GPC Newsletter Oct-2025

On 12 September 2025, The U.S. Food and Drug Administration (FDA) has launched the FDA Adverse Event Reporting System (FAERS) Public Dashboard for Cosmetic Products, an interactive platform designed to provide real-time access to adverse event reports related to cosmetic products. The launch, announced via a FDA press release, supports the FDA’s broader modernization strategy and responds to growing demand for transparency in product safety.

The dashboard covers a wide range of cosmetic categories, such as moisturizers, shampoos, conditioners, hair dyes, and tattoos.

FDA Adverse Event Reporting System (FAERS)

The launch of the cosmetic products dashboard is part of the FDA’s borader push for transparency, complementing earlier initiatives such as real-time reporting of adverse events and medication errors for drugs and therapeutic biologics.

The new platform centralizes reports exclusively related to cosmetic products, including those required under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) and voluntary submissions from healthcare professionals, consumers, and cosmetic industry professionals.

Key Features of the FAERS Dashboard

• Real-time Access: Reports updated daily with downloadable datasets.
• Comprehensive Search: Filter by product, event, severity, date, or type.
• Public Transparency: Addresses demand for safety visibility.
• Limitations: Reports are unverified and do not establish causation or confirm product safety.



Stakeholder Obligationsunder MoCRA

MoCRA requires companies are required to submit serious adverse event reports for cosmetic products to the FDA. Other stakeholders, inlcuding healthcare professionals, salon professionals, cosmetologists, and consumers are encouraged to voluntarily report incidents to strengthen safety surveillance.

While the dashboard enhances transparency, the FDA notes that the data is intended for monitoring purposes only.  Companies are expected to evaluate safety signals proactively and take mitigation measures when risks are identified.

From 1 July 2026, the European Chemicals Agency (ECHA) will begin publishing the names of companies that have submitted classification and labelling (C&L) notifications under the CLP Regulation. The name of every notifier will be made publicly available in the C&L Inventory in accordance with the amended Article 42 of the CLP, introduced by Regulation (EU) 2024/2865 published in the EU Official Journal on 20 November 2024.

Confidentiality Requests Before June 2026

Companies wishing to keep their name confidential must update their dossiers and submit a justification by 30 June 2026. Unless confidentiality is granted, ECHA will make notifier names publicly accessible from 1 July 2026. ECHA also released an updated CLP notification manual in June 2025 to guide companies through the process.

CLP Notification Requirements

Manufacturers and importers placing hazardous substances on the EU market are required to notify ECHA within a month of placing the substance on the market. Article 40 (1) of the CLP (Classification, Labelling and Packaging) Regulation outlines the data that must be included in the Substance dataset. The following details are needed for CLP notification (relevant IUCLID section in brackets):

·       Notifier details: Name and contact information (from REACH-IT).

·       Confidentiality request (notifier name): Justification and category must be provided.

·       Notifier contact person: To be specified in section 1.1.

·       Substance identity: According to Annex VI sections 2.1–2.3.4 (sections 1.1, 1.2, 1.4).

·       Confidentiality request (IUPAC name): Provide a publishable name for the C&L inventory and justification.

·       Classification: As required under the CLP Regulation (section 2.1).

·       No classification justification: Required if the substance is not classified under all hazard classes.

·       Reason for classification: Based on supporting data.

·       Concentration limits, M-factors, acute toxicity estimates: Where applicable, with justification referencing Annex I (section 13).

·       Label elements: Hazard pictograms, signal words, hazard statements.

ECHA has removed the harmonised classification of titanium dioxide (TiO₂, CAS 13463-67-7) from the C&L Inventory and updated the registry of intentions, following the Court of Justice of the European Union (CJEU) ruling of 1 August 2025 annulling the classification. Related guidance documents on classification and labelling have also been deleted from ECHA’s website.

Annex VI to CLP Amended

The Court’s judgment directly amends Annex VI to the Classification, Labelling and Packaging (CLP) Regulation. The following entries no longer apply to titanium dioxide:

• Carc. 2 (H351: inhalation) classification
• Supplemental hazard statements EUH211 and EUH212
• Notes V, W, and 10

Immediate Effect for Businesses

Because the ruling has direct legal effect, the removal of the titanium dioxide entry does not require a further amendment (ATP) to CLP. Companies can already update safety data sheets (SDS) and labels to reflect the deletion of the harmonised classification.

Implications for Industry

The removal has significant implications for manufacturers and importers of paints, coatings, plastics, and other products containing TiO₂. Labelling requirements are now simplified, and suppliers can base hazard communication on their own product assessments rather than the harmonised entry.

The full text of the ruling of the European Court of Justice on the classification of titanium dioxide can be found here.

On 24 September 2025, the European Council approved the introduction of a “stop-the-clock” mechanism for the revised Classification, Labelling and Packaging (CLP) Regulation. The measure, part of the Commission’s Omnibus VI simplification package, delays the entry into application of the new rules to 1 January 2028.

