Happy New Year… New Tariffs
Mexico has started the year with new tariff measures that will impact products, supply chains, and trade relationships.
On December 29, 2025, Mexico published a controversial reform to the Law of the General Import and Export Taxes (LIGIE) that takes effect January 1, 2026.
The reforms impose steep new duties on over 1,400 tariff lines coming from countries that don’t have a free trade agreement with Mexico – including China, South Korea, India, Vietnam, Thailand, Brazil, Indonesia, Chinese Taipei, UAE, and South Africa.
Let’s look at impacted product categories …
Cosmetics, Personal Care & Hygiene Products
- Perfumes and eaux de toilette
- Makeup products (lip, eye, face)
- Hair care products (shampoos, lacquers, styling)
- Oral hygiene products
- Shaving and bath preparations Spread across HS Chapter 33
Soaps, Detergents & Cleaning Preparations
- Soaps in various forms
- Skin-washing preparations
- Scouring pastes and powders Spread across HS Chapter 34
Plastics & Plastic Articles
- Plastic tubes, pipes, hoses, fittings
- Plastic sheets, films, laminates
- Containers, bottles, caps, closures
- Household plastic items
- Office, school, decorative and safety plastic articles Spread across HS Chapter 39
Rubber & Automotive-Related Products
- Tires (passenger, truck, specialty)
- Rubber seals, gaskets, joints Spread across HS Chapter 40
Leather Goods, Travel & Personal Accessories
- Bags, backpacks, handbags
- Suitcases and briefcases
- Wallets, belts, gloves
- Saddlery and animal harnesses Spread across HS Chapter 42
Paper, Cardboard & Packaging Materials
- Printing and writing paper
- Boxes, cartons, bags, sacks
- Labels and envelopes
- Wallpaper and decorative paper Spread across HS Chapter 48
Books, Office Supplies & Stationery
- Notebooks and registers
- Folders and planners
- Albums and filing products Spread across HS Chapter 48
Textile Fibers, Yarns & Threads
- Cotton, wool, silk, synthetic fibers
- Yarn (carded, combed, twisted)
- Industrial and high-tenacity yarns Spread across HS Chapters 50–55
Textile Fabrics
- Cotton fabrics and denim
- Synthetic and blended fabrics
- Felt and non-woven textiles Spread across HS Chapters 52–56
Carpets, Rugs & Floor Coverings
- Hand-woven rugs
- Synthetic carpets
- Artificial turf Spread across HS Chapter 57
Decorative, Household & Miscellaneous Consumer Goods
- Decorative articles
- Tableware
- Safety and signaling items
- Camping and hydration containers Spread across HS Chapters 39, 42, 48
Even companies with so-called twin plants (maquiladoras) will need to analyze whether this tariff change impacts their operations.
Link to reforms of the LIGIE:
https://www.dof.gob.mx/nota_detalle.php?codigo=5777376&fecha=29/12/2025#gsc.tab=0%20
Chile “REACH”: Second National Inventory
✔️ Chile has just released its second national chemical inventory under its “REACH”-inspired regime – covering hazardous substances for non-industrial use that were notified by the August 2025 deadline under Decree 57/2021.
Second inventory — why?
Chile decided to divide chemical registration into four (4) groups with staggered deadlines:
Industrial hazardous substances — 2024
Non-industrial hazardous substances — 2025
Industrial hazardous substances in mixtures — 2027
Non-industrial hazardous substances in mixtures — 2029
📌 As a result, in 2025 local manufacturers and importers of non-industrial hazardous substances (so-called “pure” substances) were required to notify them using the current process: 📊 Excel submission with attached SDS.
📄 This second inventory reflects the substances notified by the deadline.
⚠️ Notably, the list is very short — only eleven (11) substances, identified by name and CAS number.
❗ Why does this matter? 🚫 If a hazardous substance intended for non-industrial use (professional or consumer) is not included on the list, it may no longer be imported into Chile without first completing the notification process as a “new” substance.
➡️ What’s next?
📆 In 2026, substances originally notified in 2024 (hazardous industrial-use substances) must be re-notified by August 30.
📆 In 2027 and 2029, the biggest batches of the four groups will be up for registration: • Hazardous substances in industrial mixtures (2027) • Hazardous substances in non-industrial mixtures (2029)
⚖️ For companies operating in or supplying Chile, this inventory has direct implications for market access and regulatory risk.
Link to new inventory:
Mexico: Limits on Lead and GHS Labeling for Paint Products
Mexico’s long-awaited modern standard on lead limits and GHS labeling for paint products has finally been posted for a sixty (60) day public comment period. PROY-NOM-003-SSA1-2025, a draft Mexican Official Standard, would cap total lead in paints and related products at 90 mg/kg (90 ppm) and strengthen require labeling based on the GHS.
