Switzerland Revises Authorized Substance Lists for Food Contact Materials

SafeGuardSHardgoodsDecember 22, 2024

SG 185/24

Switzerland has amended the nation’s positive list for food contact plastics and packaging inks. These will become effective on January 1, 2025.

On December 9, 2024, Switzerland published Official Collection 2024 755 (RO 2024 755) to update two annexes in the nation’s Ordinance on Materials and Articles Intended to Come into Contact with Foodstuffs (RS/SR 817.023.21).

These two annexes are:

Annex 2 ‘List of permitted substances for the manufacture of plastic materials and articles and related requirements’ (Edition 3.2)
Annex 10 ‘List of permitted substances for the manufacture of packaging inks and related requirements’ (Edition 3.2)

Highlights of important changes in these two annexes, when compared to their (previous) Edition 3.1 versions, are summarized in Table A.

Annex to RS/SR 817.023.21 (Edition 3.2)

Highlights of changes

Annex 2
‘List of permitted substances for the manufacture of plastic materials and articles and related requirements’

Table 1 ‘List of substances’:

Strengthens specific migration limit (SML) for each of DBP, BBP and DEHP, as well as the sum DINP and DIDP
Adds group restriction no. 43 in relation to total SML for DBP, BBP and DEHP
Prohibits the use of DINP with DBP, BBP, DEHP or DIBP

Table 2 ‘Group restriction of substances’

Strengthens total SML for the sum of DINP and DIDP under group restriction no. 26
Introduces group restriction no. 43 with a total SML of 0.6 mg/kg for group restriction of DBP, BBP, DEHP and DIBP using a specified equation

(see Table B below for a comparison of changes between Annex 2 in Editions 3.2 and 3.1)

Annex 10
‘List of permitted substances for the manufacture of packaging inks and related requirements’

Table 1 ‘List of substances’

Strengthens SML values for DBP (0.12 mg/kg), BBP (6 mg/kg) and DEHP (0.6 mg/kg)
Adds group restriction no. 43 for each of DBP, BBP and DEHP
Inclusion of adipic acid, dihydrazide (substance no. 1091) and diacetone acrylamide (1421)

Table 2 ‘Group restrictions’

Strengthens group restriction no. 26 for the sum of DINP and DIDP from 9 mg/kg to 1.8 mg/kg
Adds group restriction no. 43 with a total SML of 0.6 mg/kg for DBP, BBP, DEHP and DIBP using a specified formula

Table A

Substance (No)	Annex 2 to RS/SR 817.023.21 ‘Permitted substances for plastics’, Edition 3.2	Annex 2 to RS/SR 817.023.21, Permitted substances for plastics’, Edition 3.1
DBP (160)	0.12 mg/kg (SML) Total SML group restriction nos. 32 and 43	0.30 mg/kg (SML) Total SML group restriction no. 32
BBP (168)	6.0 mg/kg (SML) Total SML group restriction nos. 32 and 43	30.0 mg/kg (SML) Total SML group restriction no. 32
DEHP (621)	0.6 mg/kg (SML) Total SML group restriction nos. 32 and 43	1.5 mg/kg (SML) Total SML group restriction no. 32
DINP (3710)	Total SML = 1.8 mg/kg (sum of DINP and DIDP, group restriction no. 26) Not to be used in combination with substance nos. 160, 168, 621 or 5353 (DIBP)	Total SML = 9 mg/kg (sum of DINP and DIDP, group restriction no. 26)
DIDP (3711)	Total SML = 1.8 mg/kg (sum of DINP and DIDP, group restriction no. 26)	Total SML = 9 mg/kg (sum of DINP and DIDP, group restriction no. 26)

Table B.

The strengthened SML for DBP, BBP, DEHP, DINP and DIDP further aligns Annex 2 in the Swiss legislation with those falling under Commission Regulation (EU) 2023/1442, amending Regulation (EU) 10/2011, on food contact plastics in the European Union (SafeGuardS 89/23)

Abbreviations

Abbreviation	Name	CAS number
BBP	Phthalic acid, benzyl butyl ester	85-68-7
DBP	Phthalic acid, dibutyl ester	84-74-2
DEHP	Phthalic acid, bis(2-ethylhexyl ester	117-81-7
DIBP	Diisobutyl phthalate	84-69-5
DIDP	Phthalic acid, diesters with primary, saturated C₉-C₁₁ alcohols, more than 90 % C₁₀	26761-40-0 68515-49-1
DINP	Phthalic acid, diesters with primary, saturated C₈-C₁₀ branched alcohols, more than 60 % C₉	28553-12-0 68515-18-0

SGS has the expertise to help manufacturers and suppliers of FCM achieve compliance with markets around the globe. Our technical experts have extensive experience of testing materials and articles for many markets. We offer the full range of FCM testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Our experience can ensure your products meet the appropriate territorial regulations for food contact materials and help pave the way for compliance. Contact us to know more or visit our website. In the end, it’s only trusted because it’s tested.

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