Countries › Mexico › Guide › 13. Regulation › Hazardous waste and the circular economy law in Mexico: generator categories, registration, six month storage limit, SEMARNAT authorizations and extended producer responsibility

Hazardous waste and the circular economy law in Mexico: generator categories, registration, six month storage limit, SEMARNAT authorizations and extended producer responsibility

Last verified: 2026-10-26 · Status: Changing

Every business that generates hazardous waste in Mexico falls into one of three categories by annual volume: large generators (10 tonnes or more) register with SEMARNAT, file a management plan and annual report and carry environmental insurance; small generators (400 kg to under 10 tonnes) register and keep a log; microgenerators register with state or municipal authorities. Waste may be stored for no more than six months, carriers and treatment, recycling and disposal firms need SEMARNAT authorization, and the generator remains jointly liable if it hands waste to an unauthorized operator. The General Law of Circular Economy of DOF 19 January 2026 adds extended producer responsibility: producers and importers must organize and finance circularity schemes for their products and register their circular management in a national platform, with details set by regulations and product specific implementation agreements.

USD conversions use MXN 18.6638 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 23 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Peso amounts set in UMA use the 2026 daily UMA of MXN 117.31, in force since 1 February 2026 (INEGI publication in the DOF of 9 January 2026, as cited in IMSS Technical Council agreement ACDO.AS2.HCT.270126/9.P.DIR). Conversions are for orientation only.

Key facts

Annual hazardous waste volume from which a business is a large generator	10 tonnesLGPGIR art. 5, section XII, as of 2026-10-26 · in force
Annual hazardous waste volume up to which a business is a microgenerator	400 kgLGPGIR art. 5, section XIX, as of 2026-10-26 · in force
Maximum storage period for hazardous waste without extension	6 monthsLGPGIR art. 56, as of 2026-10-26 · in force
Maximum LGPGIR fine (days of minimum wage read as UMA)	50000 UMALGPGIR art. 112, section V, as of 2026-10-26 · in force
Federal duty for a hazardous waste confinement authorization, 2026	134197.72 MXNLFD art. 194-T, section VII, as of 2026-10-26 · in force
Term for the Executive to issue the Circular Economy Law regulations	180 calendar daysLGEC transitory Second, as of 2026-10-26 · in force

The rule

1. Generator categories and duties. Generators of hazardous waste are large (10 tonnes or more gross weight a year), small (400 kilograms or more and under 10 tonnes) or micro (up to 400 kilograms). Large generators must register with SEMARNAT, submit a hazardous waste management plan, keep a log, file an annual report on generation and handling and hold environmental insurance. Small generators must register with SEMARNAT, keep a log of annual volumes and handling, including transfers of waste to industries that use it as an input, and follow management plans where applicable. Microgenerators register with state or municipal authorities, follow local management plans and take waste to authorized collection centers or use authorized transport. Anyone generating or handling hazardous waste must notify the competent authority.
Cost to do it: Registration is an administrative filing; large generators add a management plan, annual report and insurance premium.
Example: A plant generating 12 tonnes of spent solvents and oily rags a year is a large generator: it must register, file a management plan and annual report, and insure. / A small office generating fluorescent tubes and batteries below 400 kg a year is a microgenerator under state or municipal control.Ley General para la Prevención y Gestión Integral de los Residuos (LGPGIR), DOF 8 October 2003, last reform DOF 19 January 2026, Arts. 5, sections XII, XIX and XX, 43, 44, 46, 47 and 48, 2003-10-08 official text · verified 2026-10-26

2. Storage limit and shared responsibility. Hazardous waste may not be stored for more than six months from generation, recorded in the log; an extension may be requested from SEMARNAT. Responsibility for handling and final disposal lies with the generator. Generators may hire firms authorized by SEMARNAT or transfer waste to industries that use it as inputs under an authorized management plan, but share joint responsibility; once waste is delivered to an authorized firm, that firm is responsible for its operations, without removing the generator's own responsibility. Generators must check with SEMARNAT that the provider holds valid authorizations, or they answer for damage caused by the handling. Mining and metallurgical waste is the generator's responsibility, with verifiable evidence of compliance.
Cost to do it: Contracting authorized carriers and disposal firms; checking their authorizations is a low cost control.
Example: Drums of waste generated in January must leave the site by July unless SEMARNAT grants an extension. / Using a cheaper unlicensed hauler leaves the generator liable for any dumping.LGPGIR arts. 42 (reformed DOF 8 May 2023) and 56, Arts. 42 and 56, 2023-05-08 official text · verified 2026-10-26

3. Activities needing SEMARNAT authorization and 2026 fees. Authorization is required to provide hazardous waste handling services, use hazardous waste in production processes, collect and store third party waste, incinerate, transport, build on site confinement, use thermal treatment, transfer authorizations, and import or export hazardous waste. Federal fees per application in 2026: collection and transport units MXN 6,137.82; collection and storage centers MXN 6,134.51; recycling or co processing MXN 3,872.69; reuse MXN 3,872.69; treatment MXN 10,111.10; incineration MXN 81,499.65; confinement or final disposal MXN 134,197.72; handling services MXN 9,590.09. Transfers, modifications or extensions pay 50 percent.
Cost to do it: From MXN 3,872.69 (USD 207) for recycling to MXN 134,197.72 (USD 7,190) for confinement, per application.
Example: A recycler of used lubricants applies for a recycling authorization (MXN 3,872.69) and, if it collects from clients, a transport authorization (MXN 6,137.82). / Total about USD 536.LGPGIR art. 50; Ley Federal de Derechos art. 194-T; Resolución Miscelánea Fiscal para 2026, Annex 4, DOF 28 December 2025, LGPGIR art. 50; LFD art. 194-T, 2025-12-28 official text · verified 2026-10-26

