On October 9, 2026, Department Administrative Order (DAO) No. 2026-28, the Chemical Control Order for Vinyl Chloride, and DAO No. 2026-29, the Chemical Control Order for Benzene, issued by the Department of Environment and Natural Resources (DENR) of the Philippines, formally entered into force. Formulated under Republic Act No. 6969, the Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990 (RA 6969), and its 1992 Implementing Rules and Regulations (DAO 1992-29), among others, and implemented by the Environmental Management Bureau (EMB), the two orders impose whole-chain control over the import, manufacture, distribution and use of vinyl chloride (CAS No. 75-01-4) and benzene (CAS No. 71-43-2) and their mixtures. The enterprises concerned must complete Chemical Control Order (CCO) registration, apply for an import clearance for each import shipment, and comply with use restrictions; violations will result in administrative penalties and even criminal liability.
Background of the Two Orders
Both orders were signed on June 22, 2026, were published in The Manila Times on September 24, and were filed on the same day with the Office of the National Administrative Register (ONAR) of the University of the Philippines Law Center; pursuant to their effectivity clauses, under which they take effect on the fifteenth day after publication, the two orders formally took effect on October 9. The orders note that vinyl chloride has been classified by the International Agency for Research on Cancer (IARC) as a Group 1 carcinogen, with sufficient evidence that it causes hepatic angiosarcoma and hepatocellular carcinoma, while benzene is a flammable, highly volatile aromatic hydrocarbon that evaporates very readily at room temperature. This control action aims to reduce the risks of human health and environmental exposure to the two substances in industrial processes, raise industry awareness of their toxicity and of their technically superior and safer alternatives, and provide guidance for enterprises on identifying potential release and exposure points.
Covered Entities and Exemptions
The two orders apply to the same entities, covering five categories: importers, distributors, manufacturers, industrial users and commercial users (including laboratory facilities). At the same time, each order lists the situations regulated by other laws and regulations to which it does not apply:
- Exemptions under the vinyl chloride order: polymers with vinyl chloride as a monomer; food, drugs, cosmetics, household/urban hazardous substances (HUHS) and consumer health products regulated by the Philippine Food and Drug Administration (FDA); product standardization under the Bureau of Philippine Standards (BPS) of the Department of Trade and Industry; and vinyl chloride and its mixtures that are articles as defined in EMB MC 2020-005.
- Exemptions under the benzene order: fuels, fuel additives and petroleum products regulated by the Oil Industry Management Bureau (OIMB) of the Department of Energy; food, drugs and the other FDA-regulated products mentioned above; fertilizers, pesticides and agricultural chemicals regulated by the Fertilizer and Pesticide Authority (FPA) of the Department of Agriculture; and benzene and its mixtures that are articles or are naturally occurring, as defined in EMB MC 2020-005.
Use Controls: Vinyl Chloride Banned in Aerosols, Six Uses of Benzene Prohibited
The vinyl chloride order explicitly prohibits the use of vinyl chloride as a propellant or ingredient in aerosol products, and no exemption application mechanism similar to that of the benzene order is provided. Enterprises holding vinyl chloride and its mixtures intended for prohibited uses must cease the relevant activities and complete the phase-out in accordance with the phase-out schedules set out in their registration conditions, by eliminating stocks, replacing them with substitutes, or diverting them to permitted uses, among other means.
The benzene order defines "benzene-containing mixtures" as mixtures with a benzene content of more than 1% (by volume), and applies dual-list management of "permitted uses plus prohibited uses" to benzene and its mixtures. There are five permitted uses in total: the manufacture and production of benzene; use in chemical synthesis; use in motor vehicle fuels; laboratory analysis or research; and other industrial and commercial uses of mixtures with a benzene content equal to or less than 1% (by volume).
The prohibited uses cover six product areas: paints, varnishes, coatings, solvents and thinners; glues, contact adhesives and rubber products; solutions for textiles, fabrics and leather; inks and dyes; cleaning and degreasing agents; and toys and other children's products. Enterprises intending to continue using benzene in the above uses must submit a written application to the EMB stating the reasons why no technically and economically feasible alternatives exist; an exemption may be granted only after formal approval by the EMB, and the corresponding conditions and procedures must be observed.
CCO Registration and Import Clearance Requirements
With respect to registration, all five categories of covered entities must submit materials and obtain registration certificates through the CCO Registration (CCOR) module of the Online Permitting and Monitoring System (OPMS). The applicable situations include: enterprises newly engaging in the import, manufacture, distribution or use of vinyl chloride, benzene and their mixtures; enterprises already holding Priority Chemicals List (PCL) Compliance Certificates or PCL Exemptions (issued under EMB MC 2014-003 and EMB MC 2017-007 respectively), which must be re-classified as new applicants for registration; and already registered enterprises applying for changes, additions or deletions, or updates to registration and permit information (except changes in facility location).
