Mexico Reforming its Environmental Magna Carta

The foundation of Mexican environmental law is the General Law of Ecological Equilibrium and Environmental Protection (Ley General del Equilibrio Ecológico y la Protección al Ambiente) – known by everyone as the LGEEPA for its Spanish acronym.  The law was first enacted in 1988 – almost 40 years ago.  Mexico has posted on its regulatory reform website a wholesale revision of the existing law.

Here, we take a look at what the revision is proposing.

The proposed new LGEEPA is much more than a technical amendment exercise and reads instead as a substantial modernization of Mexico’s environmental governance framework. The draft introduces an entirely new vocabulary and architecture centered on restoration, biodiversity, climate adaptation, ecosystem services, environmental justice, and prevention principles. Among the concepts that do not exist — or do not exist in any meaningful way — in the current law are “circular economy” (economía circular), “nature-based solutions” (soluciones basadas en la naturaleza), “strategic environmental assessment” (evaluación ambiental estratégica), “biocultural heritage” (patrimonio biocultural), “environmental human rights defenders” (personas defensoras de derechos humanos ambientales), “ecosystem services” (servicios ecosistémicos), “equivalence criteria” (criterios de equivalencia), and the “economic valuation” (valoración económica) of environmental impacts. The proposal also formalizes new mechanisms around environmental compensation, restoration approaches, biodiversity planning, environmental certification, emissions inventories, and precautionary enforcement measures. In that sense, the draft clearly aligns Mexico more closely with global trends in ESG-style governance, climate resilience, biodiversity protection, and rights-based environmental regulation.

At the same time, many of the core concepts already present in the current LGEEPA are not replaced so much as expanded and reframed. Existing themes such as sustainable development, environmental impact assessment, climate change mitigation, hazardous materials regulation, pollution prevention, and ecological restoration are preserved but significantly broadened in scope and language. The draft strengthens the role of cumulative and synergistic impact analysis in environmental impact assessments, incorporates environmental justice and transparency considerations into policy objectives, expands atmospheric pollution and emissions concepts, and reframes restoration as a much more ambitious ecosystem recovery and compensation framework. Similarly, existing concepts such as “environmental services” (servicios ambientales), “environmental education” (educación ambiental), and “coastal ecosystems” (ecosistemas costeros) are rewritten using more contemporary ecological and governance terminology. The result is a draft that is less focused on traditional pollution-control regulation alone and more oriented toward integrated environmental governance, climate adaptation, biodiversity conservation, and ecosystem resilience.

One notable development in the draft is the incorporation of “circular economy” (economía circular) principles directly into the structure of the law. Mexico adopted the General Circular Economy Law (Ley General de Economía Circular or LGEC) last year, and the proposed LGEEPA reform appears designed in part to harmonize environmental policy with that newer framework. The draft defines circular economy as a sustainable production and consumption model aimed at reducing environmental impacts through the reintegration and continued use of materials and products within both technical and biological cycles. While the LGEEPA draft does not itself create a detailed operational circular economy regime, it signals a broader policy integration between environmental protection, waste reduction, resource efficiency, sustainable production, and climate objectives. This reflects a wider regional and global shift toward embedding circularity principles into core environmental legislation rather than treating them solely as waste-management concepts.

Notably, however, the current draft still does not meaningfully engage with the broader chemicals-management agenda where Mexico increasingly lags behind several Latin American jurisdictions, including Peru, Chile, Colombia, and Brazil. Although the proposal contains more references to “chemical substances” (sustancias químicas) within emissions, hazardous materials, and pollution-control provisions, it does not create a standalone chemicals-management framework, define chemical substances as a regulated category, establish registration or prioritization systems, or introduce modern risk-evaluation mechanisms comparable to developments seen elsewhere in the region and globally. In practical terms, the draft largely preserves the existing LGEEPA structure under which chemicals remain regulated indirectly through hazardous waste, emissions, and industrial permitting frameworks, rather than through a comprehensive lifecycle-based chemicals regime. For companies tracking emerging regulation of industrial chemicals, substances of concern, PFAS, endocrine disruptors, and product-related chemical compliance obligations, the draft therefore represents continuity more than transformation.

Link to Draft:

https://www.herramientasregulatorias.gob.mx/AirConstancia?IdAir=903&tab=tab1&search=Ecologico

Chile: WEEE and Batteries EPR Decree Published — The Clock Is Now Running

It’s taken years, but Chile finally has its EPR decree for electrical and electronic equipment and batteries under Law 20.920. Published on May 7, 2026, the decree enters into force immediately. Collection and valorization targets and associated obligations take effect 24 months from publication — May 7, 2028.

