Switzerland’s UFI transition is complete – but are your products ready for 2026?
Switzerland has now completed its transition to PCN equivalent notification requirements. As of 1 January 2026, all hazardous mixtures placed on the Swiss market must be submitted to the Swiss Register of Products for Chemicals (RPC) together with a UFI on the label or SDS (depending on the product packaging).
This obligation is set out in Article 48 of the Swiss Chemicals Ordinance (ChemO) and completes the phased introduction of Switzerland’s poison centre framework. While the system is closely aligned with EU CLP Annex VIII, several Swiss specific obligations apply under ChemO that companies must consider.
Who’s in scope?
Swiss UFI requirements apply to any mixture placed on the Swiss market that is classified for:
- Physical hazards (except mixtures classified only as gas under pressure)
- Human health hazards
There are exemptions from the obligation to notify, listed here.
Mixtures classified only as hazardous to the environment must also be notified. Any mixture classified as hazardous to the environment must include an estimate of the annual quantities manufactured or imported. These can be reported using the following tonnage bands: <1 t, 1–10 t, 10–100 t, >100 t per year.
Mixtures containing nanoform substances must have the information about that nanoform included within the notification, if information is available on the SDS.
How Swiss obligations compare with EU CLP
Companies selling hazardous products in Europe are familiar with submitting Annex VIII notifications through the ECHA PCN Portal. While Switzerland is largely aligned with Article 45 of CLP, the process of submitting a notification differs in its format.
Switzerland provides no general small-volume exemption for products sold for consumer use, however products sold for “professional use” (under Swiss legislation this includes both professional and industrial use) are exempt from notification requirements if they are placed on the market in a quantity of less than 100 kg/year
Finally, non-Swiss companies must ensure they have a Swiss legal or commercial representative, as local presence is required to fulfil notification responsibilities.
UFI rules by market placement
EU → CH: Products placed on both the EU/EEA and Swiss markets may reuse their EU generated UFI, making this the preferred approach for dual market products.
CH only: A product sold only on the Swiss market may bear a UFI generated from a Swiss VAT number utilising the tool provided here.
CH → EU: Swiss generated UFIs are not valid for EU PCN submissions, so any product placed on the EU/EEA market must carry an EU generated UFI.
Finally, non Swiss suppliers must appoint a Swiss legal or commercial representative – typically an importer or designated entity – to complete the necessary Swiss notifications on their behalf.
Action checklist
- Portfolio sweep: Confirm every mixture classified for health or physical hazards has a UFI and a complete RPC notification, unless exempt.
- Dual-market strategy: Standardise on EU UFIs for products sold in both the EU/EEA and Switzerland.
- Representation: If you do not have a company operating in Switzerland, ensure your Swiss importers/customers have submitted a notification.
- Internal controls: Maintain unique formulation numbers and composition change governance to keep UFIs accurate over time.
Key takeaway
Switzerland’s PCN equivalent is now fully live. Companies should align their notification workflows, UFI strategy, labelling and data governance to ensure full compliance, maintain market access, and enable rapid, reliable support for medical emergencies.
PCNs are not the only regulatory requirement in Switzerland, to find out more about how to place on the market in Switzerland click here.
Ricardo's team of regulatory and compliance experts can assist with Swiss notifications by working directly with your in country importers or customers to establish accounts, prepare submissions, and complete all required notifications, making compliance straightforward and efficient.
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