ASEAN CHEMICAL MARKET ACCESS
Companies supplying chemicals to Southeast Asia need to answer three questions before a product enters each market: Is a substance notification or registration required? Does the product trigger import controls? Who is responsible for local classification, safety data sheets and labels?
The answers vary across the region. A substance listed on an inventory in one country may require a separate review elsewhere. A product that does not require new substance notification may still be subject to licensing, import clearance or hazard communication rules.
At CRAC China 2026, Fabien Henry, representing the Nickel Institute, examined how six ASEAN markets manage industrial chemicals and why regional cooperation has not eliminated national differences. His practical message for suppliers was to maintain substance-level information for each market, assign local responsibilities and monitor regulatory developments before they affect shipments.
This article focuses on Vietnam, the Philippines, Singapore, Malaysia, Thailand and Indonesia. It provides a framework for initial assessment; the applicable requirements depend on the substance, product, use, company role and destination.
Quick Navigation
One Region, Different Chemical Control Systems
ASEAN countries share a common interest in chemical safety and participate in regional and international cooperation. However, they use different legal frameworks and administrative systems to manage industrial chemicals.
In practice, a market-access assessment may involve several separate checks:
Substance status: Is the substance listed on an applicable inventory or subject to new substance requirements?
Controlled lists: Is the substance prohibited, restricted or subject to a specific control order?
Activity and use: Does the intended import, manufacture, sale, storage or use require a notification, registration, licence or permit?
Hazard communication: What classification, safety data sheet (SDS) and label requirements apply?
Local responsibilities: Which entity must complete the applicable action and maintain the records?
Henry noted that common regulatory drivers do not automatically produce identical national rules. For businesses, this means a regional product launch should start with a country-by-country assessment, supported by a consistent set of substance and product data.
Six ASEAN Markets: Where Should Companies Start?
| Market | Initial market-access question | Practical focus |
|---|---|---|
| Vietnam | Is the chemical subject to import declaration, controlled chemical requirements or the developing new chemical registration framework? | Review the product, intended use and component substances against applicable lists, identify the local importer's obligations, and prepare Vietnamese SDSs and labels where required. |
| Philippines | Are the substances in the product listed on the Philippine Inventory of Chemicals and Chemical Substances (PICCS)? | For unlisted substances, assess whether PMPIN or another simplified notification pathway applies. Listed substances should still be checked against the Priority Chemical List and Chemical Control Orders. |
| Singapore | Is the substance controlled by a relevant authority, and which local activity is planned? | Assess whether the importer, seller, user or storage operator needs a licence or permit, alongside workplace hazard communication requirements. |
| Malaysia | Is the product a hazardous chemical supplied for workplace use? | Assess supplier responsibilities for classification, labelling, SDS and applicable inventory reporting under the CLASS Regulations. |
| Thailand | Is the product listed as a hazardous substance, and which authority regulates its intended use? | For listed substances, assess registration, notification or licensing based on the control type and activity. For unlisted substances, check whether notification is required. |
| Indonesia | Is the substance subject to hazardous and toxic substance controls, trade controls or industrial reporting requirements? | Review obligations across the relevant ministries; a single product may fall under more than one framework. |
The table is a starting point, not a list of exemptions. Products regulated under sector-specific frameworks, such as pesticides, food or medicines, may require a separate assessment.
Vietnam: Check Import Controls While Monitoring the New Substance Framework
Vietnam's chemical management framework requires companies to consider both substance status and the intended activity. Depending on the chemical and circumstances, a business may need to assess import declaration, eligibility or licensing requirements and hazard communication documents.
Henry also highlighted the development of Vietnam's national chemical inventory and new substance registration framework. The new Law on Chemicals has established an initial legal framework, while inventory development and implementation continue to evolve. Companies should check current implementing rules and practice before relying on an expected registration route or timetable.
For a more detailed assessment of product scope and applicable procedures, see Vietnam Chemical Registration and Compliance Services.
Philippines: Check Mixture Components Against PICCS
For the Philippines, the starting point is often the Philippine Inventory of Chemicals and Chemical Substances. The inventory applies at substance level: for a mixture, the relevant components should be checked individually.
A substance absent from PICCS may trigger the Pre-Manufacture and Pre-Importation Notification (PMPIN) process. Companies should assess whether an exemption or another simplified notification pathway applies to their circumstances. A PICCS listing also does not settle every question: a listed substance may still be subject to the Priority Chemical List or a Chemical Control Order.
The Philippine Environmental Management Bureau provides a PICCS information page and PMPIN guidance for manufacturers and importers.
Singapore: Identify the Controlled Substance and Local Activity
Singapore's framework involves different authorities and controls for different purposes. For chemicals controlled under the Environmental Protection and Management Act, the National Environment Agency (NEA) administers licensing requirements for activities such as import, sale and export. Permits may also be required for purchase, storage or use, while transport approval can apply in specified circumstances.
Since 1 January 2026, NEA has required Hazardous Substances Licence and Permit holders to screen all chemicals they import into Singapore or manufacture locally during licence or permit renewal and report chemicals that meet the applicable criteria. The framework has specific requirements for the entities and chemicals covered; it is not a universal registration requirement for every chemical supplied to Singapore.
Companies should therefore identify both the substance and the local activity before deciding which approvals or reports may apply. See NEA's management of hazardous substances guidance.
