Chemical law

The Hazardous Chemicals Regulations, 2024: what changed for operators

S.I. No. 21 of 2024 brings the Globally Harmonized System (GHS) into Ugandan law and regulates a chemical across its whole life cycle, from import to disposal.

· 3 min read · Industrial & Natural Resources Consults Ltd

The National Environment (Management of Hazardous Chemicals and Products Containing Hazardous Chemicals) Regulations, S.I. No. 21 of 2024 are made under section 71 of the National Environment Act Cap. 181. They replace a patchwork of guidance with a single regime for hazardous chemicals.

What the Regulations cover

  • registration of hazardous chemicals, and of the people and businesses that handle them, with NEMA;
  • classification and labelling aligned with the GHS;
  • packaging and advertising controls;
  • control of imports, exports and transit;
  • requirements for distribution, storage, transport and handling;
  • monitoring of the effects of chemicals and their residues on health and the environment;
  • disposal of expired and surplus chemicals;
  • restriction or banning of extremely hazardous chemicals, including a ban on mercury and mercury compounds in mining.

What operators must do in practice

  1. Register and license. Register each hazardous chemical and hold a NEMA licence before importing, storing, manufacturing, repackaging or using it.
  2. Classify and label to the GHS. Every container needs the six label elements:
    • product identifier;
    • pictogram(s);
    • signal word;
    • hazard statements;
    • precautionary statements;
    • supplier details.
  3. Keep a current SDS. A 16-section Safety Data Sheet must be available where the chemical is used.
  4. Store properly. Use facilities that are bunded, ventilated and secure, with incompatible chemicals kept apart.
  5. Transport safely. Use suitable vehicles, carry SDSs and spill kits, and have an emergency response plan.
  6. Keep records and allow inspection. Maintain registers, report as required and give inspectors access.

Why it matters. Before 2024, many sites relied on supplier labels in whatever format arrived. GHS labelling is now a legal requirement. An unlabelled decanting bottle, or a drum with only a trade name, is a compliance failure as well as a safety risk. Failing to register or label is an offence under the Regulations and under s. 161 of the National Environment Act.

What to do

  • Reconcile your chemical inventory against your NEMA registrations and licences.
  • Audit labels on primary and secondary containers against the six GHS elements.
  • Replace any SDS that is not in the 16-section format or is more than a few years old.
  • Brief storekeepers and drivers on the new requirements.

Check any penalty amount against the gazetted text of S.I. No. 21 of 2024 before relying on it.

How INRC can help

Our environmental audits check chemical inventories, labels and Safety Data Sheets against the Hazardous Chemicals Regulations, 2024, and our training brings storekeepers, drivers and supervisors up to date with the new requirements. Contact us to discuss your site.

This article is general guidance, not legal advice. Check current legislation and regulations for your specific project.

Questions about your own project?