SWITZERLAND Trends and Developments Contributed by: Annemarie Lagger and Amina Chammah, Walder Wyss Ltd
• products were produced in compliance with the relevant environmental and human rights legislation in the country of production. Operators must also comply with respective documentation and annual reporting obligations. While the EUDR was initially scheduled to apply from 30 December 2024, it was granted a 12-month additional phasing-in period. To avoid unnecessary administrative costs and burdens for companies, the European Commission pub - lished a guidance document in April 2025, outlin - ing clarifications and simplifications on the inter - pretation of the EUDR’s interpretation. It also updated respective FAQs and published a draft delegated act (Delegated Regulation amending Annex I of Regulation (EU) 2023/1115), which is, at the time of writing, pending final adoption. Switzerland has, to date, not adopted a corre - sponding regulation. According to a statement from the Federal Council, it is closely follow - ing the approach of the EU but does currently not see a requirement to harmonise Swiss law. Although the EUDR does not apply directly to Swiss entities, as its scope is limited to a natural person whose place of residence is in the EU or a legal person established in the EU, Swiss com - panies acting as suppliers to EU operators may be indirectly affected due to its supply chain- wide approach and are expected to support compliance with the Regulation’s due diligence requirements. Battery Legislation Regulation (EU) 2023/1542 concerning batteries and waste batteries (the “Battery Regulation” ) establishes a comprehensive legal framework covering the full battery life cycle. Under the Regulation, market operators must, for example:
• implement a due diligence policy to ensure responsible sourcing of raw materials; • affix QR codes and digital battery passports to certain batteries, providing key data on capacity, chemical composition, and expect - ed lifetime, with information uploaded to a central EU database; • meet specific collection, recycling efficiency and material recovery targets; and • finance collection, treatment and recycling systems for used batteries. The Battery Regulation provides for imple - mentation timelines between 2024 and 2031, depending on the type of batteries. It applies to all market operators placing batteries on the EU market, including operators established in third countries. Switzerland has not yet implemented an equiva - lent battery legislation. The current Swiss law is comparable to the former EU battery direc - tive (Directive 2006/66/EC) and is limited to cer - tain content, labelling and waste obligations, outlined in Annex 2.15 of the Chemical Risk Reduction Ordinance , the Waste Movements Ordinance and specifying ordinances. Key obli - gations include: • a prohibition on the sale of batteries contain - ing more than 5mg of mercury per kilogram; • mandatory labelling of batteries with the sym - bol for separate collection; and • indication of chemical symbols if the content exceeds specific thresholds for mercury, cad - mium or lead. The Swiss Federal Office for the Environment, ie, the responsible Swiss authority, has stated that it is monitoring developments in the EU and assessing whether existing Swiss instruments
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