Over five years in development, the decree covers four product categories under a single framework: batteries (under 5 kg, excluding lead-acid), electrical and electronic equipment, temperature exchange equipment, and photovoltaic panels — the last of which receives its own dedicated regulatory treatment, a notable development given the explosive growth of solar infrastructure in Chile and the hazardous material content of end-of-life panels.

• Who is Covered

EPR obligations apply to all producers introducing covered products into the Chilean market — manufacturers, importers, brand owners, and professional-use importers. Microenterprises as defined under Law 20.416 are exempt from collection and valorization targets, though not from reporting obligations. Key exclusions include military equipment, large fixed industrial installations, and road vehicles requiring circulation permits. Solar parks are explicitly not considered large fixed installations — photovoltaic panel producers are in scope.

• Collection and Valorization Targets

The decree establishes a gradual ramp-up of targets tied to products introduced into the market:

For batteries and general electrical and electronic equipment, starting at 3% in year one, rising to 45% from year ten onward. For temperature exchange equipment, starting at 6% in year three, reaching 30% from year nine. For photovoltaic panels, starting at 10% in year three, reaching 50% from year ten — calculated using a Weibull distribution formula that accounts for the long and variable lifecycle of panels rather than a simple three-year average.

• Management Systems

Compliance must flow through authorized management systems — individual or collective. The decree creates a specific category of Large Collective Management Systems (GRANSIC) for systems with 20 or more unrelated producers. GRANSICs have broader flexibility in how they meet targets and carry the most demanding geographic coverage obligations, including nationwide household collection campaigns reaching at least 80% of Chilean households by year five, and drop-off infrastructure in municipalities based on population thresholds — starting with cities over 500,000 in year one, reaching all municipalities over 150,000 by year four.  These GRANSIC are already a part of EPR landscape in Chile under the packaging decree.

Two collective management systems are already in formation — TRAEE and Wee Chile — and management plans must be submitted within 15 months of publication.

• Hazardous Substance Limits for Batteries

The decree introduces Chile’s first explicit concentration limits for hazardous substances in batteries, aligned with the EU Battery Regulation: maximum 0.0005% mercury by weight and 0.002% cadmium by weight. Batteries for emergency equipment, alarms, and medical devices are exempt.

• Reporting Obligations Already Apply

As we noted previously, producers of electrical and electronic equipment and batteries are already subject to annual market introduction reporting obligations under Resolution 4771/2025, independent of the target compliance timeline. That obligation remains in effect.

• What’s Next

The 24-month window before targets kick in is structured and sequential — not a grace period. Management system plans must be submitted within 15 months. Collective systems must obtain Competition Tribunal authorization before they can begin operating. Industrial consumers who wish to self-manage their waste streams must declare that intention within 18 months. The strategic organization phase starts now.

Link to Decree: https://www.diariooficial.interior.gob.cl/publicaciones/2026/05/07/44443/01/2805526.pdf

Colombia: Animal Testing Ban for Cosmetics Now Has Teeth

As we have noted in other editions, bans on animal testing are a regional trend with Brazil, Chile, and Colombia enacting measures.  In Colombia, Law 2047 of 2020 banned animal testing for cosmetics — but without implementing regulations, enforcement was limited. That changes with Resolution 0814 of 2026 which establishes the technical requirements that make the prohibition operational.

• The New Requirement

The centerpiece is a mandatory first-party declaration of conformity to be submitted to INVIMA — Colombia’s national food and drug authority. The declaration must certify that neither the finished product nor any of its ingredients have been subject to animal testing. It applies to anyone manufacturing, importing, or commercializing cosmetics in Colombia, including parallel importers.

The declaration is tied to the Mandatory Sanitary Notification (NSO) and carries the same validity period. It is strictly mandatory for new NSO applications and all renewals. For modifications to existing NSOs it is voluntary — for now.

INVIMA will verify the declaration at all stages of sanitary control. Absence of the document will result in either an information request or outright rejection of the procedure.

• Exceptions

The regulation contemplates two narrow exceptions where animal testing data may be accepted, subject to technical justification before INVIMA: where an ingredient requires safety testing due to health or environmental risk and no validated alternative exists; and where the safety data were generated for a purpose other than cosmetics.

• Key Take-Away for Companies

For cosmetics companies selling into Colombia — whether as brand holders, manufacturers, or importers — the declaration requirement is now a hard compliance step for any new NSO and every renewal. Supply chain documentation tracing ingredient testing history will need to be in order. INVIMA has published a model declaration format to facilitate the process.

Link to Declaration Format: https://www.invima.gov.co/biblioteca/formato-ii-declaracion-conformidad-resolucion-814-de-2026xlsx

Argentina/MERCOSUR: Two More Substances Banned from Cosmetics — The EU Signal Pattern Continues

A pattern worth naming: safety signals from the EU are becoming law across Latin America, often moving through MERCOSUR’s harmonization machinery before landing in national regulation. The gel nail products category is a clear example — and Argentina just added another chapter.

