On December 9, 2025, the Federal Department of Home Affairs (DFI), through the Federal Food Safety and Veterinary Office (FSVO), published the official RU 2025 824⁽¹⁾ amendment to the Cosmetics Ordinance (OCos, RS 817.023.31⁽²⁾), defining a specific, limited group of markers to determine the furocoumarin content in leave-on cosmetic products with potential solar exposure.

The targeted approach is introduced through the revision of Article 6, Paragraph 1, of the Cosmetic Ordinance (RS 817.023.31).

The revision of the Ordinance introduces a new approach: the 1 ppm limit and the current scope of application remain unchanged, but it will now apply to the sum of eight markers recognized as the most relevant to human health, rather than to the entire class of furocoumarins, based on the latest scientific evidence.

Framework: what are Furocoumarins and how are they regulated?

Furocoumarins are phototoxic substances naturally contained in some plants, such as citrus peels. When activated by UV radiation, they can react with proteins or DNA in the skin, causing cutaneous reactions such as redness, edema, and hyperpigmentation. In the long term, furocoumarins applied to UV-exposed skin can modify the genetic material of cells, leading to a genotoxic carcinogenic effect.

For the maximum protection of public health, Switzerland adopted one of the strictest international limits in its Cosmetics Ordinance. Unlike the European Union, where the 1 ppm limit applies only to sunscreens and self-tanning products, Switzerland extended this requirement to all cosmetic products that remain on the skin (“leave-on” products) and may be directly exposed to sunlight under normal conditions of use.

The scope of application includes natural essential oils, creams, emulsions, lotions, gels, skin-care oils, make-up products, sunscreens, and self-tanning products.

What changes with the amendment: control over only 8 Furocoumarins

Instead of generically regulating the entire class of furocoumarins, the amendment now targets only eight specific markers, clearly indicating those that must be assessed:

• Byakangelicol (CAS No. 61046-59-1)
• Epoxybergamottin (CAS No. 206978-14-5)
• Isopimpinellin (CAS No. 482-27-9)
• 5-Methoxypsoralen (5-MOP, Bergapten; CAS No. 484-20-8)
• 8-Methoxypsoralen (8-MOP, Methoxsalen, Xanthotoxin; CAS No. 298-81-7)
• Oxypeucedanin (CAS No. 737-52-0)
• Oxypeucedanin hydrate (CAS No. 2643-85-8)
• Psoralen (CAS No. 66-97-7)

Timeline and scope

The revised Ordinance will enter into force on January 1, 2026.

• No transition period: non-compliant cosmetic products will not be allowed to be placed on the Swiss market from January 1, 2026.
• Stock exhaustion: cosmetic products already present on the market before December 31, 2025, may continue to be sold until existing stocks are exhausted. This guarantees immediate application of the new requirement while allowing time to clear existing inventory.

The requirements of this ordinance apply to all operators commercializing cosmetic products in Switzerland, regardless of their origin or provenance.

What to do now?

From January 1, 2026, non-compliant cosmetic products, meaning those that exceed the 1 ppm limit for the sum of the eight selected furocoumarins, will no longer be allowed to be placed on the Swiss market.

Cosmetic products falling under the scope of the ordinance, intended to be placed on the Swiss territory, must undergo a quantitative analysis to determine their furocoumarin content. It is required to specifically quantify the eight defined markers, ensuring that the sum of their concentration does not exceed 1 ppm.

It is essential to take action as soon as possible to check all cosmetic products with potential solar exposure, to ensure compliance and market access in Switzerland.

>>> Combining our regulatory expertise and analytical services, we support your products’ entry into the Swiss market, ensuring both product compliance and consumer health.

(1) RU 2025 824 https://www.fedlex.admin.ch/eli/oc/2025/824/it

(2) OCos, RS 817.023.31 https://www.fedlex.admin.ch/eli/cc/2017/165/it