4. Infringements and sanctions. Sanctionable conduct includes handling, storing, transporting, treating or disposing of hazardous waste without authorization; breaching handling rules, the Circular Economy Law or extended producer responsibility agreements; mixing incompatible waste; dumping; storing over six months without extension; false information; not registering as a generator; not filing reports; not notifying emergencies or losses; not removing all waste when operations end; and failing to return to the country of origin waste from temporarily imported materials. Sanctions include closure, arrest of up to 36 hours, suspension or revocation of authorizations, site remediation and fines of 20 to 50,000 days of minimum wage, read as UMA.
Cost to do it: Fine range MXN 2,346.20 to MXN 5,865,500 (about USD 126 to USD 314,271).
Example: A maquiladora under a temporary import program that leaves its waste in Mexico instead of returning it breaches art. 106, section XXII. / Up to about USD 314,271 per sanction, plus remediation.LGPGIR art. 106 (section II reformed DOF 19 January 2026) and art. 112; deindexation decree DOF 27 January 2016, transitory Third, LGPGIR arts. 106 and 112, 2026-01-19 official text · verified 2026-10-26 · changed: Decree DOF 19 January 2026 added breaches of the Circular Economy Law and extended producer responsibility agreements to art. 106, section II.

5. Circular economy and extended producer responsibility. The General Law of Circular Economy, published in the DOF on 19 January 2026 and in force the next day, requires productive sectors to design circular products where environmentally, technically and economically viable and to apply extended producer responsibility (REP) under general implementation agreements. Producers and importers must organize, promote and, where applicable, finance circular economy schemes for the products they make or import; they, or a coordinating body representing their sector, must register their circular management (covering the product life cycle and circular design) in the public registry of a national platform. Compliance can be direct or through third parties, or by environmental compensation when justified (restoration, reforestation, emission reductions, certified green bonds or carbon credits). The Executive had 180 calendar days to issue the regulations, and the national program, including plastics, follows within 180 days of the regulations.
Cost to do it: Cost depends on the implementation agreements per product category: take back, recycling or compensation schemes, typically shared through a sector coordinating body.
Example: An importer of packaged consumer goods must expect to register a circular management plan for its packaging and finance its recovery once the REP agreements for that category are issued. / A foreign brand selling through a Mexican importer should allocate REP costs in the distribution contract.Ley General de Economía Circular (LGEC), new law DOF 19 January 2026, Arts. 2, section XXXI, 36 to 41; transitory articles First to Third, 2026-01-19 official text · verified 2026-10-26 · changed: New law DOF 19 January 2026 created extended producer responsibility and the circular economy registry, and reformed the LGEEPA and LGPGIR.

Category	Annual volume	Register with	Main duties
Large generator	10 tonnes or more	SEMARNAT	Management plan, log, annual report, environmental insurance
Small generator	400 kg to under 10 tonnes	SEMARNAT	Log of volumes and handling, management plans where applicable
Microgenerator	Up to 400 kg	State or municipal authority	Local management plans, authorized collection or transport

Hazardous waste generator categories (LGPGIR arts. 5 and 46 to 48)

Activity	MXN 2026	About USD
Collection and transport	MXN 6,137.82	USD 329
Collection and storage center	MXN 6,134.51	USD 329
Recycling or co processing	MXN 3,872.69	USD 207
Reuse	MXN 3,872.69	USD 207
Treatment	MXN 10,111.10	USD 542
Incineration	MXN 81,499.65	USD 4,367
Confinement or final disposal	MXN 134,197.72	USD 7,190
Handling services	MXN 9,590.09	USD 514

Hazardous waste authorization duties in 2026 (LFD art. 194-T; USD at MXN 18.6638)

Worked example

A foreign owned electronics assembler in Baja California generates 25 tonnes of hazardous waste a year: it registers as a large generator, files a management plan and annual report, insures, and hires a SEMARNAT authorized carrier after checking its authorization (LGPGIR arts. 42 and 46). Waste from components imported temporarily must be returned or handled as the law requires (art. 106, section XXII), and drums cannot sit on site more than six months (art. 56). Under the 2026 Circular Economy Law it should also map which of its products and packaging will fall under extended producer responsibility agreements.

Step by step

1. Measure annual hazardous waste volumes and determine the generator category.
2. Register with SEMARNAT (large and small) or the state or municipality (micro); large generators file a management plan and get insurance.
3. Keep a log, label and store waste under the official standards, and ship before six months.
4. Contract only authorized carriers and disposal firms and verify their SEMARNAT authorizations.
5. File the annual report; notify emergencies and losses.
6. Track REP implementation agreements under the Circular Economy Law for your product categories and plan registration of the circular management plan.

Common traps

Storing waste beyond six months without an extension (LGPGIR arts. 56 and 106, section VII).
Assuming the hauler takes over all liability: the generator remains jointly responsible and fully liable if the provider is unauthorized (art. 42).
Closing a plant without removing all hazardous waste (art. 106, section XX).
Ignoring the 2026 Circular Economy Law until product agreements arrive: breaching it or REP agreements is now an LGPGIR infringement (art. 106, section II).

Sources

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