ANMAT published Disposition 2820/2026 on May 15, 2026, incorporating MERCOSUR Resolution GMC 27/25 into Argentine national law. The measure adds two substances to the regional list of components prohibited in personal hygiene products, cosmetics, and perfumes:

• Trimethylbenzoyl diphenylphosphine oxide (INCI: trimethylbenzoyl diphenylphosphine oxide, CAS 75980-60-8)
• N,N-dimethyl-p-toluidine (CAS 99-97-8)

Both are photoinitiators and chemical accelerators used in gel nail and UV-cured nail products. Both were banned in the EU on September 1, 2025, due to their classification as carcinogenic, mutagenic, or toxic to reproduction (CMR). That EU ban triggered an immediate cascade across Latin America — Costa Rica, Chile, Colombia, and Peru all took action within weeks, and Brazil formally banned both substances in October 2025. We have been tracking this story from the beginning:

• September 2025: CMR concern spreads to Latin America — ambientelegal.com/ghs-in-latam-cmr-substances-mexico-and-brazil-on-pesticides-pcbs-cosmetics-used-tires-epr-climate-change-chemical-safety
• November 2025: Brazil bans CMR substances in gel nail products — ambientelegal.com/plastics-chemicals-cosmetics-personal-care-cleaners-regulatory-roundup-pesticides-sustainable-standards
• December 2025: Chile issues recall alert for nearly 35 nail polish products — ambientelegal.com/water-rights-for-industry-cosmetics-recalls-for-cmr-ingredients-ecolabeling-epr-rules-tighten

Argentina’s action through MERCOSUR now formalizes the regional prohibition at the bloc level. Companies with products already holding NSO authorization in Argentina have 60 days from publication to update formulations and registrations.

The broader takeaway is consistent: EU hazard signals on cosmetic ingredients are not staying in Europe. They move — through MERCOSUR harmonization and national regulatory action — into binding restrictions across Latin America, often within months. Cosmetics companies selling in the region should be monitoring EU restriction proposals as an early warning system for what is coming.

Link to Disposition: https://www.boletinoficial.gob.ar/detalleAviso/primera/342011/20260515?busqueda=1

Argentina: Cosmetics and Cleaning Products in Focus

On May 8, 2026, ANMAT published two dispositions on the same day, each incorporating a recent MERCOSUR resolution into Argentine national law. Together they update the regulatory frameworks for two broad product categories — cosmetics and household sanitary products — in a single sweep of regional harmonization.

• Cosmetics, Personal Care, and Perfumes — Disposition 2576/2026

ANMAT incorporated MERCOSUR Resolution GMC 35/22, updating the lists of permitted and restricted substances for personal hygiene products, cosmetics, and perfumes. The substantive changes are targeted but relevant to formulators and importers:

• Zinc Pyrithione — conditions of use updated, limiting concentration to 1% in rinse-off hair products with an anti-dandruff function.
• Climbazole — newly authorized as an anti-dandruff ingredient in rinse-off shampoos at a maximum concentration of 2%.
• New prohibited substances — additional substances added to the list of components that may not be used in these product categories.

The disposition also amends and partially replaces prior ANMAT dispositions 7885/2022 and 6365/12.

Link to Disposition: https://www.boletinoficial.gob.ar/detalleAviso/primera/341712/20260508?busqueda=1

• Household Cleaning Products — Disposition 2577/2026

ANMAT incorporated MERCOSUR Resolution GMC 36/22, updating the regulatory framework for household sanitary products — a broad category covering cleaning, disinfection, deodorization, and pest control products for home, office, and public spaces, including bleaches, detergents, insecticides, waxes, and air fresheners.

This update is a comprehensive overhaul rather than a targeted amendment. Six prior MERCOSUR resolutions dating back to 1996 are expressly revoked — GMC Resolutions 25/96, 26/96, 27/96, 35/99, 56/00, and 24/05 — replacing a fragmented regulatory history with a single updated framework. One specific change worth noting: Article 18 of ANMAT Disposition 1112/13, covering labeling of products intended for the food industry, has been updated.

Link to Disposition: https://www.boletinoficial.gob.ar/detalleAviso/primera/341698/20260508

Both regulations enter into force simultaneously across all MERCOSUR member states, 30 days after official communication by the MERCOSUR Secretariat. The effective date will be confirmed through the Official Gazette. For companies manufacturing, importing, or distributing any of these product categories in Argentina and across MERCOSUR, a review against the updated frameworks is warranted now.

