Professional Documents
Culture Documents
DISCLAIMER
The Guide Manual for the HUHS Industry – Initial Product Registration has been prepared
by the Center for Cosmetics and Household/Urban Hazardous Substances Regulation and
Research (CCHUHSRR) as a guidance document supplementary to its administrative
issuances to support its Household/Urban Hazardous Substances (HUHS) stakeholders as
they comply with the Food and Drug Administration’s (FDA’s) regulatory requirements and
secure initial Certificates of Product Registration for their HUHS products. It is the first in a
series of guidance documents that will revolve around the Agency’s current policies, rules and
regulations on HUHS establishments and the products they place in the market. The Guide
Manual for the HUHS Industry – Initial Product Registration is not a legal text of the rules and
regulations promulgated and implemented by the FDA which remains to be the administrative
issuances signed by the FDA Director-General.
The information contained in this guidance document is up-to-date as of the date of its
publication; however, readers, particularly the HUHS industry, are also advised to regularly
check the FDA website at www.fda.gov.ph for any new information or update to the current
HUHS regulations.
Lastly, the use of this document remains the sole responsibility of the readers; the FDA does
not accept any liability with regard to the use that may be made of the information contained
in this document.
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Guide Manual for the HUHS Industry – Initial Product Registration
REVISION HISTORY
VERSION CHANGES DATE OF REVISION
2023 Edition First Edition 20 October 2023
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Guide Manual for the HUHS Industry – Initial Product Registration
CAS number refers to a unique numeric identifier assigned to a specific substance by the
Chemical Abstracts Service.
Expiration or Expiry Date refers to the date within which an HUHS product is expected to
remain within established specifications if stored correctly. It is established for a specific
batch/lot of an HUHS product by adding the product shelf-life to the date of manufacture or
manufacturing date.
Food and Drug Administration (FDA) refers to the National Regulatory Authority for health
products
Hazard Category refers to the division of criteria within each hazard class, i.e., oral acute
toxicity includes five hazard categories and flammable liquids include four hazard categories.
Hazard Class refers to the nature of the physical, health or environmental hazard of a
chemical, i.e., flammable solid, carcinogen, acute oral toxicity.
Hazard Statement refers to a statement assigned to a hazard class and category that
describes the nature of the hazards of a hazardous product, including, where appropriate, the
degree of hazard.
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Guide Manual for the HUHS Industry – Initial Product Registration
(1) any substance or mixture of substances intended for individual or limited purposes and
which is toxic, corrosive, an irritant, a strong sensitizer, is flammable or combustible, or
generates pressure through decomposition, heat or other means, if such substance or
mixture of substances may cause substantial injury or substantial illness during or as a
proximate result of any customary or reasonably foreseeable ingestion by children, but
shall not include agricultural fertilizers, agricultural pesticides, and agricultural insecticides,
and other economic poisons, radioactive substance, or substances intended for use as
fuels, coolants, refrigerants and the like;
(2) any substance which the FDA finds to be under the categories enumerated in clause
(1); and
(3) any toy or other articles intended for use by children which the FDA may determine to
pose an electrical, chemical, physical, or thermal hazard. For this purpose, “toys and other
articles intended for use by children” refers to toys and articles specified to be for children
less than fourteen (14) years of age.
(4) This term shall not apply to food, drugs, cosmetics, devices, or to substances intended
for use as fuel when stored in containers and used in the heating, cooking or refrigeration
system of a house, but such term shall apply to any article which is not in itself an
agricultural pesticide but which is a hazardous substance, as construed in clause (1), by
reason of bearing or containing such harmful substances described therein.
HUHS Product Registration refers to the process whereby the FDA approves the sale and
use of an HUHS product following the evaluation of scientific data demonstrating that the
product is effective for its intended purposes and does not pose an unacceptable risk to human
or animal health as well as the environment.
Industrial Use refers to product use in manufacturing and/or production facilities, aviation
industry, utilities and electric power companies including nuclear power plants.
Label refers to a display of written, printed, or graphic matter on the immediate container, or
other materials affixed thereto, of any article. The label of an HUHS product shall include other
informative materials such as but not limited to inserts, hangtags, etc.
Label Element refers to one type of information that has been harmonized (under GHS) for
use in labels. The GHS label elements are the signal words, pictograms and hazard
statements.
Manufacturing Date refers to the date when a specific batch/lot of an HUHS product has
been manufactured.
Marketing Authorization (MA) refers to the approval granted by the FDA to market a specific
HUHS product in the Philippines. For Categories III and IV HUHS products, the marketing
authorization is the CPR.
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Guide Manual for the HUHS Industry – Initial Product Registration
Mixture refers to a mixture or a solution composed of two or more substances in which they
do not react.
Overlabeling or relabeling refers to the act of placing a new label over an old label
Pictogram refers to a graphical composition that may include a symbol plus other graphic
elements such as a border, background pattern or colour that is intended to convey specific
information.
Professional Use HUHS products refer to HUHS products that are highly concentrated
requiring further dilution and are restricted only to be applied by trained personnel.
Ready-to-Use HUHS products refers to HUHS products that are ready to be used outright of
the packaging and for general purposes, which require no further dilution prior to application.
This term also refers to HUHS products that are diluted before use whose application are NOT
restricted to trained personnel or professionals.
Shelf-life refers to the period of time during which an HUHS product, if stored correctly, is
expected to comply with its established specifications.
Signal Word refers to a word used to indicate the relative level of severity of hazard and alert
the reader to a potential hazard on the label. The GHS uses “Danger” and “Warning” as signal
words.
Substance refers to chemical elements and their compounds in the natural state or obtained
by any production process, including any additive necessary to preserve the stability of the
product and any impurities deriving from the process used, but excluding any solvent which
may be separated without affecting the stability of the substance or changing its composition.
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Guide Manual for the HUHS Industry – Initial Product Registration
LIST OF TABLES
Table Title Page
2.1 Illustrative List of Category III HUHS Products (Cleaners, Fresheners
15
and Deodorizers)
2.2 Illustrative List of Category IV HUHS Products (Do-It-Yourself and
16
Hobby Items)
2.3 Schedule of Fees for Initial HUHS Product Registration Depending on
19
the Number of Years of CPR Validity Applied For
2.4 List of Adopted Standards for HUHS Products 21
2.5 Classification of Carcinogens Under IARC and their Equivalents in GHS 22
2.6 Different Hazard Classes Under Physical, Health and Environmental
Hazard According to the Globally Harmonized System of Classification 24
and Labeling of Chemicals
2.7 Hazard Criteria for GHS Acute Toxicity (Oral/Dermal/Inhalation) and Its
Five (5) Hazard Categories (Adapted from Table 3.1.1 of the 8th Revised 25
Edition of the GHS)
2.8 Hazard Criteria for GHS Skin Corrosion/Irritation Category 1 and Its
25
Subcategories (Table 3.2.1 of the 8th Revised Edition of the GHS)
2.9 GHS Pictograms and Their Corresponding Codes and Names (Table
28
A3.4.1 from the 8th Revised Edition of the GHS)
2.10 Minimum Information for Safety Data Sheets (SDS) (Adapted from Table
30
1.5.2 of the 8th Revised Edition of GHS)
2.11 Examples of HUHS Product Claims and the Documents Acceptable to
35
Support Said Claims
2.12 List of the National and Regional Poison Centers in the Philippines and
Their Contact Information as Listed in Department of Health Department 40
Circular No. 2020-0081
2.13 Variants of ABC Disinfectant Spray 66
2.14 Different Ways to Register the Two (2) Variants of ABC Disinfectant
67
Spray
2.15 Sample HUHS Product for Registration and Its GHS Hazard
71
Classifications with the Corresponding Assigned GHS Label Elements
2.16 Hazard Information for non-GHS Compliant HUHS Products (Adapted
73
from Administrative Order No. 311 s. 1977)
2.17 Sample Formulation of a HUHS Product Containing an Ingredient in the
Form of a Mixture and its Declaration in the Ingredient List Section of the 77
Initial HUHS Product Registration Application Form
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Guide Manual for the HUHS Industry – Initial Product Registration
LIST OF FIGURES
Figure Title Page
2.1 Decision Matrix to Identify Categories III and IV HUHS Products Regulated
17
Under FDA Circular No. 2020-025
2.2 Application of the Globally Harmonized System of Classification and
24
Labeling of Chemicals (GHS)
2.3 Decision Logic for GHS Flammable Liquid (Decision Logic 2.6 from the 8th
26
Revised Edition of the GHS)
2.4 A Sample of an Acceptable Certificate of Analysis (COA) 33
2.5 Sample Labeling Material for HUHS Products Not Intended for Children’s
Use Containing the Mandatory Label Information Prescribed in FDA 41
Circular No. 2020-025
2.6 Sample Labeling Material for HUHS Products Intended for Children’s Use
Containing the Mandatory Label Information Prescribed in FDA Circular 46
No. 2020-025
2.7 User’s Registration Form 51
2.8 Log-in Interface of FDA Electronic Portal V2.0 System 53
2.9 FDA Electronic Portal V2.0 Homepage 54
2.10 “Summary” Dialogue Box 55
2.11 On Process Folder Displaying the Relevant Information of a Case
55
Application
2.12 Business Process Flow for the Initial Registration of HUHS Products 56
2.13 Steps to Create a New Case Application for Initial HUHS Product
57
Registration
2.14 Sample of the Order of Payment Sent to the HUHS Establishment for Initial
59
HUHS Product Registration That Passed Pre-Assessment
2.15 Agreement of the HUHS Establishment to the Declaration of Undertaking 62
2.16 Dropdown Menu Showing the License to Operate Number/s Issued to the
63
Applicant
2.17 Required Information on Product Source for Applicants with License to
64
Operate as HUHS Manufacturer
2.18 Required Information on Product Source for Applicants with License to
64
Operate as HUHS Trader
2.19 Procurement Process for Directly-Sourced HUHS Products 65
2.20 Procurement Process for Indirectly-Sourced HUHS Products 65
2.21 Dropdown Menu for Product Line / Type 66
2.22 Net Content Declaration for a HUHS Product Available in 10mL Sachet
69
and 50mL/100mL Tube
2.23 Net Content Declaration for the Varying Pack Sizes of the Two (2) Variants
69
of ABC Air Freshener
2.24 Declaration of Hazard Information for a GHS-Compliant HUHS Product
72
with Multiple Hazard Classifications
2.25 Declaration of Hazard Information for Non-GHS Compliant HUHS Product 73
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Guide Manual for the HUHS Industry – Initial Product Registration
TABLE OF
CONTENTS
Disclaimer 2
Revision History 3
Definitions and Abbreviations 4
List of Tables 7
List of Figures 8
I. Introduction, Scope and Applications 10
II. Initial Registration of HUHS Products 12
General Guidelines on Securing an Initial Certificate of Product Registration for 13
HUHS Products
Information on the Technical Requirements 22
A. Product Formulation 22
B. Globally Harmonized System of Classification and Labeling of Chemicals 23
C. Certificate of Analysis 32
D. Claim Substantiation 34
E. HUHS Product Labeling and Packaging 38
FDA Electronic Portal V2.0 System 51
A. Introduction to FDA Electronic Portal V2.0 51
B. Navigating FDA Electronic Portal V2.0 53
Initial HUHS Product Registration in FDA Electronic Portal V2.0 System 56
A. Initial HUHS Product Registration Process 56
B. Initial HUHS Product Registration Application Form 61
III. Annexes 80
Annex A Self-Assessment Checklist for Initial HUHS Product Registration 81
References 93
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Guide Manual for the HUHS Industry – Initial Product Registration
I. INTRODUCTION, SCOPE
AND APPLICATIONS
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Guide Manual for the HUHS Industry – Initial Product Registration
Introduction
In 2019, the Secretary of Health signed Administrative Order (AO) No. 2019-0019, effectively
repealing AO No. 2015-0038 and instructing the Food and Drug Administration (FDA) to issue
the rules and regulations that would implement the reinstated licensing and registration
requirements for Household/Urban Hazardous Substances (HUHS) establishments and
products, respectively. A year later, in 2020, the FDA released the guidelines for the licensing
and inspection of HUHS establishments as well as the guidelines for the registration of HUHS
products through FDA Circular (FC) No. 2020-025.
