GPC Newsletter Sep-2025

On 1 August, the European Commission launched a public consultation and Call for Evidence for the upcoming Circular Economy Act, marking a major step in its impact assessment. Set for adoption in 2026, the Act aims to boost the EU’s circular economy by creating a Single Market for secondary raw materials, enhancing recycled material supply, and increasing demand. It supports EU goals on competitiveness, resilience, decarbonisation, and aligns with initiatives like the Competitiveness Compass and Critical Raw Materials Act. Inspired by key reports and declarations, the Act seeks to double the EU’s circularity rate by 2030.

Circular Economy Act

The circular economy is essential for strengthening economic security, resilience, competitiveness, and decarbonisation, and it is widely supported by the public as a key solution to environmental challenges. However, progress has been limited, prompting renewed calls for action from European industry, institutions, and recent policy reports. In response, the European Commission has committed under its 2024–2029 Political Guidelines and related initiatives to adopt the Circular Economy Act by 2026. This Act will aim to strengthen the single market for waste and secondary raw materials, boost the availability and demand for high-quality recycled materials at competitive prices, and ensure effective market conditions for circular products.

The Circular Economy Act aims to strengthen the EU’s economic resilience and competitiveness while driving sustainable production, circular economy practices, and decarbonisation. It will support the smooth trade of circular products, secondary raw materials, and waste across the EU. Additionally, the Act seeks to boost the availability of high-quality recycled materials and encourage greater demand for them within the Union.

Feedback period

Stakeholders are invited to take part in the online consultation through the Have Your Say portal. The feedback window remains open until 6 November 2025.

On 8 August 2025, the European Commission adopted a regulation amending Annex XVII to REACH (Regulation (EC) No 1907/2006) concerning carcinogens, germ cell mutagens and reproductive toxicants (CMRs). This update reflects recent changes to the EU’s harmonised classification and labelling of chemicals.

New Substances Added to Annex XVII

The amendment incorporates substances newly classified as CMR category 1B under Commission Delegated Regulation (EU) 2024/1973. These substances are now listed in Appendices 2, 4, and 6 of Annex XVII, meaning that they cannot be supplied to the general public above the set concentration limits.

Among the substances included are:

• Diuron (CAS 330-54-1)
• Tetrabromobisphenol-A (CAS 79-94-7)
• N,N-dimethyl-p-toluidine (CAS 99-97-8)
• 4-nitrosomorpholine (CAS 59-89-2)
• 4-methylimidazole (CAS 822-36-6)
• Several phosphonium salts and diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide
• Dibutyltin compounds, including dibutyltin maleate and dibutyltin oxide

Derogation for Cumene in Aviation Fuels

The Commission also clarified the status of cumene (CAS 98-82-8). Although cumene had already been included in Annex XVII in 2023, the restriction had created practical issues for aviation fuels used by non-professional pilots. The new regulation introduces a derogation permitting the use of cumene in kerosene and gasoline for aviation that meet recognised international standards (e.g. Jet-A, Jet-A1, JP-x, DEF STAN, ASTM, EN 228).

Entry into Force and Application

The Regulation will enter into force 20 days after publication in the Official Journal of the EU. The restrictions related to the newly classified CMRs will apply from 1 September 2025, in line with the implementation of the updated CLP classifications. The full text of the Regulation and the Annex can be downloaded here. 

On 6 August 2025, the UK Health and Safety Executive (HSE) issued a bulletin reminding companies exporting chemicals listed under the GB Prior Informed Consent (PIC) Regulation that they must submit export notifications at least 35 days before the first shipment in 2026. This requirement applies to exports to all countries, including Northern Ireland.

Submission Requirements

Export notifications must be sent to ukdna@hse.gov.uk using the GB PIC export notification form. Each email should cover a single chemical or mixture and include a Safety Data Sheet (SDS) in English and, where available, in the official language of the importing country. Where no SDS is provided, sections 4 and 5 of the notification form must be completed. The intended use should be clearly stated to facilitate processing by the importing authority.