Mexico: COFEPRIS Continues Regulatory Simplification Push

COFEPRIS has published another round of administrative simplification measures — the latest in an ongoing effort by Mexico’s federal health regulator to streamline the procedures companies must navigate to bring regulated products to market. The Agreement, published May 4, 2026, enters into force 30 business days after publication.

For companies in food, cosmetics, pesticides, and related regulated product categories, the practical changes include:

• Food additive and cosmetic ingredient list requests — three separate procedures for incorporating additives, food supplement coadjuvants, permitted/restricted cosmetic ingredients, and plant ingredients for teas and infusions are merged into a single unified procedure, with processing time reduced from 40 to 30 business days.
• Advertising permits — permit and notice procedures for food and non-alcoholic beverages, cosmetics, and health product advertising consolidated into streamlined unified procedures. Advertising permits for food and non-alcoholic beverages cut from 20 to 15 business days.
• Pesticide and plant nutrient registrations — updated requirements for technical pesticide registration, equivalency registrations, and export-only registrations, with administrative modification processing time cut from 30 to 15 business days.
• Import product sampling and release — processing time cut dramatically from 90 calendar days to 3 business days.
• Physical document requirements eliminated — dozens of procedures no longer require physical submission of supporting documents, with information instead captured digitally.

The agreement also consolidates and simplifies a range of health establishment licensing and other health services procedures, as well as pharmaceutical and medical device-related processes.

COFEPRIS has been steadily building out this simplification agenda — this agreement follows earlier rounds published in April 2025, July 2025, and October 2025. The cumulative effect is a meaningfully lighter administrative footprint for companies managing multi-product regulatory portfolios in Mexico.

Link to Agreement:

https://www.dof.gob.mx/nota_detalle.php?codigo=5786603&fecha=04/05/2026

Chile: Mandatory Certified Plastic Product Label Coming

Anybody working in consumer products and packaging knows the nightmare posed by the patchwork of product labeling requirements.  Increasingly we see EPR trends like recycled content and recyclability requirements driving complexity – and cost – for companies putting covered products on the market.  Add to your radar Chile’s Single-Use Plastics Law 21.368 that requires that certified plastic products carry a mandatory label.  The Ministry of Environment is now collecting industry input on what that label must look like graphically. A 15-business-day public information period opened May 7, 2026. The final label specification is due by approximately July 2026.

• Who This Applies To

Companies manufacturing or importing single-use products that use or qualify as certified plastic in Chile — packaging, food service items, single-use containers, bottles – are on the hook. A certified plastic under Chilean law is one that is at least 20% derived from renewable resources and is compostable at home, industrially, or both.

• What the Label Must Include

The implementing Regulation already defines the required content:

• The phrase “Certified plastic Law 21.368”
• A unique certificate identification number
• Either “Compostable” or “Compostable industrially” depending on the product’s compostability level

What is still being defined — and what this consultation is about — is the graphic expression: dimensions, font size, placement, and exceptions for small-format products where standard sizing would be impractical.  As anyone in industry knows, these details are where the real rubber hits the road.

• Why It Matters

The label specification that comes out of this process will be a hard compliance requirement. Sizing, placement, and legibility exceptions have direct packaging design implications. Companies with products in scope should review the requirements and consider submitting input before the consultation closes.

Link to Resolution: https://www.diariooficial.interior.gob.cl/publicaciones/2026/05/07/44443/01/2805379.pdf

Argentina: Chemical Precursor Registration Requirements Updated

Argentina’s Ministry of National Security published Resolution 424/2026 on May 8, 2026, updating the General Obligations and Requirements Regime for the National Chemical Precursors Registry. The resolution enters into force immediately upon publication.

The change is procedural but meaningful. Under the prior framework, companies registering or re-registering to handle chemical precursors were required to demonstrate their facility conditions primarily through documentation issued by municipal or local authorities. The resolution acknowledges that this model has produced regulatory asymmetries, administrative delays, and compliance burdens disproportionate to the actual risks involved.

The update introduces an alternative accreditation mechanism: companies may now satisfy facility condition requirements by presenting a Comprehensive Technical Safety and Risk Management Report signed by a qualified professional. The report must objectively assess operational risks and the risk of substance diversion — aligning the framework with a modern, risk-based regulatory approach.

This does not eliminate existing requirements — it adds a technically grounded alternative pathway that reduces dependence on municipal permitting timelines and inconsistencies across jurisdictions.

For companies handling chemical precursors in Argentina, the practical implication is a more flexible and predictable registration process. Companies currently navigating re-registration should assess whether the new technical report pathway is more efficient for their circumstances.

Link to Resolution:

https://www.boletinoficial.gob.ar/detalleAvise/primera/341698/20260508

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