Switzerland is consulting on proposed amendment to the Chemicals PIC Ordinance (ChemPICV). The consultation, initiated by the Federal Department of the Environment, Transport, Energy and Communications (DETEC) runs from 22 December 2025 to 12 April 2026.
The primary goal is to align the ChemPICV with current bans and restrictions under the Chemicals Risk Reduction Ordinance (ChemRRV) and international obligations under the Rotterdam Convention. This amendment would expand the list of substances requiring export notification, ensuring that receiving countries are informed of the risks associated with certain hazardous chemicals and pesticides.
Key Features of the Proposed Amendment
The update concern Annex 1 of the ChemPICV, adding substances that have recently faced strict restrictions or bans in Switzerland.
1. Plant Protection Products and Biocides
New additions include active ingredients banned since 2019 that meet specific hazard criteria, such as:
- Acute Toxicity: Categories 1, 2, or 3.
- CMR Effects: Carcinogenic, mutagenic, or toxic to reproduction (Category 1A or 1B).
- Environmental Hazards: Acute or chronic toxicity to water bodies (Category 1 or 2).
2. Industrial Chemicals
Several substance groups restricted since 2022 are slated for inclusion:
- PFAS Compounds: Perfluorohexanesulfonic acid (PFHxS) and C9–C14-PFCA.
- Specialized Chemicals: Dechloran Plus and UV-328.
- Lead Compounds: Broadening the scope beyond the three currently listed lead pigments to include all lead compounds.
3. SVHCs (Substances of Very High Concern)
Substances listed in Annex 1.17 of the ChemRRV - identified as SVHCs in the EU where the authorization application deadlines have expired - will now be subject to Swiss export notification.
Compatibility and Legal Alignment
- International: The amendment ensures Switzerland’s compliance with the Rotterdam Convention.
- EU Relations: As Switzerland is not bound by EU law, these amendments ensure no conflict with European chemical safety standards.
Expected Impact
On the Federal Government (FOEN)
The Federal Office for the Environment (FOEN) will manage the increased workload of preparing substance dossiers and notifying the PIC Secretariat using existing resources.
On the Economy and Industry
- Administrative Burden: Exporters will face an increase in notification requirements for the newly listed substances.
- Company Profile: Experience suggests that larger companies (100+ employees) are most affected.
- Efficiency: To mitigate the burden, companies can utilize the electronic export notification form available since November 2024.
On Environment and Health
The amendment ensures that importing countries can make informed decisions about hazardous substances originating from Switzerland.
Next Steps for Stakeholders
Affected companies and interested parties are encouraged to review the proposed changes and submit their comments before the 12 April 2026 deadline.