With the new regulatory framework in effect for HUHS, the Center for Cosmetics and
Household/Urban Hazardous Substances Regulation and Research (CCHUHSRR) has seen
it fit to prepare a series of guidance documents discussing the FDA’s regulatory requirements
for HUHS. This particular guidance document, Guide Manual for the HUHS Industry – Initial
Product Registration, focuses on the FDA’s technical and documentary requirements for
initial registration of HUHS products as well as the procedural guidelines to secure said
marketing authorization.
Scope
The Guide Manual for the HUHS Industry – Initial Product Registration covers information
related to the initial registration of Categories III and IV HUHS products for consumer and
institutional use as defined and categorized in Republic Act No. 9711 and FC No. 2020-025,
respectively. It does not apply to other HUHS product categories (e.g., Categories I, II or V)
and products for industrial use nor does it discuss the licensing of HUHS establishments as
well as FDA’s post-registration requirements for HUHS.
Applications
The Guide Manual for the HUHS Industry – Initial Product Registration contains detailed
information on HUHS product registration that is aimed to provide the HUHS industry with the
necessary support as they fulfill their regulatory obligations to register their HUHS products.
The instructions provided in this document have been simplified as much as possible and have
been designed to be clear, comprehensible and easy to follow, ensuring that the readers can
make full use of the guidance document as they prepare their initial HUHS product registration
applications in accordance with the FDA’s requirements and standards.
The Guide Manual is a working document based on FDA’s existing laws, rules and regulations
on HUHS and is subject to revisions, as necessary, following future updates and amendments
to these laws, rules and regulations.
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Guide Manual for the HUHS Industry – Initial Product Registration
However, note that by virtue of FC No. 2021-011-A, a transitory period on the mandatory
HUHS product registration is in effect until 31 December 2023. During this time, HUHS
establishments are allowed to continue distributing their HUHS products not yet
registered with the FDA nor fully compliant with its standards and requirements. Starting
01 January 2024, a CPR shall be mandatory for all HUHS products.
For initial HUHS product registration purposes, notations discussing the special
considerations given to the HUHS industry during the transitory period are found in
certain parts of this guide manual for the industry’s reference.
(2) Item 6, Section IV (General Guidelines) of FC No. 2020-025 states that only FDA-
licensed HUHS establishments shall be allowed to apply for a CPR. More particularly,
only FDA-licensed HUHS establishments who own the product and product
formulation in the local setting are allowed to submit initial HUHS product registration
applications. These include the:
(a) FDA-licensed HUHS Manufacturers,
(b) FDA-licensed HUHS Traders, and
(c) FDA-licensed HUHS Distributor-Importers.
(3) The registration guidelines provided in FC No. 2020-025 only applies to Categories III
(Cleaners, Fresheners and Deodorizers) and IV (Do-It-Yourself and Hobby Items)
HUHS products intended for consumer and institutional use.
HUHS products intended for consumer and institutional use are those that are used in
places of human habitation, work and recreation. Examples of such products are those
used in homes including pools, dormitories, office, restaurants, cars, schools, malls,
condominiums, hospitals, among others.
It shall NOT apply to Categories II (Yard and Home Products) and V (Toys and Childcare
Article Products) HUHS products, the licensing and registration/notification of which are
covered by existing FDA guidelines and procedures specific for such HUHS product
categories, nor will it apply to Category I (Novel HUHS Products) HUHS products whose
product list includes the Vapor Products and Heated Tobacco Products currently
regulated by the Department of Trade and Industry (DTI) pursuant to Republic Act No.
11900.
The registration requirements contained in FC No. 2020-025 shall also NOT apply to the
following:
(a) HUHS products intended for donation;
(b) HUHS products imported for personal use;
(c) HUHS products intended for exhibit purposes;
(d) products intended exclusively for industrial use;
(e) products intended exclusively for use in agricultural setting;
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Guide Manual for the HUHS Industry – Initial Product Registration
(f) products intended for other health-related/medical-related use covered by the other
Centers of the FDA (e.g. disinfectant products under the jurisdiction of Center for
Device Regulation, Radiation Health and Research);
(g) products directly applied on animals or pets; and
(h) raw materials used in the manufacture of HUHS products.
An illustrative list of Categories III and IV HUHS products subject to FDA’s regulatory
requirements under FC No. 2020-025 are provided in Tables 2.1 and 2.2, respectively.
Readers may also access the illustrative list of HUHS products by category from this link:
https://www.fda.gov.ph/wp-content/uploads/2021/04/HUHS-Product-Listing-2.pdf.
Note that these illustrative HUHS product lists are non-exhaustive. Other products not
included in the lists may still be subject to FDA’s registration requirements under FC No.
2020-025. HUHS establishments are referred to the decision matrix provided in Figure
2.1 to assist in identifying Categories III and IV HUHS products regulated under FC No.
2020-025.
In cases wherein the illustrative HUHS product lists found in Tables 2.1 and 2.2, and the
decision matrix in Figure 2.1 are not sufficient to determine whether a product is regulated
under FC No. 2020-025, HUHS establishment may inquire with the CCHUHSRR via
landline (+63 2 8 857 1900 local 8113/8107) or email (cchuhsrr.lrd.huhs@fda.gov.ph).
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Guide Manual for the HUHS Industry – Initial Product Registration
Table 2.1 Illustrative List of Category III HUHS Product (Cleaners, Fresheners and
Deodorizers)
Chlorine Bleach
Oxygen Bleach
Bleaching Powder
Bleaches
Solid Bleach
Bleaching Textiles and Fur
Household Laundering and Sanitizing
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Guide Manual for the HUHS Industry – Initial Product Registration
Table 2.2 Illustrative List of Category IV HUHS Products (Do-It-Yourself and Hobby
Items)
Contact Cement
Adhesives, Glues and Sealants
Sealants General Purpose Adhesives (households, floor, tiles,
surfaces)
Cleaners
Automotive, Furniture
Shampoo
and Jewelry Care, and
Waxes
Restoring Products
Jewelry Restoring Products
Crayons
Coloring Materials
Watercolors
Fabric Dyes
Fabric Dyes, Tattoo Dyes
Synthetic Fabric and Tattoo Dyes
Paint Stripper
Paint Stripper
Paint Remover
Chemical Removers
Rust
Rust Converters
Remover/Degreasers
Chelating Agents
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Guide Manual for the HUHS Industry – Initial Product Registration
Figure 2.1 Decision Matrix to Identify Categories III and IV HUHS Products Regulated
Under FDA Circular No. 2020-025
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Guide Manual for the HUHS Industry – Initial Product Registration
(4) Categories III and IV HUHS products are further classified as either:
(a) Ready-to-Use, which refers to HUHS products that are ready to be used outright of
the packaging and for general purposes, which require no further dilution prior to
application. This term also refers to HUHS products that are diluted before use whose
application are NOT restricted to trained personnel or professionals.
(b) For Professional Use, which refers to HUHS products that are highly concentrated
requiring further dilution and are restricted only to be applied by trained personnel.
(5) HUHS products bearing brand and product names that are identical to those already
registered with FDA as HUHS, and/or which are offensive, obscene, scandalous or
otherwise contrary to public morals and policy are NOT allowed in accordance with AO
No. 2005-0016.
Hence, no two (2) HUHS products bearing the same brand and product name but
having different formulations are allowed to be registered at the same time nor is
an HUHS product allowed to be registered by two (2) different HUHS
establishments.
(6) The hazards of the HUHS product must be classified based on the Globally Harmonized
System of Classification and Labeling of Chemicals (GHS).
Because of the highly hazardous nature of chemicals classified as GHS Category 1 in any
physical, health or environmental hazard class, HUHS products classified as such require
proof of product safety under normal conditions of use during their initial product
registration. For more information on the documents that may be submitted to substantiate
product safety under normal conditions of use, proceed to the Claim Substantiation
section of this guide manual.
(7) Products having multiple uses regulated by FDA and other National Regulatory Agency
(i.e. Fertilizer and Pesticide Authority) must be registered with both regulatory authorities.
An example of such multiple-use product having other non-HUHS uses regulated by
another National Regulatory Agency are surface disinfectants also intended to be used in
agricultural setting.
(8) HUHS products must only have claims that are within the definition, scope and
intended use of HUHS. Non-HUHS claims and intended use including but not limited to
cosmetic, agricultural and industrial use are not allowed.
For HUHS products bearing additional household pesticide claims, these shall be
registered following the guidelines set forth in AO No. 2019-0008 and its future
amendments.
(9) HUHS products must be registered on a per formulation basis. HUHS products intended
to be marketed in multiple pack sizes and/or packaging materials (i.e. 10mL Sachet as
well as 150mL, 500mL and 1000mL HDPE Bottle) may be registered together in a single
initial HUHS product registration application, provided that all pack sizes and/or packaging
materials are declared in the application.
(10) HUHS products which have the same base formulation but differ in the fragrance and/or
colorant/s used are considered as variants and may be registered together in a single
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Guide Manual for the HUHS Industry – Initial Product Registration
initial HUHS product registration application, provided that all variants of the HUHS
products and their formulations are declared in the application. The initial HUHS product
registration application platform in FDA Electronic Portal V2.0 system (e-Portal 2)
accommodates up to a maximum of five (5) variants per application.
(11) HUHS products that have been banned or withdrawn in the country of
origin/source/manufacture are NOT allowed to be registered with FDA nor are they
allowed to enter the Philippine border.
(12) Applications for HUHS product registration are submitted through e-Portal 2 accessible at
https://eportal2.fda.gov.ph following the registration procedure provided in FC No. 2023-
006 and detailed in the Initial HUHS Product Registration in FDA Electronic Portal V2.0
System section of this guide manual.
(13) Applications for initial HUHS product registration must be accompanied by the following
documentary requirements as provided in Annex E of FC No. 2020-025:
(a) Declaration and Oath of Undertaking (embedded in the online application platform)
(b) Accomplished Application Form (embedded in the online application platform)
(c) Safety Data Sheet (SDS) of the HUHS Product (in GHS format)
(d) Certificate of Analysis (COA) of the Finished Product
(e) Documentation to substantiate product claims that are within the scope of HUHS, if
applicable
(f) Clear and complete loose labels or artworks of all packaging sizes, as applicable, in
Filipino or English language (in .png format)
(g) Pictures of the product in all angles and in different packaging sizes, allowing visual
recognition of a product similar to the one being registered
(h) Payment of fees
The current schedule of fees for HUHS product registration is based on AO No. 50 s.
2001, subject to a Legal Research Fund (LRF) of 1% of the computed fee or Php 10.00
whichever is higher, and is listed in Table 2.3.
Table 2.3 Schedule of Fees for Initial HUHS Product Registration Depending on the
Number of Years of CPR Validity Applied For
Years of CPR Validity Fees and Charges LRF
(14) Depending on the evaluation of the submitted application, the final result of an initial HUHS
product registration application may either be approved or disapproved.