Who’s impacted: all entities that manufacture, import, or commercialize paints and related products in Mexico.
Covered product categories (“paints and related products”) include: thinners, varnishes, colorants, enamels, primers, lacquers, pigments, sealers, inks (including printing inks), and fillers/resanadores—water- or solvent-based, for consumer, industrial/professional, commercial, residential, roads, and graphic arts uses.
Key compliance points
- Lead limit: must not exceed 90 ppm in the non-volatile portion/dry film; verified via specified analytical test methods.
- Labeling: Requirements are based on the GHS (included in the annexes) and would be different for consumer products vs. industrial/professional goods. The labeling requirements include warnings, precautionary statements, and (for industrial) full GHS elements (signal word, pictograms, H/P statements, hazardous ingredients).
- Timeline: 60-day public comment for the draft; once finalized (which can take a while) it would enter into force 360 days after publication, and it would replace NOM-003-SSA1-2006.
Significance:
- Mexico would be aligning itself with the global standard on lead content in paints.
- It would be a foray into GHS labeling for a product outside of the workplace setting. As a reminder, up to now the GHS has only been mandatory for employers in the workplace for hazard communication under NOM-018-STPS-2015.
Link to Draft:
Argentina: Market Access Easier for Products from Select Countries
On December 17, 2025, Argentina published Decree 892/2025, introducing a structural shift in how technical compliance for imports is recognized. For the short list of recognized nations, selling their wares in the country just got much easier thanks to international mutual recognition practices, significantly reducing duplicative testing and certification requirements.
🔑 Why this matters
Under the new regime, technical requirements for importation and commercialization in Argentina are deemed fulfilled when products already comply with:
- Regulations of recognized reference countries (Annex I),
- Certifications issued by accredited international certification bodies, or
- Test reports from accredited laboratories.
This means: ✅ Faster market access ✅ Lower compliance and time-to-market costs ✅ Reduced bureaucratic friction ✅ Greater predictability for importers and manufacturers
🌍 Recognized reference countries and regions
Argentina will recognize compliance and authorizations issued in the following markets:
- Australia
- EFTA countries (European Free Trade Association)
- European Union member states
- United States of America
- State of Israel
- Japan
- United Kingdom of Great Britain and Northern Ireland
Products legally marketed or certified in any of these jurisdictions may now enter Argentina without duplicative local technical evaluations, subject to the decree’s conditions.
🧪 Products that DO benefit (examples) (regulated by ANMAT or SENASA)
- Low- and medium-risk medical devices (Class I & II)
- Certain in vitro diagnostic products (Classes A & B, no cold chain)
- Cosmetics, perfumes, and personal care products
- Household cleaning products
- Veterinary therapeutics and immunological products (with sworn declaration)
🚫 Products that do NOT benefit from the new regime
The decree explicitly excludes sensitive or specially regulated categories, which remain subject to existing frameworks:
- ❌ Food products regulated under the Argentine Food Code
- ❌ Human-use medicines
- ❌ Fertilizers and soil amendments
- ❌ Unprocessed agricultural and livestock products (grains, fruits, meat, seeds, live animals, etc.)
- ❌ Used or refurbished goods
- ❌ Weapons, explosives, and hazardous chemicals
- ❌ Products prohibited from commercialization in Argentina
- ❌ Goods governed by special laws with distinct quality or authorization regimes
⚖️ Bottom line
Decree 892/2025 signals Argentina’s continued move toward deregulation and cutting red tape. The country is trying to strike the right balance by trusting robust international regulatory systems, while preserving strict oversight for food, pharmaceuticals, and primary agriculture.
For companies operating in industrial goods, medical devices, cosmetics, and regulated non-food sectors, this reform can translate into months saved in approvals and a more efficient path to market.
The new rules go into effect 60 days after publication.
📌 Key takeaway: Less bureaucracy red tape and much easier market access for covered products from recognized markets.
Link to Decree:
https://www.boletinoficial.gob.ar/detalleAviso/primera/336319/20251217
Mexico: Regulatory Guidance on Medical Devices
Mexico’s FDA- analog (COFEPRIS) just released a very handy FAQ on common questions that come up with regard to the “AGREEMENT ANNOUNCING THE LISTS OF MEDICAL DEVICES CONSIDERED LOW RISK THAT REQUIRE HEALTH REGISTRATION, THOSE THAT DO NOT REQUIRE HEALTH REGISTRATION, AND THOSE PRODUCTS THAT, DUE TO THEIR NATURE, CHARACTERISTICS, AND USE, ARE NOT CONSIDERED HEALTH SUPPLIES AND THEREFORE DO NOT REQUIRE HEALTH REGISTRATION” that was published in July 2025.
Now we have answers to common questions like how to classify dandruff shampoo, mouth wash, toothpaste, and N95 masks.
