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Selling cosmetics in Switzerland

In Switzerland, cosmetics are utility articles under food law, set by the LGV and the FDHA Ordinance on Cosmetic Products (VKos). Before first sale, a product information file with a safety report is prepared, in an official language or English. Substance lists follow the annexes of Regulation (EC) No 1223/2009. Cantonal authorities enforce.

Updated · Each section links to the official source it comes from

Law
LGV and the FDHA Ordinance on Cosmetic Products (VKos)
Before first sale
Product information file with a safety report
File language
An official language or English; kept 10 years
Substances
Annexes II to VI of Regulation (EC) No 1223/2009 apply
Animal testing
Products tested on animals may not be placed on the market
Who enforces
Cantonal enforcement authorities

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Is it a cosmetic, or a biocide or medicine under Swiss law? Read more
  2. 2Are its substances allowed under the 1223/2009 annexes as applied in Switzerland? Read more
  3. 3Is there a product information file with a safety report by a qualified person? Read more
  4. 4Does the label carry the ingredients, responsible person, durability and warnings? Read more
  5. 5Do the claims meet the criteria, including any 'not tested on animals' claim? Read more
  6. 6If it comes from the EU, does it qualify under the Cassis de Dijon principle? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

What counts as a cosmetic

The definition, and where other law takes over.

  • Cosmetics are utility articles under the Foodstuffs Act, alongside food contact materials, toys and other consumer articles (LMG Article 5).
  • The FSVO says products are classified under Swiss law: hand disinfectants such as ethanol hand gels are biocidal products in Switzerland, not cosmetics, and need authorisation, with the FOPH among the competent authorities.
  • The FSVO publishes criteria for telling cosmetics apart from medicines.

How we help: Compliant Always reads your product description and claims against the definition and shows which need a second look. Ask about this

Regulated substances

What may and may not go into a cosmetic.

  • Substances in Annex II of Regulation (EC) No 1223/2009 are prohibited; Annex III substances, Annex IV colourants and the preservatives and UV filters of Annexes V and VI are allowed only under their conditions (LGV Article 54).
  • Substances classified as carcinogenic, mutagenic or toxic for reproduction in categories 1A, 1B or 2 are prohibited in cosmetics, subject to the conditions in VKos Article 6.
  • The FSVO says LGV Article 54 refers to the updated Regulation (EC) No 1223/2009, with Swiss deviations in VKos Articles 6 and 7; the lists it publishes are aids, and only the legal texts are binding.
  • Substances not explicitly regulated may be used where the safety report shows they are safe (FSVO).

How we help: Compliant Always reads your formula against the substance lists and shows any ingredient without a status on file. Ask about this

Product information file and safety report

The file that stands behind each product.

  • Before a cosmetic is first placed on the market, a product information file is prepared, containing a safety report with a safety assessment (LGV Article 57).
  • The safety assessment is made by a person qualified in pharmacy, toxicology, medicine or a similar subject, and covers intended use and systemic exposure (VKos Article 4).
  • The file is in an official language or English, and kept for ten years after the last batch is first placed on the market (VKos Article 5).
  • A file prepared abroad that meets these requirements may be used; the importer or distributor must then be able to prove it to the cantonal authorities (VKos Article 5).
  • Cosmetics are made under good manufacturing practice (VKos Article 12).

How we help: Compliant Always keeps the product information file, safety report and GMP evidence with each product, dated, and shows what is missing. Ask about this

Labelling and claims

What the pack carries and what may be said.

  • The pack lists the ingredients under the heading «Ingredients», in descending order of weight (VKos Article 8).
  • Packs show the function where not obvious, the name and address of the manufacturer, importer, distributor or responsible person under Regulation (EC) No 1223/2009, the durability date or period after opening, the batch and precautions (VKos Article 9).
  • Claims may not suggest properties the product does not have, and follow the criteria in VKos Annex 6 (VKos Article 10).
  • A statement that no animal tests were carried out may be used only where neither the manufacturer nor its suppliers carried out or commissioned such tests (VKos Article 10).
  • Cosmetics whose final formulation or ingredients were tested on animals to meet food law may not be placed on the market (LGV Article 59).

