Dear Clients and Friends,
In line with our commitment to keep you informed about legal and regulatory developments with business impact, we hereby inform you that on January 19, 2026, the Decree enacting the General Law on Circular Economy ("LGEC") was published in the Federal Official Gazette. This new legal framework, promulgated by President Claudia Sheinbaum Pardo, shall come into force on January 20, 2026, and marks a mandatory transformation in the operational model of all companies in Mexico.
The primary purpose of the Law is to transition from a linear economy to a circular one, seeking to increase the useful life of products, minimize waste generation, and establish a system of shared responsibility between the public and private sectors.
Critical Impact
- Extended Producer Responsibility ("EPR"): The LGEC establishes EPR as the obligation of producers and importers to be environmentally responsible for their products throughout their entire Life Cycle. This responsibility is complementary to the shared responsibility already provided for in the General Law for the Prevention and Integral Management of Waste (“LGPGIR”).
- Registration and Circular Management Obligation: Companies must prepare a Circular Management plan (which includes a Life Cycle Analysis) and register with the Circular Economy Registry installed on the National Platform. Failure to register or the use of false information may result in severe sanctions under the terms of the General Law on Ecological Balance and Environmental Protection (“LGEEPA”).
- National Circular Economy Seal: An official seal with a three-year validity period is created. Obtaining this seal not only validates regulatory compliance but also grants preference in public procurement, representing a strategic competitive advantage for the holder company.
- Amendments to Existing Laws (LGEEPA and LGPGIR): The publication is not isolated; it amends LGEEPA to require that the utilization of natural resources and virgin materials prioritize the integration of secondary raw materials. Likewise, waste management must now follow principles of hierarchization and traceability.
- Liabilities and Sanctions: The LGEC stipulates that failure to submit reports or documents provided for in the registered Circular Management, as well as any violation of the Law and its Regulations, shall be sanctioned by the Ministry of Environment and Natural Resources ("SEMARNAT") following the parameters of LGEEPA. Administrative sanctions may include fines ranging from 20 to 60,000 UMA (Units of Measurement and Update), temporary or permanent closure of facilities, suspension or revocation of authorizations and licenses, and even administrative arrest. It should be noted that these measures shall be imposed without prejudice to civil liability for environmental damage or to criminal penalties in the event of offenses.
Implementation Timeline
It is vital that any company initiate the adaptation process immediately, considering the following legal timeframes:
- 180 calendar days: Deadline for the issuance of the Law's Regulations and for state legislatures to harmonize their local laws.
- 180 calendar days: Deadline following publication of the Regulations to issue the National Circular Economy Program.
- 5 years: Maximum deadline for the progressive conversion of landfills toward circular economy models.
How Can Ramos, Ripoll & Schuster Support You?
The transition toward a circular economy requires not only operational adjustments but also a preventive legal strategy to avoid sanctions and leverage the tax and commercial benefits contemplated by the law.
Our specialized services include:
- Compliance Diagnostic: Assessment of your business model against the new obligations under the LGEC.
- Circular Economy Registry Advisory: Comprehensive support in registering your Circular Management and preparing Life Cycle Analysis.
- EPR Strategy: Design of extended responsibility schemes and concertation agreements with the SEMARNAT.
- Voluntary Environmental Audit: Implementation of preventive processes to identify improvement opportunities and protect the company from inspections.
- National Seal Certification: Management and compliance with requirements to obtain preference in public tenders.
At Ramos, Ripoll & Schuster, we are ready to advise you on adapting your operations and ensuring that this transition strengthens your business's competitiveness.
Authors:
Edmundo Elías-Fernández
eelias@rrs.com.mx
Mario Jorge Yañez Vega
jorge.yanez@rrs.com.mx
Lourdes Gutiérrez Valdez
lgutierrez@rrs.com.mx