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For initial HUHS product registration applications that have NOT satisfactorily complied
with all applicable FDA requirements and standards, a Letter of Disapproval (LOD) is
issued. Pursuant to FC No. 2020-025, the following instances are grounds for the
disapproval of an initial HUHS product registration application:
(a) The application requirements show that the establishment does not meet the required
technical requirements or appropriate standards;
(b) The applicant made misrepresentations, false entries, or withheld any relevant data
contrary to the provisions of the law, existing FDA rules and regulations, or appropriate
standards;
(c) The holder or owner has violated any of the terms and conditions of its license,
registration or authorization;
(d) The label of the health product is false and misleading or does not conform with current
labeling requirements;
(e) Such other analogous grounds or causes as determined by the FDA.
(15) Variation in the circumstances of a registered HUHS product involving changes in the
address of the manufacturer and/or product formulation requires an initial HUHS product
registration application.
(16) FDA regulations on HUHS extend beyond securing the appropriate marketing
authorization for HUHS products intended to be placed in the market. Marketing
Authorization Holders (MAH) are responsible for the continued compliance of their
registered HUHS products with existing FDA laws, rules, regulations and applicable
adopted standards as well as in ensuring the safety, efficacy and quality of their HUHS
products. The list of adopted standards for HUHS products are found in Table 2.4 and
Annex G of FC 2020-025. For more information on the post-registration
obligations/responsibilities of MAH, readers are referred to FC No. 2020-025.
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Guide Manual for the HUHS Industry – Initial Product Registration
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Guide Manual for the HUHS Industry – Initial Product Registration
(2) HUHS products are generally not allowed to contain any carcinogenic, mutagenic,
reprotoxic (CMR) ingredients. However, since CMRs, according to the GHS, are classified
into multiple hazard categories depending on the strength of available evidence and
application of weight of evidence approach, and in consideration of the fact that there are
instances wherein the use of a CMR ingredient in a HUHS product is sufficiently proven
to be safe and without undue health risks, HUHS products containing CMR ingredient/s
may be allowed to be registered without additional documentary requirements, provided
that the:
(a) CMR ingredient/s does not exceed the cut-off value/concentration limit specified in
their respective GHS hazard class chapters that would trigger the classification of the
HUHS product as GHS CMR Category 1, and
(b) HUHS product is not classified as GHS CMR Category 1A/B.
Should the HUHS product be classified as GHS CMR Category 1A/B based on available
test data on the product itself or based on the presence of GHS CMR 1A/B ingredients in
concentrations exceeding the specific cut-off value/concentration limit, proof of product
safety under normal conditions of use (i.e. risk assessment) must be submitted as part of
the initial HUHS product registration application. Particularly for HUHS products classified
as GHS Carcinogenic Category 1A/B based on available test data on the product itself or
based on the presence of GHS Carcinogenic Category 1A/B ingredients in concentrations
beyond the GHS cut-off value/concentration limit, proof of product safety must show
negligible carcinogenic risk to exposed population (i.e. Excess Lifetime Cancer Risk = 10-
6
).
HUHS industry may use the following international databases as sources of information
as to a chemical’s GHS hazard classification:
(a) European Chemicals Agency C&L Inventory
(b) ECHA Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
(c) Japan National Institute of Technology and Evaluation
(d) International Agency for Research on Cancer (IARC) Monographs for carcinogens
Because the classification of carcinogenic chemicals under IARC is different from the
one used in GHS, Table 2.5 contains the IARC and GHS equivalency table for
carcinogens.
Table 2.5 Classification of Carcinogens Under IARC and their Equivalents in GHS
IARC GHS
Group 1 – Carcinogenic to Humans Category 1A
Group 2A – Probably Carcinogenic to Humans Category 1B
Group 2B – Possibly Carcinogenic to Humans Category 2
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Guide Manual for the HUHS Industry – Initial Product Registration
(3) The use of restricted ingredients in HUHS products must comply with the set restrictions
or conditions of use. Restricted ingredients are found in the following:
(a) Annex XVII to REACH Regulation
(b) ACD Annex III and VI (applicable only for HUHS products with skin exposure under
normal conditions of use)
(4) HUHS products containing GHS Category 1 chemicals/ingredients in any health hazard
class other than those listed in Item (2) or in any environmental hazard class in
concentrations that would trigger the classification of the finished product as GHS
Category 1 are not allowed to be registered, unless proof of product safety under normal
conditions of use can be provided. For documents that may be submitted to substantiate
product safety under normal conditions of use, proceed to the Claim Substantiation section
of this guide manual.
GHS is an international system that harmonizes hazard classification and the communication
of such hazards. As seen in Figure 2.2, it is a logical and comprehensive approach to:
(1) defining the physical, health and environmental hazards of chemicals;
(2) applying agreed hazard criteria to classify chemicals based on their hazardous effects;
and
(3) communicating hazard information on labels and SDS.
GHS has been developed in order to improve chemical safety and health through the provision
of consistent and comprehensive information on the hazards of chemicals based on a
harmonized classification criteria and appropriate protective measures through hazard
communication tools such as labels and SDS.
At present, the Center, together with other GHS-implementing regulatory agencies, is adopting
the 8th revised edition of the GHS Purple Book for implementation. Readers may access a copy
of the 8th revised edition of the GHS Purple Book through the following links:
https://unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev08/ST-SG-AC10-30-
Rev8e.pdf
https://www.fda.gov.ph/wp-content/uploads/2022/04/Globally-Harmonized-System-of-
Classification-and-Labelling-of-Chemicals-GHS-8th-rev.-ed..pdf
The GHS Purple Book is divided into the following four (4) parts:
(1) Part 1: Introduction - outlines the purpose, scope and application of GHS as well as
provides the definition of terms and general information on hazard classification and
communication including labeling and SDS
(2) Part 2: Physical Hazards – chapters containing the different physical hazard classes
(3) Part 3: Health Hazards – chapters containing the different health hazard classes
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(4) Part 4: Environmental Hazards – chapters containing the different environmental hazard
classes
Under the GHS, there are three (3) main group of hazards - Physical, Health and
Environmental hazards. Within each hazard group, there are a number of hazard classes.
Hazard class is the nature of the physical, health or environmental hazard. Table 2.6 lists the
twenty-nine (29) hazard classes in GHS.
Table 2.6 Different Hazard Classes Under Physical, Health and Environmental Hazard
According to the Globally Harmonized System of Classification and Labeling of
Chemicals
Hazard Classes Under Hazard Classes Under Hazard Classes Under
Physical Hazard (17) Health Hazard (10) Environmental Hazard (2)
Explosives Acute Toxicity Hazardous to the
Flammable Gases (Oral/Dermal Aquatic Environment
Aerosols and Chemicals /Inhalation) (Acute/Chronic)
Under Pressure Skin Hazardous to the
Oxidizing Gases Corrosion/Irritation Ozone Layer
Gases Under Pressure Serious Eye
Flammable Liquids Damage/Eye Irritation
Flammable Solids Respiratory or Skin
Self-Reactive Substances Sensitization
and Mixtures Germ Cell
Pyrophoric Liquids Mutagenicity
Pyrophoric Solids Carcinogenicity
Self-Heating Substances Reproductive Toxicity
and Mixtures Specific Target Organ
Substances which, in Toxicity - Single
contact with water, emit Exposure
flammable gases Specific Target Organ
Oxidizing Liquids Toxicity - Repeated
Oxidizing Solids Exposure
Organic Peroxides Aspiration Hazard
Corrosive to Metals
Desensitized explosives
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Hazard classes are then divided into hazard categories. A hazard category is the division of
the criteria within a hazard class meant to be an indication of the degree of severity. As an
illustration, Table 2.7 presents the five (5) hazard categories of Acute Toxicity
(Oral/Dermal/Inhalation) based on the division of the hazard criteria which is the Acute Toxicity
Estimate (ATE).
Table 2.7 Hazard Criteria for GHS Acute Toxicity (Oral/Dermal/Inhalation) and Its Five (5)
Hazard Categories (Adapted from Table 3.1.1 of the 8th Revised Edition of the GHS)
Exposure Route Category 1 Category 2 Category 3 Category 4 Category 5
Oral (mg/kg
ATE ≤ 5 5 < ATE ≤ 50 50 < ATE ≤ 300 300 < ATE ≤ 2000
bodyweight) 2000 < ATE
≤ 5000
Dermal (mg/kg
ATE ≤ 50 50 < ATE ≤ 200 200 < ATE ≤ 1000 1000 < ATE ≤ 2000
bodyweight)
Gases (ppmV) ATE ≤ 100 100 < ATE ≤ 500 500 < ATE ≤ 2500 2500 < ATE ≤ 20000
Vapours (mg/l) ATE ≤ 0.5 0.5 < ATE ≤ 2.0 2.0 < ATE ≤ 10.0 10.0 < ATE ≤ 20.0
Table 2.8 Hazard Criteria for GHS Skin Corrosion/Irritation Category 1 and Its
Subcategories (Table 3.2.1 of the 8th Revised Edition of the GHS)
Criteria
Destruction of skin tissue, namely, visible necrosis through the
Category 1 epidermis and into the dermis, in at least one tested animal after
exposure ≤ 4 h
Corrosive responses in at least one animal following exposure ≤ 3
Sub-category 1A
min during an observation period ≤ 1h
Corrosive responses in at least one animal following exposure > 3
Sub-category 1B
min and ≤ 1 h and observations ≤ 14 days
Corrosive responses in at least one animal after exposures > 1 h and
Sub-category 1C
≤ 4 h and observations ≤ 14 days
However, it should be noted that not all GHS hazard classes are divided into hazard categories.
In some physical hazard classes, instead of hazard categories, terms such as groups (i.e.
Gases under Pressure) and types (i.e. Self-reactive Substances and Mixtures) are used to
differentiate within a hazard class.
To aid the HUHS establishment in the classification of their HUHS products according to GHS,
a decision logic is incorporated into each of the hazard class chapter in the GHS Purple Book.
A decision logic is a graphical display of the classification process for a particular hazard
class that aims to assist in hazard classification by ensuring that all steps of the classification
process are followed. Hence, the HUHS establishment, in the classification of their HUHS
products, are advised to refer to these decision logics.
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Figure 2.3 presents GHS Decision Logic 2.6 for flammable liquids. After determining the flash
point and initial boiling point of a chemical, the chemical can be classified for GHS Flammable
Liquid using Decision Logic 2.6.
Figure 2.3 Decision Logic for GHS Flammable Liquid (Decision Logic
2.6 from the 8th Revised Edition of the GHS). The first step in the
classification process is to determine whether a chemical is a liquid. If the
answer is yes, proceed to the 2nd step - determining whether the chemical
has a flash point of ≤ 93°C. If the answer is no, the chemical is not classified
as GHS Flammable Liquid. If the answer is yes, proceed to the 3rd step –
determining whether the chemical has a flash point > 60°C. If the answer is
yes, the chemical is classified as GHS Flammable Liquid Category 4. If the
answer is no, proceed to the next step. The classifier goes through all the
steps in the decision logic until a final GHS classification for Flammable
Liquid is reached.
In the classification of chemical mixtures, where test data is available for the mixture itself,
classification will always be based on such test data. For physical hazard classes, chemical
mixtures are classified the same way a chemical substance is classified – through testing. GHS
has identified appropriate test methods that should be used to obtain relevant data needed for
classification. For health and environmental hazard classes, on the other hand, the GHS is test
method neutral, provided that tests are conducted according to internationally recognized
scientific principles.