Mixtures with the same classification, labelling, and use can be covered by one notification, provided concentration changes do not affect labelling.

Special RIN Applications

For exports intended solely for research or analysis, and for quantities up to 10 kg per year per importing country, companies may apply for a Special Reference Identification Number (Special RIN). This also applies when an importing country has waived the notification requirement under the Rotterdam Convention. Requests should be submitted to HSE using the Special RIN form or the bulk RIN option.

Further details and forms are available in the bulletin here. 

On August 1, 2025, the Eurasian Economic Commission (EEC) Council approved two essential “second-level” documents under the EAEU Technical Regulation “On Safety of Chemical Products” (TR EAEU 041/2017):

• Procedure for forming and maintaining the EAEU register of chemical substances and mixtures
• Procedure for notification of new chemical substances

These procedures were developed by the EEC in collaboration with all EAEU Member States — Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia—to standardize chemical product management across the EAEU.

Purpose of the Procedures

The EEC Council’s decision aims to implement the provisions of TR EAEU 041/2017, ensuring:

• A unified register of chemical substances and mixtures circulating in the EAEU
• Standardized notification procedures for new chemical substances
• Up-to-date information for market participants on chemical products
• Reduced financial and time costs for preparing documents, including safety data sheets and conformity assessment

Implementation through the EAEU Integrated Information System

The Unified Register will be maintained using the EAEU integrated information system, enabling a common and streamlined process across all EAEU member states. This digital system ensures accurate and timely updates for companies and regulatory authorities.

Importance for TR EAEU 041/2017

Approval of these procedures is a key condition for enacting the EAEU Technical Regulation “On Safety of Chemical Products” (TR EAEU 041/2017). Once fully implemented, the regulation will strengthen chemical safety standards across the EAEU, providing legal certainty and harmonized rules for all companies operating in the union.

The Ministry of Environment, Urbanization and Climate Change has announced via its official website that the long-awaited procedures and principles under the Registration, Evaluation, Authorization and Restriction of Chemicals (KKDİK) regulation have been finalized.

Draft versions of the communiqué had previously been shared with the public, and feedback from industry stakeholders was collected. It was known that the document had reached its final stage and was awaiting signature. The communiqué is expected to be published on the Official Gazette in the coming days.

The highlights of the circular can be listed as below:

• Selection of Lead Registrants:

  • Lead companies will be determined by the end of 2025.
  • If no volunteer LR is found, an appointment will be made under the guidance of TOBB  (Turkish Union of Chambers & Commodity Exchange).
  • SIEF members will have 30 days to respond, and decisions will be based on a simple majority.

• Responsibilities of Lead Companies:

  • For substances without a submitted registration dossier, the lead company must share data gap analysis, tonnage bands, and contractual details with SIEF and seek renewed approval.
  • If approval is not obtained, the lead company will lose its status, and a new lead will be appointed.

• Temporary Registration Dossier:

  • If the LR cannot access existing data, it must submit a temporary registration dossier by March 31, 2026.
  • Member companies must submit their temporary dossiers by September 30, 2026.

• Pre-SIEF (Pre-registration) Deadlines:

  • For substances already placed on the market, the pre-registration deadline is October 31, 2025.
  • For substances placed on the market after this date, a 30-day pre-MBDF window will apply.

• New Working Groups:

  • Two main groups will be established within the Ministry: Chemicals Advisory Group and Chemicals Science Group, to ensure scientific and strategic process management.

The Government of India has officially notified the Cosmetics (Amendment) Rules, 2025, amending the Cosmetics Rules, 2020. The new rules aim to improve regulatory clarity, streamline procedures, and strengthen the oversight of cosmetic products in India. These amendments are effective immediately from the date of publication in the Official Gazette.

