Mexico Enacts General Law for the Circular Economy

The Mexican government has published the full text of the newly approved General Law for the Circular Economy, establishing a nationwide legal framework that obligates producers, importers and public authorities to integrate circularity principles across product design, production, consumption and waste management. The law was published in the Official Journal of the Federation (DOF) on Jan. 19 and entered into force the following day. Its provisions will be implemented gradually through sector-specific regulations and coordination agreements. The legislation was approved on Dec. 10 with the backing of Environment and Natural Resources Minister Alicia Bárcena.

The law is of public order and nationwide application, grounded in constitutional provisions related to environmental protection, economic development, and federal regulatory authority. Its stated objectives include extending product life cycles, reducing waste generation, recovering and valorizing materials, and defining shared responsibilities among the federal government, state and municipal authorities, producers, consumers, and other economic actors.

A central pillar of the legislation is the creation of a circular management system linked to extended producer responsibility (EPR). Once the Ministry of Environment and Natural Resources (SEMARNAT) publishes a general implementation agreement for a specific product category or sector, all covered producers and importers must develop a Circular Management Plan and register it on a national digital platform within established deadlines. Registration will be deemed automatic if the authority does not issue a decision within 60 business days.

Each Circular Management Plan must be supported by a life-cycle assessment by product category or, where technically or economically unfeasible, by a simplified life-cycle study authorized under EPR agreements. Plans must also describe applicable direct or indirect circularity mechanisms, compliance targets, and any coordination agreements with authorities or third parties. Authorities may approve, condition, modify, or deny registration based on compliance with the law and related environmental regulations.

The law formally establishes both direct and indirect compliance pathways. Direct compliance applies when producers implement circularity mechanisms themselves, while indirect compliance allows the use of third parties through sustainable value-chain agreements or environmental compensation mechanisms. Sectoral coordinating entities may act on behalf of producers, although they share legal responsibility for compliance and reporting obligations.

To oversee implementation, the law creates the National Circular Economy System, chaired by SEMARNAT and comprising the ministries of Economy (SE), Finance (SHCP), Energy (SENER), Infrastructure, Communications and Transport (SICT), and Education, as well as environmental authorities from each state. The system will operate through an intergovernmental coordination structure supported by a technical secretariat within the federal administration.

Policy execution will be guided by a National Circular Economy Program, which must align with Plan México — Mexico’s US$277 billion national development strategy — as well as sector-specific strategies. The program will identify priority sectors and product categories, establish cross-cutting targets, and promote reductions in environmental footprints, emissions, and resource use, while avoiding unjustified barriers to trade. The program must be published within 180 days of the issuance of the law’s implementing regulations.

The law introduces  a range of policy instruments, including voluntary environmental audits, inspection and surveillance programs, economic incentives, and a National Circular Economy Distinction that may only be used with official authorization. The use of misleading environmental claims or unauthorized labels is expressly prohibited.

Education and innovation are also identified as key enablers of the transition to a circular economy. Federal authorities are required to promote circular economy training at secondary and higher education levels, integrate circularity into research and technological development, and encourage the formation of specialized professionals and applied technologies.

From a compliance perspective, the law stipulates graduated implementation mechanisms. Authorities may set differentiated targets based on sectoral capacity and company size, with special consideration for micro, small, and medium-sized enterprises. These targets may be formalized through publicly disclosed coordination agreements published in the DOF.

Enforcement will rely on existing environmental sanction regimes. Failure to submit reports, provide accurate information, or comply with registered Circular Management Plans may result in administrative penalties under Mexico’s General Law of Ecological Balance and Environmental Protection, without prejudice to potential civil or criminal liability. Authorities may also pursue alternative dispute resolution mechanisms with non-compliant entities.

The law further amends Mexico’s waste and environmental statutes to embed circularity principles in resource extraction, industrial activity, and waste management. Where technically and economically feasible, companies must prioritize secondary raw materials over virgin inputs and maximize product durability and waste valorization. Waste definitions are updated to emphasize recoverability and value retention.

State governments are required to harmonize their legislation within 180 days of the law’s entry into force. If they fail to do so, the federal law will apply directly at the local level. Federal authorities must also update or issue relevant technical standards within the same timeframe.

According to Pedro Prata of the Ellen MacArthur Foundation, the new law could strengthen the long-term resilience of Mexican companies. “Our current linear model is creating multiple risks for businesses,” he said. “Environmental challenges such as climate change are already disrupting value chains and exposing companies to commodity price volatility. By applying circular economy principles, companies can become more resilient and benefit from keeping products and materials in use.”

Prata added that these benefits stem from the model’s ability to prevent waste throughout the value chain. “It is a model that prevents waste from the design stage, reduces costs, and creates new revenue streams,” he said, noting that it also helps lower overall waste management costs for cities and communities.