WTO Circulates the Notification of Switzerland Regarding Adaptation of Annex 1.10 of the Chemicals Risk Reduction Ordinance

"On April 14, 2025, the World Trade Organization (WTO) circulated the notification of Switzerland regarding the draft adaptation of Annex 1.10 of the Chemicals Risk Reduction Ordinance (ChemRRV; SR 814.81). This adaptation incorporates updates from Commission Regulation (EU) 2025 and Commission Delegated Regulation (EU) 2024/1973 (21st ATP of the CLP Regulation), aligning Swiss law with changes to the EU-REACH Regulation. According to Annex 1.10 of ChemRRV, carcinogenic, mutagenic, and reprotoxic substances (CMR substances) may not be sold to the general public. The ban also applies to preparations containing CMR substances if the mass content exceeds the concentration limits defined in Annex I, Section 1.1.2.2 of Regulation (EC) No. 1272/2008 (CLP Regulation). These limits are based either on substance-specific concentration thresholds in Annex VI of the CLP Regulation or on general concentration limits for the respective hazard class if no specific limit exists. The draft revision adds 16 new substances to Annexes 1–6 of Annex XVII of the EU-REACH Regulation, which are referenced in Annex 1.10, point 1, paragraph 1 of the ChemRRV. These substances have been newly classified as CMR substances and, as such, will be subject to a ban on sale to the general public starting September 1, 2025. The relevant annexes are regularly adapted through ATPs (Adaptations to Technical Progress) to reflect updates in classification and labelling. Proposed date of entry into force is 1 August 2025 with transition period until 31 August 2025 and comment by date is 60 days from the notification (i.e. June 13, 2025) The 16 substances newly classified as CMR under the 21st ATP , some of chemicals are: 4-nitrosomorpholine; N,N-dimethyl-p-toluidine; 4-methylimidazole; diuron (ISO); 3-(3,4- dichlorophenyl)– 1,1- dimethylurea; 2,2',6,6'-tetrabromo–4,4'- isopropylidenediphenol;tetrabromobisphenol-A; 1,4-Benzenediamine, N,N’-mixed Ph and tolyl derivs; benzyl(diethylamino) diphenylphosphonium 4-[1,1,1,3,3,3- hexafluoro- 2-(4-hydroxyphenyl)propan-2-yl] phenolate; diphenyl(2,4,6- trimethylbenzoyl) phosphine oxide; reaction mass of 1-(2,3-epoxypropoxy)–2,2-bis ((2,3- epoxypropoxy)methyl) butane and 1- (2,3-epoxypropoxy)- 2-((2,3-epoxypropoxy)methyl)- 2-hydroxymethyl butane; reaction mass of 4,4'- [2,2,2- trifluoro-1- (trifluoromethyl)ethylidene] diphenol and benzyl(diethylamino)diphenylphosphonium 4 [1,1,1,3,3,3- hexafluoro- 2-(4-hydroxyphenyl) propan-2-yl]phenolate (1:1) n etc. "