Purpose: Legal Certainty and Simplification

The mechanism is designed to provide legal certainty for businesses and to avoid a fragmented regulatory framework. Without the postponement, different provisions of the revised CLP would have applied on different dates, creating additional compliance challenges for companies.

The alignment of deadlines covers obligations on:

• Relabelling of substances and mixtures
• Formatting requirements for labels
• Advertisements and distance sales
• Labelling at fuel pumps

By postponing these obligations, the European Council aims to give companies, particularly SMEs, more time to adapt to the new requirements while ensuring continued protection of health and the environment.

Background: Original Deadlines

The revised CLP Regulation entered into force on 10 December 2024, with the majority of obligations initially scheduled to apply from 1 July 2026, and some provisions from 2027 (see more details here). The “stop-the-clock” mechanism shifts all these dates to 1 January 2028, creating a single, harmonised starting point for compliance.

Next Steps in the Legislative Process

Following the European Council’s approval, negotiations will continue with the European Parliament to finalise the regulation. The measure forms part of the broader Omnibus VI package, which seeks to simplify EU chemicals legislation while maintaining high levels of health and environmental protection.

On 16 September 2025, the European Chemicals Agency (ECHA) announced the expansion of its ECHA CHEM database to include regulatory data on chemicals. The upgrade means that, in addition to substance information, users can now access details on regulatory processes and legal obligations under several EU laws.

Integration of Key EU Regulations

In this release, ECHA CHEM incorporates regulatory processes and lists from the following chemicals regulations and directives:

• REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)
• CLP (Classification, Labelling and Packaging) Regulation
• POP (Persistent Organic Pollutants) Regulation
• Drinking Water Directive

Under REACH, the update covers the list of restricted substances and the restriction process, the Authorisation List and ECHA’s recommendations for inclusion, substances of very high concern (SVHC) and the Candidate List, as well as dossier and substance evaluation.

This integration provides a single point of access to chemical identity data, classification and labelling information, REACH registration details, and other regulatory lists.

Drinking Water Directive Positive Lists

On 24 September 2025, ECHA further announced that the European positive lists under the Drinking Water Directive are now available in ECHA CHEM. The information is searchable, can be filtered by material type, and is linked with relevant data collected under REACH and CLP.

Improved Access and Transparency

The expanded system aims to improve transparency and efficiency by centralising regulatory and substance data. Companies, regulators, and other stakeholders can now more easily assess compliance obligations, restrictions, and potential risks related to chemical use.

Webinar Recording Available

ECHA presented the new features in a webinar on 23 September 2025. The session is now available for viewing and includes demonstrations of the platform and explanations of the first set of regulatory process and obligation lists. The recording can be accessed here.

The UK Health and Safety Executive (HSE) has launched a six-month public consultation on a proposed restriction of per- and polyfluoroalkyl substances (PFAS) in firefighting foams under UK REACH. The consultation will run until 18 February 2026.

Scope of the Proposal

The restriction targets PFAS used in firefighting foams, covering their manufacture, placing on the market, use, storage, and disposal. PFAS are defined to include substances containing at least one fully fluorinated carbon atom (-CF₂ or -CF₃) without hydrogen, chlorine, bromine, or iodine substituents. The proposal includes transition periods tailored to sectors to allow operators time to adopt PFAS-free alternatives.

Risks and Rationale

According to the Annex 15 restriction dossier, PFAS in firefighting foams present significant threats to human health and the environment. Their persistence, mobility, and potential for bioaccumulation mean that existing controls are insufficient to protect against exposure. Firefighting foams are highlighted as a key source of PFAS emissions, especially via runoff into soil and water systems when used outdoors.

Next Steps

Once the consultation closes, the HSE will review stakeholder submissions and issue its final opinion. That opinion will be forwarded to the Secretary of State for Environment, Food & Rural Affairs and to the devolved administrations for a decision.

The consultation documents, including the full Annex 15 dossier, are available on the HSE site here

India's Directorate General of Foreign Trade (DGFT) has issued a significant policy amendment via Notification No. 28/2025-26, revising the export obligation (EO) period under the Advance Authorization Scheme for imports exempted from mandatory Quality Control Orders (QCOs) issued by the Department of Chemicals & Petrochemicals (DCPC).

Key Amendment to Export Obligation Period

·         Previous Provision (FTP 2023 - Para 2.03(A) (1) (g)): EO period was limited to 180 days from the date of import clearance for chemical products exempted from QCOs.

·         Revised Provision: The EO period for such imports is now fully aligned with Para 4.40 of the Handbook of Procedures, i.e., 18 months from the date of clearance.

This change effectively removes the previously reduced 180-day limit for QCO-exempt imports, placing them on the standard 18-month timeline.

