The Food Packaging Forum (FPF) submitted comments to the Swiss Federal Office for the Environment’s (FOEN) public consultation on amendments to the Ordinance on the Prevention and Disposal of Waste (VVEA), and new Regulation on Packaging (VerpV) (FPF reported). The consultation closed on October 16, 2025.
The government’s proposals included extended producer-responsibility obligations beyond drinks bottles to all packaging formats, raising recycling targets, prioritizing reuse and recycling over other waste treatment options, and introducing nationwide littering fines and tougher penalties for large-scale illegal dumping.
FPF submitted feedback on both the VVEA and VerpV texts. The following is a shortened version of FPF’s comments. The full comments were submitted in German, but an English translation is available, and both contain information on supporting scientific studies and resources.
Key takeaways
Across both ordinances there were three general themes to FPF’s suggested amendments to the proposed texts.
- Health: FPF’s comments highlight risks from inherently chemically complex, non-inert materials (e.g., plastics, paper/cardboard) and stress the value of inert materials (stainless steel, glass, ceramics) for safe reuse and recycling loops.
- Reuse: The government’s proposed texts assign the same value to recycling and reuse. FPF asks regulators to consider stating unambiguously that reuse comes before recycling in the well-established waste hierarchy and to remove an “economically viable” carve-out that could weaken implementation.
- EU alignment: FPF sees evidence-based requirements and mechanisms in the EU’s Packaging and Packaging Waste (PPWR) that are missing in the Swiss drafts. These include measures on recyclability, reuse targets, recycled content, single use restrictions, and strict limits for all PFAS.
Waste Ordinance (VVEA): clarify the hierarchy and close loopholes
FPF proposed text changes to make preparation for reuse the default, followed by material recovery, and only then energy recovery. This explicitly elevates reuse above recycling and would align the ordinance with the well-established waste hierarchy. FPF also proposed deleting a clause that obligations apply only when “economically viable” as some of these approaches will require additional investments and systems change to sufficiently protect health.
Packaging Ordinance (VerpV): build a safe, circular system
FPF’s feedback focused on the first three Articles within the new Packaging Regulation.
Article 1 defines the scope of the ordinance. FPF identified the need to expand the scope to (i) restrict and/or ban hazardous substances (where not covered by ChemRRV), (ii) require reuse systems, and (iii) mandate labeling such as reusability, recycled content, recyclability, and substances of concern.
Within Article 2, which defines terms, FPF proposed adding definitions for inert packaging, for various materials that are becoming more popular such as biodegradable and compostable, and ensuring a definition of compostable packaging is enforceable (“fully biodegraded within six months in an industrial facility, with no toxic residues”).
For general requirements, Article 3, the available evidence supports minimizing material use while ensuring design for reuse and recycling, stepwise reuse targets, and mandatory labeling. However, FPF recognizes clear risks associated with implementing the draft’s blanket “max recycled content” goals that ignore chemical safety in low-inertness materials (such as plastics and paper) and proposes changes to adapt this aim.
Why it matters
The available evidence shows that recycling alone cannot offset packaging waste without upstream measures. Even where recycling is used, hazardous chemicals can persist or concentrate and expose consumers in non-inert material recycling loops (FPF reported). FPF’s comments explain that focusing on reuse with inert materials and tightening chemical rules in products are necessary to protect public health while advancing circularity in Switzerland.
Ahead of the public consultation, a coalition of ten Swiss civil society organizations announced a set of ten demands for the federal government to address plastic pollution, and the group also submitted comments on the VerpV together with a press release outlining their concerns and suggestions.
References
Food Packaging Forum (October 16, 2025). “Zusammenfassung der eingereichten Rückmeldung: Verordnungspaket Umwelt Frühling 2026.” Bundesamt für Umwelt (BAFU). (pdf, in German).
Food Packaging Forum (October 16, 2025). “Summary of feedback received: Spring 2026 environmental regulation package.” Federal Office for the Environment (FOEN). (pdf).
Read More
Swiss Plastic Action Coalition (October 17, 2025). “Press release: Swiss NGOs call for stronger packaging ordinance: from recycling to real prevention and reuse.” (pdf).
Swiss Plastic Action Coalition (October 2025). “Joint statement: 10 urgent requests from Swiss NGOs to the Federal Council on plastic pollution.” (in French).
