In effect as of January 17, 2026

Purpose

The purpose of the Law is to protect and conserve the environment through the implementation of policies and mechanisms in the area of ​​Circular Economy to increase the useful life of products and minimize, recover, utilize and valorize waste.

Among its provisions, it is worth noting that specific obligations are established for the transition to circular production schemes that are environmentally, technically and economically viable.

Circular Economy. An economic model of sustainable production and consumption that includes systematic solutions for economic development, which reduce environmental impact through technical and biological cycles that allow the permanence and sustainable reintegration of product materials into the economy, whose guiding principles are the elimination of waste and pollution, keeping products and materials in use, as well as regenerating natural systems.

Circular Management. Legal entities that produce or import goods, such as IMMEX[1] companies, must design a Production and Consumption Scheme tailored to their economic activity and industrial sector. This scheme must include principles, actions, processes, strategies, and circular economy schemes to promote responsible consumption and extend the life cycle of their raw materials, products, and waste, thereby reducing the environmental footprint generated by their manufacturing activities (“Circular Management”). This Circular Management must be registered with the Circular Economy Registry of the Ministry of Environment and Natural Resources (“SEMARNAT”).

Circular Management, involves redesigning and reconditioning products whenever environmentally, technically, and economically viable, to maximize their useful life, as well as incorporating schemes that consider product repairability, and implementing strategies that allow for waste recovery or integration into other processes such as treatment, recycling, and valorization.

Circular Economy Registry. The application request  for the registration of Circular Management submitted to SEMARNAT must contain the following information:

  1. Life Cycle Analysis by category of raw materials, products and waste;
  2. Circular design of products, when technically, environmentally and economically feasible;
  3. Circular Economy Mechanisms to be implemented. These mechanisms are divided into direct and indirect mechanisms. Direct mechanisms are those circular economy mechanisms carried out by the Producer directly and individually, and indirect mechanisms are those carried out by the Producer through third parties;
  4. Goals for the gradual implementation of circular economy mechanisms;
  5. Indicators and methodologies for measuring compliance with the goals to be achieved in the area of ​​circular economy;
  6. Environmental measures dedicated to mitigating or proportionally reversing the environmental footprint caused by the productive activity;
  7. For the evaluation of the registration, SEMARNAT must take into consideration the Waste Management Plans that the Producer has at the time of the application request;
  8. If requested by SEMARNAT, a cooperation agreement must be entered into with SEMARNAT, this being a binding agreement by Producer for compliance with the circular economy mechanisms established in Circular Management;
  9. Likewise, it must be observed the other requirements indicated in the Regulations of the General Law of Circular Economy, which must be published no later than July 2026 (“R-LGEC”) and the National Circular Economy Program, documents that are described below.
  10. The registration procedure for Circular Management will be carried out directly with SEMARNAT, taking into account the requirements of the procedure that said federal agency disclosed in its official media and must be resolved within a period of 60 business days, if SEMARNAT does not issue a corresponding resolution within said period, the Circular Management will be considered registered.

Extended Producer Liability (“REP”). The new General Law on Circular Economy includes a new concept of responsibility for legal entities, producers, or importers, identified as Extended Producer Liability (“REP”). This responsibility implies that legal entities, producers, or importers must redesign their products when it is environmentally, technically, and economically viable, and are environmentally responsible for their product throughout its life cycle. Therefore, they must implement the principles and frameworks of the circular economy established in Circular Management at their own cost and expense, in compliance with the R-LGEC, the General Decree for the Implementation of REP, and the National Circular Economy Program.

The incorporation of extended producer responsibility constitutes the central instrument to materialize the circular economy, but in its current state within the law it remains as a guiding principle whose effective scope will depend on its subsequent regulatory development.

Below, we elaborate on REP:

Although there is no regulation R-LGEC, our opinion is that REP obligates the producer to take responsibility for the product until the end of its life cycle. To comply effectively, they need to implement Circular Management and Circular Design.

The legal obligation is that the producer is responsible for the product, even when it becomes waste, and must collect, recycle, and dispose of it properly (legal duty).

