On August 21, 2026, Switzerland's joint Notification Authority for Chemicals (Anmeldestelle Chemikalien, the BAG/BAFU/SECO body) updated its ongoing revisions overview to list the adaptation of Annexes 2 and 3 of the Chemicals Ordinance (ChemV, SR 813.11) with an entry into force of February 1, 2027. That date is the current official target on the authority's live revisions tracker. The dedicated Annex 2/3 adaptation page still carries its July 28, 2025 text citing September 1, 2025 and has not been refreshed, so compliance teams must read the revisions list, not that page alone, for the operative deadline.
The substance of the adaptation is unchanged: Annex 2 ChemV takes in the harmonised classifications and labelling from ATP 22 and ATP 23 of the EU CLP Regulation plus the latest OECD Test Guidelines and UN Manual of Tests and Criteria, and Annex 3 adds seven new SVHC candidate-list substances ("besonders besorgniserregende Stoffe") and updates one existing entry. The stated purpose, still set out on the adaptation page, is to avoid trade barriers with the EU and keep the Swiss protection level high.
What does the ChemV Annex 2/3 adaptation change?
Annex 2 is Switzerland's harmonised-classification list. The amendment ports across the ATP 22 and ATP 23 classifications under Regulation (EC) No 1272/2008 (CLP), adding new substances and substance groups and amending existing entries, and brings through the current OECD and UN test-method suite for hazard testing. Annex 3 is the Swiss SVHC candidate list: seven further substances of very high concern are added and one entry is updated, tracking the EU REACH candidate list. The two explanatory reports, for Annex 2 and Annex 3 (both dated September 9, 2025), set out the detail.
Who must comply, and by when?
The duties fall on manufacturers, importers and downstream users who place hazardous substances or mixtures on the Swiss market under the ChemV. The operative deadline on the Anmeldestelle's revisions list is February 1, 2027. From that date, substances in scope must carry the updated harmonised classification and labelling in their SDS and packaging, and the newly added Annex 3 substances trigger the candidate-list notification and supply-chain communication duties that Swiss law mirrors from REACH. The Basel and Geneva chemicals hubs (for example Novartis, Roche, Syngenta, Clariant, Givaudan, DSM-Firmenich and BASF Schweiz) illustrate the densest exposure, but the obligation is nationwide for any Swiss-placed chemical in scope.
Treat February 1, 2027 as the binding planning date unless and until the revisions list moves again. Do not rely on the September 1, 2025 date still printed on the dedicated adaptation page: that page is a July 2025 snapshot and does not match the authority's current schedule.
How should compliance teams re-time the work?
Re-baseline the affected SKUs against the ATP 22 and ATP 23 harmonised-classification deltas and the seven new Annex 3 SVHC entries now, then schedule the SDS and label updates, SVHC notifications and downstream-user communications to complete before February 1, 2027. Keep the work in the queue; the schedule moved, the alignment did not.
Two adjacent tracker items are also clear from the live revisions page. A broader ChemV amendment is listed with entry into force in 2028, and an update of the Biocidal Products Ordinance (VBP) active-substance lists is listed for September 1, 2026. Older completed items, including the prior VBP revision once listed for January 1, 2024 and the revision of Annex 1.10 of the ChemRRV once listed for September 1, 2025, no longer appear under ongoing revisions.
| Item | Source of date | Current target |
|---|---|---|
| Annex 2/3 ChemV adaptation (CLP ATP 22/23, OECD methods, 7 SVHC) | Revisions overview (published August 21, 2026) | February 1, 2027 |
| Same adaptation (stale page text) | Dedicated Annex 2/3 page (published July 28, 2025) | September 1, 2025 (not refreshed) |
| VBP active-substance list adaptation | Revisions overview | September 1, 2026 |
| Broader ChemV amendment | Revisions overview | 2028 |
Continuous, per-jurisdiction monitoring surfaces a schedule change like this the moment the Anmeldestelle updates its revisions list, instead of after teams have already locked a wrong deadline.
Take advantage of this real-time watch
Next steps: confirm which of your substances sit in the ATP 22 and ATP 23 harmonised-classification deltas or the seven new Annex 3 SVHC entries; plan SDS, label and notification work to land before February 1, 2027; and brief product safety and supply-chain teams that the Swiss schedule is set by the revisions overview, not by the unrefreshed adaptation page. Obsidian tracks Swiss chemicals law alongside the EU CLP and REACH updates it mirrors, so the alignment, not just the national copy, stays in view.
