On January 19, 2026, the decree enacting the General Circular Economy Law (the “LGEC”) and amending and supplementing various provisions of the General Law of Ecological Balance and Environmental Protection (the “LGEEPA”) and the General Law for the Prevention and Integral Management of Waste (the “LGPGIR”) was published in the Official Gazette of the Federation.
This new legal framework creates new operational obligations primarily for producers and importers of products, under an Extended Producer Responsibility (“EPR”) scheme, including the preparation of a Circular Management Plan and the filing of an application for its registration in the Registry within the timeframes set forth in the corresponding agreement, being subject to reporting, verification, conditions, and gradual compliance targets.
With respect to the application for registration in the Registry, the authority may grant, condition, or deny such application; silence for a period of 60 business days from the upload to the National Platform produces the effects of automatic registration (affirmative fictitious approval).
For waste generators that are not producers or importers, the LGEC does not expressly impose novel obligations of registration or of submitting their own plans under the new Registry; however, it strengthens duties of responsible management, source separation, and circular recovery, as well as subjection to the existing LGPGIR, now updated to incorporate circularity principles and to sanction non-compliance by reference to the LGEC and to the general agreements for the implementation of EPR, which will establish, by sector or product category, the applicable circularity mechanisms (direct and indirect), targets, methodologies, and indicators, and will convene the productive sector for their development.
The Ministry of Environment and Natural Resources may authorize the use of the National Circular Economy Distinction for products that comply with the principles and criteria of the LGEC; its use is linked to voluntary environmental audits and has a term of three years, renewable. Products bearing such Distinction will have preference in public procurement, a market effect incentive that should be considered by institutional lessors and property managers in their procurement policies.
On the other hand, the amended LGPGIR reaffirms that the regulation of the generation and integral management of municipal solid waste and special management waste shall be carried out in accordance with the LGPGIR, the LGEC, and state provisions, which raises the compliance standard for generators by linking their management obligations to circularity principles and to potential related EPR agreements.
Likewise, it incorporates circularity into definitions and principles, requiring that the regulation of municipal solid waste and special handling waste also conform to the new LGEC.
The LGEEPA is amended to define waste in an aligned manner and to incorporate the circular economy into the sustainable use of virgin materials in economic activities, prioritizing the progressive integration of secondary raw materials where feasible.
The LGEC provides that non-compliance in the management of hazardous waste constitutes administrative infringement, by reference to the Circular Economy Law and the EPR agreements. Inspection procedures shall be conducted in accordance with the procedure set forth in Title VI of the LGEEPA.
Environmental damage caused in violation of the LGEC shall give rise to environmental liability pursuant to the Federal Environmental Liability Law. Violations of the LGEC may trigger the elements of criminal unlawfulness provided for in the offenses regulated by the Federal Criminal Code, giving rise to the criminal liability of legal entities.
The LGEC and the amendments to the LGEEPA and the LGPGIR entered into force on January 20, 2026.
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