Mexico Joins the Race with a New Circular Economy Framework
This blog was originally posted on 3rd February, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
AUTHORED BY CRISTIAN BARROSO, REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS
Introduction
On 19 January 2026, Mexico’s new General Law on Circular Economy (LGEC) was published in the Official Gazette. The Law marks a significant milestone in the country’s environmental policy, establishing a comprehensive framework to promote circular-economy practices, extend product life cycles, and enhance waste minimization, reuse, and recovery.
In Mexico, more than 120,000 tons of waste are generated daily, yet only 2,394 tons per day account for waste recovery. Against this backdrop, the Law adopts circular economy principles across the entire value chain, addressing not only downstream activities—such as recycling, recovery, and disposal—but also upstream measures, including prevention, reduction, and reuse. As a result, the Law is expected to have direct and far-reaching implications for business operations nationwide.
Notably, the new Law differs from existing regulations, such as the General Law for the Prevention and Comprehensive Management of Waste (LGPGIR), which have traditionally focused primarily on waste management. In contrast, the LGEC embraces a holistic approach centred on product life-cycle management and extended producer responsibility (EPR), placing greater obligations on producers and other economic actors.
In this context, this blog explores the Law’s key requirements and its implications for businesses.
Extended Producer Responsibility (EPR) and Circularity Management
The Law embeds an Extended Producer Responsibility (EPR) policy, making producers and importers responsible for their products throughout their life cycles, including the post-consumer stage. Under this framework, producers and importers will be required to register and implement a Circular Management Plan (gestión circular) that addresses both the environmental footprint and the circularity of their products.
Products and Sectors in Scope
The Law does not explicitly identify specific products or sectors in scope and appears to apply broadly to all products manufactured in or imported into Mexico. However, the Ministry of Environment will progressively define specific products (B2B or B2C) and sectors through implementing regulations and general agreements, establishing obligations and compliance targets for producers and importers.
Circular Management Plan and Reporting Obligation
Producers and importers must register a Circular Management Plan with the National Circular Economy Registry and comply with circularity requirements across the product life cycle. The specific targets, indicators, and compliance deadlines will be established in the implementing agreements and may include, among others:
- Life cycle analyses by product category.
- Circularity mechanisms, such as repair, reuse, refurbishment, recycling, and recovery, in accordance with the waste hierarchy (or “hierarchy of circularity”), where final disposal is a last resort.
- Performance targets and measurable indicators.
When evaluating Circular Management Plans, authorities will place particular emphasis on reducing the product’s environmental footprint and implementing ecodesign measures, where technically and economically feasible. Compliance with these requirements will be monitored through periodic reporting as specified in the implementing regulations.
EPR Compliance Mechanisms
Producers and importers are required to organise, promote, and, where applicable, finance circular economy schemes for the products they manufacture or import, in accordance with the implementing regulations.
Compliance may be achieved:
- Directly by the producer or importer, or
- Indirectly, through authorized third parties.
Additionally, where duly justified, compliance may also be fulfilled through environmental compensation measures, such as ecological restoration, reforestation, or the acquisition of financial instruments, when the producer or importer cannot otherwise meet the applicable obligations.
Circular Economy Label and Voluntary Audits
Products that comply with circular economy requirements—such as ecodesign standards, responsible use of raw materials, repairability, durability, and reduced environmental footprint (as detailed in the implementing regulations)—may be eligible to bear a Circular Economy Label.
Use of the label is subject to voluntary environmental audit procedures conducted by the Federal Attorney for Environmental Protection (PROFEPA). The label will be valid for three years, and products bearing this distinction may receive preferential treatment in public procurement procedures.
Prohibition on Greenwashing and Penalties
The Law expressly prohibits greenwashing practices, including the generation or use of false or misleading information regarding the environmental characteristics of products, as well as the unauthorised use of circular economy labels.
In the event of non-compliance with the obligations established under the LGEC, authorities may impose the following penalties:
- Fines ranging from 30 to 50,000 days of minimum wage,
- Temporary or permanent, total or partial closure of facilities,
- Administrative arrest,
- Seizure of products, and/or
- Suspension or revocation of concessions, licenses, permits, or authorisations.
Next Steps
The Ministry of Environment is required to publish the National Program of Circular Economy within 180 days, which will identify the productive sectors and product categories subject to general agreements or regulations implementing EPR obligations. Particular consideration will be given to micro, small, and medium-sized enterprises.
Notwithstanding the above, the identification of productive sectors and product categories for the 2026-2030 period must include those corresponding to plastics.
Conclusion
Mexico’s General Law on Circular Economy embeds EPR within a broader circular-economy approach, placing greater emphasis on ecodesign, reduction of environmental footprint, and full product life-cycle responsibility. While this approach has the potential to be more transformative, its practical impact will depend on the scope, ambition, and timing of the forthcoming implementing regulations, including the definition of covered products, performance targets, and compliance mechanisms.
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