Registration materials include the Environmental Compliance Certificate (ECC), a chemical management plan (covering four aspects: exposure prevention and release control, site management and occupational hygiene, safety equipment used in handling chemicals, and the provision of personal protective equipment for workers), a contingency plan, a substitution and phase-out plan, GHS-compliant safety data sheets (SDS), process flow diagrams, worker safety training certificates, photos of storage and production facilities, the latest self-monitoring report (SMR), and proof of payment. Other environmental permits, such as the hazardous waste generator registration certificate, the wastewater discharge permit, the Permit to Operate (PTO) for air pollution source installations, and the Pollution Control Officer (PCO) accreditation, must still be obtained in accordance with their respective legal requirements, but do not serve as prerequisites for the review, evaluation and approval of CCO registration.
With respect to imports, on top of completing CCO registration, importers must apply through the OPMS for a CCO Import Clearance (CCOIC) and obtain an import clearance certificate for each shipment. An import clearance is valid for one year and covers only shipments arriving and entering through ports within its validity; renewal may be applied for as early as 20 working days before expiry, and amendment applications must be submitted no later than 20 working days before expiry. The application materials are proof of import (such as the Single Administrative Document for customs, a bill of lading or a packing list) and proof of payment. In addition, the issuance of the CCOR and the CCOIC will be devolved to the EMB Regional Offices three years after the two orders take effect.
Ongoing Compliance Obligations and Legal Liability
The two orders require enterprises, in their daily operations, to keep SDSs readily available; to classify and label storage containers and packaging in accordance with the current GHS implementation guidelines; and to identify vinyl chloride and benzene wastes in accordance with the current hazardous waste management procedures manual. In manufacturing and use, engineering controls, good work practices, and industrial hygiene measures should be applied to reduce the spread of the substances into the environment and lower employee exposure; personal protective equipment must be worn in hazardous areas as required by the Occupational Safety and Health Center (OSHC) of the Department of Labor and Employment; hazardous areas must be delineated where employee exposure concentrations are relatively high; and potential release sources must be monitored through self-inspection in accordance with the EMB wastewater discharge and air emission standards and included in SMR submissions. In addition, basic training covering hazard awareness, safe operation, emergency response and other content must be provided regularly for exposed workers.
With respect to legal liability, where there are reasonable grounds to find that the sale, storage, keeping, use, manufacture, transport or import of the substances concerned does not conform to the requirements of the orders, the DENR Secretary or an authorized representative may seize or confiscate the chemical substances as well as their transport vehicles and containers. Manufacturers, importers, or distributors that sell the substances concerned to unauthorized persons or end users (including sales through online marketplaces and e-commerce systems) will be held liable under RA 6969. Storage fees for confiscated chemicals are borne jointly and severally by importers and/or distributors together with end users; where related activities cause damage to public health or the environment, importers and distributors likewise bear joint and several liability together with end users, and must properly compensate the affected parties and restore the damaged areas. Violations will be subject to progressive administrative fines and even criminal penalties under Sections 14 and 15 of RA 6969, Sections 43 and 44 of DAO 1992-29, and DENR MC 2005-003.
ChemRadar Insights
ChemRadar reminds enterprises that export vinyl chloride, benzene, and their mixtures to the Philippines, and enterprises engaged in related production, distribution, and use activities in the Philippines, of the following:
- Check as soon as possible whether you fall within the scope of control and complete registration. Both orders are now in force, and all five categories of covered entities (including commercial users such as laboratories) must complete CCO registration; enterprises already holding PCL Compliance Certificates or PCL Exemptions will not automatically be brought into the CCO system and must apply anew as new applicants.
- Enterprises producing benzene-containing products should review their formulations and uses. Mixtures with a benzene content of more than 1% (by volume) are already under control, and benzene may no longer be used in the six prohibited uses such as coatings, adhesives, inks, cleaning agents and toys; where continued use is genuinely necessary because no technically and economically feasible alternatives exist, a written exemption application should be submitted to the EMB as early as possible.
- Adjust the aerosol uses of vinyl chloride immediately. The use of vinyl chloride as a propellant or ingredient in aerosols is an explicitly prohibited use; the enterprises concerned should adjust formulations or stop the related export activities, and those already holding relevant stocks must complete the phase-out in accordance with the phase-out schedules set out in their registration conditions.
- Import clearances are managed on a per-shipment basis, so plan ahead. The CCOIC is valid for one year and covers only shipments arriving within its validity; exporting enterprises are advised to confirm with their Philippine importers the progress of CCO registration and import clearance applications, and to arrange renewals or amendments at least 20 working days before expiry, to avoid goods failing to clear customs after arrival at port.
CIRS Services
CIRS can provide domestic and foreign enterprises with the following related services. Enterprises with such needs are welcome to contact the CIRS compliance team for consultation:
- PICCS Inquiry
- PICCS Certification Application
- PMPIN for New Substance Application
- Exemption Application for Polymer
- SQI Application
- Philippines Chemical Regulation Consulting Service
