Switzerland Circulates Proposal to Amend ORRChem

Switzerland has notified the World Trade Organization
(WTO) of its proposal to align its Chemical Risk Reduction Ordinance (ORRChem) with
recently adopted European Union (EU) restrictions on dangerous substances,
preparations and articles.

The Federal Office for the Environment (FOEN) circulated
the notification in November 2021. The proposal will align ORRChem with
recently adopted provisions in Annex XVII of Regulation (EC) 1907/2006
Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)
and Regulation (EU) 2019/1021 on persistent organic pollutants (POP Recast

Stakeholders should be aware the draft ordinance contains
important changes to several sections under Annex 1 of ORRChem in relation to
‘Provisions Concerning Specific Substances’. These include:

  • Persistent organic
    pollutants (Annex 1.1)
  • Halogenated organic
    substances (Annex 1.2)
  • Ozone depleting
    substances (Annexes 1.4 and 2.9)
  • Substances stable in
    the atmosphere (Annex 1.5)
  • Asbestos (Annex 1.6)
  • Carcinogenic,
    mutagenic and reprotoxic substances (CMR substances, Annex 1.10)
  • Per- and
    polyfluoroalkyl substances (PFAS, Annexes 1.16 and 2.11)
  • Plastics, their
    monomers and additives (Annex 2.9)
  • Extinguishing agents
    (Annex 2.11 – this is in relation to PFAS in Annex 1.16)

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It is interesting to note that, if adopted, the draft
Ordinance will regulate perfluorohexane sulfonic acid, its salts (PFHxS) and
PFHxS-related substances, a measure that is currently under consideration in
the EU.

For a more in-depth review of the changes,
stakeholders are advised to review SGS’s original SafeGuard 159/21.

This ordinance will also amend the nation’s Plant
Protection Products Ordinance of May 12, 2010.

The draft ordinance contains multiple effective dates:

  • April 1, 2022 – all provisions
  • October 1, 2022 – Annex
    1.16 ‘Per- and polyfluoroalkyl substances’
  • April 1, 2023 – for
    the Plant Protection Products Ordinance of May 12, 2010

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further information contact:

Dr. HingWo Tsang

Global Information and Innovation Manager

(+852) 2774 7420


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