GHS FOR CONSUMER PRODUCT LABELS IS HERE
Are your products ready?
The trend in Latin America is to require GHS-compliant consumer product labels. Up until now, the obligation has expanded category by category: household cleaning products and cosmetics in the Dominican Republic, cleaners in Peru, lawn care products in Argentina, among others. And Panama’s proposed GHS regulation would apply to all hazardous consumer products.
The biggest new development: Chile now requires ALL hazardous consumer products to carry GHS-compliant labels by February 9, 2027.
⚠️ You have less than 6 months to get your hazardous consumer products labeled properly for the Chilean market.
Hazardous consumer products can include:
➡️Cleaning and household products
➡️Paints, varnishes, and coatings
➡️Adhesives and sealants
➡️Lubricants and automotive fluids
➡️Garden and lawn care products
➡️Personal care products with hazardous ingredients
➡️DIY and hobby products
Pro tip: Chile’s GHS label requirements go beyond what you may be used to. One requirement that catches companies off guard: the label must include a Chilean toxicology center phone number, available 24 hours a day, 365 days a year, with access to the product’s Safety Data Sheet.
That is a Chile-specific requirement under Decree 57/2019 that does not exist in many other markets.
⏰If you sell hazardous consumer products into Chile, now is the time to review your labels, update your artwork, and confirm your SDS is on file with a Chilean toxicology center.
Brazil: Waste Standard Incorporating GHS Applicable in Sao Paulo State
In Brazil, the national technical standard for defining hazardous waste for over two decades has been a non-binding technical standard incorporated by reference into other laws on environmental licensing, waste transport, and other regulatory frameworks. In 2024, the Brazilian Assocaiton of Technical Standards (ABNT) introduced a major revamp of that waste classification rule. The new NBR 10004:2024 has been around for almost two years now, but it’s becoming enforceable by adoption, notably in Sao Paulo state.
The new standard makes two changes of particular note. First, it simplifies the classification structure from three categories to two, Class 1 (Hazardous) and Class 2 (Non-Hazardous), eliminating the prior inert/non-inert subdivision. Second, and more significantly, it incorporates GHS hazard classifications into the hazard assessment methodology. Companies generating industrial waste must now apply GHS hazard logic, including acute toxicity, carcinogenicity, mutagenicity, reproductive toxicity, and ecotoxicity, to determine whether their waste streams are Class 1. GHS is finding its way into more and more regulatory schemes in the region. It’s not just labeling and SDS anymore.
São Paulo’s environmental agency CETESB has set the first hard deadline: the prior 2004 standard remains valid through December 31, 2026, after which the new standard applies in the state. Expect others to follow.
Link to CETESB Decision 078/2025/I/C:
Brazil: Rio de Janeiro Updates Its Reverse Logistics Framework
Extended Producer Responsibility is big news globally, from the EU’s new Packaging and Packaging Waste Regulation to expanding national schemes across Latin America. For the region’s large federated republics (Argentina, Brazil, and Mexico) the complexity multiplies. Brazil’s states have authority to enact their own environmental laws, provided they meet or exceed the national floor. Rio de Janeiro state is one of many that has exercised that authority.
Brazil’s National Solid Waste Policy establishes reverse logistics obligations at the federal level, but states layer their own requirements on top. States add their own implementing decrees, digital reporting systems, enforcement agencies, and penalty regimes. For companies operating nationally, this means navigating a patchwork of federal plus state obligations wherever they sell products. Rio de Janeiro is one of the more active states on this front.
Decree 50.426/2026, published August 14, 2026, updates Rio de Janeiro’s General Reverse Logistics Regulation, replacing the 2023 framework. The seven covered product categories mirror the federal baseline: batteries, tires, lubricating oils and their residues and packaging, fluorescent and mercury lamps, domestic electrical and electronic equipment, expired household medications and their packaging, and general packaging. Companies must register plans and report annually through SISREV-RJ, the state’s digital platform, by July 30 each year. The decree explicitly covers e-commerce retailers selling into the state regardless of where they are based.
The more forward-looking news is what did not make the final text. The public consultation draft proposed adding edible oils, large-volume products, and clothing and textiles. None survived to enactment. Article 2 keeps the door open for additional sectors through commitment agreements. Companies in those three categories operating in Rio de Janeiro should treat inclusion as a matter of when, not whether.
Link to Decree:
https://www.seas.rj.gov.br/Logistica-Reversa
Mexico’s Circular Economy Law: Framework in Place, Key Pieces Still Missing
Mexico’s General Circular Economy Law is a game changer. Adopted in January 2026, the law creates a nationwide framework to extend product life cycles, reduce waste, and promote the reuse, repair, recycling, and valorization of materials. Extended Producer Responsibility will be a central focus. But the new framework lacks key pieces, including its implementing regulation. That instrument was due within 180 days of the law’s entry into force: a deadline that passed in July 2026 without publication.
Where do things stand?