Highlights of Key Amendments

Clarification of “Use before” and “Expiry Date”

• The term “use before” now means use before the first day of the mentioned month on the label.
• The term “date of expiry” now means the cosmetic product expires on the last day of the month indicated.

Revised Terminology

The term “controlling officer” has been replaced by “Controlling Authority” across relevant rules for consistency.

Appointment of Government Analyst

Only a Government Analyst appointed under section 20 of the Act will be recognized as the Government Analyst under the rules.

Central Cosmetics Laboratory Functions

The Central Drugs Laboratory will now function as the Central Cosmetics Laboratory for:

• Testing and analysis.
• Appellate laboratory purposes.
• Any other specific functions assigned by the Central Government.

Licensing Amendments

• All mentions of the “Central Licensing Authority” in specific sub-clauses have been changed to “State Licensing Authority” for clarity.
• Records and batch data can now be maintained electronically or in hardcopy and must be retained for three years or six months after expiry, whichever is later.
• Requirements for testing and documentation do not apply to the manufacture of soap. Soap manufacturers follow procedures approved by the Licensing Authority.

License Cancellation or Suspension

• The State Licensing Authority can suspend or cancel a license for non-compliance after giving the licensee a chance to be heard.
• An appeal against suspension or cancellation must be made within 90 days to the State Government. The State Government’s decision shall be final.

Labelling for Export

• Labels on cosmetics meant for export must comply with the importing country's laws.
• If the consignee requests, the manufacturer’s name and address may be omitted on the label, replaced by an approved code number.

Other Notable Changes

• References to “courier” in relation to sample transportation have been omitted.
• Definitions for spurious and adulterated cosmetics are now aligned with Section 17D of the Act.
• The terms “license” and “licensed premises” are changed to “approval” and “approved premises” in licensing and quality control related rules.

These amendments bring enhanced clarity and reinforce regulatory frameworks within the cosmetics industry. All stakeholders are hereby advised to ensure strict compliance with the revised provisions, especially those pertaining to record retention, licensing procedures, labelling standards, and definitions of competent authorities.

Update: As per scheduled information, mandatory standard GB 30000.1-2024 becomes effective on 1 August 2025. Now from 1 August 2025 onwards, classification and labelling of chemicals must be applicable as per GB 30000.1-2024 (GHS Rev.8) only. More information can be found here.

Original Text:

On 24 July 2024, GB 30000.1-2024 "Specification for Classification and Labelling of Chemicals—Part 1: General Rules" was officially published on the National Public Service Platform for Standards Information. This updated standard, which aligns with the eighth revised edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS 8), will come into force on 1 August 2025 and will replace the existing GB 13690-2009 "General Rules for the Classification and Hazard Communication of Chemicals."

Draft Release and Public Consultation

On 12 March 2024, China's Ministry of Industry and Information Technology (MIIT) released a draft of the revised standard GB 30000.1. This update aims to align China's chemical classification and labelling standards with the UN's GHS 8. Public comments on this draft were invited until 12 April 2024.

Key updates to GB 30000.1

The revised GB 30000.1 introduces significant updates and new categories:

• Terminology and Definitions: Consistency with GHS 8 ensures clear, internationally recognized terminology.
• Hazard Classification: Adds a new category for desensitized explosives, bringing the total number of hazard classes in China to 29.
• Labeling Requirements: Special provisions are made for labeling, particularly for metals and alloys in non-dispersible forms. GHS labels must be used in workplaces, with alternative methods like area-specific labels allowed.
• Safety Data Sheets (SDS): Updated SDS requirements include detailed hazard communication guidelines and cut-off values for different hazard categories.

Exemptions

Certain products, such as pharmaceuticals, food additives, cosmetics, and pesticide residues in food intended for ingestion, are exempt from these labeling requirements unless workers are likely to be exposed during transport.

