Circular economy in Mexico: the law is now in force. Is your company ready?
By Erika Ramos Flores · CO2SFC · October 6, 2026
Mexico now has a circular economy law. What it does not yet have is the complete rulebook, and that is exactly what your company needs to understand today.
A law in force that is still waiting for its regulations
The General Law on the Circular Economy (LGEC) was published in the Official Gazette (DOF) on January 19, 2026, and took effect the following day, together with amendments to the General Law on Ecological Balance and Environmental Protection (LGEEPA) and the General Law for the Prevention and Integrated Management of Waste (LGPGIR). Its key innovation is Extended Producer Responsibility (EPR): for the first time at the federal level, whoever places a product on the market is also responsible for what happens to it at the end of its useful life.
One detail is decisive: the law does not, on its own, impose obligations on any sector. Its obligations take effect when SEMARNAT publishes implementation agreements by sector, by product or both (Art. 10). As of October 6, 2026, we had not found any. And the implementing Regulation, due on July 19, had still not been published according to the latest source consulted, dated September 8.
How EPR will work
Once the first agreement is issued, the process will have four stages:
Clear targets
SEMARNAT defines activities, indicators and methodologies for the sector.
Circular Management
Producers and importers, or their Coordinating Body, submit their plan with a Life Cycle Assessment and their targets (Arts. 12 and 15).
Resolution
SEMARNAT approves, approves with conditions or rejects. If it does not respond within 60 business days, tacit approval (afirmativa ficta) applies and the registration becomes final (Arts. 13 and 14).
Reporting and review
The registration can be ratified, amended or canceled (Art. 16).
Companies will be able to comply directly (reuse, redesign, recycling, recovery) or indirectly, through sustainable supply chain linkages or environmental offsetting. The latter allows instruments such as carbon credits regulated or validated by the authority. Whether voluntary market credits will qualify will depend on the Regulation and the agreements.
What you can start measuring now
- Life cycle carbon footprint. It is an official indicator, along with materials, water footprint and energy recovery.
- Gradual treatment for SMEs. Agreements may set differentiated targets based on economic and technological capacity (Arts. 47 and 48).
- Zero greenwashing. Giving false information about environmental attributes or using the National Seal without authorization is prohibited (Art. 43).
- Circular Economy Seal. It is obtained through a voluntary audit, is valid for three years and gives preference in public procurement.
Who oversees it and what comes next
SEMARNAT is the central authority: it issues agreements, operates the Registry and the National Platform, verifies and imposes penalties (under the LGEEPA, as failure to meet targets is not yet defined as an offense). PROFEPA conducts the voluntary audits, and states and municipalities must harmonize their legislation.
The expected path is: the Regulation, then the 2026-2030 National Program (180 days later, including plastics) and, according to our projection, the first EPR agreements between 2027 and 2028. The conversion of sanitary landfills has a base deadline of January 2031, which can be extended.
There are risks: an operational gap until the Regulation is issued, broad «feasibility» criteria that leave room for discretion, and a SEMARNAT that must implement everything without additional budget (Seventh Transitory Article).
How to prepare now
Do not wait for the first agreement. Measure your products' carbon footprint, document your waste management plans, make sure your environmental claims are substantiated and follow the publication of the Regulation: the first EPR agreement will mark when the obligations start being enforced.
For information only. This text does not replace legal advice. Check the status of the Regulation and EPR agreements in the DOF before making decisions.
Is your company ready for the circular economy?
We help you measure your footprint, document your management plans and prepare for compliance before the first EPR agreement.