LATAM REACH: DON’T FORGET THE DEADLINES
As we await the Brazil REACH implementing regulation and the volume thresholds for Peru REACH, it’s easy to forget that two systems are already up and running in Chile and Colombia — with deadlines coming fast.
⚠️ CHILE — August 30, 2026
Did you register hazardous industrial substances (“pure” substances) in Chile in 2024? If so, you are required to re-notify with volumes for 2024 and 2025 before August 30, 2026. Re-notification is submitted via a downloadable Excel form sent by email to the competent authority.
⚠️ COLOMBIA — September 30, 2026 D
id you register substances under Colombia REACH in 2025? If so, you are required to report the volumes of those substances imported or manufactured during calendar year 2025 before September 30, 2026. Volumes are reported through the INSQUI database.
If you need support meeting these obligations, we are ready to help. We assist companies around the world with LATAM REACH compliance.
Biocide Registration in Mexico
Unlike the EU and its Biocides Regulation, most Latin American countries treat industrial biocides based on their function within different categories of regulated products. Mexico has historically grouped biocides with pesticides, and it still does.
But since 2014, Mexico has granted certain industrial biocides, specifically when formulated products, with a streamlined data package compared to agricultural pesticides.
Under the PLAFEST Regulation — Mexico’s framework for registration, import and export authorization of pesticides, plant nutrients, and toxic or hazardous substances — four distinct biocidal categories require a sanitary registration:
- Biocides for use as materials preservatives
- Biocides for industrial processes, water systems, refrigeration systems, and air conditioning
- Biocides for use as wood preservatives
- Biocides for use in paints
The market for these products in Mexico continues to expand alongside the country’s industrial growth. The path to registration for foreign products requires a team that can navigate the technical requirements and find solutions to the challenge of local presence. If you need support bringing biocidal products to market in Mexico or anywhere in Latin America, we are ready to help.
Colombia: Big GHS News in Dangerous Goods Transport
Colombia’s Ministry of Transport has published a draft decree that would replace the country’s dangerous goods road transport regulation — unchanged since 2002 — and deliver something the chemical sector has been waiting for since Colombia adopted GHS in 2018: a formal, binding integration of GHS into the transport rules. Until now, the connection between GHS and road transport operations was handled through an administrative circular rather than the regulation from Ministry of Transport envisioned in Decree 1496/2018. This draft would close that gap.
- The GHS Connection
The draft formally recognizes both the UN Orange Book and the GHS Purple Book as co-equal reference frameworks for road transport of dangerous goods in Colombia. Under the proposal, GHS labels would be required on inner packaging, while transport labels would apply to outer packaging in combined configurations. Safety Data Sheets would need to comply with the GHS framework under Decree 1496/2018 and Resolution 773/2021, with Section 14 (transport information) explicitly driving vehicle placarding and UN number marking decisions. For chemical manufacturers, importers, and distributors moving goods through Colombia, this proposal would bring transport documentation and hazard communication into a single coherent regulatory system.
- The Broader Overhaul
Beyond GHS integration, the draft would modernize the entire framework, from packaging certification and structured training for all transport chain actors to electronic reporting and alignment with the current UN Orange Book. This Draft would replae rules that predate Colombia’s chemical safety framework entirely.
- What Comes Next
The comment period runs July 21 through August 4, 2026. If adopted, the decree would enter into force 12 months after publication.
Link to Draft:
https://mintransporte.gov.co/info/mintransporte/media/anexos/JSs2go67.pdf
Colombia: Hazardous Waste Rules Modernized with New Pathway for Industrial Reuse
Colombia’s Ministry of Environment published Decree 766 on July 15, 2026, partially updating the regulatory framework for the generation, management, and final disposal of hazardous waste. The most commercially significant change is the introduction of a formal pathway to recognize certain hazardous waste streams as subproducts eligible for industrial reuse, a concept the decree frames as “industrial symbiosis.” For chemical, manufacturing, and industrial companies generating waste streams with valorization potential, this option could reduce disposal costs and compliance burdens while supporting circular economy objectives.
- Digital Platform and Reporting
Hazardous waste management plans must now be uploaded to the Single Environmental Registry (Registro Único Ambiental or RUA) digital platform, with phased deadlines based on generator size. Starting in 2027, certifications of valorization and final disposal must also be uploaded to the RUA. Mandatory training on hazardous waste handling must be conducted annually.
Minimum Storage Requirements
The decree establishes minimum technical requirements for on-site hazardous waste storage, including physical delimitation, weather protection, signage, spill containment, and a digital or physical entry and exit log. Generators have 12 months from entry into force to comply.
- The Subproduct Pathway
The decree introduces a formal mechanism to declare certain hazardous waste streams as subproducts eligible for use as raw material in another industrial production process, what the decree calls “industrial symbiosis.” The declaration is voluntary and free of charge, issued by the competent environmental authority following a joint application by both the generating and receiving establishments.
