Mexico LGPGIR Hazardous Waste Regulation: Impose hazardous and special waste compliance duties central to ESG risk control and environmental liability management

What’s Required

LGPGIR creates binding compliance duties for waste generators and handlers, typically including:

• Waste classification and segregation: Facilities must classify wastes (hazardous, special handling, municipal) and implement segregation and safe storage consistent with legal definitions and applicable NOMs and procedures.

• Generator responsibilities: Generators must ensure appropriate handling, temporary storage, and transfer to authorised transporters and facilities, retaining evidence of lawful management.

• Manifest and documentation controls: Hazardous waste management depends on traceability documentation, including manifests and service contracts. Firms must maintain records demonstrating chain-of-custody from generation through transport to treatment/disposal.

• Authorisations and service provider due diligence: Where facilities handle hazardous waste beyond generator activities (transport, storage, treatment), specific authorisations apply. Generators should verify that contracted service providers hold valid permits and operate within scope.

• Internal procedures and training: Facilities should implement SOPs, emergency response procedures, and staff training for hazardous waste handling and incident management.

• Reporting interactions: Waste management data often intersects with COA/RETC reporting and permit compliance, making data reconciliation important for avoiding inconsistencies in regulatory reporting.

Important Deadlines

• LGPGIR statute: In force as a federal law with amendments over time.

• Regulation (new regulation DOF reference): The LGPGIR regulation is a core implementing instrument and defines procedures and operational requirements.

• Ongoing obligations: Most duties are continuous; reporting and documentation must be maintained throughout operations and for defined retention periods.

Current Status

• In force as the primary federal waste management law with an active implementing regulation supporting enforcement.

Penalties for Non-Compliance

Non-compliance can trigger:

• administrative sanctions and corrective measures,

• suspension of activities or closure for severe violations,

• environmental liability exposure where mismanagement causes contamination,

• knock-on contractual consequences (customer audits, supply-chain removal).

Examples of Known Violations

• misclassification of hazardous waste as non-hazardous,

• use of non-authorised transporters or disposal facilities,

• missing manifests or incomplete chain-of-custody records,

• inadequate storage leading to leaks/spills,

• failure to train staff and maintain emergency response readiness.

Resources

• https://www.diputados.gob.mx/LeyesBiblio/pdf/LGPGIR.pdf

• https://www.profepa.gob.mx/innovaportal/file/4140/1/reg_lgpgir.pdf