The Food Packaging Forum (FPF) submitted comments to the Swiss Federal Office for the Environment’s (FOEN) public consultation on amendments to the country’s Chemical Risk Reduction Regulation (ChemRRV). The consultation closed on April 12, 2026.
The following is a shortened version of FPF’s comments. The full submitted comments are available in German.
Banning PFAS in food contact materials on the Swiss market
Considering the available scientific evidence, FPF supports the proposal to add Section 6.3 into ChemRRV specifically banning the placement of food contact materials onto the market containing PFAS at or above the suggested levels.
This requirement will bring Switzerland in line with and even beyond requirements already being implemented by the EU within its recent Packaging and Packaging Waste Regulation (PPWR; (EU) 2025/40; FPF reported) set to become fully applicable in August 2026. In its explanatory report, the Swiss Confederation correctly provides of an overview of the many known and problematic properties of PFAS, including their diverse range of hazards to both environmental and human health. The Confederation’s initiative to apply the PFAS limits also on empty packaging and articles that can be sold in stores goes beyond the EU’s requirements and is justified considering the evidence for PFAS also in these products.
Expanding the scope
The current proposed legal text limits the PFAS ban to packaging and consumer goods intended for single use. FPF’s FCCmigex Database shows that PFAS are also present on the European market in reusable food packaging and articles, many of which can allow the migration of PFAS into food.
To more fully protect consumer and environmental health, the ChemRRV could be adapted to remove this limitation to single use packaging and articles (thereby also including reusable packaging and articles). Especially considering potential initiatives promoting reusable products, it seems appropriate to avoid this unnecessary restriction.
Reference
Food Packaging Forum (April 9, 2026). “FPF Comments on the Swiss Chemikalien-Risikoreduktions-Verordnung.” (pdf).