Implications for Trade Community

·         Increased Flexibility: Exporters, EOUs, and SEZ units now have a standardized 18-month EO period, improving planning and execution of export orders.

·         Policy Simplification: Removes the special reduced EO timeline for chemical product imports under QCO exemptions.

·         Trade Facilitation: Supports operational ease and compliance consistency across sectors importing regulated inputs under Advance Authorisation.

Effective Date

The amendment took immediate effect from the date of publication (28 August 2025).

The Ministry of Chemicals and Fertilizers (Department of Chemicals and Petrochemicals) has issued three Gazette notifications amending the timelines for the enforcement of the Quality Control Orders (QCOs) for Ethylene Dichloride, Polycarbonate, and Vinyl Chloride Monomer under the Bureau of Indian Standards Act, 2016.

The amendments, notified on 16 September 2025, extended the enforcement date of these QCOs to 12 September 2026.

Notifications Issued

• Ethylene Dichloride (Quality Control) Amendment Order, 2025
  S.O. 4177(E)
• Polycarbonate (Quality Control) Amendment Order, 2025
  S.O. 4176(E)
• Vinyl Chloride Monomer (Quality Control) Amendment Order, 2025
  S.O. 4175(E)

Impact on Industry

These QCOs mandate that the notified chemicals must conform to Indian Standards and bear the BIS Standard Mark, ensuring quality, safety, and compliance for domestic use as well as imports.

By extending the deadlines, the government provides additional time for industries and stakeholders to align with the mandatory certification requirements, facilitating a smoother transition into full compliance.

On August 28, 2025, China’s national standardization authorities officially published the 18th batch of national standards for 2025. Among them are several standards directly relevant to chemical management, fire suppression chemicals, and hazardous substance restrictions. The full texts of these standards are now accessible through the national standards system.

Fire Suppression Chemicals

Key standards introduced for fire protection and suppression include:

• Foam Extinguishing Agents (GB 15308-2025)
• Dry Powder Fire Suppression Systems and Components (GB 16668-2025)
• Hexafluoropropane Fire Extinguishing Agent (GB 45944-2025)
• Remote-Controlled Fire Monitor Systems – General Technical Conditions (GB 19157-2025)

These standards define chemical composition, performance requirements, and safe use, providing guidance for the production and application of fire suppression systems.

Grain Storage and Other Chemical Agents

• Standards for Management and Use of Grain Storage Chemical Agents (GB 46032-2025)

This standard specifies requirements for safe management, usage methods, and protective measures when applying chemicals in grain storage.

Hazardous Substance Limits in Materials and Products

Two new standards set limits on hazardous substances in products and materials:

• Limit Values for Leachable Hazardous Metals in Wall Materials (GB 46040-2025)
• Requirements for Restricted Use of Hazardous Substances in Electrical and Electronic Products (GB 26572-2025)

These standards set limits on hazardous chemicals to ensure products comply with environmental and safety regulations.

Strengthening Chemical and Environmental Safety

The release of these updates reflect China’s ongoing efforts to strengthen chemical safety, environmental protection, and hazardous substance control in both industrial and consumer sectors.

On August 20, 2025, South Korea announced a revision of the enforcement decree of K-REACH Act (Act on the Registration and Evaluation of Chemical Substances). The amendment follows the revision of the K-REACH Act (Law No. 20860, promulgated on March 25, 2025, and effective from September 26, 2025). The amendment designates the Korea Environmental Preservation Institute (KEPI), as defined under Article 59 of the Framework Act on Environmental Policy, as a newly eligible institution to be entrusted with related governmental tasks under K-REACH.

As a result, this amendment to the Enforcement Decree further specifies KEPI's the scope of responsibilities.

Key Contents

1. Expansion of SME Support Programs (New Subparagraph 7 of Article 29-2): The support scope for small and medium-sized enterprises (SMEs) is broadened to include activities aimed at reducing the use of highly hazardous chemical substances, establishing legal grounds for financial and technical support in these areas.
2. Designation of Tasks for KEPI (New Paragraph 7 of Article 31): KEPI will be responsible for:
• Operating and supporting the Information Review Committee under Article 7-1-4
• Conducting preliminary research and reviews for the committee
• Supporting SMEs’ activities to reduce hazardous chemical use as newly established in Article 29-2-7
3. Task Allocation Among Environmental Organizations (New Paragraph 8 of Article 31): The following tasks may be entrusted to KEPI, the Korea Environment Corporation, and the Korea Chemical Management Association:
• Training professionals in chemical management (under Article 42-2-5 of the Act)
• Implementing legal compliance programs, education, and public outreach (under Article 29-2-1 of the Enforcement Decree)

The specific tasks to be assigned will be announced separately through an official notice.

Public Comment Submission

Institutions, organizations, or individuals who wish to express their opinions on this proposed amendment must submit their comments by September 29, 2025, to MoE.

