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Editor's Note: This article was originally published in September 2024 to analyze the proposed revision to Thailand's List of Hazardous Substances, and was updated on 19 March 2025 to introduce the revision progress.
On March 18, 2025, Thailand's Department of Industrial Works (DIW) of the Ministry of Industry notified WTO of the Draft Notification of the Ministry of Industry regarding List of Hazardous Substances (No.8). This draft revision, which was released for public comments in September last year, is now submitted to WTO for consultation. Thailand DIW plans to officially publish this revision in the Royal Gazette in April 2025.
For more details on the proposed updates, please refer to the previous ChemLinked article below.
Reference links to the WTO Notification G/TBT/N/THA/770 and the Draft MOI Notification (in Thai) are provided at the bottom of this article.
Article originally published in September 2024:
Thailand’s Ministry of Industry (MOI) recently opened a public consultation to solicit comments on the proposed updates to the List of Hazardous Substances under the Hazardous Substances Act B.E. 2535 (1992). Comments period is due by September 26, 2024.
Background
The List has been updated several times since its master version was published in 2013. By official announcements, six partial amendments pertaining to this control list were released. The most recent revision is the Notification of MOI on List of Hazardous Substances (No.7) B.E. 2565 (2022), dated December 21, 2022. Subsequently, the responsible agencies, including the Department of Industrial Works (DIW), the Food and Drug Administration (FDA), and the Department of Agriculture (DOA), have reviewed the control of certain chemicals and proposed several updates. These include the cancellation of certain controls, the adjustment of hazard types, and the addition of new hazardous substances to ensure that regulations are appropriate, aligned with current conditions, and fulfill Thailand's obligations as a member party to international conventions. The responsible agencies have separately gathered feedback on these proposals from the public in 2023 and early 2024. Therefore, the Ministry of Industry compiled the feedback and prepared a draft announcement for further comments. Partial amendment to the List will take effect immediately if it is officially announced in the Royal Gazette.
Proposed updates
Annex 5.1 of the List (regulated by the DIW)
To elevate the hazard type of six cyanide compounds (see Table 1 below) from Type 1 to Type 3, thereby imposing on them more stringent control (read more). Manufacturers and importers shall complete the registration and apply for permit beforehand.
Table 1
To change the specific condition for six cyanide compounds in Annex 5.1, i.e., removing the concentration limit "with concentration > 1% w/w" (see Table 2 below).
Table 2
Annex 4.1 and 4.2 of the List (regulated by the FDA)
To remove “Citronella oil (CAS No. 8000-29-1)” from Annex 4.1 to address the inconsistency and eliminate unreasonable compliance burden (read more).
To update condition for “Hydrogen peroxide (CAS No. 7722-84-1)” in Annex 4.1 (see Table 3 below).
Table 3
To update condition for “Chlorine and chlorine releasing substances” in Annex 4.2 (see Table 4 below).
Table 4
Annex 1.1 and 1.2 of the List (regulated by the DOA)
To elevate the hazard type of “Dicofol (CAS No. 115-32-2)” in Annex 1.1 from Type 3 to Type 4, prohibitions will apply.
To add “Pentachlorobenzene (PeCB; CAS No. 608-93-5)” and “Hexachlorobutadiene (HCBD; CAS No. 87-68-3)” in Annex 1.1 as Type 4 hazardous substances, prohibitions will apply.
To remove Entry No. 8 “Extracts from plants such as neem, galangal, lemongrass, etc. used for preventing and eliminating pests” from Annex 1.2.
To add the condition “Except for parts of plants with natural characteristics that have been processed into products, such as drying, chopping, grinding into powder, or fermenting with water without adding other substances” for Entry No. 9 ~ 12 in Annex 1.2.
Manufacturers, importers, exporters and possessors of the abovementioned hazardous substances should pay attention to related obligations to ensure compliance, especially for those to be newly designated as Type 3 or 4 hazardous substances.
*Notably, the propsal this time does not encompass the 147 PFHxS-related substances previously proposed for inclusion in Annex 5.1 as Type 3 hazardous substances (read more). ChemLinked will keep an eye on this issue, and provide you with the latest updates.
