Mexico Enacts First Circular Economy Law:  Deep Dive

On January 19, 2025, Mexico enacted its first Circular Economy Law setting a nationwide framework to extend product life cycles, reduce waste, and promote the reuse, repair, recycling, and valorization of materials

High Level Overview:

• ♻️ Extended Producer Responsibility (EPR): Producers and importers must design, register, and implement Circular Management Plans covering the full life cycle of their products.
• 📊 Lifecycle & footprint focus: Mandatory use of life-cycle analysis, circularity indicators, and environmental footprint reduction.
• 🏷️ National Circular Economy Label: A new official label to identify compliant products, with procurement advantages in public purchasing.
• 🤝 Shared responsibility: Involves federal, state, and municipal governments, the private sector, consumers, and informal recyclers through inclusive recycling models.
• 📈 Gradual implementation: Phased obligations by sector and product type, with flexibility for SMEs.
• 🌱 Economic incentives & innovation: Encourages circular business models, secondary raw materials markets, and technological innovation.

Business Responsibility & Extended Producer Responsibility (EPR)

Two key pillars of the new system are repairability and EPR.

The Law defines them as follows:

• Repairability: Ensures that products are designed, manufactured, distributed, imported, and marketed by providing clear and accessible information on the possibility of repairing them; the availability of spare parts, tools, replacement parts, and places where they can be repaired.
• Extended Producer Responsibility: An obligation that applies in a complementary and non-exclusive manner to other obligations of public entities and individuals under the terms defined in this Law;

Here is what the Law says about industry’s role and responsibility.

• Circular design obligation: Producers must design and develop products using Circular Design principles, where environmentally, technically, and economically feasible.
• Mandatory EPR schemes: Producers and importers are responsible for organizing, promoting, and financing circular economy systems for their products, including waste recovery and the reintegration of secondary raw materials into value chains.
• Shared but non-substitutable responsibility: Producer obligations under EPR complement—and do not replace—shared responsibilities of consumers and authorities under existing waste laws.
• Role of Coordinating Organizations: Authorized Organismos Coordinadores are responsible for promoting circular strategies, supporting compliance, co-developing Circular Management Plans, and are jointly liable under EPR.
• Mandatory registration: Producers, importers, or their coordinating organizations must register a Circular Management Plan in the National Circular Economy Registry, covering the full product life cycle, including design.
• Two compliance pathways: Direct compliance: Producers implement circularity measures themselves. Indirect compliance: Producers comply via third parties through sustainable value-chain agreements or environmental compensation.
• Environmental compensation as a fallback: When direct or indirect compliance is not feasible, EPR obligations may be met through proportional environmental compensation, subject to regulatory approval.
• Eligible compensation measures include: Ecosystem restoration and conservation Environmental damage remediation Reforestation Emissions reductions Certified instruments (e.g., green bonds, carbon credits)
• Regulatory oversight: Detailed procedures, eligibility criteria, and supervision mechanisms will be defined in the Regulations and EPR implementation agreements.

The Critics

Not everyone is a fan.  International environmental NGOs have released comments to the effect that the new measure does not go far enough – including the inclusion of Waste-to-energy (burning waste to generate electricity) as a viable means of waste recovery.

Interplay with Existing EPR Schemes

Mexico is not entirely new to EPR responsibilities – including existing NOMs on Special Management Wastes like electronics and batteries.  The new Law calls for the modification of existing NOMs – so companies need to be aware of the changing compliance landscape during the transition.

Next Steps

A new law as big as this one will not be implemented overnight.  We are entering a transition phase.  Here is what the Law sets out as the government’s next steps:

1. Issue implementing regulations: Within 180 days of the law’s entry into force, the Federal Executive must publish the Regulation(s) of the General Circular Economy Law.
2. Update technical standards (NOMs): Federal authorities must begin procedures to amend existing Mexican Official Standards (NOMs) and develop new ones aligned with circular economy requirements, following Article 6(III).
3. Publish the National Circular Economy Program: Within 180 days after the Regulation is published, the National Circular Economy Program (2026–2030) must be issued, explicitly identifying priority sectors and product categories, including plastics.

Key Take Away:

Companies selling products in Mexico must be prepared to design products for circularity and take full, lifecycle responsibility for their environmental impact—including registering and implementing Extended Producer Responsibility (EPR) plans, either directly or through approved partners, with compensation required if circular compliance is not feasible.

Link to new Law:

https://www.dof.gob.mx/nota_detalle.php?codigo=5778439&fecha=19/01/2026#gsc.tab=0

Mexico’s 2026 Legal Reforms: Market Entry Is No Longer Business as Usual

Mexican legal reforms enacted in late 2025 and early 2026 may appear unrelated at first glance.

New tariffs. Sweeping Customs Law reforms. A major overhaul of the Federal Health Law and stronger COFEPRIS enforcement.

Taken together, they tell a clear story.

Mexico is moving decisively toward stricter controls, mandatory due diligence, and stronger government oversight—before products ever reach the market.

• Tariffs: A Strategic Shift

As of January 1, 2026, Mexico imposed steep new duties on more than 1,400 tariff lines from countries without a free trade agreement, including China, India, Vietnam, Brazil, and others.

These measures are widely viewed as part of Mexico’s broader trade alignment with the United States and reflect a shift toward tighter origin and supply-chain discipline.

• Customs Law Reforms: Compliance Moves Upstream

Major Customs Law reforms, also effective January 1, 2026, fundamentally change the role of customs agents.

Agents now carry expanded responsibility and liability, leading them to impose new testing, certification, and due-diligence requirements on importers. For many companies, this has become a new barrier to market entry.

The reforms expand customs authority, mandate electronic filings and inventory controls, and introduce penalties of up to 300% of a product’s commercial value.

