News Brief
From 1 January 2026, Switzerland (a non-EU member state) will fully implement the mandatory Poison Centre Notification (PCN) requirements : All preparations classified as 'hazardous' due to health or physical hazards, including biocidal products, fertilizers, and electronic cigarette liquids, must be notified to the Swiss Poison Centre. This notification must include the Unique Formula Identifier (UFI) and detailed composition information.
In fact, Switzerland introduced the UFI mechanism as early as 2022. The aim was to accurately and reliably identify chemical products and their specific ingredients, providing technical support for subsequent emergency response and risk management.
This obligation is established by Article 48 of the Swiss Chemicals Ordinance (ChemO). While the overall framework is largely aligns with the PCN system under Article 45 of the EU CLP Regulation, enterprises must navigate several compliance requirements with local characteristics in practical operations.
Why the Swiss PCN System Matters？
The primary function of the PCN system is to enable the designated Poison Information Centre to swiftly access product formulas and hazard information in the event of poisoning or suspected poisoning incident. This information is crucial for determining appropriate medical treatment.
The designated poison information centre in Switzerland is Tox Info Suisse (see Article 79 of the Chemicals Act), which provides a free 24/7 medical advice service for cases of poisoning or suspected poisoning.
For enterprises, the shift of PCN from 'advisory information provision' to a 'mandatory pre-market/market-synchronous compliance obligation' means that the management of formula information, label compliance, supply chain data collection, and compliance entity arrangements within Switzerland will directly affect the sustainable entry of products to the Swiss market.
Implementation Dates of Swiss PCN
From 1 January 1 2022: All fertilizers, preparations, and biocidal products that are newly placed on the market and intended for private users must complete the PCN notification and display a UFI label.;
From 1 January 2022: The EU UFI can be used in the Swiss RPC for fertilizers, preparations and biocidal products imported from the European Economic Area (EEA) that already bear a UFI label.;
From 1 January 2026: All preparations classified as 'hazardous' due to health or physical hazards, including biocidal products, fertilizers, and electronic cigarette liquids, must submit a PCN notification and label the UFI;
From 1 December 2027: All plant protection products classified as 'hazardous' due to health or physical hazards must also fulfill the PCN notification obligation and display the UFI.
Key Requirements of Swiss PCN
UFI Generation and Usage Rules: Categorized by Target Market
Target Market | UFI Generation Requirements | Usage Rules | Key Considerations |
EEA→Switzerland (Dual Market) | Generate a UFI using the EU UFI Generator (based on EU VAT number or random code) | The UFI generated by the EEA can be used for the Swiss market. | This is the preferred approach for dual-market products; ensure PCNs have been submitted in the EU. |
Switzerland market only | A UFI must be generated using the Swiss UFI Generator (based on the Swiss VAT number). | This UFI cannot be used in the EEA market. | For sale in Switzerland only; not for use in the EU market. |
Switzerland →EEA | Must use the EU UFI generator to generate a UFI that complies with EU requirements. | The UFI generated by the EEA can be used for the Swiss market. | Even products with identical formulations entering the EU must complete an EU PCN process and display a UFI. |
*It is strongly recommended that the UFI is indicated in Section 1.1 'Product identifier' of the Safety Data Sheet (SDS).
Submission Portal
PCN dossiers must be submitted via the Swiss RPC (Register of Products for Chemicals) online portal at least 3 months before the hazardous product is placed on the market for the first time.
Non-Swiss Enterprises
In order for a non-Swiss company to fulfil the PCN submission obligation, it is necessary for a Swiss local entity to act as a commercial representative and perform the PCN submission.
Compliance Suggestions: Priority Action List for Enterprises
Product Scope Inventory: Review all mixtures placed on the Swiss market in accordance with the classification standard set out in the CLP Regulation, in order to identify hazardous substances and substances that may be exempt (if applicable).
Establish a UFI and Label Linkage Mechanism: For products intended solely for Switzerland, use the Swiss UFI generator to create a Swiss UFI, and incorporate it into the 'Label — PCN Dossier — Formula Version' label change control process to ensure consistency.
Prepare Pcn Dossiers And Familiarise Yourself With Submission Pathways In Advance: Test the process and data requirements on the Swiss RPC online portal well in advance to avoid internal resource constraints caused by a high volume of submissions near the deadline.
Non-Swiss Enterprises Should Implement Local Commercial Representation ASAP: Clearly designate a Swiss local entity to take responsibility for submissions, and set out duty boundaries, data provision obligations and response timelines in contracts and authorisation documents.
Final Thoughts
From 1 January 2026, Switzerland will enforce the mandatory submission of PCN (including UFI and detailed formula information) for all mixtures classified as 'hazardous' due to health or physical hazards. While the system's general framework is highly similar to the EU PCN system, it contains several Switzerland-specific compliance requirements and EU experience cannot simply be applied.
To ensure a smooth transition and maintain the legal supply of products in the Swiss market, REACH24H recommends that enterprises complete the following tasks as soon as possible:
Confirming the scope of products
Creating UFI and matching labels
Preparing for submission to the RPC portal
Arranging a Swiss local commercial representative (for foreign enterprises)
This will reduce compliance risks and ensure continued availability in the Swiss market.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
