to the EU’s rigorous standards, and especially on BPA and related chemicals. Businesses handling FCMs and articles should review the new requirements now, adapt manufacturing processes where needed, and update documentation to ensure compliance.
