The Peruvian government has officially enacted Supreme Decree No. 005-2026-MINAM, approving the Regulations for the Law on Integral Management of Chemical Substances. This landmark regulation represents a comprehensive upgrade of Peru's chemical oversight system, formally aligning it with the international Globally Harmonized System (GHS) and establishing the National Registry of Chemical Substances (RENASQ).
With this move, Peru joins the ranks of Chile, Colombia, and Brazil as the fourth nation in Latin America to adopt a unified chemical management framework. The regulation will officially enter into force six months after its publication.
Core Regulatory Framework and Key Highlights
I. Division of Regulatory Authority: Inter-Ministerial Synergy
The regulation delineates specific responsibilities between the Ministry of Environment (MINAM) and the Ministry of Health (MINSA):
Ministry of Health (MINSA): Oversees substances falling under specific sanitary authorization frameworks, including hazardous substances for household, industrial, and public health use.
Ministry of Environment (MINAM): Responsible for the notification and supervision of all other chemical substances outside the above scope that exceed defined quantitative thresholds.
II. Core Compliance Obligations: Notification and Reporting
Obligations are categorized into "Hazard Information Notification" and "RENASQ Reporting":
Hazard Information Notification: Manufacturers or importers exceeding the prescribed thresholds must submit the chemical’s hazard classification, labeling, and Safety Data Sheet (SDS) information to MINAM.
RENASQ Annual Reporting: For hazardous chemicals exceeding the thresholds, companies must report the actual volume manufactured or imported during the previous calendar year via the RENASQ system.
III. Compliance Timeline: A Tiered Transition
The regulation features a List of Harmonized Classifications (LCA) containing over 4,000 substances. This list serves as the basis for a phased compliance schedule from 2028 to 2031. Manufacturers and importers in Peru must notify hazard information within the following windows:
| Substance Characteristics | Notification Deadline |
| Substances with hazard classifications matching the LCA (or including additional hazards) | Jan 1, 2028 – Sept 30, 2028 |
| Substances with hazard classifications differing from the LCA | Jan 1, 2029 – Sept 30, 2029 |
| Classified hazardous substances NOT listed in the LCA | Jan 1, 2030 – Sept 30, 2030 |
| Substances with no hazard classification | Jan 1, 2031 – Sept 30, 2031 |
| Existing Substances* (First-time production/import post-2032) | Within 1 month of market entry |
| New Substances** (Exceeding thresholds) | Prior to market entry |
*Existing Substances: Refers to substances for which hazard information notification was completed and which were included in the official inventory and the National Registry before September 30, 2031.
**New Substances: Refers to substances that did not complete registration before the end of September 30, 2031, and were not included in that year's Hazard Classification List or the National Chemical Registry.
The table below specifies the subsequent Annual Reporting deadlines in RENASQ following the completion of the notifications mentioned above:
| Substance Characteristics | Annual Reporting Period |
| Notified substances matching/exceeding the LCA | Jan 1, 2029 – Mar 31, 2029 |
| Notified substances differing from the LCA | Jan 1, 2030 – Mar 31, 2030 |
| Notified hazardous substances not in the LCA | Jan 1, 2031 – Mar 31, 2031 |
IV. Technical Specifications and Exemptions
GHS Standard: Peru currently adopts the 6th Revised Edition of GHS. While classification data from the EU, USA, Canada, UK, and Japan are permitted for reference, the SDS must be provided in Spanish.
Exemptions: Categories regulated by specific sectoral frameworks—such as pharmaceuticals, pesticides, food/feed, cosmetics, and medical devices—are exempt. Additionally, articles that do not release substances under normal use, as well as non-chemically modified minerals, crude oil, and natural gas, are excluded.
Exclusive Representative in the Exterior (REE): Drawing from the "Colombia Model," foreign manufacturers may appoint an REE to submit Confidential Business Information (CBI). This ensures compliance for the importer without compromising trade secrets.
V. Subsequent Risk Management
Notification and annual reporting are only the foundational steps. Based on the data collected, the Peruvian government will build a national inventory and initiate Risk Assessments (ERSQ) for substances of high concern. Consequently, businesses may face a heavier burden for risk studies and potential substance restrictions or bans in the future.
Strategic Outlook and Recommendations
With the implementation of these Regulations, Peru is shifting from reactive administrative approvals to proactive risk prevention. Through the integration of the RENASQ registry with the Single Window for Foreign Trade (VUCE), the government will gain unprecedented data insights to identify hazardous sources and cross-border risks.
The two-year window before mandatory enforcement begins in 2028 is a critical period for enterprises to gain a competitive edge through systematic adjustment. REACH24H recommends that relevant companies—particularly international suppliers exporting to Peru and local importers—begin auditing their product portfolios, verifying existing SDS and labels, and paying close attention to the compliance tonnage thresholds to be announced in 2027.
Enterprises should be fully prepared for the phased mandatory compliance starting in 2028. REACH24H will continue to provide timely updates on further regulatory details.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
