The National Energy Commission Issues General Administrative Provisions for the Marketing of Hydrocarbons

The National Energy Commission Issues General Administrative Provisions for the Marketing of Hydrocarbons

November, 2026

The new provisions establish requirements for marketing permits, product traceability, transactions among permit holders and electronic contract registration, along with deadlines for compliance.

On November 5, 2026, a resolution of the National Energy Commission (CNE) issuing the General Administrative Provisions Regulating the Marketing of Natural Gas, Petroleum Products, Liquefied Petroleum Gas, and Petrochemicals (DACGs) was published in the Official Gazette of the Federation, supplementing the Hydrocarbons Sector Law and its Regulations.

The provisions establish regulatory conditions applicable to marketing activities and specify the requirements for obtaining permits, demonstrating applicants' logistical and operational capacity, and verifying the lawful origin and traceability of marketed products. They also introduce specific restrictions on certain transactions among permit holders and on the marketing of products derived from their own production processes.

One of the key developments is the implementation of the Contract Form, through which marketers must register, validate, amend and terminate contracts with suppliers and customers via the CNE's Electronic Filing Office (OPE). The provisions also establish minimum contractual requirements, documentation obligations and conditions for demonstrating the substantive nature of marketing activities.

The DACGs entered into force on November 6, 2026, and establish several transitional deadlines, including periods of 30 business days, 90 calendar days and 180 calendar days, depending on the applicable obligations and circumstances. Existing permits will remain valid under the terms in which they were granted, without prejudice to compliance with applicable regulatory requirements.

These provisions have implications for participants in the hydrocarbons sector, particularly regarding the review of their permits, contractual relationships, operational documentation and regulatory compliance mechanisms.

Read our full Legal Flash News for further details on the applicable requirements, restrictions and deadlines.