New NOM on Hazardous Waste Management Plans: Publication for Public Consultation

On June 9, 2026, SEMARNAT published Draft Official Mexican Standard PROY-NOM-160-SEMARNAT-2026 (the “Draft Standard”), which seeks to establish the elements and procedures for the preparation of Hazardous Waste Management Plans.

Interested stakeholders may submit comments during the 60-calendar-day period following publication, which is expected to expire on August 8, 2026.

This initiative forms part of the ongoing update of Mexico’s regulatory framework following recent reforms relating to the circular economy and integrated waste management. Key aspects of the Draft Standard include the following:

1. Expanded and clarified scope of application

The Draft Standard proposes that the Official Mexican Standard (“NOM”) apply to: (i) Large generators of hazardous waste; (ii) Producers, importers, exporters, and distributors of products that become hazardous waste upon disposal; and (iii) Generators of hazardous waste referred to in Sections XII through XV of Article 31 of the General Law for the Prevention and Integral Management of Waste (Ley General para la Prevención y Gestión Integral de los Residuos – “LGPGIR”), including biohazardous infectious waste.

2. New minimum content requirements for management plans

The Draft Standard establishes in detail the information that each type of management plan must contain, including:

a. Identification and characterization of waste streams.

b. Generation volumes or collection estimates.

c. Source reduction and waste minimization measures.

d. Recovery, recycling, and valorization actions.

e. Performance indicators and targets.

f. Description of internal and external waste management practices.

g. Legal instruments supporting allocation of responsibilities and waste traceability.

3. Greater emphasis on waste minimization and valorization

One of the most significant changes is the strengthened obligation to document measures aimed at reducing hazardous waste generation at the source, as well as actions intended to promote waste recovery, reuse, or valorization where technically and environmentally feasible.

4. Shared responsibility and traceability

For management plans covering products that become hazardous waste upon disposal, the Draft Standard further develops the principle of shared responsibility and introduces specific requirements relating to logistics, collection centers, take-back mechanisms, consumer communication, and waste traceability.

5. Registration, amendment, and deregistration of management plans

The Draft Standard expressly regulates:

a. Participation in or adherence to previously registered management plans.

b. Circumstances requiring amendments to an existing management plan.

c. Grounds for requesting deregistration of a management plan.

6. Conformity Assessment Procedure

For the first time, the Draft Standard establishes a Conformity Assessment Procedure to be carried out by accredited and approved inspection units, whose findings may be used to verify compliance with the obligations established under the NOM.

7. Transitional provisions

The transitional provisions establish a 180-calendar-day delayed effective date, preserve the legal framework applicable to pending registration applications, grant a 120-calendar-day compliance period for regulated entities that do not yet have a registered Management Plan, and require that future amendments to previously registered plans comply with the provisions of the new NOM.

Authored by Mauricio Llamas and Sofia de Llano.