SEMARNAT and PROFEPA Simplify Environmental Inspection and Audit Procedures

On July 23, 2026, the Ministry of the Environment and Natural Resources (SEMARNAT) published in the Official Gazette of the Federation (DOF) the Agreement that simplifies procedures and standardizes forms under the jurisdiction of the Federal Attorney General’s Office for Environmental Protection (PROFEPA). This provision consolidates reference codes, extends the validity periods for cross-border verification, and eliminates duplicate requirements regarding environmental audits, industrial inspections, and natural resources. The Agreement takes effect 15 business days after its publication in the DOF.

What changes does the Agreement introduce?

This Agreement does not introduce any new substantive obligations, but it sets forth the following operational changes by PROFEPA division:

Environmental Auditing and Certification

  • Environmental Certificate (PROFEPA-02-001): Combines categories A, B, and C into a single reference code with a processing time of 30 business days. The copy of the RFC is eliminated and the process is standardized using form FF-PROFEPA-008.
  • Certificate Renewal (PROFEPA-02-002): Consolidates renewals based on diagnostic assessments and environmental performance reports under the PROFEPA-02-002 reference code (25 business days). Duplicate free-form documents are eliminated using form FF-PROFEPA-011.
  • Verification Units (PROFEPA-02-003): Reduces the response time from 10 to 5 business days and adopts the FF-PROFEPA-012 form.

Industrial Inspection and Surveillance

  • Cross-Border Verification: Consolidates flora/fauna and forestry procedures under the homoclave PROFEPA-03-004-A (FF-PROFEPA-003) and those for hazardous waste and substances under the homoclave PROFEPA-03-004-D (FF-PROFEPA-006). The validity period of the Verification Record is extended from 10 to 20 business days, and the requirement to submit invoices, bonds, and reports is eliminated.
  • Emergency Notices (PROFEPA-03-017): Standardizes the immediate notification and its formalization under the reference code PROFEPA-03-017 (FF-PROFEPA-021). Institutional email addresses are officially designated by state for direct response.
  • CO₂ Credits and Landfills: Form FF-PROFEPA-002 (PROFEPA-03-018) has been issued, reducing the requirements for CO₂ credit transfers from 8 to 3 (NOM-163). In addition, Form FF-PROFEPA-023 has been officially adopted for the notification of refusal of hazardous waste at containment sites (NOM-173).

Natural Resources

  • Turtle Excluder Devices (PROFEPA-03-001): Reduces the response time from 90 to 45 business days using form FF-PROFEPA-020.

What regulatory considerations should be taken into account?

  • Certainty in Foreign Trade: The extension of the Verification Registry’s validity to 20 business days provides importers and customs brokers with some leeway in the event of delays in logistics or at customs.
  • Official Digital Channels for Emergencies: The email addresses assigned by state for the PROFEPA-03-017 procedure provide a certified date for immediate reports of hazardous waste spills (≧1 m³).
  • Direct Electronic Notifications: The receipt of electronic notifications is governed by Article 35, Section II, of the Federal Law on Administrative Procedure, which requires regulated entities to continuously monitor their registered mailboxes.

What are the practical implications for businesses?

  • Chemical, Manufacturing, and Logistics Sectors: Update internal emergency response protocols to direct immediate spill notifications to the specific email addresses designated by PROFEPA based on the geographic location of the plant or route.
  • Audit Firms and Inspectors: Ensure the use of the new standardized forms (FF-PROFEPA-008 and FF-PROFEPA-011) 15 business days after they take effect, including the facility’s polygonal georeferencing in decimal coordinates.
  • Automotive Industry: Taking Advantage of the Reduction in Documentation Requirements for CO₂ Credit Applications (PROFEPA-03-018).

At Vega Guerrero & Asociados, we continuously monitor key regulatory developments that impact the environmental and energy sectors.

Our team has extensive experience in environmental, energy, and regulatory law, enabling us to advise domestic and international companies on identifying risks, opportunities, and strategies for regulatory compliance.

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