Link to FAQ:
Brazil’s New Framework for Sustainable Chemical Industry
Brazil is not stopping with its plans for a sustainable economy – and industries. In the fall of 2025, we got their new Sustainable Taxonomy. Now, the country has enacted Law 15.294/2025, creating the Special Program for Sustainability of the Chemical Industry (PRESIQ), in force from 2027 to 2031. The law establishes a targeted incentive regime to boost competitiveness, decarbonization, innovation, and global integration of Brazil’s chemical sector.
🔍 What’s new
- Two eligibility tracks: ▪️ Industrial mode: tax credits of up to 6% on key chemical inputs ▪️ Investment mode: tax credits of up to 3% of gross revenue, linked to capacity expansion or modernization
- Focus on sustainability: energy efficiency, low-carbon technologies, circular economy, and renewable feedstocks
- Mandatory R&D investment tied to the use of tax credits
- Refundable or off-settable tax credits
⚖️ Why it matters
PRESIQ signals Brazil’s commitment to neo-industrialization—using fiscal policy to modernize its chemical industry, reduce idle capacity, and strengthen its role in global value chains, while aligning growth with climate and innovation goals.
📌 Effective date: incentives apply as of January 1, 2027 📌 Key takeaway: Brazil is trying mightily to balance industrial competitiveness with sustainability by using concrete fiscal incentives. All companies in the chemical sector should take note.
Link to law:
https://www.in.gov.br/web/dou/-/lei-n-15.294-de-19-de-dezembro-de-2025-676915237
Ban on CMR Ingredients in Cosmetics in Andean Community
The fallout from the EU’s ban of two chemicals in gel nail polish for potential reproductive toxicity and potential carcinogenic effects continues in Latin America. As reported, several countries issued near immediate bans after the September 2025 action in Europe.
Now, the Andean Community, which is comprised of Ecuador, Colombia, Bolivia, and Peru, issued a regional ban on the same two substances in all cosmetics.
Specifically, the resolution bans the use of Trimethylbenzoyl Diphenylphosphine Oxide (TPO) and N,N-dimethyl-p-toluidine (DMPT) in cosmetic products marketed in the Andean Community.
- Products containing these ingredients cannot obtain, renew, or recognize a Sanitary Notification (NSO) as of the regulation’s entry into force.
- Existing cosmetic products with these substances must be withdrawn from the market within 60 calendar days.
- No sell-off of existing stock or product reformulation is allowed.
- After the 60-day period, the NSO will be automatically cancelled.
- Non-compliance will result in administrative sanctions under Andean Community and applicable national regulations.
Resolution 2548 was published in the Andean Community official gazette on December 15, 2025.
Link to Resolution:
https://www.comunidadandina.org/DocOficialesFiles/Gacetas/GACETA%205717.pdf
Brazil: CONASQ News
Brazil’s National Commission on Chemical Safety – known by its Portuguese acronym “CONASQ” – is a veritable reference in the region – and the world – for its collegial approach to regulatory development and implementation. The multidisciplinary, multi-stakeholder body not only developed the draft that eventually became Brazil’s “REACH”-inspired Law 15.022- but then developed the draft regulation that will further flesh out the requirements of the new chemical control scheme.
Now, the government just published the notice that it is time t elect 10 seats on the CONASQ for he 2026-2028 term. Civil society, private sector, academia, and professional associations may apply and vote within their own segments.
🗓️ Key dates: • Registration: Jan 12–23, 2026 • Online voting: Feb 3 – Mar 6, 2026 • Final results announced: Mar 18, 2026
📌 Companies active in Brazil should consider participating in the CONASQ if they have the opportunity.
Lost in Latin America’s Chemical Regulations? Here’s Your Shortcut to Compliance
🌎 Latin America’s chemical regulations can feel like a maze — fragmented rules, local nuances, and “REACH-style” systems that aren’t always easy to interpret.
That’s exactly why we built practical, time-saving tools at AMBIENTELEGAL ACADEMY.
📌 New self-paced video courses, including downloadable reference reports you can keep:
- 🎓 Crash Course on Colombia “REACH”
- 🎓 Crash Course on Chile “REACH”
📌 Key regulatory documents — translated into English, so you don’t lose time or meaning:
- 📄 Brazil “REACH” Law
- 📄 Instruction Guides for Colombia “REACH” Registration
- 📄 Instruction Guide for Chile “REACH” Registration
Whether you work in regulatory affairs, compliance, EHS, or market access, these resources are designed to: ✅ Save you time ✅ Reduce regulatory uncertainty ✅ Help you make informed compliance decisions faster
👉 Explore all courses and materials here: https://ambientelegalacademy.teachable.com/p/homera-a-DD-no-051.2024.A-que-estabelece-procedimento-para-a-demonstracao-do-cumprimento-da-logistica-reversa.pdf
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