The function of Circular Management is how to operate it, that is, systems for collection, reuse and recycling, and

Circular Design is about preventing the problem at its source; that is, designing products to be recyclable, reusable, and durable. It’s the strategic component of circularity.

Example: a plastic bottle company.

  1. The REP company’s obligation is to recover used bottles and ensure their recycling;
  2. Circular Management implementing collection centers, establishing agreements with recyclers, and implementing return programs;
  3. Circular Design modifying the product, using recyclable plastic, reducing labels that are difficult to separate, and designing reusable spaces; with the above

For the reasons mentioned above, the implementation of REP will be gradual and may be defined: (i) by industry sector; (ii) by product type; or (iii) through a combination of both criteria.

General Decree for the Implementation of the REP. The General Decree(s) for the implementation of REP must be published in the Official Gazette of the Federation and will establish the following:

  • Simplified schemes for carrying out circular economy activities and mechanisms by productive activity;
  • The cases, technical criteria, procedures and conditions for determining environmental compensation measures (if applicable) in Circular Management;
  • The goals regarding the circular economy and the gradual implementation of these goals (progress by stages depending on the productive sector or product), considering the economic, financial and technological capabilities of the Producers;
  • Specifications for the submission of reports with the periodicity determined by SEMARNAT that reflect compliance with said goals.

The above is intended to allow each producer or importer, according to their productive activity, to design a Circular Management system that will be registered before SEMARNAT’s  Circular Economy Registry.

National Circular Economy Program. The National Circular Economy Program is a mandatory and binding planning instrument for importers and producers that will integrate, coordinate, and promote public policies, subprograms, projects, and activities, under the criteria and principles of the Circular Economy. It will also establish objectives, general goals, strategic lines, methodologies, harmonized guidelines for the proper classification of waste, and Circular Economy indicators and evaluations that are environmentally, technically, and economically feasible. The National Circular Economy Program will be published in the Official Gazette of the Federation within a period not exceeding 180 calendar days from the publication of the R-LGEC.

National Circular Economy Distinction. The National Circular Economy Distinction is also created as the mechanism through which SEMARNAT will recognize producers whose products comply with the principles and criteria of the circular economy, providing final consumers of these products with consistent information regarding compliance with these principles and criteria. The Distinction is valid for three years and is renewable for the same period.

To obtain the National Circular Economy Distinction, Producers must undergo a voluntary environmental audit process conducted by the Federal Attorney for Environmental Protection, as a preventive process to identify opportunities for process improvement, optimize resource use, and minimize environmental impacts.

The requirements, formalities, and criteria for the voluntary environmental audit for obtaining and using the National Circular Economy Distinction will be established in the R-LGEC. Products bearing this Distinction will be given preference in public procurement processes with the Government of Mexico.

National Platform. With the new General Law on Circular Economy, a National Platform will be implemented with the purpose of gathering information for research and access to information on the circular economy. This platform will be operated by the National Institute of Statistics and Geography (“INEGI”). The Platform will contain basic information on the circular economy, models, and practices, and will serve as a support tool for producers and importers to develop the Circular Management.

State Laws on Circular Economy. Some states of Mexico already had laws on circular economy. The new General Law on Circular Economy (Federal Law) instructs the legislatures of the state entities to adapt and harmonize their legislation with the provisions of the LGEC within 180 calendar days from the entry into force of the LGEC, that is, no later than July of this year, preventing that if they do not carry out the corresponding harmonization, the provisions of the LGEC must be applied at the local level.

  • Articles 3, section XXXII; 15, section VII and 39, first paragraph are amended, and section III Bis is added to article 22 Bis, Chapter II Bis “Sustainable Use in Economic Activities” to Title Three, and articles 107 Bis 1 and 107 Bis 2, of the General Law of Ecological Equilibrium and Environmental Protection.

Among these provisions, the following stand out:

The definition of waste is updated, recognizing its potential for recovery; it is established that the use of renewable natural resources must, in addition to guaranteeing their conservation, implement circular economy mechanisms where applicable. The powers regarding the use of natural resources are expanded, and environmental education is incorporated with an emphasis on sustainable development, the circular economy, and climate change. Furthermore, Chapter II Bis, “Sustainable Use in Economic Activities,” is created, which instructs that the use of virgin materials in production processes adhere to the principles of the circular economy, promoting production linkages, the progressive integration of secondary raw materials, maximizing product lifespan, waste recovery, and reducing the environmental footprint.

