Published: 25.09.2026. · ISO 14001

New Law on Chemicals 2026: what companies in Montenegro should check

Publisher: ConsultHQ

The new Law on Chemicals 114/2026 further aligns Montenegro with REACH and CLP rules and changes how chemicals are managed, labelled and stored.

Montenegro has applied the new Law on Chemicals 114/2026 since 11 August 2026. It brings the national framework closer to the EU’s REACH and CLP rules and covers the classification, labelling, packaging, manufacture, use, testing, placing on the market, import and export of chemicals.

For companies that use chemicals, this is not only a supplier issue. Chemicals may be part of production, maintenance, cleaning, laboratory work or storage. The new law therefore needs to be considered alongside environmental management, procurement, storage and the company’s existing records.

Law 114/2026 has applied since 11 August

The Law on Chemicals was published in the Official Gazette of Montenegro 114/2026 on 3 August 2026 and entered into force on 11 August 2026. It replaced the previous Law on Chemicals and continues Montenegro’s alignment with EU chemicals rules. The Government identifies REACH and CLP as key European frameworks behind the updated system.

REACH and CLP matter increasingly to Montenegrin companies

REACH is the EU framework for the registration, evaluation, authorisation and restriction of chemicals. CLP governs the classification, labelling and packaging of substances and mixtures. The new Montenegrin law brings the domestic framework closer to these rules, aiming to strengthen protection of human health and the environment while reducing technical barriers to trade with the EU.

Chemical information should not remain only in a supplier file. Classification affects labels, storage, safety data sheets, internal controls and actual use.

Digital labels are one specific change

When the law was adopted, the Ministry of Ecology highlighted the possibility of digital chemical labelling. A digital label can make additional information available without registration or payment, while protecting users’ privacy and keeping information accessible over time.

This does not mean that physical labels disappear. Applicable classification, packaging and labelling rules still determine the required information. Digital labelling signals the direction of the regulatory framework.

Classification and labelling rulebook — date of entry into force: 26 September 2026

The Rulebook on the Method of Classification, Packaging and Labelling of Chemicals was published in Official Gazette 136/2026 on 18 September 2026. Its effective date is 26 September 2026, when it replaces the previous rulebook based on the UN Globally Harmonized System.

Companies that manufacture, import or place chemicals on the market should review existing classifications and labels against the new text. Documentation prepared under the previous rulebook should not be assumed sufficient without a check.

Hazardous-chemical storage rulebook — date of entry into force: 29 September 2026

The Rulebook on Detailed Conditions for Storage and Measures for Safe Keeping or Use of Hazardous Chemicals was published in Official Gazette 137/2026. Its effective date is 29 September 2026, when it replaces the earlier storage rulebook.

This matters directly to companies with chemical stores, production plants, laboratories or substantial quantities of hazardous chemical products. They should compare current storage practices and procedures with the new rulebook.

Safety data sheets remain central to the system

A safety data sheet, or SDS, is a key source of information for managing a chemical safely. Montenegro also updated related documentation in 2026, and the competent authorities publish a separate rulebook on SDS content.

An SDS kept in a folder is not enough. Check that it matches the product actually used, is current, and informs storage, incident response, material compatibility and internal procedures.

Buying a new chemical should trigger an internal review

Chemicals often enter a company through procurement. A decision based only on price and technical function can leave regulatory or environmental risks unchecked. Before introducing a new chemical product, review:

• its classification;
• the current SDS;
• storage requirements;
• labels;
• applicable restrictions;
• intended use;
• handling of residues and waste;
• relevant environmental aspects and potential incidents.

This is especially important in manufacturing, where one new chemical can affect several existing procedures.

The law updates the system for poisoning information

The Ministry highlighted a new competent body for receiving information needed to provide emergency medical assistance in chemical poisoning cases: the Centre for Hospital Epidemiology and Toxicology within the Clinical Centre of Montenegro.

This forms part of closer alignment with European arrangements for exchanging information on hazardous mixtures. Businesses placing such products on the market should pay close attention to the accuracy and structure of information on composition and hazards.

Registers and regulatory databases remain important

The law also updates the institutional framework and databases used in chemicals management. The Government identified appropriate databases as part of the modernised system.