Implementation and Compliance

The revised GB 30000.1 will replace the existing GB 13690-2009 standard. Once adopted, it will better align China's chemical safety standards with international practices, improve hazard communication and ensure safer handling and transportation of chemicals within China and in international trade.

The adoption of GB 30000.1 is a significant step in enhancing chemical safety and regulatory compliance in China. By aligning with the UN GHS 8, China is demonstrating its commitment to global safety standards, facilitating smoother international trade and improving overall chemical safety management.

Update: On 13 August 2025, China’s Ministry of Industry and Information Technology (MIIT) releases draft standard for GB 15258 and reopened public consultation on 14 August 2025 which remain valid till 12 October 2025. China published the notice on MIIT portal. The key revisions include the introduction of a Safety Information QR Code, new rules for small packages and folding labels, reordering of hazard statements, updated simplified label rules, and examples for kit packaging. This time revised GB 15258 standard aligned with the tenth revised edition of the Globally Harmonized System for Classification and Labelling of Chemicals (GHS 10). Prior to enforcement, GB 15258-XXXX permits a one-year transition period from the final draft publication date. More details can be found here.

Original Text:

On 14 September 2024, China’s Ministry of Industry and Information Technology (MIIT) announced a consultation to revise the national standard on "Regulations on the Preparation of Chemical Safety Labels" to align with the ninth revised edition of the Globally Harmonized System for Classification and Labelling of Chemicals (GHS 9). The Ministry released this announcement on the portal of the National Standards Administration and invited stakeholders to comment on it by 14 October 2024. 

After the official publication of the National Standard on the Provisions on the Preparation of Chemical Safety Labels, the National Technical Committee for Standardization of Hazardous Chemicals Management will work on its implementation. 

Insights of New Labelling Standard 

This new labelling standard will have the following revised information: 

• Alignment with the technical content of the ninth edition of the United Nations GHS, including hazard classification and precautionary statements. 

• Implementation of the "one enterprise, one product, one code" regulation to meet the needs of national safety supervision of hazardous chemicals. Additionally, the means of transmitting hazardous chemical hazard information needed to be strengthened, and the last mile of hazardous chemical hazard information transmission needed to be opened. 

Previous Update  

Previously China’s National Standards Administration revised the Provisions on the Preparation of Chemical Safety Labels in 2009. However, this 2009 version followed GHS 2 while the Ministry has now proposed to align with the provisions of GHS 9. 

Comment Period and Enforcement Date 

Stakeholders are invited to comment on this draft announcement till 14 October 2024. The Ministry has not yet officially announced the enforcement date of the same. 

On 5 August 2025, Taiwan's Environmental Protection Administration (EPA) announced a draft plan to regulate 269 (per- and polyfluoroalkyl substances (PFAS) as Concerned Chemical Substances. These chemicals are widely used and can persist in the environment, posing potential risks to human health. Taiwan is following global trends to strengthen chemical safety management. 

On 25 July 2025, Japan’s Ministry of Health, Labour and Welfare (MHLW) published draft ordinance for amending the Poisonous and Deleterious Substances List on the country’s e-Gov Public Comment Portal. Fenazaquin has been proposed to get added, whereas formulations containing sodium chlorate or sodium bicarbonate scheduled to get removed from the list. Furthermore, Japan notified the World Trade Organization (WTO) on August 1, 2025, of a draft designating fenazaquin as a deleterious substance.

Poisonous and Deleterious Substances List

The Poisonous and Deleterious Substances List under Japan's Poisonous and Deleterious Substances Control Act (PDSCA) classifies chemicals based on their toxicity and health risks, categorizing them as "poisonous" or "deleterious." These substances are regulated for safe handling, storage, and transportation to prevent accidents and ensure public safety. Updated regularly by Japan's MHLW, new substances are added based on scientific evidence. The regulations include safety procedures such as labelling, record-keeping, and reporting to minimize health and environmental risks. Currently there are 587 entries present on the list.