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Where test data on the chemical mixture is not available, the GHS classification process allows
the use of available information on a similar tested mixture for certain hazard classes. This is
called bridging principle. GHS bridging principles includes dilution, batching, concentration
of highly toxic mixtures, interpolation within one toxic category, substantially similar mixtures
and aerosols. Hazard classes that allow the use of bridging principles to classify a chemical
mixture will have a section in their respective chapters in the GHS Purple Book dedicated to
bridging principles.
Where test data on the chemical mixture itself or a similar mixture are not available, the GHS
classification process allows the use of available information on the individual ingredients to
classify a chemical mixture for certain hazard classes. This is based on the general premise
that the less amount of a hazardous substance present in a chemical mixture, the less likely
the chemical mixture is going to pose a particular hazardous effect. Under the GHS, there are
three (3) types of calculations whereby a chemical mixture can be classified based on known
ingredient information:
(1) Cut-off value or concentration limit, where a chemical mixture is classified or meets the
hazard criteria for classification if the concentration of at least one ingredient having a
certain hazard category exceeds a set cut-off value or concentration limit (i.e.
Carcinogenicity)
(2) Summation method (based on the theory of additivity), where a mixture is classified
or meets the hazard criteria for classification if the total sum concentration of the
ingredients having a certain hazard category exceeds a threshold classification cut-off
value (i.e. Skin Corrosion/Irritation)
(3) Proportional calculation, where the toxicity of the mixture is calculated using the toxicity
of each ingredient and their respective concentration in the mixture
When classifying chemical mixtures based on known information of its individual ingredients
using summation or proportional calculation, care must be taken in determining the relevant
ingredients. Applicants are advised to refer to the respective hazard class chapters in the
GHS Purple Book for a detailed discussion on the relevant ingredients that must be taken into
consideration when classifying a chemical mixture using known information on its individual
ingredients.
The GHS hazard communication aims to provide consistent and comprehensive hazard
information and appropriate protective measures to end-users. The hazard communication
tools in GHS include the label and SDS.
Label
Annex J of FC No. 2020-025 incorporates the three (3) GHS label elements into the minimum
mandatory information that must be printed on the label of HUHS products not intended for the
use of children – signal word, pictogram/s and hazard statement/s. These GHS label elements
must be located together in the label consistent with the provisions of the GHS.
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Guide Manual for the HUHS Industry – Initial Product Registration
(2) signal word, which is a word used to indicate the relative level of severity of a hazard and
alert the end-users to a potential hazard. GHS uses Danger and Warning as signal words.
(3) hazard statement, which are statements assigned to a particular hazard class and
category that describe the nature of the chemical hazard, including, where appropriate, the
degree of hazard. Section 1 of GHS Annex 3 lists the different hazard statements, their codes
and the hazard class and category where they are assigned.
Table 2.9 GHS Pictograms and Their Corresponding Codes and Names (Table A3.4.1
from the 8th Revised Edition of the GHS)
GHS02 Flame
GHS05 Corrosion
GHS09 Environment
Once a chemical has been classified into a specific hazard category, the appropriate GHS
label elements can be determined as each hazard category is assigned its own signal word,
pictogram and hazard statement.
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Guide Manual for the HUHS Industry – Initial Product Registration
However, classification in multiple hazard classes can occur for chemicals particularly for
mixtures due to the presence of different chemical substances having their own intrinsic
hazardous properties. To determine the appropriate GHS label elements in such cases, the
GHS has set out rules of precedence in the allocation of hazard information. The following
arrangements shall apply, as applicable, in chemicals classified in multiple hazard classes:
In addition to the above rules of precedence in the allocation of hazard statements, Table
A3.1.2 in Annex 3 of the 8th revised edition of GHS includes specific combinations of hazard
statements that may be used.
SDS is a document compiled by the chemical supplier that provides detailed information on
the chemical including its identity, chemical composition, physical characteristics, hazard
classification, (eco) toxicological information and measures for safe handling, storage and
disposal as well as accidental release and personal protection measures, among others.
Under the current regulatory guidelines of the FDA, an SDS is required for all HUHS products.
For HUHS products with multiple variants, applicants may opt to prepare only one (1) SDS,
provided that all the variants covered by said SDS are clearly identified and that the information
contained within the document applies to all the variants.
In the preparation of the SDS, the minimum information required by GHS must be presented
under the relevant heading/section (n=16), where applicable and available, in the order
provided in Table 2.10. The SDS should not contain any blank space; where information is not
available or lacking, this should be clearly stated. For a detailed guide on SDS preparation,
readers are advised to refer to Chapter 1.5 and Annex 4 of the 8th revised edition of the GHS.
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Table 2.10. Minimum Information for Safety Data Sheets (SDS) (Adapted from Table 1.5.2
of the 8th Revised Edition of GHS
SECTION CONTENT
1 Identification of
the a. GHS product identifier
Substances or b. Other means of identification
Mixture and of c. Recommended use of the chemical and restrictions on use
the Supplier d. Supplier’s details (including name, address, phone number, etc.)
e. Emergency phone number
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For initial registration purposes, applicants may submit one (1) COA for HUHS products with
multiple packaging presentation and/or size. However, for HUHS products with multiple
variants, one (1) COA for each declared variant shall be submitted. All COAs must reflect the
following minimum information:
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Guide Manual for the HUHS Industry – Initial Product Registration
(1) Brand and product name including the variant name, if any
(2) Batch/lot/SKU/Item no., manufacturing date, expiration date or date of analysis
(3) Name and/or logo of the company that conducted the tests (may be the product
manufacturer or a third-party laboratory)
(4) Name and signature of the laboratory analyst
(5) Name and signature of the laboratory manager or quality assurance (QA)
(6) Technical specifications of the HUHS product
(7) Actual Test Results, which must be in numerical values for quantitative tests
An example of an acceptable COA is presented in Figure 2.4. However, note that special
considerations are given to the following COAs and are accepted for initial registration
purposes:
(1) electronically-generated COA without the signatures of the laboratory analyst and manager,
provided that the document has been proven to be valid without the signatures, and
(2) COAs without the name and signature of the laboratory analyst, provided that a document
showing proof of adherence to written procedure has been submitted.
CERTIFICATE OF ANALYSIS
Remarks: PASSED
Analyzed by:
Checked by:
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D. Claim Substantiation
Annex E of FC No. 2020-025 lists the documentary requirements that must be part of an initial
HUHS product registration application, one of which is the documentation to substantiate
product claims that are within the scope of HUHS. Hence, HUHS products for registration are
not allowed to have claims that are beyond the definition, scope and intended use of HUHS
and which are not adequately substantiated.
It should be noted that the HUHS establishment or applicant is responsible for ensuring that
the submitted substantiation documents are relevant, appropriate and sufficient to support the
HUHS product claim.
Table 2.11 lists a number of HUHS product claims and the corresponding supporting
documents deemed acceptable to substantiate said claim.
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Table 2.11 Examples of HUHS Product Claims and the Documents Acceptable to Support Said Claims
HUHS Claim Acceptable Substantiation Document
(1) Claims against bacteria, Qualitative claim except viricidal claims (i.e. kills bacteria and fungi):
fungi and virus (a) Peer-reviewed journals on the properties of the active ingredient/s or a similarly formulated HUHS product,
taking into consideration the percent (%) concentration of the active ingredient/s, target organisms and the
exposure time.
(b) Reports of laboratory tests conducted on the HUHS product or a similarly formulated HUHS product (i.e.
variants of the HUHS product) in accordance with internationally accepted standard references or validated test
method, taking into consideration the recommended dilution rate, if any, target organisms and exposure time.
Quantitative claims (i.e. kills 99.99% bacteria) and qualitative claims of viricidal activity (i.e. antiviral
activity against SARS-CoV-2):
(a) Reports of laboratory tests conducted on the HUHS product or a similarly formulated HUHS product (i.e.
variants of the HUHS product) in accordance with internationally accepted standards or validated test method,
taking into consideration the recommended dilution rate, if any, target organisms and exposure time. If available
test data of a similarly formulated HUHS product is used to substantiate a quantitative claim, justification for the
bridging of data must be submitted.
An example of an internationally accepted standard is the US EPA Product Performance Test Guidelines OCSPP
810.2200 Disinfectants for Use on Environmental Surfaces Guidance for Efficacy Testing. According to the
standard, the following microorganisms are used during efficacy testing depending on the HUHS product claim:
Bacteria Representative Gram Positive (Staphylococcus aureus)
Representative Gram Negative (Salmonella enterica or Pseudomonas aeruginosa)
In case of claims against specific bacteria, the product shall be tested against the identified
bacteria.
Tuberculoidal Mycobacterium bovis
Fungus Trichophyton interdigitale
Virus Virus claimed on the label
Note: HUHS product claiming viricidal activity must identify on its label the specific virus
against which the product has been tested and proven to be effective.
For sporicidal claims, tests organisms that can be used in efficacy testing are Bacillus subtilis and Clostridium
sporogenes.
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(2) Product shelf-life (in Report of stability study conducted on the HUHS product. For HUHS products with multiple declared packaging
cases where there is an presentation / material and/or variants, one (1) stability study report must be submitted per packaging presentation
indication of an expiry / material and/or per variant. The submitted reports must indicate the following information:
date in any of the (a) Product Information (brand/product/variant name, batch/lot number, manufacturing date, packaging
submitted document or presentation / material, in case there are multiple packaging presentation / material)
on the HUHS product (b) test duration, environmental conditions under which the product has been stored and testing interval
itself) (c) technical specifications of the HUHS product
(d) test results (results for quantitative tests must be in numerical values)
(e) conclusion
(f) name and signature of the laboratory analyst and manager
To substantiate a claimed product shelf-life, the HUHS establishment may conduct an accelerated or a real-time
stability study. For real-time stability studies, these must be conducted locally or in an environment with similar
climatic conditions as the Philippines.
In selecting which type of study to conduct, the HUHS establishment must take into consideration their knowledge
of the HUHS product including but not limited to its physico-chemical properties, and determine whether the
extreme environmental conditions used in an accelerated stability study would be appropriate (i.e. will it negatively
affect the stability of the HUHS product) or would a real-time stability study be more suitable.
For accelerated stability study, the US EPA and FAO/WHO have used the following testing conditions which are
equivalent to 2-year shelf-life:
(a) 54 ± 2°C for 14 days
(b) 50 ± 2°C for 4 weeks
(c) 45 ± 2°C for 6 weeks
Note that during the transitory period provided in FC No. 2021-011-A, for initial product registration, HUHS
establishments are allowed to submit either a stability study report to substantiate the claimed product shelf-life or
a self-declaration of product shelf-life with a commitment to provide the complete stability data during CPR
renewal.
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(3) Product Safety Under GHS Category 1 in any physical hazard class as well as Skin Corrosion/Irritation and Serious Eye Damage/Eye Irritation
Normal Conditions of (a) Presence of appropriate GHS precautionary statements and sufficient instructions for safe handling, storage and
Use (for HUHS products disposal on the HUHS product label
classified as GHS (b) Use of child-resistant packaging
Category 1 in any (c) less severe GHS classification of diluted solution (in cases where dilution is required prior to use)
hazard class)
GHS Category 1 in any environmental hazard class
(a) Presence of appropriate GHS precautionary statements and sufficient instructions for safe handling, storage and
disposal on the HUHS product label
GHS Category 1 in any health hazard class other than Skin Corrosion/Irritation and Serious Eye Damage/Eye Irritation
(a) Risk Assessment prepared in accordance with internationally accepted references/guidelines (i.e. WHO Human
Health Risk Assessment Toolkit: Chemical Hazards)
(b) Exposure studies showing negligible direct/indirect human exposure to the HUHS product under normal conditions
of use.
