REGULATORY UPDATE | PHILIPPINES PICCS
DENR Administrative Order No. 2026-24 (DAO 2026-24) formally adds 81 chemicals to the Philippine Inventory of Chemicals and Chemical Substances (PICCS) for calendar year 2024. The Order was published in The Manila Times and acknowledged by the Office of the National Administrative Register on July 15, 2026. Under its effectivity clause, it took effect on July 30, 2026.
DAO 2026-24 confirms the official adoption of the previously circulated 2024 PICCS supplemental list. Companies importing or manufacturing chemicals in the Philippines should use the Order as the controlling reference when reviewing the inventory status of affected substances.
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DAO 2026-24 Makes the 2024 PICCS Update Official
DAO 2026-24 states that the 81 substances constitute the additional list of chemicals to PICCS for calendar year 2024. According to the Order, the substances were included after completing the Pre-Manufacture and Pre-Importation Notification (PMPIN) process and submitting the corresponding Notice of Commencement (NOC) report.
The DENR also states that additional chemical lists will be issued annually and made available through the Environmental Management Bureau (EMB) website and the Online Permitting and Monitoring System.
Companies assessing a substance that is not currently listed in PICCS can refer to REACH24H's guide to the Philippines PMPIN process for information on notification pathways, exemptions, documentation, and post-notification requirements.
How the Official List Differs from the Earlier Draft
An earlier 2024 supplemental draft contained 71 entries. A subsequent Final Draft increased the list to 81 substances, and DAO 2026-24 has now formally adopted the 81-entry list.
A comparison based on normalized CAS Registry Numbers (CAS RNs) shows the following:
| Comparison Item | Earlier Supplemental Draft | DAO 2026-24 |
|---|---|---|
| Number of entries stated in the document | 71 | 81 |
| Unique CAS RNs after deduplication | 70 | 81 |
| CAS RNs appearing in both versions | 68 | 68 |
| CAS RNs appearing only in that version | 2 | 13 |
| Notable data issue | One duplicated CAS RN | Certain chemical names differ from the earlier draft |
13 CAS RNs Included in DAO 2026-24 but Not in the Earlier Draft
The following 13 CAS RNs appear in the official Order but were not included in the earlier 71-entry supplemental draft:
| No. | CAS RN | Chemical Name in DAO 2026-24 |
|---|---|---|
| 1 | 2489703-47-9 | Benzene, 1-methoxy-4-[3-methyl-4-(2-phenylethoxy)-3-buten-1-yl]- |
| 2 | 68141-13-9 | Quinoline, 6-(1,1-dimethylethyl [wording appears truncated in the published Order] |
| 3 | 127459-79-4 | 2-Naphthalenecarboxaldehyde, 5,6,7,8-tetrahydro-3,5,5,6,7,8,8-heptamethyl-, (6R,7R)-rel- |
| 4 | 55066-54-1 | Bicyclo[2.2.1]heptan-2-ol, 1,3,3-trimethyl-, 2-benzoate |
| 5 | 96690-39-0 | Glycerides, C12-14 mono- and di-, 2,3-bis(acetyloxy)butanedioates |
| 6 | 8024-35-9 | Sandalwood oil, Western Australia (Santalum spicata) |
| 7 | 834893-60-6 | Phenol, polymer with 1,4-bis(chloromethyl)benzene, glycidyl ether |
| 8 | 1627851-18-6 | D-Glucopyranose, oligomeric, heptyl glycosides |
| 9 | 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 |
| 10 | 7440-56-4 | Germanium |
| 11 | 147900-93-4 | Fatty acids, C18-unsatd., trimers, compounds with oleylamine |
| 12 | 85711-55-3 | Fatty acids, tall-oil, compounds with oleylamine |
| 13 | 105-44-2 | 4-Methylpentan-2-one-oxime |
Source note: Chemical names reproduce the wording shown in DAO 2026-24. The entry for CAS RN 68141-13-9 appears incomplete in the published Order; companies should verify the official record before relying on the name for substance identification.
Two CAS RNs Not Carried into the Official Order
Two CAS RNs that appeared in the earlier draft are not included in DAO 2026-24. A review indicates that both substances had already been included in PICCS before the 2024 update.
| CAS RN | Earlier Draft | Status in the Official Order |
|---|---|---|
| 6712-98-7 | Appeared twice in the earlier draft under two equivalent chemical-name entries | Not included in DAO 2026-24; already listed in PICCS before the 2024 update |
| 186432-61-1 | Appeared once in the earlier draft | Not included in DAO 2026-24; already listed in PICCS before the 2024 update |
DAO 2026-24 also resolves certain data inconsistencies. For example, CAS RN 68441-03-2, which was associated with "Lead titanium zirconium oxide" in the earlier draft, is recorded in the official Order as "Steroids, hydroxy, ethoxylated."
Companies should therefore verify both the CAS RN and the official chemical name, rather than relying on CAS data alone or continuing to use an earlier draft list.
Why PICCS Status Matters for Chemical Market Access
PICCS is the Philippines' inventory of existing chemical substances that are stored, imported, exported, used, processed, manufactured, or transported in the country. The inventory contains chemical names and corresponding CAS RNs.
Under DAO 2026-24, a chemical imported into or manufactured in the Philippines that is not included in PICCS is regarded as a new chemical for Philippine inventory purposes.
For substances within the applicable regulatory scope, manufacturers and importers may need to complete a new chemical notification or exemption process before commercial importation or manufacture. Depending on the substance identity, annual volume, polymer characteristics, intended use, and other relevant conditions, the applicable route may include:
PMPIN notification;
Small Quantity Importation (SQI);
polymer exemption; or
another pathway accepted by the DENR-EMB.
PICCS listing confirms inventory status, but it should not be interpreted as confirmation that every other Philippine chemical control or sector-specific obligation has been addressed.
Recommended Compliance Actions for Companies
| Substance or Business Scenario | Recommended Action |
|---|---|
| Substance is included in DAO 2026-24 | Update internal inventory records and verify the substance against both its CAS RN and official chemical name. |
| Documentary proof of PICCS status is required | Assess whether PICCS validation or a PICCS Certificate should be obtained from the EMB. |
| Substance is not listed in the current PICCS | Determine whether PMPIN, SQI, polymer exemption, or another applicable new chemical pathway is required before importation or manufacture. |
| A PMPIN certificate has already been issued | Confirm that the corresponding NOC report has been submitted and review any applicable post-notification obligations. |
| Supplier, composition, chemical identity, or import arrangement changes | Repeat the inventory-status and notification-pathway assessment instead of relying on an earlier product conclusion. |
Companies should also maintain substance identity records, supplier information, composition data, annual volume estimates, and evidence supporting the selected regulatory pathway.
How REACH24H Can Help
REACH24H supports chemical manufacturers, exporters, and Philippine importers with:
chemical identity and PICCS status checks;
screening against PICCS and recognized international chemical inventories;
assessment of the appropriate PMPIN, SQI, or polymer exemption pathway; and
customized PMPIN filing plans and NOC or post-submission support.
Unsure whether your substance is listed in PICCS or requires a new chemical pathway?
Submit the available substance identity, composition, annual volume, and intended use. REACH24H can help assess the inventory status and the appropriate PMPIN, SQI, polymer exemption, or post-notification route.
