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Chemical Precursors, Hazardous Substances, Pesticides, Import/Export, Cosmetics, Personal Care Products

Mexico Reforms Authorizations for Hazardous Materials, Pesticides, Waste and More

Calling all companies with plants in Mexico – including maquiladora facilities.  You need to take note.  Mexico’s national environmental agency (SEMARNAT) just published reforms of 39 environmental permits and procedures.  SEMARNAT’s modernizations are part of a broader move by federal agencies to streamline bureaucracy by cutting down on the number of permits, moving to electronic submission of documents, ending the need for simple copies and document comparisons, and merging related processes to reduce overlap in permits.

The changes impact the following areas:

  • Forestry management
  • Air emissions
  • Wildlife
  • Hazardous materials, including pesticides, toxics, and plant nutrients, and hazardous waste

For our purposes, let’s look a bit more in detail at the hazardous materials, substances, and waste provisions.  These include reforms to:

  • Authorizations for hazardous materials and substances – including pesticides, toxics, and plant nutrients – (import, export, handling, and storage) are streamlined, with previously separate applications and extensions now unified into clearer, more efficient processes.
  • Cross-border movement of hazardous waste now uses consolidated procedures for authorizations, modifications, extensions, and reporting, replacing multiple overlapping formats.
  • Facility suspension and closure notices for generators and service providers of hazardous waste are merged into a single, simplified notification process covering suspension, partial closure, and final shutdown.
  • Remediation proposals and program conclusions for contaminated sites—whether due to emergencies or environmental liabilities—are combined into a single procedure that covers proposal submission, follow-up, and formal closure.

The published reforms go into effect on December 11, 2025.

Link to reforms:

https://www.dof.gob.mx/nota_detalle.php?codigo=5773501&fecha=20/11/2025#gsc.tab=0

Mexico: Major Reforms for Controlled Substances & Chemical Precursors

Anyone active in chemicals understands that the controls on so-called chemical precursors and essential chemicals impact a broad swath of industry and products from cosmetics to adhesives.  Mexico has had controls on narcotics and substances that can be used to derive narcotics (the “precursors” and “essential” chemicals) for decades.  Now, the agency tasked with their regulation, COFEPRIS, has joined the greater national move toward slashing red tape and moving processes online (notably to the SISUS platform and the federal “Citizen Portal” or Portal Ciudadano Único).

The new rules accomplish their modernization by the elimination of 44 physical documentation requirements, consolidation of 18 homoclaves (unique process codes) into 13, and introduction of the homoclave “COFEPRIS-03-022” for regulated activities of essential chemical products (via the SISUS platform), plus “COFEPRIS-03-021” for authorizng use or sale of narcotics/psychotropics. Once the digital system is operational, those procedures will migrate into it.

The changes call for reducing official response times for multiple key procedures (e.g. import/export/acquisition permits, verification designations, electronic recetario permissions, annual forecasts, control books, permit modifications and new authorizations), in many cases cutting deadlines by half or more, and in others making the response “immediate” once fully digitalized.

Although most of the substantive changes are to enter into force 30 business days from the November 18th publication date, many of the improvements won’t really materialize until the SISUS and digital systems are fully operational.  Until then, certain documents (e.g., control books, recetarios, existing permits, and SEMARNAT authorizations for destruction) must still be presented physically.

Companies active in Mexico who handle chemical precursors or essential chemicals should become familiar with the reforms even if the new system is not yet fully operational.  In periods of transition, compliance often requires more effort to ensure that filings don’t fall between the cracks.

Link to reforms:

https://www.dof.gob.mx/nota_detalle.php?codigo=5773158&fecha=18/11/2025#gsc.tab=0

New Rules on Cosmetics & Hygiene Products in Ecuador

Major regulatory changes sometimes go through a few revisions before they are final.  Ecuador’s National Health Regulation Agency (ARCSA) in in the midst of major changes to the requirements for the Mandatory Sanitary Notification (NSO) of:

✔️ Cosmetics

✔️ Household hygiene products

✔️ Personal hygiene absorbent products

In September, ARCSA posted a draft for public comment.  Now, the agency has released a second draft for public comment.

This DRAFT is still really big – setting out five annexes based on Andean Community legislation that covers:

  • Guide to requirements for obtaining NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products (check out the new guidance on cannabis-derived ingredients and electronic signatures).
  • Guide to requirements for joining an existing NSO (as a parallel importer).
  • Guide to requirements for renewing NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products.
  • Guide to requirements for recognition of the NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products.
  • Guide to requirements for modifying the information in the NSO for cosmetic products, household hygiene products, and absorbent personal hygiene products.

The current version of the Draft (V4) keeps the structure but introduces significant improvements, including:

  • Expansion and clarification of technical requirements.
  • New documentary obligations.
  • Inclusion of specific regulatory references.
  • More detailed procedures.
  • New scenarios considered (e.g., stock depletion).

The current public comment period runs until November 27, 2025.

📌 Key Take-Away: If you operate in the cosmetics or hygiene sector in Ecuador (as a manufacturer, importer, or distributor – or parallel importer), these changes impact you directly.

Link to Proposal:

https://www.controlsanitario.gob.ec/wp-content/uploads/downloads/2025/11/8.-Borrador_IE_Requisitos_Cos.PHD_V4.pdf

LATAM “REACH”

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Melissa Owen

For over 25 years, she has advised companies as well as international trade associations on emerging chemical regulations, Circular Economy, Extended Producer Responsibility, product stewardship and a myriad of other regulatory topics. She serves as acting regional counsel for companies with Latin American business.  She is a recognized expert on law in Latin America and a frequent speaker at international events about issues ranging from law for inhouse counsel to emerging chemical regulations.”

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