From December 1st 2025, Switzerland updated the Chemical Risk Reduction Ordinance, (ORRChem – 814.81), issued by the Federal Office for the Environment (FOEN / UFAM), introducing more precise definitions and new rules regarding the use of microplastics.
With this update, Switzerland aligns more closely with the European framework, adopting clearer provisions on bans, limits, and obligations for manufacturers and formulators.

1. Microplastics: a precise and binding definition
   The regulation defines in detail which solid synthetic polymers are considered microplastic, specifying:

• Physical state: must be solid
• Particle size: ≤ 5 mm, or particle length ≤ 15 mm (with L/D ratio > 3)
• Minimum concentration in the particle: ≥ 1% by mass

The following are excluded from the definition and are therefore not considered microplastics:

• Unmodified natural polymers
• Polymers without carbon atoms in their chemical structure
• Degradable polymers
• Highly soluble polymers (water solubility ≥ 2 g/L)

2. Bans, exemptions, and documentation obligations
   The Ordinance prohibits to place on the market microplastics and preparations containing concentrations ≥ 0.01% when the microplastic is present to impart a desired characteristic to the product.

Exemptions apply to:

• Products intended for research or analysis
• Food and animal feed
• Medicinal products
• Specific fertilizers

Use-related exemptions:

• Synthetic polymer microparticles to be used in industrial sites
• Synthetic polymer microparticles encapsulated using technologies that prevent environmental release
• Synthetic polymer microparticles whose physical properties are permanently modified during the intended final use
• Synthetic polymer microparticles that are permanently incorporated in a solid matrix during the intended final use

Documentation obligation:
To declare that a product is not classified among microplastics, the manufacturer must, through a technical dossier, provide evidence of:

• The specific identity of the polymer
• Polymer degradability
• Polymer water solubility

3. How to calculate microplastic content
   When it is not possible to determine the microplastic content of a product through available analytical methods or the manufacturer’s documentation, the Ordinance specifies a procedure. Only particles exceeding the following minimum dimensions should be considered to verify compliance:

• 1 μm for particles with all dimensions up to 5 mm
• 3 μm in length for particles up to 15 mm in length and with a length/diameter ratio greater than 3 (i.e., elongated shapes)

This means that particles too small to be reliably measured are not included in the total microplastic content calculation. The goal is to ensure a consistent assessment based on dimensions that are realistically detectable by analytical methods.

4. Implications for the cosmetic industries
   These provisions have direct implications on:

• Formulation: Verification of all polymers present in products
• Regulatory & QA: Obligation to prepare technical documentation to justify any exemptions (degradability, solubility, chemical identity)
• Supply chain: Requirement for compliance and traceability from suppliers

5. Why act now
   The ORRChem provisions provide a clear and stringent framework for microplastic management. For the cosmetic sector, this translates into:

• Reducing the use of non-degradable polymers
• Careful verification of ingredients and materials
• Updating technical documentation
• Selecting safer and more sustainable alternatives

Since 2023, Complife Group has provided companies with a multidisciplinary task force dedicated to implementing EU Regulation 2023/2055 on the restriction of synthetic polymer microparticles. Complife Group can now assist Swiss companies, offering technical, regulatory, and analytical expertise to meet the new microplastic-related requirements introduced by the Ordinance on the Reduction of Risks Relating to Chemical Products (ORRChem – 814.81).