• Health Law Reform and COFEPRIS: Stronger Enforcement

Mexico’s Federal Health Law reform centralizes planning, expands digital health regulation, and strengthens sanitary oversight.

At the same time, COFEPRIS now exercises expanded powers, including emergency authorizations, stricter manufacturing verification, and enhanced post-market surveillance of medical devices.

Oversight of controlled substances has also intensified, with expanded lists and heightened monitoring of opioids, synthetic drugs, and cannabis derivatives.

The Bottom Line

Across trade, customs, and health regulation, Mexico is moving in a single direction:

Higher compliance expectations, deeper due diligence, and stronger state control—before products ever reach the market.

Market entry in Mexico is no longer transactional. It is compliance-driven from day one.

Brazil RoHS News

Brazil continues to move forward with its long-awaited version of the EU’s Restriction on Hazardous Subtances in Electric and Electronic Products (Brazil RoHS).  The National Environment Council (CONAMA) is the group tasked with getting out the regulation.   As a reminder, the draft underwent public consultation (Aug–Sept 2025), and it received over 180 contriobution.

The latest news is that the government has had a chance to review the comments – and has revised the text to reflect stakeholder feedback.  A consolidated response matrix and updated text have now been forwarded for evaluation by CONAMA’s Environmental Quality Technical Chamber – and are available for download! The item is on the agenda for the next meeting of that technical chamber set for January 28, 2026.

Link to revised draft and analysis:

https://conama.mma.gov.br/index.php?option=com_sisconama&view=reuniao&id=2722

EPR News from Chile

Chile continues to flesh out the regulatory infrastructure needed for full implementation of its 2016 law on Extended Producer Responsibility.  The latest brick in that wall is the issuance regulation with a simplified sanitary authorization process for the collection, reception, storage, and pre-treatment of non-hazardous waste from priority products , carried out by authorized and registered waste managers under Law No. 20.920.  It defines the timelines, conditions, and requirements that regulated entities must meet to obtain the corresponding sanitary authorization.

As a reminder, priority products in Chile includes:

• Lubricating oils
• Electrical and electronic equipment
• Batteries
• Packaging and containers
• Tires
• Newspapers and magazines
• Textiles

Link to Regulation:

https://www.diariooficial.interior.gob.cl/publicaciones/2026/01/14/44348/01/2748564.pdf

Brazil Steps Up and Out on Control of Agrochemicals

Last year, Brazil issued a rafter of new and revised standards on agrochemical products, pesticides and bio-inputs, coming from ANVISA, IBAMA, and MAPA.  Now, as the new year gets underway, ANVISA reports the launch of its new strategy to optimize toxicological reviews with in-person, on site technical inspections to verify the accuracy of data submitted in agrochemical registrations. The first visit took place in December 2025, completing the rollout of the optimized methodology under RDC 950/2024, which has already cut review times and reduced the backlog by 75% (≈750 cases).

Building on those results, Anvisa expanded the approach through RDC 1.005/2025 to additional product categories, using digital tools (FLORA and DCIPA) and clear transition deadlines into 2026. The result: greater efficiency, no added regulatory cost, and enhanced post-market oversight, reinforcing data integrity and public health protection.

Given the historically long timelines to bringing these regulated products to market, industry can only hope that new approach continues to cut down those years-long delays.

EPR in Brazil: New System to Modernize Reporting

Brazil is a regional leader in Extended Producer Responsibility – referred to there as “Reverse Logistics” – requiring industry to manage a long list of end-of-life products and packaging.  Now the national government is bringing all together what have historically been disparate plans with the development of SISREV-BR, the new National Reverse Logistics System.  The new system will digitally support the National Reverse Logistics Program. The platform will centralize reporting from all reverse logistics programs into a single national database, replacing PDF submissions with streamlined online forms and significantly improving data quality, transparency, and administrative efficiency.

SISREV-BR will also integrate with other federal government platforms to automate key metrics—such as the Recycled Content Index established under Decree No. 12,688/2025—reducing reporting burden while strengthening compliance. The draft ordinance establishing the system is now open for public consultation from January 17 to 31, 2026.

Link to proposal:

https://brasilparticipativo.presidencia.gov.br/processes/sisrev/f/2987

Climate Change & Worker Protection:  Heat Exposure

The rising temperatures and number of days of extreme heat continue to increase around the globe.  The impact on workers and their health cannot be ignored.  Chile recently published an update to its occupational health and safety rules that include a new provision on worker health during extreme heat.

Now, employers will be required to protect workers’ health from high and extreme temperatures, based on official heat alerts issued by the Meteorological Directorate of Chile and Senapred. Employers will need to monitor heat alerts daily, assess heat exposure risks across job roles, and develop—together with their occupational risk administrator and worker participation—a heat management and emergency response plan that includes preventive, mitigation, and response measures, without replacing ongoing thermal stress evaluations or immediate measures ordered by authorities.

Link to regulation:

https://www.diariooficial.interior.gob.cl/publicaciones/2026/01/16/44350/01/2749490.pdf

LatAm “REACH” is now in reach

Check out AMBIENTELEGAL ACADEMY — designed for professionals who need clarity, not theory.

📌 New self-paced video courses, with downloadable reference materials you can keep:

• Crash Course on Colombia “REACH”
• Crash Course on Chile “REACH”

📌 Essential regulatory documents — translated into English so you save time and avoid misinterpretation:

• Brazil “REACH” Law
• Colombia “REACH” Registration Instruction Guides
• Chile “REACH” Registration Instruction Guides

👉 Access the courses and downloads here: https://lnkd.in/g3RiBRG3

© 2026. All rights reserved. This publication is protected by copyright and monitored by AI-powered content tracking systems. Unauthorized use, reproduction, or distribution is strictly prohibited.