Peru REACH’s hidden bombshell — and it’s not the registry.
Everyone is focused on the new chemical registry. They’re missing the real story. 👇
Peru just mandated GHS for essentially every chemical substance in the country.
Most companies haven’t realized it yet.
🏷️ What Peru actually did
DS-005-2026-MINAM doesn’t just create a registry. It implements full GHS — classification, labels, and SDS. All mandatory. All enforceable. All in Spanish.
⚠️ Who this hits
Not just large companies. Not just hazardous substances.
👉 Every manufacturer and importer.
And importantly: 👉 This includes consumer products
Think:
• cleaners • detergents • disinfectants • air fresheners • other everyday chemical products
Yes — eventually everyone.
📋 What “full GHS” really means
⏺️ Hazard classification (keep records for 10 years)
⏺️ GHS labels in Spanish (strict format + size rules)
⏺️ 16-section SDS in Spanish (update at least every 5 years)
⏺️ Alignment with GHS 6th edition + major jurisdictions
⏰ Here’s the part most people are missing
The reporting threshold won’t be defined until mid-2027. GHS obligations apply in a staggered fashion and then …
👉 By 2032, GHS applies to everyone. No threshold. No exceptions. Even non-hazardous substances. Even consumer products.
🔍 Why this is the real risk
Your EU or US labels likely won’t comply.
Language. Format. Pictogram size. Label rules.
All different. All prescribed.
🚨 GHS labeling even for your consumer products … in Chile by 2027, in Colombia any day now, and in Peru staggered in from now to 2032.
From Compliance to Investment: Brazil’s New Approach to Packaging Waste
Latin America is NOT new to EPR schemes. In fact, the region loves them. Countries continue to role out extended producer responsibility regimes for ever more products (think: textiles in Chile) and ever further upstream (think: Mexico’s new national Circular Economy Law with mandatory eco-design). Brazil is one of the pioneers of EPR in the region. As a federated republic, it’s states also get in on the game. Now, the Brazilian state of Espírito Santo has introduced a new mechanism to accelerate packaging waste compliance—and it could reshape how companies approach reverse logistics.
In Brazil, Espírito Santo’s new “Future Mass Credit Certificate” allows companies to invest today in recycling and collection—and count it toward future packaging obligations. Issued by the state environmental authority, the mechanism applies to packaging placed on the market and enables companies to pre-finance selective collection, sorting, and recycling infrastructure. Investments can also support waste picker cooperatives and environmental education initiatives, provided measurable results are delivered within five years.
The shift is simple but significant:
- Act early, not just at compliance deadlines
- Fund collection, recycling, and waste picker systems now
- Earn credits if results are delivered within five years
This moves EPR from reactive compliance to proactive investment—while strengthening the circular economy and supporting waste picker livelihoods.
There are guardrails: projects must be viable, traceable, and deliver real outcomes. This is not a shortcut—it’s a structured path to compliance.
Why it matters: If it works, this model could scale across Brazil, signaling a broader shift toward investment-led EPR.
Bottom line: compliance is becoming a question of how early—and how strategically—you invest.
Cosmetics: Restricted Substances
Argentina has taken another step in aligning its cosmetics framework with MERCOSUR rules—this time focusing on restricted and prohibited substances.
Through Disposition No. 1612/26, ANMAT has incorporated MERCOSUR Resolution GMC No. 48/10 (“List of Substances for Cosmetic Use”) into national law under the Ouro Preto Protocol.
At first glance, this may look like a routine harmonization update. In practice, it carries important compliance implications.
The measure specifically captures substances such as lead acetate, pyrogallol, and formaldehyde (including paraformaldehyde) within the MERCOSUR mechanism for updating cosmetic substance lists. In other words, these substances are now formally embedded in the regional system that governs how ingredient restrictions and prohibitions evolve over time.
For companies, this is less about a single restriction and more about system alignment. By incorporating this resolution, Argentina further reinforces MERCOSUR’s centralized approach to managing cosmetic ingredients—meaning future regional updates will increasingly translate into national requirements with limited divergence.
Timing is also worth close attention. Under MERCOSUR rules, the measure will enter into force simultaneously across all Member States, 30 days after the MERCOSUR Secretariat confirms that all countries have completed internal incorporation. Argentina will separately publish the effective date domestically via the Official Gazette.
The takeaway is straightforward: this is another signal that regional convergence in cosmetics regulation is accelerating in South America. Companies operating across MERCOSUR markets should ensure their formulations and compliance strategies are aligned not just with national rules—but with the evolving regional lists that increasingly drive them.