(c) COA of the Raw Material of Concern, if the GHS Category 1 classification of the HUHS product is triggered by the
presence of GHS Category 1 contaminant in the raw material (i.e. 1,3-butadiene contaminant in Butane/Isobutane)
(d) IFRA certificate, if the fragrance material triggered the classification of the HUHS product as GHS Category 1
(4) Market-based claims or Reports of market surveys conducted including the methodology used; preferably conducted by 3rd party entities to
those related to the eliminate bias
popularity of the HUHS
product (i.e. No. 1
Brand)
(5) Comparative claims (i.e. Reports of comparative studies conducted including the methodology used; preferably conducted by 3 rd party entities to
cleans 2x more than the eliminate bias
old formula)
(6) Halal Certifications from accredited halal-certifying bodies
(7) Biodegradability Report of biodegradability tests conducted in accordance with internationally accepted standards (i.e. OECD Test
Guidelines 301 or 306)
(8) Plant-based, nature- Claims on the ingredient:
based, organic and such Certifications from the supplier of the raw material that the chemicals used in the production of the raw material is plant-
other similar claims based, organic and such other similar claim used.
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More particularly, HUHS products NOT intended for children’s use must bear labels that
contain the following information:
(a) Product Information
Brand and Product Name including the Variant Name, if any
Full Ingredient List (in chemical name)
Fragrance Materials – may be declared using its chemical name or as
“Fragrance”
Colorants – may be declared using its chemical name, CI number or FD&C
number
Botanical Ingredients – in its binomial nomenclature
Net Content
Batch/Lot/Item/SKU Number
Manufacturing Date / Expiry Date
Product Category (Indicate if “For Institutional Use” or “For Professional Use”)
(b) Directions for Use
(c) Handling, Storage and Disposal (include requirement for personal protective equipment
or PPE, if any)
(d) Particulars of the Company or MAH (Company Name, Complete Address and Contact
Information)
(e) Country of Manufacture
(f) Contact Information of the National/Regional Poison Center (Refer to Table 2.12 for the
contact information of the different poison centers in the Philippines)
(g) Hazard and Safety Information
Hazard Information (GHS Label Elements: Signal Word, Pictogram/s, Hazard
Statement/s)
GHS Precautionary Statements including the statement “Keep out of reach of
children”
Signs/Symptoms of Poisoning (if applicable)
First Aid Treatment / Medical Advice
For HUHS products intended for children’s use, on the other hand, the product labels
must reflect the following mandatory information:
(a) Product Information
Brand and Product Name including the Variant Name, if any
Full Ingredient List (in chemical name)
Fragrance Materials – may be declared using its chemical name or as
“Fragrance”
Colorants – may be declared using its chemical name, CI number or FD&C
number
Botanical Ingredients – in its binomial nomenclature
Net Content
Batch/Lot/Item/SKU Number
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Guide Manual for the HUHS Industry – Initial Product Registration
Table 2.12 List of the National and Regional Poison Centers in the Philippines and Their
Contact Information as Listed in Department of Health Department Circular No. 2020-0081
National Poison Control Center Contact Information
National Poison Management and Control Center,
Hotline: (02) 85241078
University of the Philippines - Philippine General
Globe: 09667189904
Hospital
Regional Poison Control Center
Baguio General Hospital and Medical Center (074) 6617910 loc 396
Poison Control Unit
(02) 89211212
East Avenue Medical Center
(02) 89280611 loc 707
Toxicology Referral and Training Center
09232711183
Rizal Medical Center (02) 88658400 loc 113
Poison Control Unit 09661783773
(045) 9632279
Jose B. Lingad Memorial General Hospital
09338746600
Poison Control Unit
09234117107
Batangas Medical Center 09218832633
Poison Control Center (043) 7408307 loc 1104
Bicol Medical Center 09165354692
Poison Control Unit 09480161575
Corazon Locsin Montelibano Memorial Regional
Hospital 09178694510
Biomarine and Toxicology Unit
Western Visayas Sanitarium 09194980443
Poison Control Unit
Vicente Sotto Memorial Medical Center 09228496542
Poison Control Center
Eastern Visayas Regional Medical Center (053) 8320308
Poison Control Center
Zamboanga City Medical Center (062) 9912934
Poison Control Center (062) 9920052
Northern Mindanao Medical Center (088) 7226263
Poison Control Center 09058855645
Southern Philippines Medical Center 09992250208
Poison Control and Treatment Institute (082) 2272731 loc 5065
For better illustration of HUHS product labels that are compliant with Annex J of FC No. 2020-
025, sample labeling materials are provided for HUHS product not intended for children’s use and
HUHS product intended for children’s use in Figures 2.5 and 2.6, respectively.
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Guide Manual for the HUHS Industry – Initial Product Registration
(a)
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Guide Manual for the HUHS Industry – Initial Product Registration
(b)
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Guide Manual for the HUHS Industry – Initial Product Registration
(c)
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Guide Manual for the HUHS Industry – Initial Product Registration
(d)
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Guide Manual for the HUHS Industry – Initial Product Registration
(e)
Figure 2.5 Sample Labeling Material for HUHS Products Not Intended for Children’s Use
Containing the Mandatory Label Information Prescribed in FDA Circular No. 2020-025
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Guide Manual for the HUHS Industry – Initial Product Registration
(a)
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(b)
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(c)
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Guide Manual for the HUHS Industry – Initial Product Registration
(d)
Figure 2.6 Sample Labeling Material for HUHS Products Intended for Children’s Use
Containing the Mandatory Label Information Prescribed in FDA Circular No. 2020-025
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Guide Manual for the HUHS Industry – Initial Product Registration
(2) The HUHS establishment must not use FDA in the promotion, advertisement, sponsorship,
marketing or commercial materials of its HUHS product. Hence, labels of HUHS products are
not allowed to bear the FDA logo, the words/initial “Food and Drug Administration”, “FDA”,
“Philippine FDA” or any imitation of such logo, words and initials in accordance with FDA
Memorandum Circular No. 2013-030.
(3) Labels of HUHS products and other information materials must not bear unsubstantiated
claims, misinformation or misleading information including those contained in brand names
or trademarks.
(4) Labels of HUHS products must not bear the words “safe”, “non-toxic”, “non-hazardous” or
other equivalent descriptive words or phrases or modifiers. Descriptive words, phrases or
modifiers considered equivalent to those expressly mentioned above include but are not
limited to “banayad sa kamay”, “hypoallergenic”, “gentle on skin/hand”, “mild”, “for sensitive
skin”, “recommended by pediatricians” and the unqualified use of the word “baby”.
(5) Labels of HUHS products must not be presented in a way that is attractive to children.
(6) HUHS products must be placed in suitable packaging, preferably in child-resistant packaging
material or containers, that will ensure protection of children from undue exposure, or their
labels must contain sufficient storage instructions so as not to be easily accessed by children.
For more information on the mandatory label information for HUHS products not intended for
children’s use, refer to Item (1) of this section.
(7) Labels of HUHS products must be in English or Filipino language and the information must
be legible, indelible and comprehensible.
(8) For imported HUHS products with labels not compliant with FC No. 2020-025, stickering and
overlabeling is allowed.
Stickering is allowed when the lacking information are only the particulars of the MAH
(company name, complete address, contact number) and the contact information of the
national/regional poison center. Stickering may be done by either the HUHS Distributor-
Importer that brought the product into the country or an FDA-licensed HUHS Repacker.
If information beyond those allowed to be stickered are missing from the label of the imported
HUHS product, overlabeling is allowed provided that the following conditions are met:
(a) the entirety of the old label is covered;
(b) written authorization from the product/formulation owner (i.e. foreign manufacturer) has
been secured; and
(c) an FDA-licensed HUHS Repacker conducts the overlabeling.
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In order for HUHS establishments to access and use the system, a request for user account
must be submitted to the CCHUHSRR. Here are the step-by-step instructions on how to secure
an e-Portal 2 user account:
(1) Go to bit.ly/ePortal2
(2) Accomplish the user’s registration form by providing all the required information as marked in
Figure 2.7.
(3) Attach proof of ownership which must be in PDF file format. Documents that may be submitted
as proof of ownership include:
(a) Certificate of Business Registration issued by the DTI
(b) Certificate of Registration issued by the Securities and Exchange Commission and
Articles of Incorporation
(c) Certificate of Registration issued by the Cooperative Development Authority and Articles
of Cooperation
(d) LTO issued by FDA for other product types
(e) Certificate of Registration issued by the Bureau of Internal Revenue
(4) After accomplishing the user’s registration form and attaching the required proof of ownership,
click “Submit”.
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Submitted requests for user accounts are processed by the CCHUHSRR within three (3) working
days upon receipt of request. User accounts are only created for HUHS establishments that have
submitted a complete and compliant user’s registration application. The user credentials
(username and password) are sent to the email address of the HUHS establishment provided in
the user’s registration form which is now the registered email address of the company. Initial
user accounts are only valid for one (1) year; requests for user account renewal must be made
via bit.ly/UserRenewal a month before the expiration of the account.
For user’s registration application that are found to be incomplete and/or non-compliant, a
notification email containing the deficiency/ies found in the request is sent to the registered email
address.
In case the HUHS establishment wishes to change its registered email address, an email request
must be sent to cchuhsrr.lrd.huhs@fda.gov.ph with the following information (Items 1 to 7) and
attachments (Items 8 to 9):
To aid HUHS establishments in securing their e-Portal 2 user accounts, walkthrough video
tutorials in English and Filipino have been prepared and can be accessed via the following links:
As holders of e-Portal 2 user accounts, HUHS establishments and their owners must always keep
in mind the following reminders:
(1) The responsibility for the security and integrity of its e-Portal 2 account rests solely with the
HUHS establishment and its owner. They must ensure that only authorized personnel have
access to the account given to the HUHS establishment.
(2) The e-Portal 2 account must always be used in accordance with existing laws, and FDA rules
and regulations. The FDA, at all times, reserves the right to suspend and cancel any e-Portal
2 user account found to be in violation of said laws, and FDA rules and regulations. The FDA
does not accept liability for any loss, damage or expenses resulting from negligence,
dereliction of duty/responsibility or violations of existing laws and FDA rules and regulations
that may be committed by the HUHS establishment in connection with the use of its e-Portal
2 user account.
(3) Only true, correct, up-to-date and complete information and documents must be uploaded to
the system and submitted to the CCHUHSRR.
(4) Documents uploaded to the system must meet the following specifications:
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Guide Manual for the HUHS Industry – Initial Product Registration
(a) Free from bugs, viruses, and the like that may compromise the FDA ICT infrastructure and
system;
(b) Scanned and saved in PDF file format at 100-150 dots-per-inch (dpi) with the exception of
required photos and loose label artwork of the HUHS product during registration, both of
which must be in PNG format;
(c) Must have a file size of 4 megabytes (mb) or less per document and a total file size of 20
mb per application; and
(d) With a filename that is composed of less than 40 characters in length and does not contain
the following characters: \ ? / : * “ > < I . ”
(1) Log-in
To access e-Portal 2, go to https://eportal2.fda.gov.ph and log in using the user credentials
(username and password) issued to the HUHS establishment.
a
b
Figure 2.8 Log-in Interface of FDA Electronic Portal V2.0 System. Log in by
entering the username (a) and password (b) issued by the CCHUHSRR to the
HUHS establishment.
