Switzerland updates Cosmetics Ordinance: targeted control of furocoumarins effective 1 January 2026

On 9 December 2025, the Federal Department of Home Affairs (DFI), via the FSVO, published RU 2025 824, amending the Cosmetics Ordinance (OCos, RS 817.023.31). The update introduces a targeted approach to control furocoumarins in leave-on products with potential sun exposure.

Key changes

The 1 ppm limit remains, but is now applied to the sum of eight specific furocoumarins, not the entire class.

The eight furocoumarins regulated are:

  • Byakangelicol (CAS 61046-59-1)
  • Epoxybergamottin (CAS 206978-14-5)
  • Isopimpinellin (CAS 482-27-9)
  • 5-Methoxypsoralen (5-MOP, Bergapten; CAS 484-20-8)
  • 8-Methoxypsoralen (8-MOP, Methoxsalen; CAS 298-81-7)
  • Oxypeucedanin (CAS 737-52-0)
  • Oxypeucedanin hydrate (CAS 2643-85-8)
  • Psoralen (CAS 66-97-7)

Understanding the risks of furocoumarins in cosmetics

Furocoumarins are naturally occurring compounds found in certain plants, including citrus peels. These substances are phototoxic, meaning they can react when the skin is exposed to UV light. Upon UV exposure, furocoumarins may interact with skin proteins and DNA, potentially causing redness and swelling. More importantly, repeated or long-term exposure can result in genotoxic effects, which may increase the risk of carcinogenicity.

In response to these risks, Switzerland has adopted one of the strictest regulatory limits internationally, applying a 1 ppm threshold not only to sunscreens and self-tanning products but to all leave-on cosmetic products that may come into direct contact with sunlight under normal conditions of use.

Scope of application

  • Within scope (not exhaustive):
    • Skin creams, lotions, gels, oils
    • Lip care and makeup
    • Sunscreens and self-tanning products
    • Post-shave leave-on products
  • Outside scope (not exhaustive):
    • Nail and hair care products
    • Oral hygiene products
    • Deodorants
    • Night skincare products
    • Rinse-off products
    • Perfumes and colognes

Deadline for compliance

  • Effective: 1 January 2026
  • No transition period: Non-compliant products cannot be marketed after this date.
  • Stock exhaustion allowed: Products sold before 31 December 2025 may continue until stocks run out.

Compliance actions

Furocoumarins are excluded from the Cassis de Dijon Principle. As a result, this restriction applies equally to cosmetic products manufactured in Switzerland and to imported products.

Operators marketing cosmetic products in Switzerland should:

  • Conduct quantitative analysis of all leave-on products potentially exposed to sunlight.
  • Ensure that the sum of the eight markers mentioned above does not exceed 1 ppm.
  • Take immediate action to guarantee compliance and uninterrupted market access.

If you have any questions or need assistance to place your products on the Swiss market, contact COSlaw Team here or at coslaw@obelis.net.

References

Federal Department of Home Affairs (DFI). (2025). RU 2025 824: Amendment to the Cosmetics Ordinance. Federal Food Safety and Veterinary Office. Retrieved on 18 December 2025.

Federal Council of Switzerland. (2017). Cosmetics Ordinance (OCos, RS 817.023.31). Retrieved on 18 December 2025.

Federal Food Safety and Veterinary Office (FSVO). Furocumarine. Retrieved on 18 December 2025.

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