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On June 1, 2019, Switzerland entered into force an amendment to its Chemical Risk Reduction Ordinance (ORRChem) that will align it with many of the provisions in Annex XVII of the European Union’s REACH.

First published in May 2005, ORRChem governs the management of substances individually, in mixtures and in articles. It is based, in part, on various EU regulations. These include:

  • Regulation (EC) 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)’
  • Regulation (EC) 1223/2009 ‘Classification, Labeling and Packaging of Substances and Mixtures’
  • Directive 2011/65/EU (RoHS II Directive)
  • Directive 2006/66/EC (Battery Directive)
  • Directive 94/62/EC (Packaging Directive)

It has been updated several times. The latest revision adopts many of the provisions from Annex XVII of REACH. These include entries relating to:

  • Nonylphenol ethoxylates (NPEs)
  • Bis(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), benzyl butyl phthalate (BBP) and diisobutyl phthalate (DIBP)
  • Bisphenol A
  • Decabromodiphenyl ether (Deca-BDE)
  • Perfluorooctanoic acid, its salts and related substances
  • Methanol
  • Octamethycyclotetrasiloxane (D4) and Decamethylcyclopentasiloxane (D5)

The latest amendment also updates the current Swiss regulation on fluorinated greenhouse gases in relation to Ozone Depleting Substances (ODSs).

Stakeholders should be aware there remain some differences between REACH and ORRChem. These are:

  • ORRChem restricts both bisphenol A (BPA) and bisphenol S (BPS) in thermal paper, EU restricts only BPA
  • ORRChem prohibits Deca-BDE in articles unless its presence is an unavoidable impurity, EU restricts it to less than 0.1% with no exemption for unavoidable impurities

The latest amendment came into force on June 1, 2019, and certain provisions/restrictions will become effective between December 1, 2019 and June 1, 2024.

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