Key Insights from the Draft Ordinance

Draft ordinance proposes the following amendments to the list of Deleterious Substances:

• 4-[2-(4-tert-Butylphenyl)ethoxy]quinazoline (Fenazaquin) (CAS: 120928-09-8) and its preparations (except from those with a concentration ≤19.4%) have been designated as a new deleterious substance.
• Taking a formulation off the list: Made with sodium bicarbonate (27–37%) (CAS: 144-55-8) and sodium chlorate (47.5–52.5%) (CAS: 7775-09–9), except powdered versions.

It was determined that fenazaquin posed a significant risk of acute toxicity upon exposure, supporting its designation as a deleterious substance. On the other hand, it was found that the sodium chlorate/sodium bicarbonate formulation had far lower toxicity, which justified its removal from the list.

Obligations for the Stakeholders

Manufacturers, importers, and distributors of the Poisonous and Deleterious Substances must register their substances with the MHLW and comply with Safety Data Sheets (SDS) and Labelling regulations.

Comment Period and Enforcement Dates

Stakeholders are requested to comment on the draft till 24 August 2025. While as per WTO notification, members can comment on the WTO draft till 30 September 2025. Final ordinance will be published in late October 2025. Enforcement is scheduled to be from 1 November 2025 (Except for delisting of entries which will come into effect on the same day of ordinance publication).

On 31 July 2025, Japan's Ministry of Economy, Trade and Industry (METI), Ministry of Health, Labour and Welfare (MHLW), and Ministry of Environment (MOE) jointly announced the addition of 157 new substances to the General Chemical Substance List under the Chemical Substance Control Law (CSCL). It has been determined that six of these substances pose major risks to both human health and the environment.

Previous update in July 2024

Earlier on 31 July 2024, Japan added 164 chemicals to the general chemical substance list & identified 3 chemicals with high toxicity profile. More details can be found here.

Classification of General Chemical Substances

Chemicals that are first submitted to the government for assessment and then monitored for five years are considered new substances, according to the CSCL. Chemicals that do not pose a significant risk are added to the list as "newly announced substances" and given the designation of general chemical substances following this evaluation period.

Notification Obligations for Manufacturers and Importers

Businesses must notify METI if they produce or import general chemicals in amounts of one tonne or more throughout the year. Even after these chemicals are included to the list of general chemical substances, this requirement guarantees that they are continuously reviewed.

Addition of Highly Toxic Chemicals

Six of the recently added chemicals have been identified as extremely toxic:

• Mixture of (1-)ammonium diaquabis(oxalato-kappa(2)O,O') oxidoniobate and (1-)ammonium diaquabis(oxalato-kappa(2)O,O') oxidoniobate-water(1/n)
• Disilver ethynediide
• Bis[4-({6-[(prop-2-enoyl)oxy]hexyl}oxy)phenyl] 2-{[(1,3-benzothiazol-2-yl)(6-{[(naphthalen-1-yl)acetyl]oxy}hexyl)hydrazinylidene]methyl}-1,4-phenylene bis[(1r,4r)-cyclohexane-1,4-dicarboxylate]
• 5,11,14,17-Tetrakis[(dimethylsilyl)oxy]-1,3,5,7,9,11,14,17-octaphenyltricyclo[7.3.3.3(3,7)]octasiloxane
• 4-[1-(2,3-Dimethylphenyl)ethyl]-1H-imidazole
• Copolymer of 2-(dimethylamino)ethyl 2-methylprop-2-enoate / N-benzyl-N,N-dimethyl-2-[(2-methylprop-2-enoyl)oxy]ethan-1-aminium chloride (It is limited that the content of the components having molecular weight less than 1,000 is 1% or less.)

Assessment results published

Additionally METI released the assessment results of these chemicals for bioaccumulation and degradability on the same day they were added to the list. The list of added chemicals can be found here.