(2) Homepage
Upon successful log-in, the e-Portal 2 homepage, as shown in Figure 2.9, automatically
appears, displaying the following features:
(a) Navigation Pane (proceed to the next item for more detailed information)
(b) Account Information, which displays the personal information of the account owner
when clicked
(c) Search and Filter Tools, which include:
Search Tab, which allows users to search for a specific application by typing in the
case number assigned to the application, establishment name or brand/product name
Filter Tools, which allows users to narrow the search parameter by category (i.e.
Licensing of Establishment, Product Registration, etc.) or type of process (i.e. e-
License to Operate, Household Urban Hazardous Substances Registration).
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Guide Manual for the HUHS Industry – Initial Product Registration
(a) New Application button, which allows users to create new case applications. For
HUHS, the different processes under which a new application may be created includes
e-License to Operate, both initial and variation application, and Household Urban
Hazardous Substances Registration (Initial Application)
(b) On Process folder, which serves as the account “inbox” for incoming applications
assigned to the user (i.e. applications routed to the HUHS establishment for compliance
as well as viewing of pre-assessment and evaluation results)
(c) Draft folder, which allows users to view all unfinished applications that have not yet been
submitted to the CCHUHSRR
(d) Processed folder, which serves as the “repository” of all applications created by the user
including drafts as well as ongoing and closed applications; this folder allows users to
view and check the status of their applications
Account Information
Search and
Filter Tools
Navigation Pane
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Guide Manual for the HUHS Industry – Initial Product Registration
(c) Application, which contains information on the type of application (i.e. Initial Application,
Variation) and the name of the product (for CPR application) or establishment (for License
to Operate application)
(d) Process, which contains information on the process under which the case application has
been created. For HUHS, the different processes under which a case application may be
created includes e-License to Operate, both initial and variation application, and
Household Urban Hazardous Substances Registration (Initial Application)
(e) Task, which contains information on the current status of the application (i.e. Initial
Application, Pre-Assessment Result, Payment Verification, Application Evaluation,
Application Checking, Final Decision, Download Result)
(f) Last Modified, which reflects the date when the application has been last opened
(g) Sent by (only found in the On Process folder), which contains information on the user who
delegated the case application to the current user
(h) Due Date (only found in the On Process and Draft folders), which reflects the estimated
“deadline” of the current task; this serves as a guide to all e-Portal 2 users as to the
application timeline
(i) Current User, (only found in the Processed folder), which reflects the user account where
the case application is currently assigned
Figure 2.11 shows the On Process folder displaying the different relevant information of a
case application.
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Guide Manual for the HUHS Industry – Initial Product Registration
Figure 2.12 Business Process Flow for the Initial Registration of HUHS Products. HUHS
establishment prepares the initial HUHS product registration application and submits it for pre-
assessment. Once the application passed the pre-assessment, the HUHS establishment and
FDA Cashier pays and posts the payment in the system, respectively, after which the application
undergoes evaluation. A final decision on the application is then rendered and the result of the
application is sent to the HUHS establishment. Not shown in this figure is the Notice of Deficiency
step during the transitory period pursuant to FDA Advisory No. 2021-3501.
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a c
Figure 2.13 Steps to Create a New Case Application for Initial HUHS Product
Registration. Create a new initial HUHS product registration application by sequentially
clicking (a) New Application, (b) Household Urban Hazardous Substances Registration (Initial
Application) and (c) Start Application, or simply double-click on (b) Household Urban
Hazardous Substances Registration (Initial Application).
(c) Prepare the initial HUHS product registration application. This step includes:
Reading through and consenting to the terms and conditions listed in the
Declaration of Undertaking.
Accomplishing the application form embedded in e-Portal 2 with the assistance of
the Application Wizard that will sequentially provide the different parts of the
application form to be filled-up. For a detailed discussion on how to correctly
accomplish the application form, proceed to the next section, Initial HUHS Product
Registration Application Form.
Upload all the documents required to support the initial HUHS product registration
application.
(d) Review the final draft of the initial HUHS product registration application before submitting
it to the CCHUHSRR. The Application Summary allows the applicant to review and
recheck the draft application including the uploaded documents. HUHS establishments
must ensure that all the declared information in the application form and in the uploaded
documents are complete, consistent and correct and that the application satisfactorily
complies with set FDA standards and requirements.
In case there is an error in the draft application form or the documents uploaded are
incomplete/incorrect, go back to the particular section of the application form where the
error occurred by clicking “Previous Steps” in the upper-left corner of the window and
then make the necessary changes/corrections.
(e) Submit the initial HUHS product registration application to the CCHUHSRR for pre-
assessment by clicking the “Next” button and then “Continue” once the draft application
has been deemed acceptable.
(2) Pre-Assessment
Pre-assessment filters out unacceptable applications by checking the submitted initial HUHS
product registration application for:
(a) Completeness of the required information and documentary requirements;
(b) Consistency of information in the application; and
(c) Correctness of information provided.
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Though the pre-assessment step has been incorporated into the initial product registration
process to filter out applications that do not meet the standards for consistency, correctness
and completeness, this merely intends to facilitate the evaluation of applications that have
been successfully lodged with the CCHUHSRR (i.e. applications with posted payment). It
remains to be the HUHS establishment’s sole responsibility to ensure that the applications
they submit meet the aforementioned standards.
Once the initial HUHS product registration application has been pre-assessed, the results are
automatically sent by the system to the registered email address of the HUHS establishment
(email notification). Results of pre-assessment may either be:
(a) Pre-Assessment Disapproval (tagged as INCOMPLETE)
A copy of the pre-assessment result may also be accessed in e-Portal 2. Go to the “On
Process” folder and double-click on the specific initial HUHS product registration
application. The system will then show the result of the pre-assessment containing the
reasons for the disapproval. Click “Next” to access the application summary and verify
the result of the pre-assessment. Once done, click “Next” and then “Finish” to end the
process.
Note that the disapproval of an initial HUHS product registration application during the
pre-assessment step does not preclude the HUHS establishment from submitting a new
application, provided that the deficiencies cited in the pre-assessment result have been
addressed prior to re-submission.
notification containing the Order of Payment, as shown in Figure 2.14, is sent to the
HUHS establishment while the application is automatically forwarded to the FDA Cashier
for posting of payment.
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(3) Payment
The Payment step involves actions from both the HUHS establishment and FDA Cashier.
The HUHS establishment pays the prescribed fees and charges indicated in the order of
payment via any of the following payment channels:
(a) BancNet
For more information on making payments through BancNet, refer to FDA Advisory No.
2015-021 accessible at https://www.fda.gov.ph/wp-content/uploads/2021/03/FDA-
Advisory-No.-2015-021.pdf.
(b) Over-the-counter in any branch of the Land Bank of the Philippines
For more information on how to pay over-the-counter in any branch of the Land Bank of
the Philippines, refer to Item B.6. (Payment Collection), Section IV (Guidelines) of FDA
Memorandum Circular No. 2013-038 available at https://www.fda.gov.ph/wp-
content/uploads/2021/08/FDA-Memorandum-Circular-No.2013-038.pdf.
For easy reference, the clearing account number for the Center for Cosmetics and
Household/Urban Hazardous Substances Regulation and Research is 0392-2220-06.
(c) Link.BizPortal e-payment facility of the Land Bank of the Philippines
For more information on how to use Link.BizPortal to make payments, proceed to
https://www.landbank.com/e-banking/other-e-banking-services/linkbizportal.
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The FDA Cashier then verifies the payment by posting the payment details in e-Portal 2. This
automatically advances the initial HUHS product registration application to the next step -
evaluation.
(4) Evaluation
This step involves the verification of the quality, safety and efficacy of the HUHS product
by evaluating the application’s satisfactory compliance with all applicable requirements and
standards in accordance with FC No. 2020-025. For initial HUHS product registration in e-
Portal 2, the evaluation step covers three (3) tasks – Application Evaluation, Application
Checking and Final Decision.
HUHS product registration applications that have satisfactorily complied with all applicable
requirements and standards are recommended for approval and issuance of CPR whereas
those that do not are recommended for disapproval and issuance of LOD.
Note that during the transitory period provided in FC No. 2021-011-A, a Notice of Deficiency
(NOD) may be issued once for initial HUHS product registration applications found to contain
minor deficiencies instead of outright disapproval pursuant to FDA Advisory No. 2021-3501
(proceed to Item 6).
Minor deficiencies are those that can be corrected or complied with through the submission
of additional supporting documents and does NOT require revision of the submitted
application form. These include but are not limited to:
(a) findings that require further clarifications from the HUHS establishment,
(b) insufficiently substantiated product claims,
(c) presence of unsubstantiated and/or safety claims on the existing product label
(d) minor errors in the submitted documents that will not affect the declared information in
the application form, and
(e) proposed label that is not compliant with Annex J of FC No. 2020-025.
Deficiencies that affect the declared information in the application form are not considered
as minor deficiencies. Instead, these are treated as major deficiencies based on the HUHS
establishment’s declaration and agreement at the start of the application process that all data
and information provided in the attached application are true, correct and based on existing
records, legal documents and available information.
(5) Result
Once a final decision has been rendered, an email notification is automatically sent to the
registered email address of the HUHS establishment containing an instruction on how to
access the result of the initial HUHS product registration application.
To access the result of the application in e-Portal 2, go to the “On Process” folder and
double-click on the specific application. The system will then show the application summary.
Click “Next Step” to view and download the issued document which may either be a CPR for
approved applications or LOD for disapproved ones. Once done, click “Next” and then
“Finish” to end the process.
To access the generated result again, go to the “Processed” folder and search for the
specific initial HUHS product registration application. Right-click on the application and select
“Summary” or click the “Summary” button ( ), then go to “Generated Documents” where a
copy of the CPR or LOD may be downloaded.
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Note that disapproval of initial HUHS product registration applications does not preclude the
HUHS establishment from submitting a new application, provided that the deficiencies noted
in the disapproved applications are addressed prior to re-submission.
(6) NOD
For initial HUHS product registration applications with minor deficiencies, the email
notification sent to the registered email address of the HUHS establishment serves as the
NOD which contains the list of deficiency/ies that must be addressed within fourteen (14)
calendar days. Failure to address all noted deficiencies within this timeline shall result to the
disapproval of the application.
To comply with the issued NOD, access the initial HUHS product registration application in
e-Portal 2. Go to the “On Process” folder and double-click on the specific application issued
with a NOD. Go through the application summary and evaluation notes by clicking “Next”
and then proceed to the part of the application process where documents are uploaded.
Upload the compliance documents and click “Next” and then “Submit” to return the
application to the CCHUHSRR for evaluation.
Submitted compliance documents are evaluated relative to the original initial HUHS product
registration application. Depending on whether these documents sufficiently address the
minor deficiencies noted in the application, an initial HUHS product registration application
may either be recommended for approval or disapproval (refer to Item 5).
HUHS establishments should note that regardless of whether compliance documents have
been uploaded into the e-Portal 2 system to address the minor deficiencies, initial HUHS
product registration applications are automatically reverted back to the CCHUHSRR once
the compliance period has lapsed.
Note that the applicant will not be able to access the initial HUHS product registration
application form unless it confirms its agreement to the Declaration of Undertaking by
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selecting “Yes, I Agree” as shown in Figure 2.15. Selecting “No, I Disagree” automatically
ends the application process.
Once agreement to the Declaration of Undertaking has been confirmed, the application
automatically proceeds to the initial HUHS product registration application form as provided by
the application wizard:
(1) Local Company Responsible for Placing the Product in the Market
As the HUHS establishment securing the marketing authorization for the HUHS product, the
applicant is recognized by the FDA as the local company responsible for placing the product
in the market and the MAH once the CPR has been issued.
