Allende & Brea – Estudio Jurídico

This report cannot be considered as legal or any other kind of advice by Allende & Brea. For any questions, do not hesitate to contact us.

Hazardous Substances: Modifications to the Integrated National Registry of PCB Holders

By means of Resolution No. 355/2020, the Ministry of Environment and Sustainable Development introduced modifications to the National Integrated Registry of PCB Holders (“RENIPP”for its acronym in Spanish), which will be administered by the National Direction of Chemical Substances and Products of the Secretary of Environmental Control and Monitoring of the Ministry of Environment and Sustainable Development.

The norm establishes that the RENIPP will be constituted by the National Registry of PCB Owners and the National Registry of Devices that Contain PCBs, and will consolidate the information contained in the registries that, to that effect, have been implemented by the local jurisdictions, information that must be provided within 90 administrative working days through their respective representatives in the Federal Council of the Environment (“COFEMA” for its acronym in Spanish).

On the other hand, the holders of PCBs located in jurisdictions that have not constituted a Local Registry of PCB Holders must proceed to their registration before RENIPP before June 25, 2021. The Resolution also establishes the re-inscription of those PCB holders already registered in the RENIPP. In both cases, the procedure for registration, modification, annual renewal and removal from the RENIPP must be complied with, as well as the requirements for the presentation of Elimination or Decontamination Programs.

The norm also approved the Technical Specifications Guide for the Transitional Deposit of Transformers, Electrical Equipment and PCB Containers, and the Standard Operating Procedures Guide. Finally, the National Direction of Chemical Substances and Products is entrusted with the conduction of the National Program for the Integral Management of PCBs, created by Resolution No. 840/2015 of the then National Secretary of Environment and Sustainable Development.

This report cannot be considered as legal or any other kind of advice by Allende & Brea. For any questions, do not hesitate to contact us.

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