News Brief
On October 14, 2025, the Environmental Management Bureau (EMB) under the Department of Environment and Natural Resources (DENR) released the Draft DENR Administrative Order (DAO) on the 2025 Philippine Inventory of Chemicals and Chemical Substances (PICCS) Supplement (DRAFT DAO-PICCS-2025). This draft proposes to add 59 new chemical substances to the PICCS.
The proposed inclusion of these 59 chemicals is mandated by the Toxic Substances and Hazardous and Nuclear Waste Control Act of 1990 (Republic Act No. 6969 or RA 6969), its Implementing Rules and Regulations (DAO 1992-29), and Section 5 of DAO 2025-09. These substances have successfully completed the Pre-Manufacture and Pre-Importation Notification (PMPIN) process and submitted their Notice of Commencement (NOC) of activity.
The draft supplement confirms the DENR-EMB's commitment to the annual updating of the PICCS, a process that is becoming the new norm. This article provides an in-depth analysis of the PICCS framework, the key provisions of the 2025 draft, and essential compliance guidance for chemical-related enterprises.
PICCS: The Cornerstone of Philippine Chemical Management
Historical Context: From RA 6969 to a Dynamic Inventory
The foundation of the Philippines' chemical regulatory system is RA 6969, enacted in 1990 to protect public health and the environment from toxic and hazardous substances. The PICCS was established as a core mechanism of this law.
The initial PICCS, compiled in 1995, listed chemical substances that were manufactured, processed, distributed, used, imported, or exported in the Philippines before December 31, 1993. The establishment of the PICCS created a fundamental distinction between "existing chemicals" (those listed) and "new chemicals" (those not listed). Existing chemicals are generally permitted for trade, while new chemicals must undergo a stringent notification process before they can be legally introduced to the market.
While the EMB ceased accepting nominations for inclusion after December 31, 1993, the PICCS is not static. It is dynamically updated by periodically incorporating substances that have successfully completed the PMPIN process. The EMB has accelerated this update frequency in recent years, issuing draft supplements for 2022, 2023, 2024, and now 2025. The 2022 and 2023 supplements have already taken effect, and the 2024 and 2025 drafts are anticipated to be officially published in 2026.
Core Function: The "Passport" for Chemical Market Access
The PICCS plays a vital role in Philippine chemical management, serving as the primary compliance hurdle for market entry.
Market Access Foundation: Any chemical substance not listed in the PICCS must undergo the EMB's New Chemical Substance Notification procedure—primarily the PMPIN—before it can be legally manufactured or imported into the Philippines. Only upon successful notification and approval can a company legally manufacture or import the substance.
Basis for Risk Assessment: The PICCS, along with the Priority Chemicals List (PCL) and Chemical Control Orders (CCOs), forms the country's chemical risk management system. Substances on the PICCS that are not subject to PCL or CCO controls are considered relatively low-risk and can be freely traded. The PCL and CCOs, conversely, impose stricter licensing, restrictions, or outright bans on high-risk substances.
Information Transparency: The public nature of the PICCS provides regulators, industry, and the public with a clear understanding of the chemicals circulating in the Philippines, offering essential data for risk monitoring, environmental management, and emergency response.
Interpreting the 2025 Draft Supplement: Strict Conditions for Inclusion
The core of the 2025 draft supplement is the proposed inclusion of 59 new chemicals that have undergone the PMPIN process, reaffirming the strict pathway for a new substance to achieve "existing chemical" status.
PMPIN: The Sole Gateway to PICCS Listing
According to EMB regulations, a chemical substance must meet the following critical conditions to be included in the PICCS:
Only substances that have completed the PMPIN application, received approval, and submitted a Notice of Commencement (NOC) of activity can be included in the PICCS by the EMB one year after the NOC submission.
This means the PMPIN is the only official route for a new chemical substance to gain "existing chemical" status. The PMPIN process requires companies to submit detailed information on the substance, toxicological data, and environmental impact assessments to demonstrate its safe use in the Philippines. After PMPIN approval, companies must submit an NOC before the substance is actually manufactured or imported. The EMB initiates the formal PICCS inclusion process only after confirming the substance's actual market application and risk profile.
Exempted Substances: Exceptions to PICCS Inclusion
In contrast to the stringent PMPIN requirements, chemical substances that enter the Philippine market through exemption procedures are explicitly excluded from PICCS listing. These exemptions primarily include:
Small Quantity Importation (SQI) Exemption: For new chemicals with an annual import volume below a specific threshold (e.g., 1 ton/year).
Polymer Exemption: For polymers that meet specific structural and safety criteria.
Exemptions are fundamentally a "conditional permission for market entry," not a confirmation of "existing substance" status. The regulatory focus for SQI and Polymer Exemptions is on their limited import volume or low inherent risk. If a company wishes to exceed the exemption limits (e.g., increase import volume or change the polymer structure), they must then proceed with the full PMPIN notification. Therefore, the EMB clearly stipulates that substances approved via SQI and Polymer Exemption cannot be listed in the PICCS.
Compliance Recommendations for Chemical Enterprises
In light of the Philippines' increasingly strict and dynamic chemical regulatory environment, companies should adopt proactive compliance strategies following the release of the PICCS draft supplement:
Compliance Action | Description | Status Check |
Product Status Verification | Cross-reference all chemicals exported to or manufactured in the Philippines against the latest PICCS (including the 59 proposed additions). | Listed in PICCS: Ensure the substance is not on the PCL or subject to a CCO, and monitor future regulatory changes. |
Not Listed in PICCS: Halt or postpone trade. Select the appropriate notification or exemption pathway based on use, volume, and chemical structure: ü Long-term, High-volume Trade: Initiate the PMPIN process early, allowing sufficient preparation time. ü Small-volume or R&D Use: Consider applying for the SQI Exemption. ü Polymers: Evaluate eligibility for the Polymer Exemption criteria. | ||
Confidential Business Information (CBI) | When submitting PMPIN, companies should apply for CBI protection to safeguard proprietary information. This ensures that critical chemical structures or names are not publicly disclosed and are instead listed in the confidential section of the PICCS. | Apply for CBI during PMPIN submission to protect trade secrets. |
Establish Dynamic Monitoring | Given the annual update cycle of the PICCS, companies should regularly monitor regulatory developments. Proactive tracking of chemicals slated for PICCS inclusion can help avoid unnecessary compliance costs. | Implement a system for continuous monitoring of EMB announcements and PICCS updates. |
The DRAFT DAO-PICCS-2025 signifies the EMB's ongoing efforts to modernize and enforce its chemical control laws. Companies must ensure their compliance strategies are robust and adaptable to these continuous regulatory changes to maintain legal market access in the Philippines.
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