,"On December 9, 2025, the Swiss Federal Department of Home Affairs published document AS 2025 824 announcing revisions to the Ordinance on Genetically Modified Food. These updates will officially take effect on January 1, 2026. The changes mainly focus on transitional rules, authorization requirements, and the categorization of genetically modified products allowed on the Swiss market.
Detailed Explanation of the Main Points
(1) New Transitional Provision
A new transition period has been introduced to support industry adaptation. Food products that do not comply with the revised ordinance of November 20, 2025 may still be:
imported,produced, and labeled under the old rules until January 1, 2027.
Furthermore, businesses are allowed to sell these existing products until stocks are fully used up, meaning no forced withdrawal is required as long as the products were legally placed on the market before the deadline.
(2) Complete Rewrite of Annex 3
Annex 3 has been entirely revised. The updated version now provides a clear list of genetically modified (GM) products that can be placed on the Swiss market without requiring a separate authorization from the Swiss Federal Food Safety and Veterinary Office (BLV).
This rewrite aims to increase transparency, harmonize with EU authorizations, and simplify market access for specific GM-derived ingredients.
(3) Part A of Annex 3 – Catalogue of Enzyme Products
Part A now functions as a comprehensive catalogue of enzymes produced using genetically modified microorganisms. It includes:
the name of each enzyme,
the systematic (scientific) enzyme name,
the producing organism (often genetically modified Aspergillus, Bacillus, yeasts, etc.), and
the intended application linked to the enzyme’s EC (Enzyme Commission) number.
These enzymes may be used across several food sectors, such as: bakery products,starch and carbohydrate processing,dairy processing,sugar manufacturing,beer and alcoholic beverage production,egg and protein processing,fats and oils.
This part clarifies which GM-derived enzymes are automatically permitted without additional Swiss authorization.
(4) Part B of Annex 3 – Alignment with EU Novel Food Approvals
Part B introduces an important harmonization measure. It states that genetically modified products which:
meet the definition outlined in Article 31(4) of the Swiss Ordinance on Foodstuffs (LGV), and are already authorized in the EU under Regulation (EU) 2015/2283 on novel foods
may also be placed on the Swiss market.
However, these products must fully comply with:
all conditions,restrictions, and labeling requirements specified in the respective EU implementing decisions and notifications.
This significantly streamlines access for products already evaluated by EU authorities.
(5) Authorization Holder Provisions
For products listed under Annex 3B, the entity named as the authorization holder in the corresponding EU decision or notification is recognized as the sole authorization holder in Switzerland.
This means:only that entity,or other parties with its explicit consent,may market the product in Switzerland.This ensures proper responsibility, traceability, and controlled market placement.
(6) Clarification Regarding Riboflavin (Vitamin B₂)
The revision adds a specific clarification:
Riboflavin (vitamin B₂) produced by the genetically modified microorganism Ashbya gossypii may legally be used in food both as:
a coloring additive, and a nutritional fortification ingredient.
This confirms its accepted status and clarifies application areas for food businesses."
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