Chile REACH: Primer and Action Plan
Chile REACH is up and running — and about to pick up steam.
Chile became the first country in Latin America to adopt a REACH-inspired chemical control scheme with Decree 57/2019.
If your company imports or manufactures chemical substances in Chile, here is what you need to know — and what you need to do before February 2027.
🔸 Who Must Notify
Chile requires importers and local manufacturers of non-exempt hazardous substances imported or manufactured in quantities over 1 metric ton per year to notify their substances by one of four phased-in deadlines, with re-notification required every two years.
🔸 The Four Deadlines
➡️ 2024: Hazardous substances for industrial use (“pure” substances) — notification window now closed – re-notified in 2026
➡️2025: Hazardous substances for non-industrial use (professional and consumer products) — notification window now closed – re-notification in 2027
⚠️ February 9 – August 30, 2027: Hazardous substances in mixtures for industrial use — this is the next major deadline
➡️ 2029: Hazardous substances in non-industrial mixtures — the final group
🔸 How Notification Works
Notification is submitted via a downloadable Excel form, uploaded together with the applicable SDS to the competent authority by email. The SDS must meet Chile’s GHS standards.
🔸 Minimum Classification List
Chile operates a CLP-inspired Minimum Classification List that companies must apply when classifying their substances.
🆕 News: The government has just re-issued the updated Minimum Classification List for 2026 — adding 400 new substances. If your portfolio includes any of the newly listed substances, your classification obligations may have changed. (Links below.)
⚠️ Important Warning on CBI
Unlike Colombia and Peru, Chile currently provides no protection for Confidential Business Information in the notification process. There is no REE or equivalent mechanism. The 2027 mixture substance filings will bring this concern into sharp focus for many companies -particularly those with proprietary formulations.
If CBI protection is a priority for your company, this is a critical issue to address in your compliance strategy before the February 2027 window opens.
The February 2027 deadline is less than six months away. Now is the time to map your substances, review your classifications against the updated list, and prepare your notification package.
We support companies with Chile REACH notification services — from substance mapping and classification review to SDS compliance and filing.
Link to New List:
Listado Oficial de Sustancias 2026 (Excel)
Listado Oficial de Sustancias 2026 (PDF)
LATAM REACH Budget Planning: Where Should Your 2027 Resources Go?
It’s budget planning season — and if your company sells chemical substances into Latin America, LATAM REACH needs a line item.
My clients are reaching out for estimates and strategic guidance as they set their 2027 compliance budgets.
Based on the regulatory calendar, here is how I would allocate resources across the four countries with active LATAM REACH frameworks — assuming a company active in all four and already registered in Colombia.
👇 See the breakdown below.
Brazil REACH — 45%
Brazil is the dominant budget priority for 2027. The implementing regulation is expected, and the registration platform is targeted to launch in the fall. That makes 2027 the pivotal year for readiness assessments, lining up regulatory and Only Representative support, and potentially beginning the registration process itself. Companies that wait until the platform launches will be behind.
Chile REACH — 30%
Chile has the most active near-term deadline of the four. The registration window for hazardous substances in industrial mixtures – the bulk of chemicals subject to the requirements – runs from February through August 2027. That is a hard deadline requiring substance mapping, notification preparation, and filing. This is not planning but execution.
Colombia REACH — 12.5%
For companies who already registered substances, Colombia shifts into maintenance mode in 2027. Annual volume reporting for calendar year 2026 substances is due by September 30, 2027. Budget accordingly for the annual filing obligation – including your REE filings if you activated that CBI-protection option.
Peru REACH — 12.5%
Peru is still in the analysis phase for 2027. The registration threshold that drives the timing of all obligations is expected to be released in late 2027. Companies need budget for the analysis work to determine whether and what substances will require registration before that threshold lands.
🗝️ Key Takeaway:
Brazil and Chile together represent 75% of your LATAM REACH compliance investment in 2027. Peru and Colombia are real but lighter lifts for most companies in that year.
