The Philippine Bureau of Customs (BOC) has reiterated temporary documentary arrangements for imported Household/Urban Hazardous Substances (HUHS) while the Food and Drug Administration (FDA) continues its licensing and product-registration transition. Customs Memorandum Circular No. 201-2026 concerns the extension of the transitory period for HUHS product registration and mandatory labelling requirements. The official BOC register confirms the circular number and subject, although its date column is blank. A Philippine logistics report states that the directive was issued on 24 August 2026. It allows qualifying HUHS shipments to continue using specified alternative documents for customs release until 31 December 2026. The arrangement is relevant to foreign suppliers, Philippine distributor-importers, customs brokers and logistics companies handling FDA-regulated HUHS products. 

Temporary Documents for Customs Release

Through 31 December 2026, customs officials may accept a copy of an expired Licence to Operate held by an HUHS distributor-importer together with the FDA acknowledgement receipt for its submitted Letter of Request and Declaration Statement. Importers should retain both documents in the shipment-clearance file and confirm that they correspond to the responsible Philippine establishment. The accommodation is linked to FDA Advisory No. 2026-0706, dated 29 June 2026. That advisory extended the transitory period for mandatory HUHS Certificates of Product Registration and compliance with the labelling requirements in Annex J of FDA Circular No. 2020-025 until 31 December 2026. The FDA states that this deadline applies unless the arrangement is repealed or amended earlier.

Regulatory Status of HUHS Products

CMC No. 201-2026 does not create a general exemption from FDA regulation or permanently validate an expired LTO. It provides a temporary documentary route for customs release while the FDA completes the ongoing HUHS licensing transition and data migration. Companies must still assess the applicable establishment licensing, product registration, safety documentation and labelling requirements. FDA Circular No. 2020-025 establishes the broader framework for HUHS establishment licensing, product registration, inspection and GHS-based labelling. It also requires regulated establishments to comply with relevant manufacturing, distribution, storage and labelling practices. FDA Circular No. 2020-025. The temporary arrangement does not restrict the FDA’s authority to conduct inspections and post-market surveillance. Products considered unsafe or injurious to public health may remain subject to banning, recall, market withdrawal or destruction. Import clearance should therefore not be treated as confirmation that a product has obtained permanent regulatory approval.

Industry Impact

HUHS importers should verify the status of their LTO renewal or system migration and retain the required FDA acknowledgement documentation. Companies should also review each product’s CPR status, ingredient documentation, safety data sheet, GHS classification and Annex J-compliant label. Internal compliance plans should assume that the present transition ends after 31 December 2026 unless the FDA announces a further extension.