Link to rule:
https://www.boletinoficial.gob.ar/detalleAviso/primera/340022/20260327
Cosmetics & Personal Care: Easier Market Access in Argentina … for some
Argentina under President Milei has instituted sweeping reforms to cut down on so-called red tape and bureaucracy. The regulated products sectors have benefited greatly from the reforms. Disposition 236/2026 covers a broad scope of imported products including medical devices and diagnostics. The news, though, is an ANMAT operational guidance on cosmetics, oral hygiene products, disposable external hygiene products, intravaginal hygiene products, and household sanitary products. (Guidance for medical devices under the same Disposition is still pending.)
For covered categories, registration now moves to a sworn declaration — the Aviso de Puesta en el Mercado — submitted as prior notification rather than full pre-approval.
Who qualifies?
Companies must already hold ANMAT authorization or be registered in THEMIS as importers in the relevant category. This is an accelerated route for established operators, not an open door for new entrants.
Three tiers based on origin:
- Option 1: Products approved in Australia, EU, EFTA, US, Israel, Japan, or UK — submit a Free Sale Certificate (max 24 months old). No local testing required.
- Option 2: Products from other markets — safety and efficacy certifications from OAA-accredited bodies or recognized multilateral equivalents satisfy requirements.
- Option 3: Products meeting neither condition follow standard registration.
👉 Faster entry for trusted jurisdictions. A workable path for others. Full registration for the rest.
What’s not changing
- Technical compliance remains mandatory
- Declarations are submitted under the company’s exclusive responsibility
- ANMAT retains full audit, withdrawal, and sanctions authority
Practical notes
- One declaration per product (variants permitted)
- Foreign documents require Apostille and certified Spanish translation
- Currently submitted by email or in person — digital platform not yet operational
- Process is transitional and will change when the platform launches
- Fee applies via ANMAT’s electronic payment system
Bottom line: Argentina isn’t deregulating — it’s becoming more selective. Market access is faster, but tied to where your products come from, how they’re certified, and how well your documentation holds up.
Link to the Disposicion:
https://www.boletinoficial.gob.ar/detalleAviso/primera/340022/20260327
Link to Guide:
Trend Watch: Greater Controls on Pesticide Use in Latin America
From registration to field-level traceability: governments are closing the enforcement gap
Latin America is an agricultural powerhouse — a global leader in commodity crops like soy, sugar, corn, coffee, and more. Along with the crops come the crop protection products. Every country in the region has regulations and complex registration systems for pesticides and fertilizers, and the rules change often.
But something is shifting. Historically, regulatory focus in the region centered on what products could enter the market. Now, governments are expanding their reach to control how those products are actually used — in the field, by whom, and with what accountability. Two recent developments illustrate this clearly.
· Brazil’s New Pesticide Misuse Hotline
The Ministry of Environment (MMA) has launched the Canal de Apoio a Denúncias por Agrotóxicos — a new digital platform designed to improve how cases of pesticide misuse are reported, tracked, and addressed. Users can submit detailed complaints quickly and securely, including information on location, exposure, and impacts, with reports routed directly to the appropriate authorities.
This is not a standalone initiative. It sits within Brazil’s National Program to Reduce (Use of) Agrotoxins — a national strategy to reduce pesticide use and mitigate impacts on human health, biodiversity, soil, and water. This is deliberate policy direction, not a one-off tool.
· Costa Rica’s Digital Prescription System for Pesticides
Costa Rica has announced the rollout of a digital prescription system — receta digital — for higher-toxicity pesticides, replacing paper-based processes with a fully traceable, real-time platform. Authorized professionals must digitally register key data including producer, crop, location, and dosage, integrated into the national agricultural database with farm-level traceability built in.
Rollout begins April 17, with mandatory adoption required by July 21, 2026.
For the first time, regulators will have granular, real-time data on who is applying what, where, and at what dose — creating a foundation for evidence-based enforcement and future policy.
Where Brazil’s tool focuses on catching misuse after it occurs, Costa Rica’s system prevents it — creating a digital trail before the product ever reaches the field.
Chile & Colombia REACH
If your company sells chemicals into Latin America, this question always comes up:“Do we need to do anything for Chile or Colombia REACH?”
The problem isn’t the answer — it’s the time it takes to figure out what the question even means.
Most teams end up digging through scattered guidance, PDFs, and half-explained summaries just to understand how these systems work.
So I built something simpler:
Step-by-step explanations (videos + downloadable report) that walk you through Chile and Colombia REACH from start to finish — so you can understand the full picture in one sitting. No piecing it together. No guesswork.
➡️ Chile REACH course:https://lnkd.in/gfyjGWxJ
➡️ Colombia REACH course: https://lnkd.in/gAqyNNHbRG3
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