In a decisive step to protect public health and reinforce chemical safety, Switzerland will enforce a nationwide ban on bisphenol A (BPA) and other hazardous bisphenols in food contact materials (FCMs) from 1 July 2025, under a revised ordinance (RS 817.023.21) issued by the Federal Food Safety and Veterinary Office (FSVO).

The Regulatory Update

On 2 June 2025, the FSVO published Announcement RO 2025 395, amending the existing FCM ordinance to explicitly prohibit the use and marketing of coatings and varnishes made with BPA and other bisphenols classified as hazardous under Swiss chemical regulations.

Under the new regulation:

BPA and its salts: are banned in varnishes and coatings for all food contact products, except for certain industrial containers over 1,000 L, subject to ultra‑low migration limits (≤ 1 μg/kg) and mandatory cleaning before food use.
"Hazardous bisphenols": those classified as carcinogenic, mutagenic, toxic for reproduction (CMR 1A/1B) or endocrine disruptors (ED Category 1) are also prohibited in coatings and varnishes used in food‑contact articles.
Any coated item made using other bisphenols or bisphenol derivatives must be free from residual BPA (limit of detection 1 μg/kg).

Key Provisions and Definitions

Structural definition of hazardous bisphenols: The FSVO limits its scope to chemicals whose phenolic rings are bridged by a single atom, per Annex 13 of the ordinance. This means substances like bisphenol M and bisphenol P, whose bridging groups involve benzene rings, fall outside the prohibition despite emerging health concerns.
Strict migration thresholds: Finished goods must demonstrate non-detectable levels of BPA or hazardous bisphenols, using validated methods sensitive to at least 1 μg per kilogram of food.
Declaration of Conformity (DoC): Suppliers must now provide detailed disclosures listing all bisphenols or derivatives used in the product’s manufacture.

Product Type

Single-use FCMs manufactured before 1 July 2025:

· Allowed until 20 July 2026

· Must be removed after 20 July 2026

Reusable or professional-use FCMs:

· Allowed until 20 January 2028

· Must be off market by 20 January 2029

These transitional provisions apply only to pre‑existing compliant inventory; new products must comply immediately post-1 July 2025.

Alignment and Divergence with EU Standards

Switzerland’s new regulations largely mirror the EU’s ban on BPA in food contact materials, which came into force in January 2025, under EU Regulation 2024/3190, with an 18‑month phase‑out period. Both regulatory regimes extend the ban beyond BPA to other bisphenols classified as hazardous (CMR or endocrine disruptors).

However, Switzerland imposes more stringent detection limits (≤ 1 µg/kg) and explicitly bans hazardous bisphenols beyond BPA in coatings, thus raising the bar for compliance More critically, Switzerland’s narrower chemical definition excludes bisphenol M and P possibly undermining the scope of health protection.

Health and Industry Implications

Public Health Focus

BPA has been widely studied for potential endocrine-disrupting effects affecting reproductive health, development, and immune function. In response, many jurisdictions including the EU have significantly tightened safe intake levels and restricted its use in food contact items.

By banning hazardous bisphenols alongside BPA, Switzerland intends to reduce chemical exposure and protect sensitive populations. Yet, the exclusion of bisphenol M and P may leave critical gaps, as regulatory agencies such as the European Chemicals Agency (ECHA) are currently evaluating bisphenol M for endocrine disruption.

Regulatory and Business Impact

The updated ordinance affects a wide range of sectors including packaging, coatings, printing inks, kitchenware, and industrial containers. Companies supplying Swiss markets will need to:

Reformulate coatings, varnishes, and inks,
Invest in ultra-sensitive testing and document reporting,
Review supply chains to ensure traceability and transparency.

However, Switzerland’s policy also sends a clear signal: harmonisation with EU standards is underway, meaning exports to Europe must already adhere to similar constraints. Companies serving both markets may benefit from unified compliance approaches.

Critical Perspectives and Future Outlook

Experts and advocacy groups have welcomed Switzerland’s bold regulatory step as a significant safeguard for chemical safety. But critics caution that restricting only a subset of bisphenol structures is insufficient. They emphasise the need for broader chemical definitions and inclusion of emerging analogues under scrutiny as bisphenol M demonstrates potential endocrine effects under ECHA review RTS Lab.

Moving forward, stakeholders will watch whether subsequent amendments address these gaps by expanding the definition of harmful bisphenols and requiring regulation of more structural variants.

Conclusion

From 1 July 2025, Switzerland banned the use and sale of coatings containing BPA and specific hazardous bisphenols in food contact applications with only narrowly defined exemptions and very low migration thresholds. While the move aligns broadly with EU law, Switzerland’s stricter analytical requirements and extended coverage of bisphenols underscore its commitment to protecting public health.

Yet, the fragmented regulatory definition may leave certain bisphenol substitutes unregulated, signalling a need for future expansion as scientific understanding of alternative compounds like bisphenol M and P evolves. For business sectors globally, these developments underscore the shifting regulatory landscape and the importance of proactive compliance and transparency.

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