Questions about how to size your LATAM REACH budget for your specific portfolio? That’s exactly what our private LATAM REACH Strategy Sessions are designed for.
And when you are ready to move from planning to action — we support companies with registration, notification, and compliance services across all four countries.
Brazil: Changing Import/Export Controls on Agricultural Inputs
Brazil’s Ministry of Agriculture and Livestock (MAPA) has opened a 45-day public comment period on a draft rule that would establish new control procedures for the import and export of agricultural inputs, including pesticides, fertilizers, and related products. The comment period runs from August 18, 2026.
Risk-based inspection channels
The draft introduces a Green, Yellow, or Red channel system for import operations, similar to customs risk management frameworks used in other countries. Channel assignment would be based on criteria including:
- Country of origin and product provenance
- Importer compliance history
- Product type, quantity, and end use
- Mode of transport and frequency of operations
Pre-shipment authorization for certain imports
For specific categories, the draft would require license approval before the shipment departs, not upon arrival in Brazil. This applies to:
- Products subject to special registration requirements
- Products destined for research or laboratory analysis
- Imports carried out by authorized third parties
Export controls
The draft establishes specific procedures for exports of technical-grade products, pre-mixes, and formulated pesticides. Export labels may be presented wholly or partially in the language of the destination country, subject to conditions in the draft.
Why compliance history matters
The inclusion of importer compliance history as a risk factor is significant. Companies with strong track records stand to benefit from faster Green channel clearance. Those with prior irregularities may face more intensive scrutiny.
This is a draft for public comment and may change before finalization. Companies should consider taking advantage of the public comment process if they stand to be negatively impacted by the reforms.
Link to Portaria:
https://www.in.gov.br/web/dou/-/portaria-sda/mapa-n-1.673-de-17-de-agosto-de-2026-726175367
Brazil: ANVISA Cleans up the Regulation on Cleaning Products
“Saneantes” is a remarkably broad category in Brazil touching everything from industrial cleaners to certain odorizing candles, and most household cleaning products along the way. Notably, they require notification and registration in Brazil, as in many Latin American countries. Here are some important updates for this category.
ANVISA recently amended the regulatory framework for this category through RDC 1.040/2026 and IN 468/2026, both published August 28, 2026. The changes revise the existing framework established by RDC 989/2025 and IN 394/2025, which govern the registration, notification, and classification of these products.
MERCOSUR harmonization corrections
The primary driver of the amendments is correction of inconsistencies identified in Brazil’s incorporation of MERCOSUR Technical Regulation GMC/RES 36/2022. Specific corrections address the definition of product versions, criteria for product registration, and rules applicable to products imported from countries outside the MERCOSUR bloc. Liquid content limits for over-the-counter products were also adjusted, and the requirement to include the phone number of a toxicological information and assistance center on reduced-surface packaging was added.
Simplified procedures
Companies may now conduct pH testing in-house for risk classification purposes, rather than relying on external laboratories. A new simplified labeling change procedure has also been created specifically for changes made solely to comply with RDC 989/2025, allowing immediate implementation after filing the petition.
Label transition periods clarified
The amendments expressly regulate label phase-out periods. Where a labeling change is made solely to comply with RDC 989/2025, companies have up to 365 days to exhaust existing label stock. For other labeling changes, the phase-out period is 60 days. The rules now expressly cover Risk 1 notified saneantes products, providing greater regulatory predictability.
All changes entered into force on the date of publication.
Links to RDC and IN:
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Tracking Brazil’s new chemical management law? Visit www.BrazilREACH.comfor plain-English guidance on Law 15.022/2024, including what an Only Representative structure means in practice.
Questions about how any of this applies to your business? Reach out directly at mowen@ambientelegal.comto talk about how we can help your business succeed in Latin America.
This site provides general information based on publicly available sources and is not legal advice.
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