To qualify, four conditions must all be met: the waste is generated as part of a production process; it will be used in another production process as a substitute for or addition to a raw material; it requires no treatment beyond standard industrial conditioning; and its use will not generate new environmental impacts requiring new permits.
The pathway is open only to manufacturing establishments. Service and commercial companies are excluded. Waste that requires treatment to reduce or eliminate its hazardous characteristics is expressly excluded, as is waste destined for use as alternative fuel in combustion processes.
Companies interested in this new concept should review the full conditions and procedures established in Decree 766.
Link to Decree:
Latin America’s Critical Minerals Moment: Sovereignty vs. Supply
The global race for critical minerals is reshaping Latin America’s regulatory and investment landscape in ways that will affect supply chains, energy transitions, and trade relationships for years to come. The region sits on a disproportionate share of the world’s lithium, copper, nickel, and rare earths — and governments are increasingly treating these resources as strategic assets to be controlled rather than commodities to be licensed. This week Mexico published a five-year roadmap for its state lithium enterprise that crystallizes the central tension: sovereignty ambition versus operational reality.
- The Lithium Triangle
Bolivia, Argentina, and Chile together hold more than 42% of global lithium resources and have taken dramatically different approaches to developing them. Chile operates the most mature framework with roughly 25% of global reserves, the world’s second-largest producer, and a model that introduced state participation in future projects while preserving private investment under concession agreements. Argentina has taken the most open approach, allowing private concessions and foreign investment, attracting significant capital and becoming the world’s fourth-largest producer. Bolivia nationalized entirely through a state entity and pursued state-to-state technology dealsm including with China , but despite sitting on some of the world’s largest resources has not achieved commercial-scale production. The pattern is instructive.
- Mexico: Ambition in Need of Infrastructure
Mexico’s situation is similar to the one in Bolivia. As we reported, lithium was constitutionally designated a strategic area and reserved exclusively to the state through LitioMx, with private concessions prohibited. The LitioMx Institutional Program 2026-2030 was published last week. The text is candid about where Mexico actually stands. The country has an estimated 1.7 million tonnes of lithium resources in clay deposits in Sonora — geological estimates, not commercially proven reserves. The technology to extract lithium from clay deposits efficiently remains unproven at commercial scale globally. For now, Mexico has no industrial lithium production. The Program’s battery manufacturing objective is a pre-industrial pilot plant, not a commercial facility. The regulatory framework to operationalize the constitutional monopoly is still in need of development.
The gap matters because Mexico signed a Mexico-US Critical Minerals Plan in February 2026, generating market expectations about Mexican lithium entering North American battery supply chains. Private investment cannot enter under the current framework. Chile and Argentina are filling the supply gap while Mexico resolves that tension.
- Why It Matters
The divergence between Latin American approaches to critical minerals is a supply chain story, a trade story, and a regulatory story. The US-China competition for these materials is pushing governments toward resource nationalism at exactly the moment Western companies need reliable access. For companies in energy, mining, chemicals, and sustainability-linked supply chains, the regulatory trajectory of Latin America’s critical mineral frameworks deserves close attention. The rules governing who can access these materials, on what terms, and under what environmental conditions are being written now.
Link to LitioMX 2026-2030 Program:
https://www.dof.gob.mx/nota_detalle.php?codigo=5794681&fecha=24/07/2026
Food Safety Signals: Red No. 3 Reaches Central America
In an ever more interconnected world, companies cannot ignore that safety signals -whether food or cosmetics – will travel quickly. Latin American countries are moving faster than ever before to adopt almost real time restrictions when the EU or the US make these moves. We saw it with the gel nail products last fall when the EU moved to ban some substances in them for CMR concerns. We also saw countries move to ban the food colorant FD&C Red No. 3 based on concerns in the U.S.
As we reported, that food colorant safety signal got to Central America’s Council of Ministers for Economic Integration (COMIECO) who eliminated Erythrosine (Red No. 3, INS 127) from the regional food additives technical standard via Resolution 496-2025, adopted May 9, 2025. That resolution gave companies 12 months from its July 15, 2025, entry into force to reformulate products and exhaust inventory. That window closed July 15, 2026.
The ban is now fully in effect across Central America. COMIECO has granted one narrow additional accommodation: Resolution 503-2026 extends until January 15, 2027 the period to exhaust already-printed labels on products indicating they contain Erythrosine. Honduras’s sanitary authority ARSA confirmed this in a notice published July 16, 2026. The extension applies exclusively to labels already in existence. All other provisions of the ban are in full force as of July 15, 2026.
For food and beverage companies still selling Red No. 3 products in Central America, the message is unambiguous: reformulation should have been completed, and the only remaining flexibility is a six-month window to use up labels already printed. That window closes January 15, 2027.
The broader pattern continues to hold. US FDA banned Red No. 3 in January 2025. Mexico followed with its own ban shortly after, which we covered earlier this year. Central America moved in parallel through the COMIECO regional framework. The safety signal that originated in the US has now traveled the length of the region.
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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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