“Around Latin America”: Now Available on a Blog
Have you ever tried to remember what edition of this newsletter covered the plastics regulation you need to know about?
Did you ever miss an issue in your inbox?
If so, you’ll love this news:
Every new issue of Around Latin America also lives on a public, fully searchable blog on my website: https://ambientelegal.com/blog/
Now every edition will be:
🔎 Searchable by keyword
📚 Archived for easy reference
🌐 Accessible to anyone, anytime — and still completely free
And don’t worry, if you are subscribed here on LinkedIn, you will still get it in your inbox every week.
Colombia: New Waste Rules Impact Plastics and WEEE
As a newish member of the OECD, Colombia continues to update its local laws to reflect its commitments to that organization. The latest is new rules for cross-border movements of hazardous and other wastes, aligned with the Basel Convention and OECD Decision OECD/LEGAL/0266.
The new Resolution applies to:
· Wastes under Amber Control (Basel Annex II & VIII; OECD Appendix 4).
· Wastes under Green Control (Basel Annex IX; OECD Appendix 3).
· Basel amendments on plastic waste and WEEE.
ANLA will authorize and monitor all transboundary waste movements based on the following rules::
Movements between OECD countries:
- Appendix 4 wastes → Amber Control Procedure.
- Appendix 3 wastes → Green Control Procedure.
Imports into Colombia
Hazardous waste imports remain prohibited. Non-hazardous waste imports are allowed only if they do not meet the criteria for hazardous waste under national regulations.
Plastics
Plastic waste movements must follow Basel Amendment BC-14/12. Under OECD rules, certain plastic wastes (AC300 / A3210 / Y48) must use Amber Control.
WEEE (Waste Electric and Electronic Products)
Movements must comply with Basel Amendment BC-15/18. Under OECD rules, hazardous WEEE and Y49-listed wastes also require Amber Control.
Entry into Force
The Resolution becomes effective three months after publication – repealing Resolution 1402 of 2006.
Link to Resolution:
Cosmetics, Personal Care & Perfumes; New Label Rules
Very often for international products there is a need to re-label it once imported into a country to comply with local requirements. In highly regulated sectors, like cosmetics, personal care, and perfumes, this practice – often referred to as an “over label” – is done by placing a sticker on the original label with details in the local language. This practice just got officially recognized – and much better spelled out – in an Andean Community regulation that will apply in Colombia, Peru, Ecuador and Bolivia. In my native Mexico we say God is in the details – here in the U.S. I learned it was the “devil’s in the details” – whatever you believe, labeling is one of those places where details matter a lot!
What’s New?
Complementary Labels
Stickers (or over labels) are now allowed to clarify, adapt, or add information to the original label. They cannot cannot replace or cover the batch number or the product name. The stickers may be applied only in authorized facilities.
The new rule sets out full label requirements for the over label – confirming the list of mandatory information (product name, generic denomination, NSO code, ingredients INCI, expiration date, warnings, etc.). Extra, non-required information is allowed if not misleading. Seasonal design changes that don’t alter information do not need notification. Final label in market must match the latest label notified to authorities.
Super helpful to have clear rules on what is the minimum required information for small containers: Product name, Generic denomination, Holder/importer name, NSO code, Content, Batch number, Risk-related ingredients (if applicable), and Expiration date.
Language requirements area also addressed. Under the new rule, warnings, instructions, storage conditions, and manufacturer precautions must appear in Spanish. But, take note: generic denomination no longer requires translation if widely understood in the Andean region.
The new rule goes into effect December 17, 2025.
Link to Resolution:
http://extranet.comunidadandina.org/sirt/sirtDocumentos/ECOTC25030.PDF
International Tort Liability: Game Changing Decision
A recent decision in the UK over a collapse of a mine tailing dam in Mariana, Brazil in 2015 that killed 19 and left in its wake environmental devastation should be a wakeup call for all international companies – not just in the extractives industries. A court in London essentially found that a parent entity can face liability abroad when it exercises operational control or risk oversight over subsidiaries. From now on, corporate structure, geographic distance, or parallel local proceedings will not insulate a company if its governance practices fall short.
The case is not over – surely the company will file appeals, and future stages on determination of damages are set into 2026 even if they don’t.
The key takeaway is that multinational firms need to ensure robust, enforceable safety and risk-management systems across all global operations.
Link to official decision:
https://www.judiciary.uk/wp-content/uploads/2025/11/Municipio-de-Mariana-v-BHP-Group.pdf
A Rose is not a Rose: Product Edition
Gertrude Stein famously said “a rose is a rose” – and yet, in the world of regulated products, not so fast. Your product’s regulatory classification may not – and often does not – cross borders. Neither do your tariff codes by the way.
Let’s look at just one interesting example by way of a recent Chilean decision.
What is a tattoo ink?
In the US, tattoo inks are considered cosmetics.
In Brazil, the same inks are regulated as medical products.
And now, based on a recent decision, we know that Chile does not consider them to be pharmaceutical products, cosmetics, or medical devices. Instead, the products must comply with the regulation in Chile on the “List of dyes permitted in pharmaceutical products.”
One product regulated three very different ways in three different countries.
Key lesson: Always get clarity on how your product is classified in the new market before you do anything else. All the tax, licensing, and other obligations depend upon getting that right.
Link to Chilean decision:
LATAM “REACH” – Where to start?
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