  • Articles 2, section XII; 5, sections II, XXIV and XLIII; 35, section I; 95; and 106, section II are amended, and a third paragraph is added, renumbering the last paragraph accordingly, to article 25, of the General Law for the Prevention and Comprehensive Management of Waste.

Among these provisions, the following stand out:

Circularity, valorization and shared responsibility are expressly incorporated as cornerstones of the environmental policy on waste; key definitions such as waste utilization, product and thermal valorization are updated, expanding the ways of recovering value and generating energy.

Furthermore, it is established that waste generation instruments and management plans must be based on the principles of circularity, waste hierarchy, and traceability, in accordance with the General Law on Circular Economy. Intersectoral coordination for the design of circular economy policies is strengthened, the regulation of municipal solid waste, special handling waste, and hazardous waste is linked to the General Law on Circular Economy, and the sanctions regime is expanded to include non-compliance with obligations derived from said law and from extended producer responsibility schemes.

Conclusions

This Law represents a structural shift in the country's environmental and production policy, moving from the traditional linear economic model (extract-produce-dispose) to a system focused on maintaining the value of products, materials, and resources for as long as possible within economic cycles. It establishes a cross-cutting public policy framework that coordinates the federal, state, and municipal governments, as well as the private sector, to promote waste prevention, reuse, repair, recycling, and the reintegration of materials into production chains. The aim is to reduce pressure on natural resources, decrease waste generation, and strengthen industrial competitiveness through more efficient and sustainable production models. One of the most relevant elements of this law is the incorporation of regulatory, economic, and planning instruments designed to incentivize technological innovation, product redesign, and shared responsibility throughout the life cycle of goods. Furthermore, it promotes the development of secondary material markets, the strengthening of circular value chains, and the integration of the productive sector into sustainable production and consumption schemes.

While in Europe Extended Producer Responsibility (EPR) is an operational regulatory instrument with clearly defined obligations, goals, and funding, in Mexico it remains a regulatory framework under construction, its effectiveness depending on subsequent regulatory development. The incorporation of EPR into Mexican legislation represents a significant conceptual step toward a circular economy, but unlike European models, it still lacks the necessary regulatory elements to operate as a fully effective instrument.

However, it is necessary to harmonize the new law with existing waste regulations, particularly the General Law for the Prevention and Comprehensive Management of Waste. There may be areas of overlap between the concepts of recovery, recycling, and byproducts, and even more importantly, it is crucial to clearly define when a material ceases to be waste and becomes a productive input.

It is obvious that the effective implementation of the law will depend on the issuance of regulations, official Mexican standards, and technical guidelines, among other things. There is a lack of clear technical criteria for eco-design, recyclability, recycled content, and material traceability, as well as the need to establish measurable circularity goals and indicators.

Finally, many companies still do not operate under linear production models, which will require adaptation to this law, including investments in process and product redesign; integration of circularity criteria in global supply chains; lack of sufficient infrastructure for advanced recycling, remanufacturing or material recovery; and the need to develop economically viable secondary material markets, with the provision of tax, financial or market incentives to promote circularity, in order to avoid the risk of it being perceived only as an additional regulatory burden.

Within one hundred and eighty calendar days following, as of January 17, 2026, the President shall issue the regulations of the General Law of Circular Economy.

Electronic Link:

https://dof.gob.mx/nota_detalle.php?codigo=5778439&fecha=19/01/2026#gsc.tab=0

Recommendations

  • Integrate the circular economy into corporate strategy and environmental compliance systems;
  • Evaluate the life cycle of products and materials to reduce waste and optimize resources;
  • Redesign products and processes to facilitate reuse, repair, and recycling;
  • Implement material recovery and valorization schemes within operations;
  • Monitor secondary regulations and adapt compliance programs accordingly;
  • Explore new circular business models and supply chain partnerships;
  • Take advantage of government incentives;
  • Be prepared with the required documentation for inspections by the relevant authorities;
  • Explore and review the impact of extended produced liability including the implications of shared liability.