The Swiss Federal Council formally adopted a new regulation on packaging on June 24, 2026, with components of the ordinance entering into force between 2027 and 2032. The ordinance replaces the previous regulation, which focused primarily on beverage containers. The new rules include design and reporting requirements for all packaging materials as well as new collection and recycling criteria for plastic packaging and beverage cartons. “These changes promote the circular economy, strengthen recycling and implement uniform fines for littering throughout Switzerland,” the government’s press release argues.
Under the ordinance, packaging must be limited to the volume and mass necessary to protect the packaged product, be suitable for collection and recycling, and contain as much recycled material as possible. A provision added after the public consultation also states that packaging must not contain substances of very high concern (SVHCs). According to Article 3 of the ordinance, all four requirements apply only “where technically possible and economically viable.” This subjective requirement may weaken implementation and not provide the mandate needed for packaging stakeholders to implement effective changes.
Defining possible and economically viable
What is technically possible and economically viable will still need to be defined. Economic viability is not defined in Article 3 of the new ordinance, though Article 2 defines “state of the art” partly by considering whether a measure is economically viable for “a medium-sized and economically healthy enterprise in the relevant sector.”
An explanatory report published by the Federal Office for the Environment (BAFU) includes some guidance about what the government considers technically feasible. Namely, it is meant to ensure that packaging functionality is maintained. This includes product safety and hygiene, packaging stability and mechanical performance, and the availability and quality of recycled materials. However, there are concerns that this approach could prioritize short-term economic needs of industry operators over the long-term protection of environmental and human health.
As the new SVHC requirement under Article 3 does not come into force until 2030, the Swiss government, packaging industry, and other stakeholders could use the time to develop clear, verifiable definitions for these aspects.
SVHC provision added, but narrower than FPF’s identified need to address chemical safety
The Food Packaging Forum (FPF) submitted comments during the 2025 public consultation on both the Packaging Ordinance and accompanying amendments to the Ordinance on the Prevention and Disposal of Waste (FPF reported). FPF welcomed the regulatory initiative considering the relevant scientific evidence, but it noted that the drafts focused too strongly on collection and recycling while giving insufficient attention to packaging reduction, safe reuse, and chemical safety.
The most direct change corresponding with FPF’s comments is the new requirement concerning SVHCs. The original 2025 draft required packaging to be minimized, recyclable, and made with the highest possible share of recycled material but contained no general chemical safety criteria.
The government’s report on the consultation process identifies FPF among several organizations calling for the restriction or prohibition of toxic substances in packaging. While the final Article 3 attempts to address this by adding a fourth requirement stating that packaging should contain no SVHCs listed under the Swiss Chemicals Ordinance (Article 70), it does not consider the much wider range of over 1,200 known priority hazardous substances that can be present in food packaging as identified in our FCCprio List. This is a potentially critical oversight considering that recycled non-inert materials (such as plastics and paper) have the potential to accumulate (unknown) chemicals of concern across each round of recycling (FPF reported).
Source reduction, reuse, and definitions not properly addressed
FPF had commented that according to the well-established waste hierarchy, Switzerland should prioritize waste prevention and reuse over recycling. Its comments also identified the value of introducing binding packaging reduction and reuse targets, which the explanatory report states are not included in Article 3. Instead, the final ordinance focuses primarily on recycling through the introduction of a 55% and 70% recycling target for plastic packaging and beverage cartons, respectively.
FPF also identified the need to add definitions for the relevant terms of inert, compostable, biodegradable, and novel bio-based packaging. It explained that an enforceable definition of compostability would need to include a defined degradation period, standardized testing considering real world environmental conditions, and confirmation that no toxic residues remain. None of these definitions appear in the government’s adopted text, and the ordinance would benefit from such definitions before it comes into force.
References
Swiss Federal Council (June 24, 2026). “Federal Council strengthens recyclign of packaging and waste.” (in German, French, and Italian).
Swiss Federal Council (June 24, 2026). “Ordinance on Packaging.” (in German, French, and Italian).
Federal Office for the Environment (June 24, 2026). “Explanatory report on the comprehensive revision of the Ordinance on Beverage Packaging (VGV, SR 814.621).” (pdf, in German).
Read more
Federal Office for the Environment. “Waste: Explanatory Reports.” (in German, French, and Italian).
Federal Office for the Environment (June 24, 2026). “Consultation-results report on the Waste and Packaging Ordinances.” (pdf, in German)