Malaysia: Connect Workplace Hazard Communication and Reporting
Malaysia's Occupational Safety and Health CLASS Regulations 2013 address the classification, labelling and SDS requirements for hazardous chemicals supplied for workplace use. They also include inventory submission requirements for applicable manufacturers and importers.
Malaysia's Department of Occupational Safety and Health (DOSH) guidance describes supplier responsibilities and the circumstances in which inventory information must be submitted. For covered hazardous chemicals, the guidance calls for SDSs in Bahasa Malaysia and English. Companies should check their role, the relevant hazard classification, reporting threshold and submission deadline against the current requirements.
Thailand: Match the Product's Use to the Competent Authority
Thailand's hazardous substance framework assigns responsibilities to different authorities according to the substance and its use. A market-access review should therefore establish the intended product use before selecting a regulatory pathway.
For listed hazardous substances, the applicable control type and authority determine whether actions such as registration, notification or licensing are needed. For substances not listed, companies should assess whether a notification requirement applies. The Department of Industrial Works publishes hazardous substance procedures for activities under its jurisdiction.
Indonesia: Assess Requirements Across Authorities
Henry described Indonesia's chemical controls as a framework involving environmental, trade and industrial authorities. Depending on the substance and activity, a company may need to consider hazardous and toxic substance controls, import requirements and GHS-related obligations together.
For a planned import, the practical first step is to identify the chemical components, hazard status, intended use and local importer. These details provide the basis for checking which authorities and procedures are relevant.
GHS Alignment Does Not Remove Local SDS and Label Requirements
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) provides a common framework for communicating hazards. Countries nevertheless make national choices about implementation.
Henry identified four reasons why the same chemical may need different hazard communication documents across markets:
The GHS revision applied locally may differ.
Countries may adopt different hazard classes and categories.
A country may have an official classification list that affects how certain substances are classified.
SDS and label rules may differ in language, format, content and local details.
A translation alone may therefore be insufficient. Before using an existing SDS or label in another ASEAN market, the supplier should review the underlying classification, applicable hazard statements and required local information.
For a wider comparison of national implementations, see REACH24H's GHS by Country and Region: A Compliance Overview.
Who Is Responsible for ASEAN Chemical Compliance?
A market-access plan needs to identify the entity responsible for each action. The overseas manufacturer may hold formulation and hazard data, while an importer or other local entity may be responsible for a notification, licence, reporting or local supply documentation.
Responsibilities depend on the applicable law and the actual supply chain. Before shipment, the parties should agree on a working matrix such as the following:
| Question | Information to confirm |
|---|---|
| Who imports the product? | Legal entity, destination country, planned import activity and expected volume |
| Who holds the substance data? | Substance identity, composition, classification evidence and any confidential information needed for assessment |
| Who checks the regulatory pathway? | Inventory status, controlled lists, intended use and applicable exemptions |
| Who completes local actions? | The eligible entity responsible for any required notification, registration, licence, declaration or report |
| Who manages the SDS and label? | Local classification review, language, supplier details, document version and updates |
| Who monitors changes? | A named contact for regulatory developments, product changes and communication with the supply chain |
Commercial agreements can define how parties cooperate, but they do not change the legal duty holder. Eligibility and responsibility should be checked for each obligation.
Build a Market-Access Record Before Launch
Henry recommended maintaining a record for each substance and country. For an exporter managing several formulations, this can turn a broad regional compliance project into a set of decisions that can be reviewed and assigned.
A useful record includes:
Substance identity: chemical name, CAS number where available, and identifiers needed to check local lists.
Product composition: the components and concentration information needed for classification and regulatory screening.
Market and use: destination, intended use, supply-chain route and local entity.
Volume: expected manufacture or import volume, recorded in the unit and period relevant to the local requirement.
Regulatory status: inventory results, controlled-list checks, potential registration or notification pathways, and licensing questions.
Hazard communication: classification basis, applicable SDS and label versions, language and supplier information.
Action ownership: responsible entity, required evidence, filing status and any follow-up date.
For a mixture, maintain the link between the finished product record and its substance-level records. A formulation change can affect classification or controlled-list screening even when the product's trade name remains unchanged.
Monitor Reform Without Treating Proposals as Current Law
Henry observed that regulatory change is underway across the six markets. Businesses planning long-term supply should monitor not only adopted requirements, but also consultations and implementing measures that may affect inventory checks, reporting or hazard communication.
When reviewing a development, record whether it is:
A proposal or consultation;
An adopted measure awaiting application;
A requirement already in force; or
An operational procedure still being developed.
This distinction helps product stewardship and supply-chain teams plan for change without applying a draft rule prematurely. Participation through relevant industry associations can also help companies understand consultations and raise practical implementation questions.
Frequently Asked Questions
Plan ASEAN Chemical Compliance with REACH24H
A coordinated market-access review helps suppliers identify which obligations can be assessed centrally and which actions require local follow-up. REACH24H supports companies with chemical regulatory compliance and hazard communication across Southeast Asian markets.
Depending on the country and project, our team can help assess applicable chemical requirements, review substance and product information, and support the preparation or review of GHS classifications, SDSs and labels. For Vietnam-specific pathways, we also provide support covering inventory checks, import declaration and controlled chemical requirements.
Plan Your ASEAN Chemical Market Entry
Discuss your target markets, substance information and SDS or label requirements with REACH24H to identify the next steps for your compliance project.