How we help: Compliant Always reads your label artwork and claims against these particulars and shows what is missing. Ask about this

EU cosmetics and the Cassis de Dijon principle

How products lawfully sold in the EU come to Switzerland.

  • The FSVO says the Cassis de Dijon principle applies to imported cosmetics: they must fully meet Regulation (EC) No 1223/2009 and be lawfully on the market in an EU or EEA member state.
  • Warnings and safety instructions on such products must be in the official language or languages of the place where they are sold (FSVO, citing Article 16e(2) of the Federal Act on Technical Barriers to Trade).
  • Cantonal authorities have no access to the EU Cosmetic Product Notification Portal, so the documents EU law requires, such as proof of the product information file or the notification number, must be available (FSVO).

How we help: Compliant Always keeps the EU documents behind each product with it, so they can be shown to a cantonal authority. Ask about this

Who answers for what

WhoWhat they answer forHow we help
BrandThe cosmetic sold under its name, its label and its claims.Formula, label and claims read against the VKos in one place.
ManufacturerThe product information file, safety report and good manufacturing practice.The file and safety report kept with each product.
ImporterCosmetics brought into Switzerland, and proof of the file where it was prepared abroad.Suppliers' documents read and dated before the goods arrive.
DistributorChecks before sale, including labels in an official language; it counts as manufacturer if it sells under its own name.Questionnaires answered from the product record.

Cantons

Federal acts and ordinances set the rules. Inside Switzerland the cantons enforce food and utility-article law, each through a cantonal chemist who heads the cantonal enforcement authority; the Confederation enforces at import, export and transit (Foodstuffs Act, Articles 38, 47 and 49).

Labels must be in at least one official language: German, French or Italian. Some rules ask for the language of the place of sale, which differs between cantons.

Questions businesses ask

Which law covers cosmetics in Switzerland?
The Foodstuffs Act, the Ordinance on Foodstuffs and Utility Articles (LGV) and the FDHA Ordinance on Cosmetic Products (VKos).
Is a product information file required?
Yes. Before first sale, a file with a safety report is prepared, in an official language or English, and kept for ten years after the last batch (LGV Article 57; VKos Article 5).
Can an EU product information file be used?
Yes, if it meets the Swiss requirements. The importer or distributor must be able to prove this to the cantonal authorities (VKos Article 5).
Who can carry out the safety assessment?
A person qualified through university study in pharmacy, toxicology, medicine or a similar subject (VKos Article 4).
Which substance lists apply?
Annexes II to VI of Regulation (EC) No 1223/2009, as updated, with Swiss deviations in VKos Articles 6 and 7 (LGV Article 54).
Can EU cosmetics be sold in Switzerland?
Under the Cassis de Dijon principle, if they fully meet Regulation (EC) No 1223/2009 and are lawfully on the EU or EEA market. Warnings must be in the official language of the place of sale.
Can Swiss authorities see the EU CPNP?
No. The FSVO says cantonal authorities have no access to the CPNP, so proof of the product information file or the notification number must be available.
Are hand sanitisers cosmetics?
No. The FSVO says hand disinfectants are biocidal products in Switzerland and need authorisation; the Cassis de Dijon principle does not apply to them.
Can a cosmetic say 'not tested on animals'?
Only if neither the manufacturer nor its suppliers carried out or commissioned animal tests on the product, its prototype or its ingredients (VKos Article 10).
What must a cosmetic label list?
Ingredients under «Ingredients», function where not obvious, the responsible business's name and address, durability or period after opening, batch and precautions (VKos Articles 8 and 9).
How does Compliant Always help with selling in Switzerland?
Our team reads the rules for the markets you sell in. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in Switzerland and what your paperwork needs to show.

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