On January 19th, 2026, a Decree was published in the Official Gazette of the Federation (the “Act”), enacting the General Circular Economy Act and amending various provisions of the General Act of Ecological Balance and Environmental Protection (“LGEEPA”, for its acronym in Spanish) and the General Act for the Prevention and Integral Management of Waste (“LGPGIR”, for its acronym in Spanish). The Decree entered into force the day following its publication.
The new Act and amendments incorporates a new obligation of circular economy model as a cross-cutting axis of the country’s environmental and productive policy, with direct and significant impact on real estate, construction, industrial, and infrastructure projects, particularly at the planning, design, construction, operation, and materials and waste management stages.
We list here below some relevant items of the amendments:
- Circular Economy as a mandatory regulatory policy. The Act introduces the Circular Economy model as a national public policy, requiring economic activities to incorporate criteria aimed to an efficient use of materials, the extension of the useful life of products and components, the recovery and valorization of waste, and the reduction of virgin material use where environmentally, technically, and economically feasible.
- New obligations for productive sectors. Productive sectors will be gradually subjected to Extended Producer Responsibility (“REP”, for its acronym in Spanish) schemes, which may translate into obligations related to a circular product and material design, waste management and recovery, as well as the preparation and registration of Circular Management in the Circular Economy Registry, when the relevant sector or product is regulated through specific agreements.
- Impact on real estate and construction projects. While the Act does not replace existing environmental permits, such as environmental impact assessments, it is incorporated as a new axis of regulatory compliance requirement. In particular, it may affect the selection and use of construction materials, the management and valorization of construction waste, the incorporation of secondary raw materials, and the potential imposition of future conditions in environmental and urban authorizations. Likewise, the amendments to the LGEEPA reinforce the principle that the use of natural resources and materials must align with circular economy criteria.
- Oversight and enforcement powers. Non-compliance with the obligations set forth in the new Act will be sanctioned in accordance with the regime established under the LGEEPA, without limitation to other administrative or environmental liabilities, thereby increasing the regulatory exposure of projects.
- Pending regulations and implementing provisions. The Federal Executive shall issue the Regulations to the General Circular Economy Act within 180 calendar days following its entry into force, as well as issue official Mexican standards and sectoral agreements that will define the specific scope of obligations for each industry.
The enactment of this Act marks a structural shift in the environmental regulation applicable to real estate and industrial projects in Mexico. Proper regulatory anticipation from a planning stage will be critical to mitigate risks, costs, and delays in project execution.
To analyze the specific impact of this new laws on current or future projects, as well as to design regulatory compliance strategies, we remain at your disposal. Should you require additional information or assistance in assessing the impact of this new regime on your operations, our professionals at Cuesta Campos are available to assist.
Contact
Berenice Soto García
Héctor Ceballos González
THE ABOVE IS PROVIDED AS GENERAL INFORMATION PREPARED BY PROFESSIONALS WITH REGARD TO THE SUBJECT MATTER. THIS DOCUMENT ONLY REFERS TO THE APPLICABLE LAW IN MEXICO. WHILE EVERY EFFORT HAS BEEN MADE TO ENSURE ACCURACY, NO RESPONSIBILITY CAN BE ACCEPTED FOR ERRORS OR OMISSIONS. THE INFORMATION CONTAINED HEREIN SHOULD NOT BE RELIED ON AS LEGAL, ACCOUNTING OR PROFESSIONAL ADVICE BEING RENDERED.