In the 1st part of the application form, the applicant must provide relevant company
information including its owner, LTO number and validity, company name and address as
well as primary and secondary activities. As e-Portal 2 houses both the licensing and
registration processes of HUHS, applicants are only required to select from the dropdown
menu its valid LTO number as HUHS establishment (manufacturer, trader or distributor-
importer), after which the system automatically provides all other relevant information. Figure
2.16 shows the dropdown menu from which the appropriate valid LTO as HUHS
establishment of the applicant is selected.
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Figure 2.16 Dropdown Menu Showing the License to Operate Number/s Issued to
the Applicant. For the purpose of initial HUHS product registration, select the
appropriate License to Operate number of the HUHS establishment that corresponds
to the activity of the applicant relative to the HUHS product for registration.
If the applicant is not confident of its LTO number, the information may be verified against
the LTO issued by the FDA. Keep in mind that the declared type of establishment must
correspond to the intended activities of the applicant relative to the HUHS product for
registration. More particularly, indicate the establishment LTO as:
(a) HUHS Manufacturer, if the formulation of the HUHS product for registration is owned by
the applicant and it manufactures the HUHS product for registration;
(b) HUHS Trader, if the formulation of the HUHS product for registration is owned by the
applicant but the product is manufactured in the Philippines by an FDA-licensed HUHS
toll manufacturer; or
(c) HUHS Distributor-Importer, if the HUHS product for registration is imported by the
applicant from a foreign supplier/source.
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Figure 2.17 Required Information on Product Source for Applicants with License to
Operate as HUHS Manufacturer. The information on product source is automatically
provided by the FDA electronic portal V2.0 system for the HUHS manufacturer.
Figure 2.18 Required Information on Product Source for Applicants with License to
Operate as HUHS Trader. The valid license to operate number of the HUHS toll
manufacturer is the only information that must be provided; the rest of the required fields
are automatically filled-up by the system once the License to Operate number has been
provided.
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- Directly sourced, if the HUHS product for registration has been procured directly from
its (foreign) manufacturer as shown in Figure 2.19.
Foreign
Manufacturer Applicant
(Product Origin)
For directly-sourced HUHS product for registration, the following information must be
provided:
Country of Origin
Information on the (Foreign) Manufacturer (manufacturer’s name and
address)
- Indirectly sourced, if the HUHS product for registration has been procured from a
foreign supplier who is not the foreign manufacturer as show in Figure 2.20.
Foreign Foreign
Manufacturer Applicant
(Product Origin) Supplier
For indirectly sourced HUHS product for registration, the following information must
be provided:
Country of Origin
Information on the (Foreign) Manufacturer (manufacturer’s name and
address)
Information on the (Foreign) Supplier (supplier’s name and address)
Note that applicants may only declare one (1) product source per initial HUHS product
registration application. Thus, for an HUHS product with multiple product sources, an initial
HUHS product registration application must be submitted by the applicant for each product
source.
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For applicants that are licensed HUHS manufacturers, the dropdown menu will only
contain the product lines / types that have been declared during the LTO application. In
case the HUHS product for registration does not fall within any of the product lines / types
found in the dropdown menu, the HUHS manufacturer must first amend its LTO via an
application for LTO variation to include the specific product line / type in its license.
Figure 2.21 Dropdown Menu for Product Line / Type. Select the product line / type
that corresponds to the HUHS product for registration based on its primary function.
The applicant must ensure that the brand and product name declared in the
application form is consistent with all the submitted documents. In case the brand
and product names reflected in the submitted documents are not consistent with the
one declared in the application form, the applicant must submit a
declaration/certification listing all the different brand and product names used and
certifying that all the names refer to the HUHS product for registration.
- List of Variants
Variants of a HUHS product refer to products with identical base formulation but
contain different colorant/s and/or fragrance. To better illustrate, Table 2.13 is an
example of a HUHS product with multiple variants.
If the applicant is uncertain that its HUHS products for registration are considered
as variants, here are some additional reminders to keep in mind:
The base formulation of the variants of the HUHS product with the exception of
the active ingredient/s may either be quantitatively and qualitatively identical, or
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In case the HUHS products for registration are considered as variants, the applicant
may either register the variants under a single application or opt to register them
individually as shown in Table 2.14. Note that a single initial HUHS product
registration application can only accommodate up to five (5) variants.
To register more than one (1) variant in a single application, declare the brand and
product name of the HUHS product under “Product Name” and list the names of
the variants under the “List of Variants” as shown in Table 2.14 (A). Remember to
only declare one (1) variant per row. Add or delete rows by clicking the “+ New”
button on the upper left corner of the field and the “ ” button at the end of the
row, respectively.
To register the variants of the HUHS product individually, the applicant may either:
Declare the variant name together with the brand and product name of the
HUHS product under “Product Name” and indicate “Not Applicable” or “N/A” in
the “List of Variants” as shown in Table 2.14 (B), OR
Declare the brand and product name of the HUHS product under “Product
Name” and declare the variant name in the “List of Variants” as shown in Table
2.14 (C).
Table 2.14 Different Ways to Register the Two (2) Variants of ABC Disinfectant
Spray
More than One
1 Variant per 1 Variant per
Application (1) Variant in a
Application Application
Form Single
(B) (C)
Application (A)
Product ABC Disinfectant Application #1 Application #1
Name Spray ABC Disinfectant ABC Disinfectant
Spray – Lavender Spray
Application #2 Application #2
ABC Disinfectant ABC Disinfectant
Spray - Lemon Spray
List of Lavender N/A Application #1
Variants Lemon Lavender
Application #2
Lemon
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For coloring materials with multiple variants/colors within a single product packaging,
indicate in this section the available packaging sizes of the product based on the
number of colors in a pack (i.e. Crayons 8 Colors; Crayons 16 Colors).
In case the HUHS product for registration does not have any variants, indicate “Not
Applicable” or “N/A”.
In case the product presentation of the HUHS product is not found in the dropdown
menu, select “Others” and indicate the most appropriate description of the primary
packaging.
In case the HUHS product for registration has multiple pack sizes with different
product presentations, select “Others” and indicate all available primary packaging
of the product. To illustrate, for a HUHS product available in 10mL Sachet and
50mL/100mL Tube, select “Others” and indicate “(a) Sachet (b) Tube”.
In case the secondary packaging presentation of the HUHS product is not found in
the dropdown menu, select “Others” and indicate the most appropriate description
of the secondary packaging.
In case the HUHS product for registration has multiple pack sizes with different
secondary packaging, select “Others” and indicate all available secondary
packaging of the product. To illustrate, continuing with the example from above, for
a HUHS product available in 10mL Sachet with no secondary packaging and
50mL/100mL Tube in a Box, select “Others” and indicate “(a) N/A (b) Box”.
In case the HUHS product does not have a secondary packaging, select “Not
Applicable”.
- Net Content
Indicate all available pack size/s of the HUHS product for registration consistent
with those printed on the product label. Remember to use the metric unit in declaring
the net content and to declare one (1) pack size per row. Add or delete rows by
clicking the “+ New” button on the upper left corner of the field and the “ s ” button
at the end of the row, respectively.
In cases where the metric unit is not the most appropriate measure of the product
content, the net content may be indicated using other means. To illustrate, for
surface disinfectant wipes, the declared net content may be the number of wipes
contained in a single pack (i.e. 80 wipes, 30 wipes) while for coloring materials, the
net content may be the number of colors available in the product packaging (i.e. 8
colors, 16 colors).
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In case the HUHS product for registration has multiple pack sizes with different
primary packaging, declare the net content together with the product presentation.
To illustrate, using the example from above, for a HUHS product available in 10mL
Sachet and 50mL/100mL Tube, declare the net content as 10mL Sachet, 50mL
Tube and 100mL Tube, one pack size per row, as shown in Figure 2.22.
Figure 2.22 Net Content Declaration for an HUHS Product Available in 10mL
Sachet and 50mL/100mL Tube
In case the HUHS product for registration has more than one (1) variant which are
available in differing pack sizes, declare the net content together with the variant
name. To illustrate, Figure 2.23 shows how to declare the varying pack sizes of the
two (2) variants of ABC Air Freshener in the application form.
Figure 2.23 Net Content Declaration for the Varying Pack Sizes of the Two (2)
Variants of ABC Air Freshener
- Product Category
From the dropdown menu, select the appropriate category of the HUHS product for
registration. Select
Ready-to-Use, if the HUHS product for registration is ready to be used outright
of the packaging and for general purposes, which require no further dilution prior
to application. Also select this product category for HUHS products diluted
before use but whose application are NOT restricted to trained personnel or
professionals.
For Professional Use, if the HUHS product for registration is highly
concentrated, requiring further dilution and is restricted to be applied only by
trained personnel
- Product Description
Indicate the technical specifications of the HUHS product for registration as
reflected in the COA. Applicants may also opt to indicate the results of the tests
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conducted on the HUHS product as reflected in the COA together with the product
specifications.
Note that applicants must ensure that the technical specifications of the HUHS
product found in the COA and declared in the application form are consistent with
those reflected in Section 9 of the SDS, if indicated.
For GHS-compliant HUHS products, applicants must then declare the GHS
hazard classification/s of the HUHS product and the appropriate GHS label
elements as listed in Section 2 of the SDS.
In case the HUHS product for registration does not meet the hazard criteria
for classification in any of the GHS hazard classes under a particular hazard
group, indicate “Not Classified”.
Note that for HUHS products classified in multiple GHS hazard classes, the
GHS has set out rules of precedence for the allocation of hazard information.
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Table 2.15 Sample HUHS Product for Registration and Its GHS Hazard
Classifications with the Corresponding Assigned GHS Label Elements
GHS Label Elements
GHS Hazard
Classification Hazard
Signal Word Pictogram
Statement
Flame
Highly flammable
Flammable Liquid
DANGER liquid and vapour
Category 2
Skull and
Crossbones
Acute Oral Toxicity Toxic if swallowed
DANGER
Category 3
Corrosion
Causes severe
Skin
skin burns and
Corrosion/Irritation DANGER
eye damage
Category 1
Environment
Hazardous to the
Aquatic
WARNING Very toxic to
Environment,
aquatic life
Acute
Category 1
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For more information on GHS and allocation of hazard information, refer to the
Information on the Technical Requirements section of this guide manual or the
8th revised edition of the GHS (Chapter 1.4 and Annex 3).
Note that during the transitory period provided in FC No. 2021-011-A, special
considerations are given to GHS-compliant HUHS products whose existing
labels do not yet reflect the appropriate GHS label elements and thus, are
inconsistent with the hazard information declared in the application form and
SDS, as companies are allowed to submit existing product labels regardless of
compliance to Annex J of FC No. 2020-025 for registration purposes, provided
that all claims are substantiated. However, should an artwork of proposed
product label be submitted together with the existing product label, full
evaluation of the proposed label shall be conducted to verify compliance to
Annex J of FC No. 2020-025 and the consistency of label information with those
declared in the application form and SDS.
For non-GHS compliant HUHS product, applicants must then declare the
hazard information of the product consistent with Item 14.3.6.3, Section V
(Specific Guidelines) of FC No. 2020-025. Table 2.16 provides a tabulation of
the hazard information that may be declared for non-GHS compliant HUHS
product based on its hazardous nature.
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Note that the non-GHS compliant hazard information declared in the application
form must be consistent with Section 2 of the SDS. Applicants should further note
that non-GHS compliant HUHS products are only allowed during the transitory
period provided in FC No. 2021-011-A, after which no non-GHS compliant HUHS
products shall be allowed to be registered with FDA and to be made available in
the market.
