Peru Defines GHS and RENASQ Implementation Milestones

By Rafael Sosa, Regulatory Specialist, Supply Chain Team, UL Solutions

In June 2023, UL Solutions reported on Peru’s Legislative Decree No. 1570, which established the legal framework for the comprehensive management of chemical substances and formally aligned hazard communication requirements with the United Nations’ Globally Harmonized System (GHS).

On April 8, 2026, Peru advanced this framework with the publication of Supreme Decree No. 005‑2026‑MINAM, which approves the implementing regulation of Decree No. 1570. The regulation provides long‑awaited clarity on compliance obligations, transitional timelines and technical criteria applicable to manufacturers and importers of chemical substances in Peru.

Entry into force and transition periods

Supreme Decree No. 005‑2026‑MINAM enters into force six months after its publication, with key obligations becoming applicable in October 2026. The regulation also establishes phased implementation periods extending through 2031, particularly for notification and reporting obligations under the National Registry of Chemical Substances (RENASQ).

This phased approach is intended to allow regulated stakeholders sufficient time to adapt internal systems, data collection processes and hazard communication practices.

Mandatory GHS classifications and annexes

One of the most significant developments introduced by the regulation is the inclusion of mandatory or “anticipated” hazard classifications for certain substances listed in Annex 3. This list may be used as a minimum, non restrictive reference; however, it does not replace the responsibility of manufacturers and/or importers to submit a complete GHS hazard classification. Accordingly, the Annex 3 classifications must be considered as part of the overall classification process, even where a company’s internal assessment identifies additional or differing hazards.

Peru adopts Revision 6 of the United Nations Globally Harmonized System (GHS). All hazard classes and hazard categories established under GHS Revision 6 are applicable for the classification of chemical substances under the Peruvian framework. The regulation includes the following technical annexes:

• Annex 1: Codification of hazard statements
• Annex 2: Codification of precautionary statements
• Annex 3: List of Hazard Classifications for Chemical Substances (LCA)
• Annex 4: Countries whose hazard classification may be used as reference.

Implications for Manufacturers and Importers

Accordingly, manufacturers and importers will be required to:

• Review and align substance classifications under GHS, considering any hazard classifications listed in Annex 3
• Update labels and Safety Data Sheets (SDS) in Spanish, as necessary, to ensure consistency with approved GHS classifications
• Prepare for phased compliance with RENASQ, including: 
  • Identification of substances subject to registration and reporting obligations
  • Collection and consolidation of annual volume data for hazardous substances placed on the Peruvian market
  • Submission of information within the applicable phase, with deadlines between 2028 and 2031, depending on substance category and risk profile
  • Ongoing data maintenance and updates, as required by the competent authority

While RENASQ notification and reporting obligations will be implemented progressively between 2028 and 2031, the adoption of Annex 3 and the application of UN GHS Revision 6 for hazard classification, labeling, and Safety Data Sheets are subject to the same transitional period and will be implemented on a phased basis.

Looking ahead

With the publication of Supreme Decree No. 005 2026 MINAM, Peru moves from a legislative framework to an operational chemical management system. Companies operating in or supplying the Peruvian market should closely monitor implementation guidance issued by competent authorities and begin aligning internal compliance programs with the new timelines and classification requirements.

Reference

Supreme Decree No. 005 2026 MINAM, published April 8, 2026