Brazilian Regulatory Authority Seeks Public Contributions

The Brazilian Health Regulatory Agency (ANVISA) has opened a consultation period for a proposal to update its regulations concerning food additives and technological aids. The new guidelines will alter the existing rules under Instrução Normativa - IN nº 211, dated March 1, 2023. The regulatory updates focus on food additives and technological aids' technological functions, maximum usage limits, and conditions of use in food products.

The proposal, published in the Official Federal Gazette (DOU) on July 8, 2025, invites public feedback between July 15 and August 28, 2025, with a potential deadline extension depending on the volume of contributions. The initiative aims to ensure that food safety regulations align with technological advancements and global standards, keeping the regulatory framework in line with evolving industry needs.

ANVISA's decision to propose updates stems from the continuous need for adjustments to the lists of authorized additives and technological aids. These updates help ensure that technological innovations remain consistent with the foundational principles governing the safe use of these substances. Additionally, the changes are driven by issues raised by industry stakeholders, including food manufacturers, public agencies, and regulatory experts, highlighting the importance of aligning with international best practices.

Food additives are substances added intentionally to foods to modify their physical, chemical, biological, or sensory properties during production, processing, or packaging. Technological aids, on the other hand, are materials that aid in food production but are not consumed directly, and their use may result in trace residues in the final product.

The proposed updates include several changes, such as:

1. Revision of Existing Categories: Adjustments to food product categories under the existing regulations will be made. For example, the category for "Other Dairy Products" will be removed, and substances used in these products will be redistributed under the newly proposed categories, aligning with market trends.
2. New Categories and Functions: The consultation aims to introduce specific provisions for the use of additives and technological aids in "plant-based" foods, a growing segment in the global food market. This will address gaps in the current regulation, as the existing list does not cater to this rapidly expanding category.
3.  International Convergence: The updates will harmonize Brazilian regulations with international standards, particularly those established by the Codex Alimentarius, the global food safety standards body. This is part of an ongoing effort to ensure that Brazilian food safety regulations meet global expectations and are consistent with international trade agreements.

Key Dates and Consultation Process

• Public Consultation Period: July 15 to August 28, 2025.
• Status: The proposal is currently open for public comments, and stakeholders are encouraged to submit their contributions.
• Regulatory Impact: The proposal is classified as low-impact, meaning it is unlikely to cause significant disruption in industry operations, but still requires consultation to ensure that stakeholders' concerns are addressed.

The regulatory body has emphasized that updates are essential to maintaining safe food production practices and promoting innovation in the food sector. With new food trends like plant-based diets growing in popularity, regulatory flexibility is crucial to enabling food manufacturers to adapt to market demands while ensuring public safety.

The updates aim to provide clarity for food manufacturers on the substances that can be used in food products, ensuring that they are safe, effective, and aligned with the best available science. The regulatory changes will also aid in reducing trade barriers, as the Brazilian framework will increasingly reflect international norms.

Contributions from stakeholders are crucial for shaping the final regulatory outcome, ensuring that it meets the needs of the food industry while safeguarding public health. ANVISA has committed to transparency throughout the process, with all relevant documents available for public review during the consultation period.

This marks the third regulatory update attempt by ANVISA, following previous initiatives in August 2023 and November 2024. For further details you can consult the regulation (in Portughese) here.

A groundbreaking law passed by the Brazilian government on July 30, 2025, now prohibits the use of animals in testing products such as cosmetics, personal care items, and perfumes, as well as their ingredients. The new legislation, signed by President Luiz Inácio Lula da Silva, marks a significant step forward in the nation's animal welfare efforts.

The law amends two critical pieces of legislation—Law No. 11,794 (2008) and Law No. 6,360 (1976)—to explicitly ban the testing of products and ingredients on vertebrate animals, including those used for safety, efficacy, or danger assessments. The amendment also enforces stricter labeling regulations on products that may have been tested on animals before the law's enforcement.