On 9 September 2025, Taiwan’s Ministry of Environment (MEO) announced that nationwide drinking water tests for PFAS (per- and polyfluoroalkyl substances) are in compliance with national limits. At the same time, the ministry issued guideline values for six additional emerging contaminants to strengthen water quality management. The new substances include germanium, thallium, boron, microcystin-LR, DEHP (a plasticizer), and the total sum of 20 PFAS compounds.

Previous PFAS Regulation Efforts

In November 2024, Taiwan revised its drinking water quality standards to include PFAS limits, becoming one of the first countries in Asia to adopt such measures. Under the updated standards, PFOA + PFOS must not exceed 50 ng/L and PFOS + PFHxS must not exceed 70 ng/L. Since the start of 2025, testing has been conducted at 130 large-scale water treatment plants, covering 91% of the national water supply, with all results meeting the standards.

Test Results Confirm Compliance Nationwide

Analysis shows that:

• For PFOA + PFOS, over 96% of samples were either undetected or at less than one quarter of the standard. Only isolated cases in central Taiwan reaching about half the limit.
• For PFOS + PFHxS, 98% of samples fell below a quarter of the limit, confirming that PFAS levels in drinking water are generally safe nationwide.
• Observed patters also show surface water sources tending to have lower PFAS concentration than groundwater, and that the northern, southern, and eastern regions exhibit particularly low concentrations.

Rolling Updates in Line with International Trends

According to the Ministry, guideline values for emerging contaminants will be continuously updated, following expert consultation and international trends such as the EU Drinking Water Directive.

The newly introduced guideline for ‘total PFAS (20 compounds)’ is 100 ng/L. Local environmental agencies and water utilities have been instructed to integrate these new values into their monitoring regimes.

The Ministry also noted that future updates will follow international developments, with the National Environmental Research Institute enhancing testing methods and capacity, including total organofluorine screening techniques, to ensure Taiwan’s drinking water remains safe and aligned with global standards.

On 19 September 2025, Japan’s Ministry of Economy, Trade and Industry (METI), Ministry of Health, Labour and Welfare (MHLW), and Ministry of Environment (MOE) jointly released the 2026 notification schedule for new chemical substances (including low production volume new chemicals). The full schedule, comprehensive details, and guidance documents are available on the METI portal.

Notifications are required for  new chemicals that are manufactured or imported into Japan under the Chemical Substances Control Law (CSCL).

Annual Update of Notification Timetable

Japan revises its new chemical notification schedule each year in September. The 2025 schedule was announced on 19 September 2024 (more details can be found here), and the newly published timetable covers October 2025 through December 2026.

Notification Schedule (2026)

Submissions will be accepted in 10 rounds during the period October 2025-December 2026). The detailed schedule is given in the table below:

*Submissions  are accepted only until 3 p.m. on the designated date. Missed deadlines automatically roll over to the next round.

Documentation Required                 

Applicants must prepare the following documentation in line with CSCL requirements and the official manual:

• Preliminary review materials (detailed data on substance properties, toxicity, environmental behaviour)
• Notification form (official format under CSCL)
• Supporting data: test reports, safety evaluations, or judgment notification copy if applicable.

For substances already reviewed and notified, applicants may resubmit using a copy of the previous notification result. In such cases, no new review is required, provided the notification is submitted by any of the scheduled deadlines.

Future Outlook

Although METI has not yet disclosed the 2027 notification schedule, it is anticipated to be made public in September 2026.

The Australian Industrial Chemicals Introduction Scheme (AICIS) has announced that all organisations which imported or manufactured industrial chemicals for commercial purposes between 1 September 2024 and 31 August 2025 are required to submit their annual declaration by 30 November 2025.

Who needs to declare

Any “introducer” under the AICIS—meaning anyone who manufactures or imports industrial chemicals—is obligated to make an annual declaration if they carried out introductions during that period. The declaration affirms that all chemical introductions comply with the requirements under the Industrial Chemicals Act 2019.

What the declaration involves

Introducers will need to specify which of the six introduction categories applies to each chemical they manufactured or imported:

• Listed introductions – chemicals that are on the Inventory and introduced according to their terms of listing
• Exempted introductions – very low-risk chemicals or other narrowly defined categories (like polymers of low concern, research & development chemicals, etc.)
• Reported introductions – low risk chemicals where a pre-introduction report was submitted
• Assessed introductions – those covered by an assessment certificate during the year
• Commercial evaluation introductions – where a commercial evaluation authorisation was in force
• Exceptional circumstance introductions – where an authorisation under exceptional circumstances was granted by the Minister

Some exempted introduction types will also require a post-introduction declaration.

Resources and guidance

AICIS has released a new video to guide introducers through the declaration process, which can be accessed here. There is also a categorisation guide to help determine which introduction category applies.