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For HUHS products NOT intended for the use of children, the statement “Keep out
of reach of children” or its equivalent must be included.
For HUHS products intended for the use of children, the statement indicating that
the use of the product requires adult supervision must be included.
Note that the information declared in the application form on signs and symptoms of
poisoning must be consistent with those found in Sections 4 and/or 11 of the SDS
and on the product label, if indicated.
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Note that the information declared in the application form on first-aid instructions /
medical advice must be consistent with those found in Section 4 of the SDS and on
the product label.
Note that the information declared in the application form on proper handling,
storage and disposal must be consistent with those found in Sections 7 and 13 of
the SDS and on the product label.
Note that the ingredient list provided in the application form must be consistent with
Section 3 of the SDS and the full ingredient list on the product label. In case the
formulation declared in the application form is inconsistent with Section 3 of the SDS,
submit a clarification letter explaining the inconsistency.
During the transitory period provided in FC No. 2021-011-A, special considerations are
given to submitted existing product labels which do not reflect the full ingredient list as
companies are allowed to submit existing product labels regardless of compliance to
Annex J of FC No. 2020-025, provided that all claims are substantiated. However, should
an artwork of proposed product label be submitted together with the existing product
label, full evaluation of the proposed label shall be conducted to verify compliance to
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Annex J of FC No. 2020-025 and consistency of label information with those declared in
the application form and SDS.
To start, applicants must first declare whether the initial registration application covers
multiple variants of a HUHS product. Select “Yes” from the dropdown menu if more than
one (1) variant have been declared in the application. Otherwise, select “No”. Once done,
provide the following ingredient information:
- Column 1 - Variant Name (only applicable if there are multiple variants in the
application) Declare the name of the variant/s where the declared ingredient
has/have been used.
Note that the variant names declared in Column 1 must be consistent with those
provided in the first part of the application form (Particulars of the Product).
In case the ingredient is a mixture, declare the individual components of the mixture
in a single row/entry with their corresponding percent concentration relative to the
overall formulation of the raw material alongside them.
For fragrance materials, these may be declared using the chemical name of the
fragrance or the word “fragrance. Botanical ingredients are not considered as
fragrance material and must be declared using its assigned binomial nomenclature
(scientific name). For colorants, these may be declared using the chemical name
of the colorant, its Food Drug and Cosmetic (FD&C) number or color index (CI)
number. For dye mixtures considered as Confidential Business Information,
applicants are advised to contact the HUHS Section of the CCHUHSRR – Licensing
and Registration Division via email (cchuhsrr.lrd.huhs@fda.gov.ph).
In case the ingredient is a mixture whose individual components have assigned CAS
numbers, indicate said CAS numbers in Column 3 as shown in Table 2.17.
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Guide Manual for the HUHS Industry – Initial Product Registration
In case the components of the mixture have no assigned CAS numbers, indicate
“Mixture”. For fragrance materials, known allergens, if present, may be declared
using their corresponding CAS numbers under Column 3 alongside their percent
concentration in the HUHS product formulation.
For more information on how to declare the Ingredient Name (Column 2) and CAS
Number (Column 3) of fragrance materials and colorants in the application form,
refer to the Frequently Asked Questions on Fragrance and Colorants available at:
https://www.fda.gov.ph/wp-content/uploads/2021/04/FAQS-Fragrants-and-
Colorants.pdf.
- Column 4 – Function
Provide the function of the declared ingredient relative to the HUHS product
formulation.
Note that the sum total concentration of the declared ingredients must be:
100%, for HUHS products with up to one (1) declared variant in the application
100% per variant, for HUHS products with more than one (1) declared variants
in the application
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Guide Manual for the HUHS Industry – Initial Product Registration
- Column 6 – Formulation
For HUHS products with more than one (1) declared variants in the application,
select “BASE” from the dropdown menu for declared ingredients that are part of the
base formulation (i.e. ingredients that are present in all declared variants) or
“VARIANT” if it is a colorant and/or fragrance material that differs between variants.
For HUHS products with up to one (1) declared variant in the application, all
ingredients including the fragrance material/s and colorant/s must be declared as
“BASE”.
The active ingredient is the chemical that gives the HUHS product the ability to
deliver its claimed benefit (i.e. quaternary ammonium chloride as the active
ingredient in surface disinfectants). Note that ingredient/s declared as active
ingredients are reflected in the marketing authorization issued by the FDA.
Note that uploaded documents must be in the correct format - PDF file format (100-150 dpi)
for documents and PNG format for the required loose label artwork and pictures of the HUHS
product. To upload documents, click “Choose Files” and select the files intended to be
submitted as part of the application. Applicants may upload documents individually or as a
set of multiple files.
During the transitory period provided in FC No. 2021-011-A, for the purpose of initial
registration, FDA accepts loose label artwork of HUHS products regardless of their
compliance to Annex J of FC No. 2020-025, provided that all product claims reflected on the
label are substantiated. However, should the existing label reflect an unsubstantiated claim,
a proposed label that is already compliant with Annex J of FC No. 2020-025 (placeholders
are allowed) with the unsubstantiated claim deleted must be submitted.
In case of unallowable safety claims in the existing product label, the applicant must submit
either of the following:
(a) a proposed label that is already compliant with Annex J of FC No. 2020-025
(placeholders are allowed) with the safety claim deleted, or
(b) a letter with the commitment that the new HUHS product label will no longer contain the
prohibited safety claim
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In case the applicant made an error in the application form, click the “Previous Step” button
in the upper left corner of the application window to revisit the page where the error is and
make the necessary correction. For the attached documents, these may be viewed and
checked by clicking its file name.
Once the applicant is satisfied that the draft initial HUHS product registration application is
acceptable and complies with FDA standards and requirements:
(a) indicate the name of the uploaded documents (i.e. SDS, COA, Documentation to
Substantiate Product Claims, Other Documents) and the side of the HUHS product
shown in the uploaded pictures (i.e. Front, Back, Right, Left, Top, Bottom, Commercial
Loose); and
(b) click “Next” and then “Continue” to submit the initial HUHS product registration
application to FDA for pre-assessment.
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III. ANNEXES
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Guide Manual for the HUHS Industry – Initial Product Registration
Annex A
SELF-ASSESSMENT CHECKLIST FOR
INITIAL HUHS PRODUCT REGISTRATION
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SELF-ASSESSMENT CHECKLIST FOR INITIAL HUHS PRODUCT REGISTRATION
• Declaration and Oath of Undertaking (Select “YES, I AGREE” only if you have read and agree with the Terms and
conditions laid down).
1. Local Company Responsible for Placing the Provide a valid LTO number as:
Product in the Market • HUHS Manufacturer (see 2.a)
• HUHS Trader (see 2.b)
• HUHS Distributor-Importer (see 2.c)
b. In case the applicant is a HUHS Trader Indicate the valid LTO number of the HUHS Toll
Manufacturer. The system automatically provides all
other relevant information once a valid LTO number has
been provided.
c. In case the applicant is a Distributor- Indicate whether the HUHS product for registration is
Importer directly or indirectly-sourced.
- Direction for Use Indicate the directions for use as reflected on the product
label.
- Number of Years Applied For Select the number of CPR validity applied for. Fees will
vary depending on the year of CPR validity selected.
- GHS Compliant (Hazard Based on the hazard information found in the Safety Data
Information) Sheet (SDS), declare the HUHS product for registration to
either be:
• GHS-compliant (product is classified according to
GHS)
• Non-GHS-compliant (product is not classified
according to GHS)
- Signs and Symptoms of Poisoning Indicate the signs and symptoms of poisoning applicable
to the HUHS product consistent with Secs 4 and/or 11 of
the SDS and the product label, if indicated.
- Handling, Storage and Disposal Indicate the handling, storage and disposal instructions
Information applicable to the HUHS product consistent with Secs 7 and
13 of the SDS and product label.
(d) Full Ingredient List Under the “With Variant” section, select “YES” if more
than one (1) variant of the HUHS product have been
declared in the application. Otherwise, declare “NO”
- Variant Name For applications with more than one (1) declared variants,
indicate the variant names where the declared ingredient
has been used.
- Ingredient Name Declare the ingredients used in the formulation of the
product using their common, chemical or IUPAC names.
Trade names are NOT allowed.
One (1) raw material per row. In case the raw material is a
mixture, declare all its components in a single row with
their corresponding % concentration relative to the raw
material formulation alongside them.
Part II. Technical Documents Documents must be in the correct format - PDF file format
(100-150 dpi) for documents and PNG format for the
required loose label artwork and pictures of the HUHS
product.
1. Safety Data Sheet (SDS) of the Formulated Refer to the Guide Manual for the HUHS Industry – Initial
Product Product Registration and 8th revised edition of the GHS for
the format and minimum information that must be found
in an SDS.
n. Signs / Symptoms of Poisoning Must be consistent with Secs 4 and/or 11 of the SDS
b. Precautionary statement Include a statement indicating that the use of the product
requires adult supervision
5. Pictures of the product in all angles and in Submit photos of the HUHS product from all angles for all
different packaging sizes declared packaging size/s.
a. Front
b. Back
c. Top
d. Bottom
e. Left
f. Right
CONSISTENCY TABLE
All information found in the application including those declared in the application form and those contained in the submitted
documents MUST be consistent. Applications found to contain inconsistent information SHALL be disapproved during pre-
assessment, unless sufficient justification/clarification have been provided.
Put “✓” if the information declared in the application form is consistent with that found in the submitted documents (per
column), and “X” if it is not consistent, and “N/A” if the information is not found in the submitted document.
3. Product Line/Type
4. Product Name
5. List of Variants
9. Product Category
REFERENCES
Republic Act No. 9711, otherwise known as the “Food and Drug Administration Act of 2009”
Administrative Order No. 2005-0016, General Policies and Guidelines Governing Brand Names
of Products for Registration with the Bureau of Food and Drugs
FDA Circular No. 2023-006, Updated Guidelines on the Filing and Submission of Applications
for the Licensing and Registration of Household/Urban Hazardous Substances (HUHS)
Establishments and Products, Respectively, Through the FDA E-Portal V.2 System
FDA Circular No. 2021-011-A, Extension of Transitory Period and Provision of Interim Guidelines
for Product Registration, including the Labeling Requirements, for Household/Urban Hazardous
Substances
FDA Circular No. 2020-032, Renaming of the Center for Cosmetics Regulation and Research to
Include Jurisdiction Over Household/Urban Hazardous Substances in its Title Pursuant to
Republic Act No. 9711, otherwise known as the “Food and Drug Administration Act of 2009”
FDA Circular No. 2020-025, Implementing Guidelines for Administrative Order No. 2019-0019,
“Reinstatement of Requirements of Licensing as Importers, Exporters, Manufacturers, Toll
Manufacturers, Wholesalers, Distributors, Retailers, or Re-Packers of Those Engaged in Certain
Household/Urban Hazardous Substances, and from the Requirement of Prior Registration and/or
Notification of Said Products”
FDA Memorandum Circular No. 2013-030, Guidelines on the Use of the FDA Logo and Name
in Promotional, Advertisement, Sponsorship, Marketing or Commercial Materials
FDA Memorandum Circular No. 2013-038, Filing and Receiving of Registration and Licensing
Applications
FDA Advisory No. 2021-0879, Ban of Silver Jewelry Cleaners Containing Cyanide
FDA Advisory No. 2015-021, The Food and Drug Administration (FDA) is Now Online Through
the BancNet for Clients Online Payment Gateway System
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Published by the
Food and Drug Administration
Civic Drive Filinvest Corporate City
Alabang, Muntinlupa City
2023
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