Switzerland Revises Chemical Ordinance to Align with EU CLP and SVHC Standards, Effective September 2025

On July 31, 2025, the Swiss Federal Office of Public Health revised the Chemical Ordinance (ChemO). This update, based on Articles 84a and 84b of the June 5, 2015 ordinance, brings Swiss regulations in line with the EU's latest rules on chemical classification and labeling and the list of Substances of Very High Concern (SVHC). The changes have been fully in effect since September 1, 2025.

Key revisions

1. Annex 2 update: Technical requirements list

1.1 Adoption of the EU CLP Regulation (Classification, Labeling, and Packaging):

Switzerland has incorporated the EU CLP Regulation (Regulation (EC) No 1272/2008) and its subsequent 23 amendments (ATP) into its national legal system. This update includes the latest content from the 22nd ATP (2024/2564) and the 23rd ATP (2025/1222), involving coordinated updates to substance classification and labeling.

1.2 Testing methods

Continued adoption of the following three types of standards:

a. Test methods under the EU REACH Regulation (Reg. (EC) 440/2008)
b. OECD Guidelines for the Testing of Chemicals (June 25, 2025 edition)
c. United Nations 'Manual of Tests and Criteria for Dangerous Goods' Eighth Edition (2023) and 2025 amendments

1.3 Transitional provisions

Non-compliant substances/preparations covered by the 22nd ATP may be sold until April 30, 2026;
Non-compliant substances/preparations covered by the 23rd ATP may be sold until January 31, 2026.

2. Annex 3 update: List of Substances of Very High Concern (SVHC list)

After the update, 7 new SVHC substances have been added, bringing the total SVHC list to 247 items. Click here to view the full list.

New SVHCs

	Substance name	EC number	CAS number	Reason for inclusion
1	Bis(α,α-dimethylbenzyl) peroxide	201-279-3	80-43-3	Reproductive toxicity
2	Triphenyl phosphate	204-112-2	115-86-6	Endocrine disrupting properties
3	6-[(C10-C13)-alkyl-(branched, unsaturated)-2,5-dioxopyrrolidin-1-yl]hexanoic acid	701-118-1	2156592-54-8	Reproductive toxicity
4	O,O,O-triphenyl phosphorothioate	209-909-9	597-82-0	Persistent, bioaccumulative and toxic (PBT)
5	Octamethyltrisiloxane	203-497-4	107-51-7	Very persistent and very bioaccumulative (vPvB)
6	Perfluamine	206-420-2	338-83-0	Very persistent and very bioaccumulative (vPvB)
7	Reaction mass of: triphenylthiophosphate and tertiary butylated phenyl derivatives	421-820-9	192268-65-8	Persistent, bioaccumulative and toxic (PBT)

Enterprises exporting to Switzerland need to make preparations in advance and adjust production and management strategies in a timely manner to avoid compliance risks. CIRS Group will continue to monitor the latest developments in Swiss chemical regulations to assist companies in compliance.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

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