Why this matters

Submissions of annual declarations are essential for AICIS to ensure that industrial chemical introductions remain compliant with Australia’s regulatory framework, intended to protect health, safety, and the environment. Introducers declaring under the correct categories help maintain transparency and regulatory oversight.

Brazil’s national health regulator, ANVISA, has introduced new sanitary requirements for regenerated cellulose films used in food packaging, in a move aimed at strengthening consumer safety and aligning domestic standards with regional trade partners. The regulation, known as RDC No. 992/2025, was approved on 27 August 2025. It will come into force in February 2026, six months after publication.

Aligning with Mercosur

The measure incorporates provisions from the Mercosur Resolution GMC No. 16/2025, ensuring that Brazil’s rules are harmonised with those of its neighbours. Regenerated cellulose films, thin sheets made from purified cellulose sourced from wood or cotton, are widely used in the food industry, including as wrappers for confectionery, baked goods and processed meats.

Key Provisions

Under the new rules, manufacturers will need to:

• Produce films under Good Manufacturing Practices.

• Restrict production to three categories: uncoated films, films coated with cellulose derivatives, and films coated with plastics.

• Use only substances authorised in Anvisa’s Instrução Normativa No. 396/2025 or in previously established regulations.

• Ensure that films comply with strict migration limits, preventing harmful chemicals from leaching into food.

Films that are printed or coloured face additional controls. For example, primary aromatic amines, a class of chemicals linked to health risks, must not migrate into food above trace levels of 0.01 mg per kilogram.

Industry and Consumer Impact

The move updates and replaces a previous 2002 regulation and is expected to modernise oversight of packaging materials that come into direct contact with food. Anvisa says the changes will increase transparency, requiring manufacturers and importers to make the chemical composition of their products available to authorities when requested. Industry experts say the resolution will also facilitate trade, given its alignment with European Union and US Food and Drug Administration (FDA) reference lists, which are commonly used benchmarks for food-contact materials.

Enforcement

Failure to comply will be treated as a sanitary infraction under Brazilian law, carrying administrative, civil and criminal liabilities.The food packaging sector has until February 2026 to adapt to the new standards. For further details on the Resolution you can find it here (in Portughese).

Switzerland is set to tighten its national rules on per- and polyfluoroalkyl substances (PFAS) with a stand-alone regulation aimed at reducing pollution and supporting farms. The National Council's Committee on the Environment, Spatial Planning and Energy (CEATE-N) has proposed measures instructing the Federal Council to curb PFAS emissions and explore independent limit values for PFAS in drinking water, separate from the European Drinking Water Directive.

CEATE-N approved a revised Motion 25.3421 to enforce stricter national measures on PFAS. The motion aims to provide timely solutions for affected sectors, support agricultural operations, and balance environmental and economic considerations when defining PFAS limits. It emphasizes reducing PFAS production and use, especially where safer alternatives exist, while a minority of the committee advocates closer alignment with EU chemical legislation due to potential health and environmental concerns.

In addition, CEATE-N supported retroactive compensation for PFAS-related site remediation under the OTAS fund, effective from April 1, 2025, aligning with provisions for other types of pollution under the Environmental Protection Act.

Beyond PFAS, the committee discussed broader environmental and energy initiatives:

• Approval of the Fish Action Plan to protect aquatic habitats and biodiversity, balancing professional and recreational fishing interests.
• Acceleration of electricity grid authorizations to support renewable energy expansion.
• Examination of conditions for small wind turbine installations to enhance Switzerland’s energy security.
• Support for a trade agreement on climate change, trade, and sustainability, already signed with Costa Rica, Iceland, and New Zealand, aimed at liberalizing trade in environmental goods and services.

CEATE-N’s proposals mark a significant step in Switzerland’s commitment to

environmental protection, sustainable energy, and innovative trade policies.

On September 5, 2025. Vietnam’s Ministry of Industry and Trade (MOIT) has opened consultation on a draft Government Decree that will operationalize the new Law on Chemicals No. 69/2025/QH15. The Decree—described by MOIT’s Chemicals Agency as the “backbone” for implementation—details state management of chemical activities and control of hazardous chemicals in products and goods.

Why it matters

The Decree will translate the 2025 Law on Chemicals (effective January 1, 2026) into practice—setting procedures for new-chemical registration, information management and confidentiality, and controls on hazardous chemicals in products. It will also modernize the regulatory regime following Decree 113/2017/ND-CP and its 2022 amendments, with an emphasis on administrative simplification and digital government.

Structure at a glance

According to MOIT, the draft features 5 Chapters and 32 Articles:

• Chapter I — Scope, definitions, and allocation of state management responsibilities.
• Chapter II — Management of chemical activities (e.g., manufacture, import, trade, use).
• Chapter III — Chemical information: new-chemical registration and evaluation, management of new chemicals, confidential business information (CBI) protections, and digital transformation in state oversight.
• Chapter IV — Hazardous chemicals: list management, production/process controls, and public disclosure requirements for hazardous chemical content in products.
• Chapter V — Implementation clauses: transitional provisions and effective date.

