Mexico’s New Water Law: Industry Beware
On December 11, 2025, Mexico published a massive new General Water Law and major reforms to the existing Law of National Waters. Now, water will be recognized as a human right.
The new General Water Law has significant implications for industry in Mexico because it firmly prioritizes human consumption and ecosystem protection over industrial and commercial water use, especially in cases of scarcity. Industrial water concessions, renewals, and allocations are now explicitly subject to the human right to water, meaning authorities may reduce or revoke permitted volumes if water availability is threatened for domestic use, increasing regulatory risk for water-intensive sectors
At the same time, the law raises expectations for water efficiency, responsibility, and sustainability across industry. It strengthens oversight of concessions, promotes water reuse, treatment of wastewater, rainwater harvesting, and nature-based solutions, and embeds concepts such as water security and hydric responsibility into governance. For companies, this translates into a stronger incentive—and in some cases a necessity—to invest in efficient water management, compliance systems, and resilient supply chains aligned with long-term water availability and climate risk in Mexico
Given the important industrial development in drought-prone portions of the country and the water dependent activities (like agriculture) in wetter areas, companies across the country need to review this new law in detail and take stock of their water concessions and the efficiencies of their operations.
Link to new law:
https://www.dof.gob.mx/nota_detalle.php?codigo=5775799&fecha=11/12/2025#gsc.tab=0
Cosmetics: CMR Ingredients in Nail Polish Leads to More Recalls
Regulators in Latin America are very tuned into – and responsive – to agendas abroad. Earlier this year, we reported how several countries, including Mexico, Peru, and Ecuador, moved to ban or limit food colorants based on the decision by the U.S. to take action on FD&C Red No. 5.
Similarly, the September 1st EU ban on gel nail polish containing trimethylbenzoyl diphenylphosphine oxide, or TPO, and N, N-dimethyl-p-toluidine (DMPT) because of their classification as carcinogenic, mutagenic, or toxic to reproduction (CMR) caused several countries in Latin America to take action to ban or restrict similar products.
Chile continues to take action. On November 25th, it issued Cosmetic Alert SP-03/25 calling for the recall of almost 35 different nail polishes for their Dimethyltolylamine (DMTA) content.
Companies need to be aware that hazard signals from the EU or the US will trigger bans and restrictions from national governments in Latin America almost in real time.
Link to Alert:
https://www.ispch.cl/wp-content/uploads/2025/12/ALERTA-COSMETICA-SPC-03.pdf
Ecolabeling for Cleaning Products
Alianza Ambiental de América (Environmental Alliance of America) (AAA) is an international governmental initiative that started over a decade ago from collaboration among Colombia, Costa Rica, and Mexico. Now, with the help of the UN and other international partners, the AAA includes five member countries—Colombia, Costa Rica, Mexico, Ecuador, and Paraguay—while Brazil, Panama, Uruguay, El Salvador, the Dominican Republic, and Honduras have expressed interest in joining the initiative. The aim of the AAA is to promote sustainable consumption and production in Latin America by strengthening consumer information, encouraging eco-labeling, improving product design, and advancing sustainable public procurement across participating countries.
AAA has just released its first Sustainability Criteria for General-Purpose Cleaning Products and Kitchen and Bathroom Cleaning Products.
Although these standards are not binding for any particular country at this time, such a regional initiative represents an important precedent that companies should put on their radar. This type of voluntary standards often serves as inspiration – if not direct reference – for regulators in countries across Latin America. When model standards are available already in their official language (here, Spanish) and have the input of such venerable entities as the UN, regulators are more likely to take notice.
Link to Standards:
Brazil: Higher EPR Take-Back Targets for Sao Paulo State
Brazil’s industrialized state of Sao Paulo already leads the nation in mandatory extended producer responsibility (EPR) for a laundry list of products and packaging. The state pioneered the approach of linking issuance and renewal of state environmental licenses to proof that companies belonged to reverse logistics systems that could show compliance with the state’s ever tightening standards.
As it stands, Sao Paulo state requires EPR for the following products and packaging:
- Pesticide packaging and related products, empty or containing residues
- Lead-acid batteries (excluding industrial batteries and those used in service provision)
- General packaging, including packaging for: Food products, Beverages. Cleaning products and related items, Personal hygiene products, Perfumery, and cosmetics, Over-the-counter household pest control products, Empty architectural paint packaging
- Automotive lubricating oil filters
- Fluorescent lamps, including: Sodium vapor lamps Mercury vapor lamps Mixed-light lamps
- Household medicines for human use and their packaging
- Edible (cooking) oil
- Lubricating oil
- Plastic packaging for automotive lubricating oil
- Portable batteries and cells
- Tires (replacement market)
- Household electrical and electronic equipment and their components, with voltage up to 240 V
The state’s environmental enforcement agency – CETESB – has now ratcheted up the percentage of products placed on the market that must be taken back through these reverse logistics systems for the 2026-2029 period in its latest Directory Decision.
Companies active in any of those listed product categories need to get check their compliance plans to ensure they are up to the task.
Link to Decision:
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