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After months of public consultation, Peru's Ministry of the Environment (MINAM) has formally approved the Regulation of Legislative Decree N° 1570, the Law on the Integral Management of Chemical Substances, publishing it in the Official Gazette El Peruano on 8 April 2026. Despite its immediate publication, the regulation will not enter into force for another six months, placing the effective start date around October 2026. However, the substantive obligations, such as classification, labelling, Safety Data Sheets (SDS/FDS) and reporting to the National Register of Chemical Substances (RENASQ), are phased in over a transitional period running from 1 January 2028 to 30 September 2031. During that window, companies will not face sanctions: enforcement bodies (the EFAs) are instructed to carry out only orientation-based supervision.

Key Exemptions Under the New Regulation

Not all substances are subject to the regulation’s requirements. The new rules specifically exclude certain chemicals from the reporting and classification processes. Exempt substances include:

• Naturally Occurring Substances: These include materials such as minerals, coal, gas, and crude oil, provided they are not chemically modified. For example, natural gas and crude oil are exempt if they are not processed chemically.
• Samples for Scientific Research: Chemicals used for research or as reference standards, provided they do not exceed a certain threshold, are not subject to the regulation.
• Radionuclides and Non-Chemically Modified Substances: Some substances that exist naturally without chemical modifications or that undergo unintentional reactions are excluded from the regulations.

Global Harmonized System (GHS) Compliance

The entire classification and labelling architecture is built around the United Nations' Globally Harmonised System of Classification and Labelling of Chemicals (GHS) — known in Spanish as the Sistema Globalmente Armonizado (SGA). The regulation adopts the GHS from its sixth revised edition (2015) onwards and requires that all chemical substances sold or used in Peru are classified, labelled and accompanied by an SDS in accordance with its standards. Labels must be written in Spanish and must include: the product identifier, hazard pictograms, signal words ("Danger" / "Warning"), hazard statements, precautionary statements and manufacturer details.

The regulation also sets specific minimum label dimensions depending on container size — for example, containers above 500 litres must carry a label of at least 148 × 210 mm with pictograms no smaller than 46 × 46 mm. SDS documents must be reviewed and updated at least every five years, and kept accessible in digital or physical form at the point of use.

Thresholds for Reporting

One of the most technically complex aspects of the regulation is its threshold mechanism. The Ministry of the Environment will determine, by Decree in the second half of 2027, the minimum quantity of manufacture or importation above which a company is formally obliged to notify MINAM of its classification, labelling and SDS data. This threshold also triggers the obligation to report to the RENASQ.

Crucially, the regulation makes clear that companies below the threshold are not entirely off the hook: from 2032, all manufacturers and importers, regardless of volume, must still carry out classification, labelling and produce an SDS. The threshold determines whether formal notification to MINAM is required, not whether the underlying safety obligations apply.

RENASQ vs. Notification System

Industry observers have flagged a common misconception: that the notification and the RENASQ are the same system. They are not.

• Notification to MINAM: A one-time (or update-triggered) disclosure of hazard classification, labelling and SDS data for a specific substance. Required before a new substance is placed on the market, or within one month of first marketing a pre-existing substance. It is the entry point to the system and feeds the RENASQ.
• RENASQ report: An annual declaratory report (1 Jan – 31 Mar each year) of the quantities of dangerous substances manufactured and/or imported during the previous year. It is a recurring, quantitative obligation, separate from notification, and only applies to those above the established threshold.

The RENASQ (Registro Nacional de Sustancias Químicas) is administered by MINAM and integrates data from the notification system, existing sectoral registers (via interoperability), and annual quantity reports. Part of its content substance names, classifications, SDS documents and geographic distribution is publicly accessible. Commercially sensitive information such as exact company-level quantities, full toxicological study reports and precise mixture compositions may be designated as confidential.

The LCA - and its 2028 deadline

The Listado de Clasificación Anticipada de Peligros (LCA — Early Hazard Classification List) forms the backbone of the transition. It is a reference tool compiled by MINAM drawing on international classification inventories and other credible official sources. It sets a minimum, but not exhaustive, classification starting point for manufacturers and importers who may not yet have conducted their own full GHS assessment.

The LCA is published as Annex 3 of the regulation and must be updated at least every two years via Ministerial Resolution, with prior favourable opinions from the Ministries of Health (MINSA), Production (PRODUCE) and Labour (MTPE). The critical practical implication is that the first group of companies — those handling LCA-listed substances with matching classifications — must notify MINAM by 30 September 2028. This is the earliest hard deadline in the entire notification calendar and the one most companies will encounter first.

Substances not present in any LCA by 1 January 2032 will automatically be deemed "new chemical substances" and face the more stringent pre-commercialisation notification and risk assessment requirements that apply to novel compounds.

Notification Deadlines - a phased calendar 

The regulation lays out a carefully sequenced timetable during the 2028–2031 adaptation period, graduated by how well a substance is already understood:

• Jan – Sep 2028: Substances whose hazard classification matches the LCA (Early Classification List) exactly, or which have additional hazard classes on top of the LCA listing.
• Jan – Sep 2029: Substances with a classification that differs from the LCA listing.
• Jan – Sep 2030: Dangerous substances not currently appearing in the LCA at all.
• Jan – Sep 2031: Non-dangerous substances.
• From 2032: Any manufacturer or importer placing a pre-existing substance on the market for the first time must notify within one month of commercialisation. New substances must be notified before commercialisation begins.

RENASQ reporting follows a parallel graduated schedule: those who notified LCA-matching substances begin reporting from 2029; differing-classification substances from 2030; substances not in the LCA from 2031

The Foreign Exclusive Representative (REE) 

The regulation introduces a mechanism specifically designed for importers who cannot access the confidential formulation data held by their overseas suppliers. An importer may designate a Representante Exclusivo del Exterior (REE),  a Foreign Exclusive Representative, who can be either a third party resident in Peru or abroad, or the foreign manufacturer themselves.

The REE submits the confidential information (such as exact mixture compositions or full toxicological study files) directly to the RENASQ on the importer's behalf. Importantly, the importer is then notified that the confidential data requirement has been fulfilled but is not given access to the submitted data. The REE can represent multiple foreign suppliers simultaneously, provided each supplier's data is kept strictly separate. The REE mechanism does not relieve the importer of its obligation to report the information it does have access to.

Prioritization of Chemicals

The prioritization of certain chemicals will be a key aspect of this new regulatory framework. Starting in 2032, substances will be prioritized based on their hazard classification and exposure risk. The Ministry of Environment (MINAM) will determine which substances should be reviewed first based on several factors, including:

• Risk levels to health and the environment
• Annual quantities imported or manufactured
• International treaties and national regulations related to chemical safety

Once prioritized, these chemicals will undergo more stringent risk assessments and be subject to specific control measures.

ANNEXES of the Regulation

The regulation includes several Annexes detailing additional information and guidelines for compliance. These Annexes include:

• Annex 1: Contains the list of hazard classification codes and precautionary advice for chemical substances.
• Annex 2: Provides examples and guidance on how to label and display GHS hazard symbols and pictograms.
• Annex 3: Includes updated lists of prioritized chemicals based on risk and exposure criteria.
• Annex 4: Defines the safety data sheet (SDS) requirements and structure, including information on the necessary components like physical properties, toxicity data, and safe handling procedures.

The Annexes ensure that all stakeholders, from manufacturers to government agencies, have the resources and clear instructions necessary to meet regulatory standards.

For futher information you can find the Supreme Decree (in Spanish) here.