Legal basis and timetable

• The National Assembly adopted the Law on Chemicals No. 69/2025/QH15 on June 14, 2025 (effective January 1, 2026).
• On July 14, 2025, the Prime Minister issued Decision No. 1526/QD-TTg, assigning MOIT to draft the implementing Decree and submit it to the Government by October 15, 2025.
• MOIT convened the drafting taskforce on August 29, 2025 to review the first consultation draft and affirmed the accelerated timeline.

Policy orientation

MOIT notes the Decree is being built in the spirit of Resolution 66-NQ/TW (April 30, 2025) of the Politburo on renewing law-making and law-enforcement to drive development—emphasizing practical, system-wide, and pro-growth reforms, including stronger decentralization and streamlined procedures.

What could change for businesses

• New-chemical regime: Clearer rules for registration and evaluation of substances not yet on Vietnam’s lists; governance of new chemicals after approval.
• CBI handling: Formalized pathways to protect sensitive information while meeting disclosure and safety obligations.
• Product controls: A framework to list and control hazardous chemicals in products/goods, including disclosure of hazardous contents and controls across manufacturing processes.
• Digital oversight: Movement toward digitalized submissions and supervision in chemical management.
• Continuity and transition: Alignment with and eventual replacement/overhaul of procedures under Decree 113/2017/ND-CP (and Decree 82/2022/ND-CP amendments), with transitional clauses anticipated in Chapter V.

Administrative reform focus

In line with Government directives on cutting business conditions, simplifying administrative procedures, and decentralizing decision-making, the drafting team is reviewing additional reductions and simplifications beyond those already approved under national programs (e.g., Decisions 1661/QD-TTg and 1015/QD-TTg).

Next steps

• Consultation: MOIT and the Chemicals Agency are receiving comments to refine the first-round draft.
• Submission target: The drafting taskforce plans to submit the dossier by October 15, 2025 to keep the Decree on track ahead of the January 1, 2026 law effective date.

Indonesia’s Ministry of Trade has issued Regulation No. 20 of 2025 on the import of chemicals, hazardous substances, and certain minerals, replacing Regulation No. 36 of 2023 (as amended). The rule was promulgated on 30 June 2025 and took effect on 29 August 2025.

Scope and Coverage

The regulation establishes import controls for the following categories:

• Non-pharmaceutical precursors, nitrocellulose (NC), industrial explosives, ozone-depleting substances (ODS/BPO), hazardous substances (B2), hydrofluorocarbons (HFCs), and certain designated chemicals (BKT) listed in the annexes. Examples in the annex materials and official briefings include commodity-grade inputs such as sodium tripolyphosphate (STPP), formic acid, and lysine and its salts, as well as numerous HFC refrigerant blends referencing components like HFC-134a and HFC-32.

Legal Basis and Key Dates

• Issued: 30 June 2025 (promulgated in the State Gazette).
• Effective: 29 August 2025 (60 days after promulgation).
• Replacing: Minister of Trade Reg. 36/2023 (as last amended by 8/2024) for the covered chemical streams.

Import Licensing and Verification

Importers must hold appropriate business permits and import approvals before goods enter Indonesia’s customs territory, using the regime defined in the regulation:

• IT (Importir Terdaftar / Registered Importer),
• IP (Importir Produsen / Producer Importer), and
• PI (Persetujuan Impor / Import Approval).

The regulation also formalizes verification/technical tracing by authorized surveyors and the issuance of Laporan Surveyor (LS) where required. Definitions for IT, IP, PI and LS are standardized in Article 1.

Electronic Realisation Reporting

Holders of PI or LS must submit electronic import realisation reports, covering both realised and unrealised volumes, in accordance with the trade licensing framework administered by the Ministry of Trade. Non-compliance triggers administrative sanctions.

Treatment in Special Regimes (FTZ/SEZ/Bonded)

The regulation distinguishes the treatment of goods entering Free Trade Zones (KPBPB), Special Economic Zones (KEK), and Bonded Warehouses (TPB):

• For BKT and certain bulk commodities (e.g., lube base stocks, cement/clinker, oil and gas), imports into TPB are not subject to import licensing/verification at entry; however, full import requirements apply when released into the domestic market.
• By contrast, ODS (BPO), HFCs, non-pharma precursors, nitrocellulose, industrial explosives, and hazardous substances (B2) are regulated upon entry into TPB, requiring import licensing and, where applicable, verification. Similar controls apply to KPBPB/KEK movements as specified in the rule.