The Senate’s Special Commission on Circular Economy and Business Development is not waiting for Mexico’s EPA, SEMARNA, to move first. In April 2026 the Commission co-organized a forum called “México Circular 2026” to bring together academia, industry, civil society, and international organizations to develop concrete proposals for the regulation. The Commission has since approved a technical document containing recommendations from over 100 specialists covering EPR design and implementation, waste traceability, legal certainty, administrative simplification, graduated timelines for small and medium enterprises, and social inclusion of informal recyclers. The Commission has also called for a technical working meeting with SEMARNAT to build common regulatory criteria, and has proposed a comparative regulation forum drawing on international experiences once the regulation is finally published.
None of this work is binding on SEMARNAT, but it certainly is importan input for the overdue regulation.
What else is happening?
While the regulation waits, SEMARNAT is building out supporting infrastructure. The agency recently published two tools relevant to the circular economy framework. The first is a National Hazardous Waste Inventory with 2025 data, covering nearly 4.8 million tons of hazardous waste generated by over 167,000 registered companies, with a state-by-state breakdown of authorized waste management capacity and import/export movements. The second is a Plastic Waste Identification Catalog covering plastic resins with high recycling potential, designed to standardize identification at Mexico’s 49 customs points for import and export of recyclate materials.
Neither instrument creates new obligations, but both signal that Mexico is building the data and identification infrastructure that a functioning circular economy framework will require.
Key Takeaway
More extensive EPR for products and packaging — along with upstream obligations like circular design and right to repair — are coming to Mexico. Companies should look for opportunities to participate in the regulation’s development through sector and industry associations, which are often formally invited into the process.
Mexico: New Food Additive Framework
Mexico’s Federal Commission for Protection against Sanitary Risks (COFEPRIS) published comprehensive new rules on food additives and processing aids on August 21, 2026, fully replacing the framework that had governed food additives, beverages, and food supplements since 2012. The new Agreement enters into force 60 business days after publication (approximately late November 2026).
The Agreement consolidates permitted, restricted, and prohibited additives and processing aids across eleven annexes covering:
- Functional additives with established acceptable daily intakes (ADIs)
- Additives permitted under Good Manufacturing Practices (GMP)
- Colorants with established ADIs
- Colorants permitted under GMP
- Sweeteners
- Enzymes
- Processing aids
- Flavorings
- Additives permitted for infant and follow-on formulas
The substantive framework and categories are broadly consistent with the prior rules, but several changes warrant attention.
Colorant limits tightened. For Annex III colorants — those with established ADIs — where prior rules permitted use according to Good Manufacturing Practices without a specific numerical ceiling, the new Agreement establishes maximum use limits. Companies have 24 months from publication to adapt formulations where needed.
Labeling requirements clarified. Additives must be declared in the ingredient list by common name or a recognized synonym listed in the Agreement. Sweeteners carry additional labeling obligations, including declaration of concentration per serving and the applicable ADI where one exists.
Dynamic update mechanism. The annexes will now be updated every three months on the COFEPRIS website, with the full Agreement republished in the Official Gazette every six months. Companies will need to monitor the COFEPRIS additives page actively rather than relying solely on official publications for compliance purposes.
Transition periods. Products or categories not currently listed in Annexes I, III, or VII that are using additives under the prior framework have 12 months to notify their use under the new Agreement. If COFEPRIS determines the use is not acceptable, companies have an additional 24 months to reformulate. Gold, silver, and aluminum colorants not included in the new text have six months to request inclusion and 18 months to eliminate them from formulations if not included.
Key Takeaway: The 2012 additive framework is gone. Companies should review current formulations against the new annexes before the late November entry into force date, flag any colorants with prior BPF-only approvals that now carry numerical limits, ensure additive labeling meets the new declaration requirements, and set up active monitoring of the COFEPRIS additives webpage since the lists can now change quarterly without a corresponding publication.
Link to Agreement on Food Additives and Processing Aids: https://dof.gob.mx/nota_detalle.php?codigo=5796825&fecha=21/08/2026
Mexico: COFEPRIS Consolidates Chemical Precursor Import and Export Permits
Chemical precursor controls are a compliance reality for many companies doing business in Mexico. COFEPRIS requires sanitary permits for the import, export, and domestic acquisition of chemical precursors (as well as narcotics and psychotropics).
As part of the agency’s multi-year move to consolidate all of its processes, COFEPRIS recently simplified these procedures by combining three previously separate permit processes into a single unified procedure. The applications for domestic acquisition, import authorization, and export authorization are now handled under a single sanitary permit: COFEPRIS-03-023. Applications are submitted through VUCEM (Ventanilla Única de Comercio Exterior Mexicano), Mexico’s single window trade portal, using an electronic signature.
The consolidation reduces administrative burden but does not change the substantive prerequisites. Companies must still hold a valid Advance Notice of Requirements and a Sanitary License or Operating Notice as applicable before submitting the unified permit request.
Separately, companies subject to the chemical precursor regime should also be aware of SISUS (Sistema Integral de Sustancias), the digital traceability platform run COFEPRIS. SISUS is not the permit application channel. SISUS is where companies record control book movements and report diversion of regulated substances, providing real-time traceability of chemical precursors from import through use.
Link to Procedure:
https://www.gob.mx/public/tramites/detalleTramite.xhtml?homoclave=COFEPRIS-03-023
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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.
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