Switzerland has just published its new Ordinance on Packaging. How does it compare to the European Union’s approach?
We take a closer look at the similarities and differences between the Packaging and Packaging Waste Regulation and the new Swiss law, from recycling rates to reporting requirements.
Design
By 1 January 2030, the Ordinance on Packaging (VerpV) requires retailers and manufacturers to ensure that pre-filled packaging is designed for collection, treatment and recycling – all without incurring additional costs or technical difficulties. This includes implementing the ‘highest possible proportion’ of recycled plastic.
Packaging volume and mass must be kept at a minimum without compromising the pack’s safety and hygiene. Substances of concern, as defined in Switzerland’s Chemicals Ordinance, must also be avoided; the Federal Department of the Environment, Transport, Energy and Communications (DETEC) may make exceptions when removing these substances would compromise the packaging’s functionality.
These requirements only apply where they are technically feasible and economically viable.
This is a similar approach to the Packaging and Packaging Waste Regulation (PPWR), which requires economic operators to design all packaging for recycling by the same deadline.
Regarding recycled content, it sets minimum requirements for plastic packaging per application:
| Packaging type | By 1 January 2030 | By 1 January 2040 |
| Single-use plastic beverage bottles | 30% | 65% |
| Non-bottle contact-sensitive PET | 30% | 50% |
| Contact-sensitive non-PET | 10% | 65% |
| Other | 35% | 65% |
Manufacturers will be incentivized to introduce recycled content into other packaging materials through eco-modulated fees under Extended Producer Responsibility (EPR) laws, which will also apply from 1 January 2030.
Similarly, the Regulation states that any packaging placed on the EU market must be designed at the minimum weight and volume necessary for its functionality; this may vary based on shape and material. Components that appear to increase the product’s volume, such as double walls and false bottoms, will be outlawed (unless exemptions apply).
Essential requirements for minimization will continue to apply until 31 December 2029.
The European Chemicals Agency (ECHA) is expected to prepare a report on the presence of substances of concern in packaging and packaging components by the end of 2026. It is expected to list the substances of concern used in packaging and components and decide whether they present an ‘unacceptable’ risk to human or environmental health.
The Regulation also prohibits the use of per- and polyfluorinated alkyl substances (PFAS) over a certain threshold after 12 August 2026. In its latest guidance, the Commission states that there is no harmonized methodology for calculating PFAS levels in food packaging at the EU level, but recommends a stepwise approach.
Some economic operators have suggested that these rules are not clear enough. Multiple industry CEOs have written to the Commission and requested that the deadline be postponed until clearer guidance can be provided – a move that has proven to be controversial.
Retailers and wholesalers have also requested a twelve-month grace period in light of the uncertainty, and asked for clearer guidance regarding the PFAS restrictions.
Collection
By 1 January 2031, a subsidiary take-back obligation will apply for beverage cartons and single-use plastic packaging on the Swiss market. If a retailer or manufacturer is not part of an industry organization that ensures the disposal of all its packaging, it must organize its own take-back system and clearly signpost, in a suitable and visible location, that packaging may be returned.
The recovery rate for single-use plastic packaging must reach or exceed 55% by 1 January 2032. Beverage cartons must achieve a return rate of at least 70% within the same time frame. If a retailer or manufacturer misses the deadline, it may be required to carry out the subsidiary take-back obligation at its own expense.
From 1 January 2028, manufacturers who supply empty glass packaging for domestic use, including imported packaging, must pay an advance disposal fee to an organization commissioned by Switzerland’s Federal Office for the Environment. This rule does not apply if the organization supplies or imports less than 1,000 units of packaging in half a calendar year; if the packaging’s filling volume is lower than 0.02L; and if the packaging is not used for food or cosmetic products.
In comparison, the PPWR expects Member States to establish deposit return systems for single-use plastic beverage bottles and metal beverage containers by 1 January 2029. The rule will apply to containers that meet or exceed a 3L capacity, but the rule excludes bottles for wine, aromatized wine products, spirits, milk, or milk-based products.
Each country must separately collect at least 90% of the containers in question per year by weight.
Exemptions may be granted to Member States that exceed a separate collection rate of 90% within two years of the Regulation’s entry into force. A Member State may also submit a request for exemption at least 24 months before the legal deadline, accompanied by a strategy with concrete actions.
Reporting
Under VerpV, economic operators subject to the advance disposal fee must notify the designated organization of the number of glass packaging units they have placed on the market or imported within a calendar half-year, no later than 30 days after the half-year has ended.
The fee will be due sixty days after the calendar half-year has ended. Default interest is payable in the event of late payment, and the organization may grant interest on pre-payments.
The organization is then required to use the fee to collect and transport waste glass, clean and sort intact glass packaging, and clean and process cullet for the manufacture of glass packaging. A maximum of 10% of the annual fee revenue may also be used for information activities (e.g. promoting reuse and material recovery for glass packaging), reimbursing fees, and its own activities within the scope of the Federal Office for the Environment’s mandate.
Single-use packaging manufacturers not covered by these rules, including manufacturers of empty single-use service packaging, must submit an electronic report to the Federal Office for the Environment by the end of February every year; the required information includes the weight of manufactured or imported packaging used for domestic consumption in the previous year, broken down by packaging material. This rule will apply from 1 January 2031.
However, the requirement only applies to companies that exceed a turnover threshold of one million francs in two consecutive financial years and have manufactured or imported more than 500 kg of packaging for domestic consumption.
Meanwhile, the most pressing reporting requirement in the European Union is the Declaration of Conformity. From 12 August 2026, every piece of packaging placed on the EU market is subject to a legally binding self-declaration that confirms its compliance with the Regulation’s rules.
The European Commission will adopt delegated acts to establish and specify reporting requirements by 1 January 2028. So far, EU Member States are expected to have reported their initial data on the quantities of packaging waste recycled by packaging category by 2030.
Each country is expected to report to the Commission that the amount of packaging waste it generates per capita has decreased by at least 5% by 2030; at least 10% by 2035; and at least 15% by 2040.
Member States must also provide yearly statistics of the packaging placed on national markets per type and material; the amount of separately collected packaging waste material; and a Member State’s installed capacities for sorting and recycling per packaging type and material.
Economic operators that implement reusable packaging must report their progress towards legally binding reuse targets to the competent authorities. This includes the relevant data for each calendar year starting in 2030 – and the information should also be made publicly available.
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