On June 9, 2026, the Draft Mexican Official Standard PROY-NOM-160-SEMARNAT-2026 was published in the Official Gazette of the Federation; it establishes the elements and procedures for the development of hazardous waste management plans.
The project is being implemented against the backdrop of changes to the regulatory framework governing waste, including the enactment of the General Law on the Circular Economy and various amendments to the General Law on the Prevention and Comprehensive Management of Waste (LGPGIR).
The project is currently undergoing a 60-calendar-day public comment period, so its content may still be modified before its eventual final publication.
Key Aspects of the Project
1. Entities Subject to Regulation
The project calls for the application of the NOM to:
- Major Generators of Hazardous Waste
- Producers, importers, exporters, and distributors of products that become hazardous waste when discarded
- Waste generators referred to in Article 31 of the LGPGIR
2. Components of management plans
The bill sets forth the elements that must be considered when developing management plans, distinguishing their content based on the type of obligated party.
It also outlines the elements that must be included in these plans, as well as the requirements for their submission and monitoring.
3. Related Procedures
The bill includes provisions regarding:
- Registration of management plans
- Deregistration from that registry
- Conformity Assessment
4. Traceability and Tracking
The project includes elements related to the identification and monitoring of waste management, which is linked to traceability systems for waste management.
Practical implications
- Companies must review the structure and content of their management plans in light of the proposed new framework.
- It will be necessary to assess whether the obligations currently being met are consistent with the requirements set forth in the NOM.
- The explicit inclusion of procedures could lead to greater clarity, but also to a more formalized approach by the authorities.
- It is recommended to identify potential gaps in documentation or compliance in advance.
Next steps
- The draft will remain open for public comment for 60 calendar days.
- It may subsequently be amended before its final publication in the DOF.
- Once published as a final NOM, it will be mandatory.
Recommendation
It is recommended to companies:
- Monitor the regulatory process
- Analyze the potential impact on its operations
- Review and, if necessary, adjust their management plans
- Prepare for a potential update to your compliance processes
At Vega Guerrero y Asociados, we have a team specializing in environmental matters that can assist with reviewing management plans, analyzing this proposed regulation, and identifying the steps needed to strengthen regulatory compliance. If you have any questions or would like more information, please do not hesitate to contact us.
