Peru Approves New Chemical Management Regulation
Following an extended public consultation process, Peru’s Ministry of the Environment (MINAM) officially approved the Regulation of Legislative Decree No. 1570, the Law on the Integral Management of Chemical Substances. The regulation was published in the Official Gazette El Peruano on 8 April 2026.
Although the regulation has already been published, it will only enter into force six months after publication, meaning that its effective implementation is expected around October 2026. The main compliance obligations, including classification, labelling, Safety Data Sheets (SDS/FDS), and reporting to the National Register of Chemical Substances (RENASQ), will be introduced gradually between 1 January 2028 and 30 September 2031. During this transition period, enforcement authorities, will focus on guidance and orientation rather than sanctions.
The regulation does not apply to all chemical substances. Several categories are excluded from the classification and reporting requirements.
These exemptions include naturally occurring substances such as minerals, coal, natural gas, and crude oil. The regulation further excludes substances that occur naturally without chemical modification, and substances formed through unintended reactions. These exclusions are intended to prevent unnecessary regulatory burden for substances or uses that are already controlled, low-risk, or outside the intended scope of the framework.
Peru’s new system is built around the United Nations Globally Harmonized 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 of 2015 onwards.
Chemical substances placed on the Peruvian market must therefore be classified, labelled, and accompanied by a Safety Data Sheet in accordance with GHS requirements. Labels must be provided in Spanish and include the product identifier, hazard pictograms, signal words such as “Danger” or “Warning”, hazard statements, precautionary statements, and supplier or manufacturer information.
The regulation also establishes minimum label sizes based on the capacity of the container. For example, containers exceeding 500 litres must carry a label measuring at least 148 × 210 mm, with hazard pictograms of no less than 46 × 46 mm. SDSs must be available at the point of use, either physically or digitally, and must be reviewed and updated at least every five years.
A key feature of the regulation is the future establishment of reporting thresholds. MINAM is expected to issue a decree in the second half of 2027 defining the minimum manufactured or imported quantity that will trigger the obligation to notify classification, labelling, and SDS information to the authority. This same threshold will also determine whether companies must submit information to RENASQ.
However, companies operating below the threshold will not be fully exempt from chemical safety obligations. From 2032 onwards, all manufacturers and importers, regardless of volume, must classify their substances, prepare labels, and provide SDSs. The threshold only determines whether formal notification to MINAM is required; it does not remove the basic obligation to manage chemical hazards properly.
One important distinction is that notification to MINAM and reporting to RENASQ are separate obligations.
Notification refers to the submission of hazard classification, labelling, and SDS information for a specific substance. It is generally required before a new substance is placed on the market, or within one month of the first commercialisation of an existing substance. This notification process functions as the entry point into the national system and provides information that feeds into RENASQ.
RENASQ reporting, on the other hand, is an annual obligation. It requires companies to declare, between 1 January and 31 March each year, the quantities of dangerous substances manufactured or imported during the previous year. This is a recurring quantitative reporting requirement and applies to companies that exceed the threshold established by MINAM.
The National Register of Chemical Substances, or RENASQ, is administered by MINAM. It brings together information from the notification system, existing sectoral registers, and annual quantity reports. Certain information, such as substance names, classifications, SDSs, and geographic distribution, may be made publicly available. However, commercially sensitive data, including exact company-level volumes, complete toxicological study reports, and precise mixture compositions, may be treated as confidential.
The Listado de Clasificación Anticipada de Peligros, or Early Hazard Classification List (LCA), plays a central role in the transition to the new system. It is a reference list prepared by MINAM based on international classification inventories and other reliable official sources.
The LCA provides a minimum starting point for hazard classification, particularly for manufacturers and importers that have not yet completed their own full GHS assessment. However, the list is not exhaustive, and companies remain responsible for ensuring that their final classifications are accurate and supported by available data.
The LCA is included as Annex 3 of the regulation and is updated at least every two years through a Ministerial Resolution. Updates require prior favourable opinions from the Ministries of Health, Production, and Labour. In practical terms, the first major deadline applies to companies handling substances listed in the LCA with matching classifications. These companies must notify MINAM by 30 September 2028.
If a substance is not included in any LCA by 1 January 2032, it will be treated as a new chemical substance. This means it will be subject to stricter pre-commercialisation notification and risk assessment requirements.
The regulation introduces a gradual notification schedule between 2028 and 2031. The deadlines depend on whether the substance is included in the LCA and whether the company’s classification matches the listed classification.
RENASQ reporting will follow a similar staged approach. Companies that notified LCA-matching substances will begin annual reporting from 2029. Those with substances classified differently from the LCA will begin reporting from 2030, while substances not included in the LCA will begin reporting from 2031.
The regulation also introduces the role of the Foreign Exclusive Representative, or Representante Exclusivo del Exterior (REE). This mechanism is intended to address situations where Peruvian importers do not have access to confidential formulation or technical data held by foreign suppliers.
An importer may appoint an REE to submit confidential information directly to RENASQ on its behalf. The REE may be a third party located in Peru or abroad, or the foreign manufacturer itself. The REE can provide sensitive information, such as exact mixture compositions or complete toxicological study files, without disclosing this data to the importer.
Once the confidential information has been submitted, the importer is informed that the requirement has been fulfilled but does not receive access to the confidential data. An REE may represent several foreign suppliers, provided that each supplier’s information is kept strictly separate. However, the appointment of an REE does not remove the importer’s responsibility to report the information that it does possess.
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