Swiss Waste Ordinance 2026: what changed on 1 January, and what still applies

The Ordinance on the Avoidance and Disposal of Waste (VVEA, known in French as the OLED) went through several changes between 2025 and 2026. For operators of waste treatment plants, site managers or anyone responsible for characterising materials, not all of them carry the same weight.

One point deserves to be cleared up straight away: the limit values applicable to the main metals have not changed.

Some deadlines, on the other hand, have moved, and new obligations have now entered into force.

Here is what that means in practice, in the field.

The limit values stay the same

This is probably the most important point — and the one that least deserves confusion.

The limit values for antimony, arsenic, lead, cadmium, chromium, copper, nickel, mercury and zinc remain identical to those previously applicable.

Comparing successive versions of the text, from January 2024 to January 2026, shows that the relevant provisions of Annex 3, number 2, for excavation and drilling material, and of Annex 5, number 2.3, for type B landfills, have not been amended.

For a company that already has a control procedure based on these thresholds, this means the monitoring method can stay as it is.

The nine elements and their limit values are set out in detail on our page devoted to Waste Ordinance analysis.

Fly ash: metal recovery will wait until 2028

This is one of the most concrete changes for professionals working on waste characterisation.

Article 32, paragraph 2, letter g, provides for the recovery of metals contained in fly ash from the thermal treatment of municipal waste.

This obligation was due to enter into force on 1 January 2026.

It has finally been postponed by two years under the ordinance of 26 November 2025: the new deadline is now set at 1 January 2028.

Until then, fly ash may continue to be permanently stored in a form bound with hydraulic binders, in a type C landfill or compartment, provided that the available treatment capacity is fully used.

On paper, two extra years may look comfortable.

In practice, they can pass very quickly.

Two years' grace, but still a need to know the contents

Postponing a treatment obligation obviously does not remove the underlying question: which metals are actually present in the ash, at what concentrations, and with what variability?

Before deciding on a recovery process or investing in a plant, the material therefore has to be characterised.

That is precisely where a measurement campaign can be particularly valuable: establishing a sufficiently precise picture of the composition of the ash before taking a technical or economic decision.

Put another way, postponement to 2028 does not mean waiting until 2028 to start measuring.

The 55 % threshold, on the other hand, has come into force

The other deadline set out in Article 54 has not been postponed.

Since 1 January 2026, plants for the thermal treatment of municipal waste must use at least 55 % of the energy content of the waste.

This obligation has therefore not been deferred.

An exemption has nevertheless been possible since 1 August 2025. The FOEN may, at the request of the canton and the operator, grant an exemption to plants due to be decommissioned by 31 December 2035.

The distinction matters: the 55 % threshold is now the rule, while the exemption concerns clearly defined cases.

Other changes worth keeping an eye on

The recent revisions of the Waste Ordinance are not limited to the two most visible deadlines.

Provision	What changes	From / deadline
Art. 52b	Maximum content of 3 µg TEQ/kg for dioxins and furans in certain thermal treatment residues, on a transitional basis	1 January 2026, until 31 December 2026
Art. 51	Cantons must complete their planning for phosphorus recovery and submit it to the FOEN	1 January 2028
Art. 4	Cantonal waste management plans must include measures to exploit the energy potential of waste	1 August 2025
Annex 2	Change to the minimum distance between a landfill and the maximum ten-year groundwater level	1 January 2025

These provisions differ in nature, but they all form part of the same movement: characterising waste better, planning its treatment better and strengthening the recovery of its resources.

So what can XRF actually contribute?

This is where the new regulatory deadlines meet a very practical field problem.

Portable X-ray fluorescence (XRF) makes it possible to measure quickly the concentrations of chemical elements present in a material. For applications linked to the Waste Ordinance, it can in particular be used to look for the nine elements covered by the regulatory limit values.

On a heap of ash, a batch of excavated material or a deconstruction site, this makes it possible to multiply measurement points and quickly identify the areas or materials that call for closer investigation.

The point is not necessarily to replace the laboratory.

It is often to measure more, faster, and in the right place.

An XRF campaign can thus serve to characterise a batch, spot heterogeneity, guide sampling or identify the materials that then warrant a laboratory analysis.

But there are two important limits to bear in mind.

Total chromium ≠ chromium VI

XRF measures total chromium.

It cannot, on its own, determine the oxidation state of the chromium, and in particular cannot distinguish chromium VI from chromium III.

Where information on chromium speciation is required, a suitable chemical method remains indispensable.

Cadmium and mercury: beware of low contents

At concentrations of the order of 5 mg/kg for cadmium or 1 mg/kg for mercury, the performance of a handheld instrument must be treated with caution, particularly on complex mineral matrices.

In such situations XRF can be very useful for guiding an investigation, but the result should not be read as an automatic equivalent of a laboratory analysis.

And dioxins?

Here the answer is simple: XRF does not measure them.

Dioxins and furans are not isolated chemical elements but molecular compounds. Determining them therefore calls for specific laboratory analytical methods.

XRF can measure the elements present in a matrix. It does not replace a molecular analysis.

Measuring in the field before deciding

In many waste-related projects, the main advantage of XRF is ultimately not to deliver an instant "verdict".

It is to be able to gather far more information in the field before deciding what to send to the laboratory, where to sample and which areas to investigate further.

On an industrial plant, a deconstruction site or a landfill, this ability to multiply measurements can considerably improve the understanding of a batch of material and avoid working from a handful of spot samples alone.

That is particularly relevant where materials are heterogeneous.

YSPEKH also supports measurement campaigns

YSPEKH distributes and deploys X-ray fluorescence solutions suited to the inspection of materials and waste.

We train operators in the use of the instruments, but also in the interpretation of results and in the limits of the measurement.

And where the need is occasional, or a full campaign has to be run on site, we can also step in directly.

Because when it comes to waste, ash or excavated material, bringing the sample to the laboratory is not always the best way to start.

Sometimes it is better to begin by going and measuring where the material actually is.

Sources: Ordinance on the Avoidance and Disposal of Waste (VVEA / OLED, SR 814.600), consolidated texts as at 1 January 2024, 1 January 2025, 1 August 2025, 1 December 2025 and 1 January 2026; amending ordinances of 25 June 2025 (AS 2025 453) and 26 November 2025 (AS 2025 799). This article describes the state of the law at its date of publication and does not replace the opinion of the competent authority in an individual case.