Key Provisions

Under the revised Law No. 11,794, the following points stand out:

1. Prohibition on Animal Testing: Sections 11 and 12 of the amended law clearly state that testing on vertebrate animals is prohibited for both finished products and ingredients used in personal care, cosmetics, and perfumes. This includes any testing aimed at evaluating the safety, efficacy, or potential harm of the substances.

2. Restrictions on Animal-Test Data: Data from animal testing carried out after the law’s enforcement will no longer be admissible for the approval or commercialization of personal care products. This extends to any animal test data used to support the safety claims of the ingredients.

3. Labeling Prohibition: Manufacturers whose products' safety has been certified through post-enforcement animal testing will not be allowed to label or advertise their products as "cruelty-free" or "not tested on animals." This aims to uphold transparency and prevent misleading claims.

4. Alternative Testing Methods: The law prioritizes the use of internationally recognized and validated alternative testing methods. It mandates that the Brazilian authorities expedite the recognition and adoption of these methods, ensuring they become widespread throughout the nation.

5. Exemptions in Exceptional Circumstances: There is a provision for exemption in rare instances where a cosmetic ingredient poses a significant health risk, and no viable alternative testing method exists. These exceptions will be handled by the National Commission for the Control of Animal Experimentation.

Implementation and Enforcement

The law mandates that the health authorities have a maximum of two years to implement and regulate these new rules. Specifically, the authorities are required to:

• Promote Alternative Testing: Create a strategic plan for the adoption of alternative testing methods across Brazil.

• Monitor Compliance: Establish measures to ensure companies do not use post-enforcement animal testing data for regulatory purposes.

• Ensure Accurate Labeling: Enforce regulations around the labeling of cruelty-free claims and ensure they align with the new legislation.

The amendment also adds a specific clause to Law No. 6,360 (1976), making compliance with the animal testing ban a requirement for product registration under Brazil’s health authority.

A Step Toward Global Change

Brazil’s landmark move positions the country as a global leader in ethical treatment of animals, aligning with international trends where more nations are adopting similar bans on animal testing for cosmetics. While some have already implemented these restrictions, Brazil is one of the largest emerging markets to take such decisive action.

This shift is expected to inspire many companies to embrace innovative, cruelty-free methods in their production processes, which could lead to broader changes across the global beauty and cosmetics industry. It is also seen as a major victory for animal rights groups, who have long advocated for such bans in the fight for humane testing practices.

The law goes into effect immediately following its publication, marking a historic day for Brazil and animal welfare advocates alike. For further details you can check the Law (in Portughese) here.

Argentina has unveiled a comprehensive regulatory framework for managing the import, export, and transit of recycled non-hazardous waste. The new measures, outlined in Resolution 393/2025, are aimed at protecting the environment, ensuring compliance with international waste management treaties, and advancing the country’s circular economy.

The resolution is built on the foundation of Decree 1/2025, which establishes guidelines for the handling of non-hazardous waste, specifically materials that have undergone a recovery process to be used as inputs for industrial processes or as direct-use products. These materials must meet strict environmental standards, and the resolution creates clear procedures to regulate their movement across Argentina’s borders.

The four annexes of the resolution are closely interconnected, establishing a unified system for the import, export, and transit of non-hazardous recycled materials. Annex IV lays out the types of materials eligible for trade, while Annexes I–III set the procedural framework for how these materials can be imported, exported, or transited through the country. All applications for permits must be processed through the Trámites a Distancia (TAD) platform, where they will undergo technical evaluations, customs validation, and compliance checks.

The Basel Convention plays a central role in this framework, ensuring that materials moving across borders meet international environmental standards. In addition, all documents will be validated through Argentina's Single Window for Foreign Trade (VUCEA) and Malvina system to streamline processing and ensure robust oversight.

