News Brief
On October 23, 2025, the Department of Environment and Natural Resources Environmental Management Bureau (DENR-EMB) of the Philippines issued the final draft Chemical Control Order (CCO) for Vinyl Chloride. This is pursuant to Republic Act (RA) 6969 (Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990) and its Implementing Rules and Regulations (IRR) DAO 1992-29, RA 8749 (Philippine Clean Air Act of 1999), and DAO 2005-05 (Toxic Chemical Substances for Issuance of Chemical Control Orders).
What is Vinyl Chloride?
Vinyl chloride (CAS# 75-01-4) is a colorless, highly flammable gas, listed as a human carcinogen, and presents an unreasonable risk to public health and the environment. Currently, vinyl chloride is listed on the Philippine Priority Chemical List (PCL). Once this draft CCO officially takes effect, it will be "upgraded" to a CCO substance, implementing more stringent controls. This draft order aims to reduce the risk of exposure to human health and the environment from vinyl chloride in industrial activities by regulating, restricting, or prohibiting its importation, manufacture, handling, processing, storage, sale, distribution, use, and disposal. It also aims to increase awareness of vinyl chloride's toxicity and encourage the adoption of technically superior and safer alternatives.
Priority Chemicals List (PCL): A list of chemicals identified by the Philippine EMB as posing significant risks to public health, workplaces, and the environment.
Chemical Control Order (CCO): A regulatory measure to control, phase out, or ban priority chemicals that pose significant risks.
Scope of Control: What is Regulated?
The draft CCO clarifies its scope, aiming to cover the full life-cycle management of vinyl chloride.
Controlled Subjects
The order primarily covers Vinyl Chloride and vinyl chloride-containing mixtures.
Applicable Entities
The order's applicable entities are broad, including all entities involved in vinyl chloride activities:
Importers
Distributors
Manufacturers
Industrial Users
Commercial Users
Allowed and Prohibited Uses
Allowed Uses
The draft does not explicitly list "Allowed Uses." However, its regulatory framework targets the importation, manufacture, distribution, and use of vinyl chloride not otherwise prohibited. Therefore, allowed uses can be understood as any use except for the prohibited uses.
Prohibited Uses
This Order prohibits the use of vinyl chloride in aerosols as a propellant or ingredient.
Exemptions
The following uses and products are excluded from this Order's scope:
Polymers containing vinyl chloride as monomer (e.g., Polyvinyl Chloride - PVC).
Products regulated by other laws, including food, pharmaceutical drugs, cosmetics, household/urban hazardous substances (HUHS), and consumer health products (regulated by the FDA of the DOH).
Products under Product Standardization by the Bureau of Philippine Standards (BPS).
Vinyl chloride and vinyl chloride-containing mixtures that are part of an article (unless otherwise specified in related policies).
Corporate Compliance Obligations: Procedures that Must be Followed
For vinyl chloride and its mixtures under allowed uses, companies must fulfill a series of strict registration, permitting, and reporting obligations. All companies must apply for CCO Registration (CCOR) and secure a corresponding Registration Certificate before their first production, importation, sale, or use. For import activities, a CCO Importation Clearance (CCOIC) must also be applied for.
When applying for a CCOR, the documentary requirements include:
Environmental Compliance Certificate (ECC)
Safety Data Sheet (SDS) (compliant with GHS)
Process flow chart
Certificates of worker training on safety
Photos of storage/processing facilities
Latest Self-Monitoring Report (SMR)
In addition to the above, applicants must also fulfill the following obligations:
Chemical Management Plan: Companies must develop and implement a comprehensive Chemical Management Plan, detailing how vinyl chloride is managed to eliminate or minimize risks, including:
General chemical exposure prevention and release control program.
Housekeeping and occupational hygiene practices.
Safety equipment and devices used in handling the chemical.
Personal Protective Equipment (PPE) provided to workers.
Contingency and Emergency Plan: Companies must establish an incident response procedure for accidents leading to vinyl chloride exposure or unintentional release (e.g., spills, fire, explosion).
Substitution and Phase-out Plan: Companies possessing vinyl chloride intended for prohibited uses must provide a plan for eliminating its stockpile, substituting with alternatives, or diverting it to other allowed applications.
Advice for Companies: Supply Chain Management and Green Substitution
Although this Order directly targets enterprises operating within the Philippines, it will also have a significant impact on overseas companies trading with the Philippines, especially suppliers of vinyl chloride and its downstream products.
For companies involved in the allowed uses of vinyl chloride, they should advise their Philippine customers to closely monitor the directive's status, begin preparations, and promptly complete all relevant registration obligations after implementation. Otherwise, their import and use activities may be interrupted or prohibited.
For prohibited uses, companies should actively develop and promote vinyl chloride-free or alternative green products to maintain their competitiveness in the Philippine market.
If you have any questions regarding regulatory compliance in the Philippines, particularly the upcoming Chemical Control Order for Benzene, please feel free to contact us at customer@reach24h.com.
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