Manufacturers, importers and suppliers placing chemicals on the market should check which registration and reporting duties apply to them under the new law and secondary rules. Old internal deadlines and procedures should be reviewed rather than carried forward automatically.

Restrictions and substances of concern require separate attention

Chemicals management does not end with product classification. Montenegro maintains separate rules on substances of very high concern and restrictions or prohibitions for chemicals presenting unacceptable risks.

Companies need to know what they actually buy and use. A supplier or formulation change can alter the regulatory status of a product.

This is not only for companies that sell chemicals

A manufacturer may use chemicals without placing them on the market. It may still have duties concerning safe use, storage and control of environmental impacts. Examples include:

• cleaning and degreasing agents;
• coatings;
• paints;
• adhesives;
• laboratory chemicals;
• process chemicals;
• water-treatment products;
• oils and other chemical products.

This is why a chemicals compliance review can be relevant outside the chemical industry.

The link to ISO 14001 is direct, but the law and the standard are different

ISO 14001:2026 provides a framework for managing environmental aspects, compliance obligations, risks and environmental performance. The current edition was published in April 2026.

The Law on Chemicals creates legal obligations; ISO 14001 is a management-system standard. A company using ISO 14001 should include Law 114/2026 and applicable rulebooks in its register of compliance obligations. An ISO 14001 certificate does not replace a legal review.

The register of environmental aspects may need an update

Where a chemical could cause a serious incident, review environmental liability as well: prevention and remediation have a separate legal framework.

A new or differently classified chemical can change a company’s assessment of environmental aspects. Relevant scenarios may include storage, spills, emissions and waste. After reviewing regulatory requirements, check the connected ISO 14001 records.

The whole management system does not necessarily need to change. The aspects register, compliance obligations, response procedures or supplier controls may need a targeted update.

Review storage against the new rulebook, not habit

A company may have used the same store for years without an incident. That alone does not show that its storage arrangements meet the updated requirements. Rulebook 137/2026 has a 29 September effective date and replaces the previous hazardous-chemical storage rule.

Companies storing hazardous chemicals should review the premises, procedures and actual use. If controls are sound, documentation may need only a small correction. Any technical gap should be identified as a priority.

A label change can require changes to internal documents

Classification and labelling are not only market-facing requirements. Employees also rely on hazard labels and product information. A classification change can call for a review of:

• the internal chemical inventory;
• storage locations;
• work instructions;
• incident response;
• information provided to employees;
• emergency plans;
• environmental management documentation.

Rulebook 136/2026 therefore needs to be connected to operational controls, rather than treated as a visual change to the label.

What companies should check now

After Law 114/2026 and the September rulebooks, companies that use or place chemicals on the market should make a focused review. Check:

• which chemicals the company manufactures, imports, uses or places on the market;
• the current classification of each relevant product;
• labels and packaging;
• current safety data sheets;
• register and reporting duties;
• restrictions relevant to particular substances;
• storage conditions for hazardous chemicals;
• incident procedures;
• employee responsibilities;
• change management;
• ISO 14001 compliance obligations and environmental aspects, if the company uses the standard.

First determine which requirements actually apply. A user of chemicals does not necessarily face the same obligations as a manufacturer or importer.

Do not automatically rebuild the ISO 14001 system

A new law is not a reason to discard an environmental management system that works. If an ISO 14001 system is functioning, regulatory change should be handled through compliance monitoring and change control. Review only the affected parts.

That is one of the strengths of a well-run ISO 14001 system: it should absorb regulatory change in a controlled way without rebuilding the entire system.

ConsultHQ can connect the new law with an existing ISO 14001 system

A company using chemicals does not need separate administrative systems for the law and ISO 14001. Legal requirements should be linked to procurement, storage, operational controls, records and environmental aspects.

Through a gap analysis, ConsultHQ can assess how Law 114/2026 and applicable secondary rules affect the existing environmental management system. The aim is to identify what the company already controls, where a real gap remains and which changes matter most before the next ISO audit or regulatory inspection.

Related services: ISO 14001 in Montenegro, ISO standards for factories and gap analysis.

Official sources: Law on Chemicals 114/2026; Rulebook 136/2026; Rulebook 137/2026; Ministry of Ecology: explanation of the Law.

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