SEMARNAT: Administrative simplification of key procedures

The Accords introduce significant changes to the structure and management of federal environmental procedures, including the following:

1. Environmental Impact Statements (“EIA”). The different EIA modalities (particular and regional, with and without environmental risk) are consolidated, reducing requirements and integrating a single procedure per modality.

Implication: administrative simplification; however, risk assessment remains part of the same file, so the substantive technical burden is not reduced.

2. Complementary procedures in environmental impact matters. Procedures such as EIA exemption and non-applicability (now unified), as well as waiver and change of titleholder, are consolidated and simplified, with reduced requirements and response times of up to 20 business days.

Implication: greater efficiency for administrative adjustments and project regularization.

3. Elimination of the unified environmental impact–forestry procedure. The mechanism allowing the joint processing of environmental impact authorization and forestry land use is eliminated.

Implication: applicants must now obtain both permits separately, which may increase timelines and require a more carefully planned regulatory sequencing strategy.

4. Wildlife. Procedures related to the control of harmful populations are consolidated, and purely informational procedures are eliminated, with reduced requirements and timelines (up to 18 business days).

Implication: operational simplification for management and control activities, with a lower administrative burden.

5. Genetically Modified Organisms (“GMOs”). The stages of environmental release (experimental, pilot, and commercial) are merged into a single procedure, consolidating previously separate administrative acts and reducing timelines (up to 45 days or less).

Implication: increased efficiency for GMO-related projects, albeit with a more comprehensive evaluation within a single application

6. Ozone layer and regulated substances. The procedure for assigning import quotas is simplified, with fewer requirements and resolution timelines of up to 20 business days.

Implication: improved timing for import operations subject to regulatory control.

7. Forms and administrative tools. Official forms were updated, technical guidelines adjusted, and electronic notifications enabled across various procedures.

Implication: greater digitalization of procedures, with potential improvements in document control and regulatory oversight.

8. Transitional regime. Applications filed prior to the entry into force of the Accords (that is, 15 business days after their issuance) will continue to be processed under the previous regime.

Implication: temporary coexistence of two regulatory frameworks, requiring case-by-case identification of the applicable regime.

Authored by Mauricio Llamas and Sofia de Llano.