Overview
The Department of Environment and Natural Resources (DENR) of the Philippines recently released the Final 2024 Supplemental Draft of the Philippine Inventory of Chemicals and Chemical Substances (PICCS).
This draft, prepared pursuant to the provisions of the Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990 (R.A. 6969), its Implementing Rules and Regulations (DAO 1992-29), and EMB Memorandum Circular 2014-001, proposes the inclusion of 81 chemical substances that have completed the Pre-Manufacture and Pre-Importation Notification (PMPIN) process into the PICCS.
This marks a change from the earlier 2024 Supplemental Draft List, which proposed the addition of 71 substances. According to the requirements outlined in EMB Memorandum Circular 2020-005, the applicant must submit a Notification of Commencement (NOC) upon the first importation of substances approved under the PMPIN process.
A new chemical substance can only be officially included in the PICCS one year after the EMB officially receives the NOC. This is currently the only pathway for PICCS inclusion. The revisions in this Final Draft are primarily based on the Dynamic Submission and Review Mechanism, with specific adjustments including the addition, removal, and information revision of chemical substances.
Key Revisions in the 2024 Final Supplemental Draft
Chemical Substances Removed from the Previous Draft List
The following substances were included in the earlier 2024 Supplemental Draft List but have been removed in the 2024 Final Supplemental Draft List.
| CHEMICAL ABSTRACT NUMBER | NOTIFIED CHEMICAL NAME |
| 6712-98-7 | 1-[N,N-Bis(2-hydroxyethyl)amino]-2-propanol |
| 6712-98-7 | 2-Propanol, 1-[bis(2-hydroxyethyl)amino]- |
| 186432-61-1 | Amines, polyethylenepoly-, reaction products with molybdenum oxide (MoO2) and succinic anhydride polyisobutylenyl derivs., sulfurized |
Chemical Substances Newly Added in the 2024 Final Supplemental Draft
The 2024 Final Supplemental Draft List includes 13 chemical substances that were not present in the earlier Supplemental Draft List, as shown in the table below:
| CHEMICAL ABSTRACT NUMBER | NOTIFIED CHEMICAL NAME |
| 2489703-47-9 | Benzene, 1-methoxy-4-[3-methyl-4-(2-phenylethoxy)-3-buten-1-yl]- |
| 68141-13-9 | Quinoline, 6-(1,1-dimethylethyl |
| 127459-79-4 | 2-Naphthalenecarboxaldehyde, 5,6,7,8-tetrahydro-3,5,5,6,7,8,8-heptamethyl-, (6R,7R)-rel- |
| 55066-54-1 | Bicyclo[2.2.1]heptan-2-ol, 1,3,3-trimethyl-, 2-benzoate |
| 96690-39-0 | Glycerides, C12-14 mono- and di-, 2,3-bis(acetyloxy)butanedioates |
| 8024-35-9 | Sandalwood oil, Western Australia |
| 834893-60-6 | Phenol, polymer with 1,4-bis(chloromethyl)benzene, glycidyl ether |
| 1627851-18-6 | D-Glucopyranose, oligomeric, heptyl glycosides |
| 127104-69-2 | 2-Propenoic acid, 2-methyl-, dodecyl ester, polymer with hexadecyl 2-methyl-2-propenoate, methyl 2-methyl-2-propenoate, octadecyl 2-methyl-2-propenoate and tetradecyl 2-methyl-2-propenoate |
| 7440-56-4 | Germanium |
| 147900-93-4 | Fatty acids, C18-unsatd., trimers, compds. with oleylamine |
| 85711-55-3 | Fatty acids, tall-oil, compds. with oleylamine |
| 105-44-2 | 4-methylpentan-2-one oxime |
Information Revision
The most significant information revision concerns the substance with CAS Number 68441-03-2.
In the earlier Supplemental Draft List, the declared chemical name for this substace was “Lead titanium zirconium oxide.” However, in the Final Draft, it has been revised to “Steroids, hydroxy, ethoxylated.”
Draft Feedback Solicitation
The 2024 Final Supplemental Draft may be implemented in the near future. Stakeholders are invited to submit comments or suggestions to the Environmental Management Bureau (EMB) or contact REACH24H for assistance in submission.
Important Recommendations for Compliance
Between 2022 and 2024, the Department of Environment and Natural Resources (DENR) has released at least one Supplemental Draft of the Philippine Inventory of Chemicals and Chemical Substances (PICCS) annually. This update frequency represents a significant increase compared to previous years.
In the past, updates to the PICCS were relatively slow and irregular. However, in recent years, with the increasing global emphasis on chemical management requirements and the growing importance of chemical regulation in the Philippines, relevant regulatory policies have gradually improved, leading to more frequent updates to the inventory.
In this context, REACH24H strongly recommends that companies engaged in the production, trade, or use of chemicals closely monitor changes to the PICCS.
Compliance Tips for Companies
For Existing Chemical Substances Listed in the PICCS:
Submit an application for PICCS Validation to the EMB to obtain a PICCS Certificate.
For New Chemical Substances Not Listed in the PICCS:
Register new chemical substances pursuant to the Toxic Substances and Hazardous and Nuclear Wastes Control Act (R.A. 6969) and its Implementing Rules and Regulations (DAO 1992-29). This includes:
Polymer Exemption: Applies to polymers that meet specific conditions and are not subject to annual activity volume limits.
Small Quantity Importation (SQI): Applies to cases where the annual activity volume is ≤1 ton.
PMPIN: Applies to annual activity volumes exceeding 1 ton or up to 1 ton.
