Since June 2014, the start of Project LARGO, Switzerland introduced many changes to its regulation. The main aim was to harmonize Swiss regulation with European Union (EU) and by doing so, opening the market, upholding bilateral treaties as well as ensuring a high level of consumers’ safety.
In addition to updates on the Ordinance on foodstuffs and consumer products, there were also updated requirements regarding cosmetic products. These updates include:
- compliance with the lists of regulated substances,
- the labelling,
- the obligation to keep product information file (PIF),
- compliance with GMP,
- the ban on animal testing.
These ordinances, including the Ordinance on cosmetic products, entered into force on May 1st, 2017. Nevertheless, they are subject to the following transitional periods:
- Appointment of responsible person (RP) and animal testing: 1st of May 2018,
- Lists of regulated ingredients: 31st of December 2018,
- PIF redaction and GMP compliance: 30th of April 2021.
Regarding cosmetic claims, Switzerland now follows the six criteria from the EU regulation: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making.
Despite harmonization, there are still some remaining differences between the Swiss and EU regulation that need to be noted:
- A manufacturer or importer must be designated to each cosmetic product placed on the Swiss market. This person is responsible for ensuring compliance with the Swiss regulation, but they may delegate their obligation to an agent who is located in Switzerland.
- It is possible to put the address of the EU RP on the packaging of a cosmetic product but the obligation of ensuring compliance with the Swiss regulation remains with manufacturer or importer and may not be delegated to that EU RP or any other person abroad.
- Every cosmetic product needs to have a complete PIF except for artisanal cosmetics sold locally that are not intended for children.
- If a cosmetic product was already placed on the market abroad, the importer/manufacturer must provide proof that a PIF on the product is already established and compliant with the Swiss regulation, without the need to present the PIF to the authorities.
If you wish to ensure that your products are compliant with the Swiss regulation and EU Cosmetic regulation, don’t hesitate to contact us. We will help you with regulatory questions and keep you up to date with the latest regulatory developments.