The new framework places circular economy principles at the center of Mexico’s environmental policy and establishes new rules on extended producer responsibility, waste recovery, resource efficiency and material traceability.
On January 20, 2026, the new General Circular Economy Law (“LGEC”) entered into force, together with several amendments to the General Law of Ecological Balance and Environmental Protection (“LGEEPA”) and the General Law for the Prevention and Comprehensive Management of Waste (“LGPGIR”).
The new framework seeks to accelerate the transition from a linear production and consumption model toward systems focused on preventing waste generation, extending product life cycles, improving resource efficiency and promoting reuse, recycling and material recovery.
One of the most significant changes is the introduction of Extended Producer Responsibility as a central element of the new regime. Under this principle, producers and importers will assume responsibility for certain products throughout their life cycle, including their recovery, valorization and potential reintegration into production chains.
Specific obligations will be developed through general agreements that will define, among other matters, the products subject to the regime, compliance targets, deadlines, technical indicators and direct or indirect compliance mechanisms. These instruments are expected to become particularly relevant for industry in the coming years.
The LGEC also introduces concepts and tools such as circular design, life-cycle assessment, secondary raw materials and circular recovery, as well as indicators including carbon and water footprints to measure performance and guide future public policy and regulatory obligations.
The Law also creates the National Circular Economy System as a coordination mechanism among the federal, state and municipal governments and requires the Ministry of Environment and Natural Resources to develop the National Circular Economy Program, which will establish objectives, targets, indicators and implementation strategies.
The framework further introduces the National Circular Economy Distinction to recognize products and processes that meet circularity criteria, as well as voluntary circular economy audits. The distinction may provide competitive advantages, including in certain public procurement procedures.
The entry into force of the LGEC does not replace waste management plans under the LGPGIR. Both mechanisms may coexist, although existing plans will need to become progressively aligned with the new principles of valorization, traceability, circularity and shared responsibility.
The amendments to the LGEEPA expressly incorporate circular economy principles into Mexico’s environmental legal framework. Among other matters, they recognize the recovery potential of waste and reinforce the application of sustainability and circularity criteria to the use of natural resources and virgin materials.
The amendments to the LGPGIR, in turn, broaden the concept of waste recovery to include reuse, remanufacturing, redesign, treatment, recycling and the recovery of secondary materials or energy. They also update the definition of product to expressly recognize the use of both virgin and secondary materials in production chains.
The new framework also strengthens the relationship between waste management and environmental compliance. Regulated activities must comply not only with the LGPGIR but also with the LGEC and the general agreements issued under the Extended Producer Responsibility regime. The amendments further expand the scope of violations related to circular economy requirements, particularly in connection with hazardous waste management.
Although the LGEC is already in force, its practical implementation will depend on secondary regulations, including its implementing Regulations, the National Circular Economy Program and the general agreements governing specific obligations.
For companies, this transition period provides an opportunity to assess the potential impact of the new regime on supply chains, product design, use of raw materials, waste management plans, material traceability, recovery processes and post-consumer collection mechanisms.
Von Wobeser y Sierra is available to assist with the analysis and implementation of the new regulatory framework and with assessing risks and opportunities related to circular economy, waste management and environmental compliance.
