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How should you label devices for Switzerland (CH-REP symbol vs text)?
I need to update my device labeling for the Swiss market. What are the specific requirements for indicating the CH-REP on labels, packaging, and IFU? Can I use the symbol or must I use text?
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Asked by Lo H. Khamis
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Lo H. Khamis, Regulatory Experts
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## How Should You Label Devices for Switzerland?
Swissmedic provides clear rules for CH-REP indication on device labels, packaging, and accompanying documents. Understanding these requirements is critical to avoid compliance issues and market access delays.
### CH-REP Symbol vs. Text
Swissmedic offers **two options** for indicating the CH-REP:
#### Option 1: CH-REP Symbol
You can use the official CH-REP symbol (if available) on your labeling.
#### Option 2: Text Indication
You can write **"CH authorised representative"** or **"CH-REP"** in text instead of using the symbol.
**Both options are acceptable**—choose based on your labeling design and space constraints.
### Required Information Adjacent to Symbol/Text
Regardless of which option you choose, Swissmedic requires that **the name and address of the authorized representative must appear adjacent to the symbol or text**.
### Address Requirements
The address must allow direct contact. According to Swissmedic:
- ❌ **PO box alone is NOT sufficient** - You cannot use only a PO box
- ❌ **Email/phone alone is NOT sufficient** - You cannot use only contact information without a physical address
- ✅ **Physical address is required** - The CH-REP's complete physical address must be included
The address should be complete enough for Swissmedic or other authorities to contact the CH-REP directly.
### Manufacturer Indication
Swissmedic's obligations sheet states that **the manufacturer must always be indicated on the label**. The CH-REP indication is in addition to (not instead of) the manufacturer information.
**Label Hierarchy:**
1. Manufacturer name and address (required)
2. CH-REP name and address (required for non-Swiss manufacturers)
3. Importer indication (if applicable, under Swiss rules)
### Where to Place CH-REP Information
Swissmedic allows flexibility in where CH-REP information appears:
- **Device label** - Directly on the device (if space permits)
- **Packaging** - On the outer packaging
- **IFU (Instructions for Use)** - In the accompanying documentation
- **Accompanying documents** - Other documentation that accompanies the device
### Practical Best Practice
To reduce regulatory risk and ensure compliance:
**Put CH-REP details on:**
1. **Packaging** - At minimum, include on outer packaging
2. **IFU/accompanying document** - Include in Instructions for Use or other accompanying documents
3. **Device label** - If space permits and your device type allows
**Why this approach?**
- Ensures information is always accessible
- Meets Swissmedic requirements regardless of which document is reviewed
- Provides redundancy in case one label/document is missing
- Aligns with best practices for international regulatory compliance
### Labeling Checklist
Before printing labels for the Swiss market, verify:
- ✅ Manufacturer name and address is present
- ✅ CH-REP name and address is present (adjacent to symbol or "CH-REP" text)
- ✅ CH-REP address is a complete physical address (not just PO box)
- ✅ Information appears on packaging and/or IFU
- ✅ Text is legible and in appropriate language(s)
- ✅ Labeling complies with other Swiss requirements (language, UDI, etc.)
### Common Mistakes to Avoid
- ❌ Using only a PO box for CH-REP address
- ❌ Omitting manufacturer information
- ❌ Placing CH-REP info only on device label (may not have space)
- ❌ Using incomplete or incorrect CH-REP address
- ❌ Forgetting to update labeling when switching CH-REPs
### Coordination with CH-REP
Before finalizing your labeling:
1. **Confirm CH-REP details** - Get the exact name and complete address from your CH-REP
2. **Review with CH-REP** - Some CH-REPs have specific preferences for how their information is displayed
3. **Plan for updates** - If you switch CH-REPs, you'll need to update all labeling—plan your label print runs accordingly
### Next Steps
1. **[Compare Swiss CH-REP providers & request quotes](https://cruxi.ai/regulatory-directories/ch_rep)** - Use our directory to find and compare qualified CH-REP providers
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*Written by **Lo H. Khamis**, Regulatory Experts. [Connect on LinkedIn](https://www.linkedin.com/in/lo-h-khamis) for regulatory guidance.*
### Official Sources:
- [Swissmedic - Labeling Requirements](https://www.swissmedic.ch/swissmedic/en/home/medical-devices/economic-operators.html)