Brazil: No Surprises as Forced Labor Bill Revived
COLOMBIA REACH: Get Ready for Prioritized Substances
LATAM REACH-inspired laws are a reality in four countries: Chile, Colombia, Peru and Brazil. The initial focus in all four has been the registration obligation and national chemical inventories, but those are always a means to an end. The next steps will be prioritization of substances of concern, risk assessments conducted by industry (in all but Brazil), and finally adoption of risk management measures. Colombia looks like it could be the first to reach the prioritization stage, posting a draft resolution for public consultation last week, moving ahead of Chile, whose own draft prioritization and risk management measures remain unpublished. LATAM REACH continues to mature.
Proposed Prioritization Mechanics
Colombia’s draft resolution sets out the methodology that will sort every substance already registered in the National Inventory of Industrial Chemical Substances (INSQUI) into low, medium or high priority. The score combines two components: a hazard weighting, built from GHS classifications across health endpoints (carcinogenicity, mutagenicity, reproductive toxicity, organ toxicity, acute toxicity, skin and eye effects, sensitization) and environmental endpoints (acute and chronic aquatic hazard), and an exposure weighting, built from reported production or import volumes combined with industrial use codes (CIIU and CPC). The two scores are added together and run through a matrix that produces the final priority category.
Companies do not calculate this score themselves. It runs on the data manufacturers and importers already submitted to INSQUI whose deadline for existing substances closed on September 30, 2025.
New Substances Subject to Higher Priority
Substances entering the Colombian market for the first time after the resolution takes effect, meaning they are not yet in INSQUI, skip the scoring algorithm entirely. The draft assigns them automatically to medium priority. The exception is substances classified as CMRTAC, category 1A carcinogens, germ cell mutagens, or reproductive toxicants, or substances with category 1 acute or chronic aquatic hazard classifications. Those go directly to high priority regardless of exposure data, since none exists yet for a new substance.
Obligations for High or Medium Priority Substances
Landing in high or medium priority, or in low priority while still carrying a CMRTAC classification, is not simply a label. It triggers a second tier of reporting obligations layered onto the standard annual INSQUI report. On the environmental side, companies must report persistence, bioaccumulation and biodegradability properties, environmental release estimates, and endocrine disruption data where applicable. On the health side, companies must report exposure data for children and other vulnerable populations, along with endocrine disruption data where applicable. Companies affected have two years from publication of the categorized list to submit this additional package.
Proposed Timeline
The draft sets a six-month clock, running from the resolution’s entry into force, for the Ministry of Environment to publish the first categorized list of substances by priority level on the INSQUI portal. A three-month comment window follows, during which importers and manufacturers can request review or validation of their substance’s categorization. The methodology itself is designed to be revisited: a first algorithm update is scheduled five years after entry into force, a second at the ten-year mark, and every five years after that.
Next Steps
The draft was posted for public consultation on June 25, 2026, with the comment period open until July 12, 2026. Companies with substances in the Colombian inventory have a narrow window to review the proposed scoring methodology, particularly the use-pattern and CIIU/CPC weighting that determines exposure scores, before it becomes binding.
Key Takeaway
Prepare for the “invitation” to conduct a risk assessment if your hazardous industrial substances registered under Colombia REACH are prioritized.
Link to consultation and draft:
Peru: Chemical Controls Expand Beyond PERU REACH
Everyone is talking about Peru REACH, but it’s not the only game in town. The country is moving forward with a broad chemical management agenda. Now, the focus spreads from the usual drug precursor controls to a new comprehensive new framework governing chemical inputs that can be diverted to illegal mining: mercury, sodium cyanide, potassium cyanide, and other substances to be designated. Supreme Decree 117-2026-EF implements Law 32412 and took effect immediately upon publication June 26, 2026.
Take note of the broader pattern: Latin American governments are steadily expanding chemical control regimes well beyond the traditional narcotics-precursor space. If you supply chemicals to Peru, this is now one more control regime to check against your product list.
Who Is in Scope
The regulation applies from the chemical’s “origin or entry into national territory until its final destination”, explicitly covering production, packaging, transport, storage, and use. This reaches foreign manufacturers exporting into Peru, not just domestic Peruvian sellers. If your company exports any of the controlled chemicals to Peru, your product is in scope the moment it crosses the border, regardless of where you are based.
Core Mechanics
Local companies must register in a new Control of Regulated Goods Registry before conducting any covered activity. Registration requires a technical dossier (planned activities, estimated quantities, full composition, safety data sheet) and is valid for two years. Import and export require prior SUNAT authorization which should be automatic for most chemicals, but mercury requires substantive review coordinated with the Ministry of Environment under the Minamata Convention. A 2% tolerance margin applies to authorized quantities.
Enforcement Is Physical, Not Financial
The sanctions table lists 22 infractions. Almost none carry a monetary fine. The standard consequence is seizure of the chemicals or nine-month impoundment of the transport vehicle.
Key Takeaway
Chemical suppliers to Peru should check their product list against the controlled substances, confirm their Peruvian counterparties are registered, and tighten transport documentation given that most violations result in physical seizure rather than a fine.
Link to Law:
https://epdoc2.elperuano.pe/EpPo/VistaNLSE.asp?Referencias=MjUyOTU0NC0xMjAyNjA2MjY=
Argentina: Cleaning Products Registration Simplified — But Underlying Limits Stay
Argentina’s ANMAT continues to update all manner of technical regulations on regulated products like cosmetics, personal care, and now cleaning products. The general trend is to ease registration burdens as part of the government’s overall goal to lighten red tape. The latest move is to incorporate the MERCOSUR Technical Regulation for cleaning products and related items (GMC 05/25) via Disposition 3678/26, replacing the regional standard that had governed since 2007.
The practical change is narrower than it might first appear. The substance limits themselves on free alkalinity in soaps, free ammonia content, pH ranges for dishwashing detergents, or enzymatic activity for enzyme-based products are not disappearing. They are now governed directly by the MERCOSUR standard rather than Argentina’s domestic disposition. The big news is that Argentina eliminated the local documentary proof burden: companies registering products in these categories no longer need to submit the specific test reports and technical dossiers ANMAT previously required to demonstrate compliance with those same limits.
Child-resistant closure documentation requirements are also removed from the local registration dossier, though the underlying closure requirement under the MERCOSUR framework remains for products meeting EU or US thresholds.
One requirement that is not changing: full qualitative-quantitative composition disclosure, including CAS numbers for all raw materials, remains a standing requirement under Argentina’s base regulation (Disposition 1112/13) and was untouched by this update.
Key Takeaway
Companies registering cleaning products in Argentina will face a lighter registration filing, but formulations still need to meet the same underlying technical limits, now referencing the MERCOSUR standard directly. All of this points toward the continued convergence of requirements around regulated products in the MERCOSUR region.
Link to Disposition: https://www.boletinoficial.gob.ar/detalleAviso/primera/343620/20260626
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Tracking Brazil’s new chemical management law? Visit www.BrazilREACH.com for 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.com to talk about how we can help your business succeed in Latin America.
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