Annex I - Import Procedures (365 Day Authorisation)

To import non-hazardous waste, businesses must submit a sworn declaration through the TAD platform, detailing the material’s origin, composition, recovery process, intended use, and confirmation of its non-hazardous status. The Dirección Nacional de Residuos (National Waste Directorate) will assess whether the waste matches the list in Annex IV and complies with both national and international regulations. If approved, the Subsecretary of Environment will issue an authorisation valid for 365 days.

Annex II - Transit Procedures (90-Day Authorisation per Shipment) 

For materials transiting Argentina en route to a third country, exporters must file a similar declaration outlining the shipment's route, estimated quantities, transport companies, and insurance details. Proof that the destination country permits the importation is also required. Transit permits are valid for 90 days, and each shipment must be treated individually.

Annex III - Export Procedures (365-Day Authorization) 

Exporters must provide detailed documentation on the waste's origin, recovery process, and destination. They must also demonstrate that the material is not classified as hazardous under the Basel Convention or is recognised as raw material by the importing country. If no objections are raised within 10 working days, the export is automatically authorised, and the permit remains valid for 365 days.

Annex IV - List of Non-Hazardous Wastes 

This annex defines what types of materials are considered non-hazardous. These include:

• Scrap metals (iron, steel, etc.)

• Certain glass waste (excluding hazardous or radioactive glass)

• Paper and cardboard waste

• Animal and vegetable oils

• Uncontaminated metal or non-plastic containers

• Selected textiles and untreated wood

• Plant residues and agro-food industry waste

• Human hair and clean refractory brick

• Processed non-halogenated plastics (PE, PP, PET, etc.)

The annex excludes materials such as fluorinated plastics, e-waste, and any contaminated materials or waste treated with hazardous chemicals. It also provides flexibility for updating the list based on new scientific evidence or regulations.

The Subsecretary of Environment has been tasked with overseeing the compliance process. Should discrepancies arise—such as a mismatch between declared and actual materials—the goods must be returned to their country of origin within 30 days at the importer's expense. In case of repeated violations, businesses may face bans on applying for new permits for up to one year.

The TAD platform and VUCEA system ensure that all trade movements are tracked electronically, improving the efficiency of processing and reducing administrative delays. The new regulations aim to streamline operations while ensuring that waste management practices meet both Argentina's environmental standards and international obligations.

The resolution also enhances international collaboration in the management of cross-border waste. Argentina has committed to upholding its responsibilities under the Basel Convention and other international agreements, ensuring that non-hazardous waste is handled according to environmentally sound practices.

The government has stated that the new rules will foster Argentina’s circular economy, enabling the country to better manage recovered materials while minimizing environmental impact. For further details, you can consult the Resolution 393 (in Spanish) here.

On August 1, 2025, the Eurasian Economic Commission (EEC) Council approved two essential “second-level” documents under the EAEU Technical Regulation “On Safety of Chemical Products” (TR EAEU 041/2017):

• Procedure for forming and maintaining the EAEU register of chemical substances and mixtures
• Procedure for notification of new chemical substances

These procedures were developed by the EEC in collaboration with all EAEU Member States — Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia—to standardize chemical product management across the EAEU.

Purpose of the Procedures

The EEC Council’s decision aims to implement the provisions of TR EAEU 041/2017, ensuring:

• A unified register of chemical substances and mixtures circulating in the EAEU
• Standardized notification procedures for new chemical substances
• Up-to-date information for market participants on chemical products
• Reduced financial and time costs for preparing documents, including safety data sheets and conformity assessment

Implementation through the EAEU Integrated Information System

The Unified Register will be maintained using the EAEU integrated information system, enabling a common and streamlined process across all EAEU member states. This digital system ensures accurate and timely updates for companies and regulatory authorities.

Importance for TR EAEU 041/2017

Approval of these procedures is a key condition for enacting the EAEU Technical Regulation “On Safety of Chemical Products” (TR EAEU 041/2017). Once fully implemented, the regulation will strengthen chemical safety standards across the EAEU, providing legal certainty and harmonized rules for all companies operating in the union.