Transitional Provisions

Existing IT/IP/PI documents remain valid until expiry and may be amended or extended under the new framework. However, previously issued PI for Certain Chemicals (BKT) under API-P/API-U are expressly revoked via the INATRADE system. Surveyor (LS) documents issued under prior rules remain valid through completion of the relevant importation.

Compliance Actions for Industry

• Map your HS codes against the annexes to determine whether your products fall under B2, ODS, HFCs, precursors, NC, explosives or BKT controls.
• Confirm permit status (IT/IP/PI) and whether LS verification applies to your line items.
• Set up reporting processes to file electronic import realisation reports for PI/LS-covered shipments.

Assess zone strategy: imports routed via TPB/KPBPB/KEK may obtain warehousing efficiencies, but domestic release will trigger full import controls; certain categories are regulated at all stages including entry. 

Argentina has introduced sweeping changes to the way pesticides and other plant protection products are approved, imported and labelled. The National Service of Agri-Food Health and Quality (SENASA) issued Resolution 458/2025, replacing more than a decade of previous rules. The new regulation creates a single national registry for agrochemicals, strengthens oversight of imports, and makes compliance with the United Nations Globally Harmonized System (GHS) for chemical classification mandatory.

National Registry

Under the reform, a National Registry of Plant Protection Products has been established, consolidating existing pesticide registrations into a single system. Companies seeking to register products will now rely primarily on sworn declarations (declaraciones juradas) for approval, subject to subsequent audits by SENASA. Trials, field tests, and experimental use, however, will still require prior authorisation. The government says the shift is designed to reduce bureaucratic delays while maintaining strict controls to protect public health and the environment.

Import Controls and “Convergence” Countries

The resolution introduces a two-tiered approach to pesticide imports, distinguishing between countries with “regulatory convergence” and those without.

• Imports from nations such as the European Union, United States, Brazil and Japan will benefit from a simplified, fast-track registration system. In some cases, provisional registrations lasting up to two years will be permitted.

• Imports from non-convergent countries must undergo full evaluation, including new efficacy trials and toxicological assessments.

Mandatory Global Harmonised System (GHS) Labels

One of the most significant changes is the mandatory adoption of the UN’s GHS system for chemical labelling and classification.

• All pesticide products must comply with the 9th edition of the GHS “Purple Book”, covering hazard categories, pictograms and safety information.

• Companies have three years to bring existing products into compliance

This brings Argentina closer to global chemical safety standards already adopted in much of Latin America, the EU and the US.

Reevaluation Powers and Environmental Safeguards

The resolution also grants SENASA expanded powers to re-evaluate pesticide approvals if new scientific data emerges or if products show unexpected environmental risks, resistance problems or residue concerns. Such reviews may result in tighter restrictions, lower maximum residue limits (MRLs), modifications of approved uses, or even outright cancellations.

Broader Context

Argentina is one of the world’s largest exporters of soybeans, maize and wheat, and among the top consumers of pesticides in Latin America. The regulatory overhaul comes as neighbouring countries, including Brazil and Chile, update their own pesticide frameworks. SENASA is seeking to modernise and unify the country’s pesticide laws under a single, internationally aligned framework.

Timeline

• 25 September 2025 — Resolution enters into force, 90 days after publication.

• September 2028 — Final deadline for all products to comply with GHS classification and labelling.

For more information, you can find the Resolution here (in Spanish). 

The Mexican government has introduced a federal programme, published in the Diario Oficial de la Federación (DOF), setting out a framework for coordinated action across priority sectors.

Background

Unlike decrees, which establish binding rules, a government programme serves as a strategic plan. It defines objectives, guiding principles, and institutional responsibilities. By publishing it in the DOF, authorities give the initiative official status and ensure transparency. The new programme reflects the administration’s commitment to strengthening governance and the protection of he environment through long-term planning, but lacks the authority that regulations or decrees have. Officials said it was designed to modernise public administration and improve accountability at both the federal and regional levels.

Key Measures

The programme outlines five major objectives for 2025–2030:

1. Biodiversity and ecosystems – conserve, protect, and use ecosystems sustainably, treating them as pillars for poverty reduction, social equality, and human rights, with special focus on indigenous and Afro-Mexican communities.

2. Restoration – restore priority ecosystems with interdisciplinary, cross-sector participation, ensuring justice and inclusion in environmental recovery.

3. Water security – guarantee the human right to water through sustainable management of rivers, aquifers, and watersheds, while protecting ecosystems.

4. Climate action – strengthen adaptation and low-carbon strategies, integrating pollution control to protect public health, ecosystems, and critical infrastructure.

5. Human-centred ecology – promote an ecological, humanistic policy with citizen participation, environmental culture, and access to justice supported by reliable information and a territorial perspective.

By combining these elements, the government seeks to build a coherent framework that avoids duplication of efforts and strengthens institutional efficiency.

