How to sell cosmetics in Switzerland: Regulatory considerations for brand owners 

Despite not being a member of the European Union, the Swiss regulatory framework for cosmetics closely aligns with EU standards, including the EU Cosmetics Regulation (EC) No. 1223/2009.  

However, specific divergences require manufacturers and distributors to adapt their products to the Swiss market. Below, we outline the key regulatory considerations for selling cosmetics in Switzerland. 

Regulatory framework and restricted substances  

The Ordinance on Foodstuffs and Utility Articles (ODerr), and the Ordinance on Cosmetics (OCos) and the Federal Act on Foodstuffs and Utility Articles, FAS (Loi fédérale sur les denrées alimentaires et les objets usuels from June 2014, 817.0) regulate cosmetic products in Switzerland. Switzerland has adopted much of the EU Cosmetics Regulation through these legislative acts, including its annexes of restricted and prohibited substances.  

While most EU rules apply directly, Switzerland introduces slight variations. For instance, specific restrictions exist for certain substances like furocoumarins and hydrogen peroxide, and fees are introduced for the use of certain Volatile Organic Compounds (VOCs) in several products, including cosmetics.  

Labelling requirements 

While broadly consistent with the EU, Swiss labelling requirements have some unique aspects.  

Unlike in the EU, Swiss regulations do not mandate labelling the country of origin, which is only advisable for consumer trust. However, instructions and warnings must be provided in at least one official Swiss language: German, French, or Italian. Although local languages are recommended for sensitive products like hair dyes or nail polish removers, English may be accepted if understood by target users.  

Claims such as “Made in Switzerland” are subject to strict criteria, necessitating evidence of manufacturing processes. The criteria for distinguishing cosmetics from therapeutic products and biocides are also significantly more stringent.  

Swiss Authorised Representative (AR) 

In the EU, a Responsible Person (RP) is mandatory for all cosmetic products. 

In Switzerland: 

• The manufacturer and importer are responsible for regulatory compliance.  

• The manufacturer and importer may appoint by written mandate an authorised representative who can take over their compliance-related duties 

However, if a company already has an EU Responsible Person, appointing a Swiss Authorised Representative is not necessary. 

It is worth emphasising that under the Swiss legislative framework, the terms Responsible Person and Authorised representative are both used, but they indicate different roles. Importantly, the Swiss meaning of Responsible Person differs from the EU usage of this term.  

In Switzerland, the Responsible Person is explicitly defined as the contact point for Swiss surveillance authorities and is a physical person. If no one is officially designated as the RP, the company’s CEO (or equivalent legal representative) assumes this function by default.  

Market controls  

Switzerland’s regulatory model operates on self-monitoring principle. Unlike the EU, where cosmetics must be notified to the Cosmetic Product Notification Portal (CPNP) prior to their placement on the market, Swiss authorities rely on market controls conducted by cantonal laboratories. Compliance with safety and labelling requirements is verified.  

The Cassis de Dijon principle 

Switzerland applies the Cassis de Dijon principle, allowing products compliant with EU law to be marketed in Switzerland without additional approvals. Exceptions exist, as those included in the negative list published on The Swiss publication platform for federal law, Fedlex.  

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