Reactions

Businesses and civil society groups are expected to review the programme’s provisions closely. For some sectors, particularly those under strict regulatory oversight, the programme may open new opportunities while also imposing additional responsibilities.

Next Steps

The federal government will now focus on implementation. Agencies are expected to issue complementary guidelines, and funding mechanisms may be clarified in the months ahead. Officials stressed that the programme should be seen as a “living framework” one that may evolve as conditions change, but which provides a structured path toward Mexico’s development priorities. 

For further details you can find the Programme here (in Spanish).

• On 8 September 2025, Singapore notified the WTO (G/TBT/N/SGP/76) of a proposal to control six mercury-added lighting products as Hazardous Substances under the Environmental Protection and Management Act (EPMA), to implement decisions adopted at Minamata Convention COP-5 (October 2023). Once the regulation takes effect, import, export, and manufacture of the listed products will not be allowed. The measure is planned for Gazette publication in Q2 2026, with phased prohibitions on 1 January 2027 and 1 January 2028. Stakeholders may submit comments until 7 November 2025.  

  Scope: Products and HS Codes 

  The proposal covers six categories of mercury-added lamps used for general lighting, with associated HS 2022 codes listed in the notification: 

  • Compact fluorescent lamps (CFLs) >30 W (e.g., 85393110, 85393130, 85393190, 85393910, 85393990). 
  • CFLs with non-integrated ballast (≤30 W; ≤5 mg Hg per burner) (e.g., 85393110, 85393190, 85393910, 85393990). 
  • Linear fluorescent lamps (LFLs), halophosphate (≤40 W; ≤10 mg Hg) and >40 W (e.g., 85393120). 
  • Non-linear fluorescent lamps (NFLs), halophosphate (e.g., U-bend/circular; 85393190, 85393990). 
  • NFLs, tri-band phosphor (e.g., U-bend/circular; 85393190, 85393990). 
  • LFLs, tri-band phosphor: <60 W (≤5 mg Hg), ≥60 W (≤5 mg Hg), and ≥60 W (>5 mg Hg) (e.g., 85393120).  

  Timeline and Entry into Force 

  • Adoption: To be determined; planned Gazette notice in Q2 2026. 
  • Prohibitions effective: 1 Jan 2027 (items S/N 1–4) and 1 Jan 2028 (items S/N 5–6). 
  • Comment window: Through 7 Nov 2025 (60 days from notification).  

  Legal Mechanism and Convention Alignment 

  Controls will be implemented under the EPMA and related hazardous substances regulations to fulfil Singapore’s obligations following the Minamata Convention amendments adopted at COP-5. The notification specifies no change to other existing EPMA requirements; the action specifically phases out the six mercury-added product categories listed above.  

  Compliance Implications for Industry 

  Once the regulation is in force, the listed lamps cannot be imported, exported, or manufactured in Singapore. Companies should: 

  • Audit inventories and SKUs against the six categories and HS codes. 
  • Plan product substitutions (e.g., mercury-free alternatives) to meet the 2027/2028 phase-out dates. 
  • Prepare licensing/permit adjustments as needed for any remaining hazardous-substance activities under EPMA (noting that the specific action here is a prohibition of import/export/manufacture for the listed products).  

  Next Steps and Contact 

  The National Environment Agency (NEA) is the responsible agency. Stakeholders should provide written comments by 7 November 2025 per the contact details in the WTO TBT notice. Final adoption and entry-into-force dates will be confirmed by Government Gazette notice ahead of the 2027/2028 milestones.  

New Zealand’s Environmental Protection Authority (EPA) has confirmed the phase-out of chlorpyrifos, with strict deadlines now in place for the use and disposal of the pesticide. The move follows the EPA’s July 2025 decision to revoke all approvals for chlorpyrifos, citing unacceptable risks to human health and the environment.

Disposal Timelines Announced

A notice published in the New Zealand Gazette (2025-au4759) sets out a staged withdrawal:

• By 8 January 2026: Use of many chlorpyrifos formulations (including liquids, solids, granules and wettable powders) must cease, with mandatory disposal required by the same date.
• By 8 July 2026: A second group of chlorpyrifos formulations, such as emulsifiable concentrates, must be withdrawn and disposed of.
• By 8 July 2027: The final remaining chlorpyrifos substances, including pure chlorpyrifos and certain granules, must be removed from the market.

After 8 January 2027, no import or manufacture of chlorpyrifos or chlorpyrifos-containing products will be permitted. The full list of affected substances is available in the New Zealand Gazette notice.

EPA Guidance

In a statement on 3 September 2025, EPA urged users to prepare for disposal well ahead of the deadlines and to consider safe alternatives. The agency stressed that holders of chlorpyrifos stocks must take responsibility for ensuring safe and timely disposal to avoid non-compliance.

The reassessment and phase-out reflect a broader regulatory shift in New Zealand, aligning with international action to reduce risks associated with organophosphate insecticides.