
One of the most common questions among plant managers and business owners is: which environmental permits apply to me? The answer isn’t always simple, because it depends on the activity, the size of the operation, the processes, the location, and whether the activity falls under federal, state, or municipal jurisdiction.
The problem with not having it clear is that many companies find out what they’re missing when PROFEPA (Mexico’s federal environmental enforcement agency) or the state authority shows up for an inspection, when a corporate customer asks for evidence of compliance, or when they plan to expand the plant. In this article we share a checklist of the main environmental permits, registrations, and studies so you can identify where to start.
First: who is your environmental authority?
In Mexico, environmental regulation is split across three levels of government:
| Level | Authority | What it generally regulates |
|---|---|---|
| Federal | SEMARNAT, PROFEPA, CONAGUA (and ASEA for the hydrocarbons sector) | Federally regulated industries, hazardous waste, national waters, and projects listed in federal law. |
| State | Each state’s environmental ministry or institute | Industries not under federal jurisdiction, special-handling waste, and state environmental impact assessments. |
| Municipal | City government and local water utility | Land use, discharges to the municipal sewer, noise, and municipal solid waste. |
A single company usually has obligations at all three levels. That’s why the first step is to identify what activities you carry out and which authority oversees each one.
Environmental permits and studies checklist
1. Environmental impact (before building or expanding)
- Environmental Impact Statement (MIA): required before starting certain projects or activities, such as building or expanding industrial facilities. If the activity is on the federal list, it’s filed with SEMARNAT; otherwise, usually with the state environmental authority.
- Preventive report or exemption: in some cases, the authority allows a simpler procedure when the impact is minor.
When to review it: before buying land or a company (as part of due diligence), building, expanding the plant, or changing a process.
2. Air emissions
- Single Environmental License (LAU): according to SEMARNAT’s procedure sheet, it’s required for federally regulated stationary sources in sectors such as chemicals, petrochemicals, paints and inks, automotive, pulp and paper, metallurgy, glass, power generation, cement and lime, and hazardous waste treatment.
- State operating license or registration: for stationary sources not under federal jurisdiction, according to each state’s legislation.
- Stationary source emission studies: measurements of stacks, boilers, and other equipment, under the applicable official standards.
3. Annual report: Annual Operating Certificate (COA)
The COA is the annual report of emissions, discharges, and waste filed with SEMARNAT. According to the official COA guide, it must be filed by, among others, federally regulated stationary sources, those discharging wastewater into national water bodies, and large generators of hazardous waste. It’s filed between March 1 and June 30 each year. Several states also have their own annual certificate or report.
4. Hazardous waste
- Registration as a hazardous waste generator with SEMARNAT, in the category that matches your annual volume: micro, small, or large generator.
- Hazardous waste management plan: mandatory for large generators.
- Generation log and temporary storage area meeting the required conditions.
- Delivery, transport, and receipt manifests with authorized service providers.
We explain each obligation by category in Hazardous waste in Mexico: a generator’s obligations.
5. Special-handling and municipal solid waste
- Registration and management plan for special-handling waste with the state authority (for example, large volumes of non-hazardous industrial waste such as cardboard, plastic, wood, or metals).
- Contracts with authorized collectors for municipal solid waste, according to local regulations.
6. Water
- National water concession from CONAGUA, if you extract water from a well or water body.
- Wastewater discharge permit:
- To national water bodies (rivers, streams, soil): with CONAGUA.
- To the municipal sewer: with the local water utility, meeting the limits of the applicable standard.
- Periodic discharge analyses performed by an accredited laboratory.
7. Noise
- Perimeter noise study: measures the noise your facility generates toward the outside and compares it with the limits of the applicable official standard. It’s especially important if your plant is near residential areas.
8. Environmental risk
- Environmental risk study: required for companies carrying out activities considered highly risky because they handle certain substances in certain quantities.
- Accident prevention program, where applicable.
9. Voluntary certifications
They aren’t mandatory, but they bring order to compliance and corporate customers often ask for them: PROFEPA’s Clean Industry certificate and ISO 14001. We explain the differences in ISO 14001 vs. Clean Industry.
Signs you may have compliance gaps
- You don’t have an up-to-date list of your environmental obligations and their expiration dates.
- You expanded the plant, added a process, or changed activity and didn’t check whether you needed new permits.
- You don’t know for sure which hazardous waste generator category you’re registered under.
- Your water, noise, or emissions analyses are more than a year old, or have never been done.
- A customer or your headquarters asked for evidence of compliance and it took you weeks to gather it.
- Environmental responsibility falls on a single person who also has other duties.
How to get your environmental permits in order
- Run an environmental legal compliance assessment: identify every obligation that applies to you based on activity, size, and location.
- Compare it with what you already have: valid permits, registrations, studies, and reports filed.
- Prioritize gaps by risk: first, whatever could lead to a shutdown or major penalties.
- Build an obligations calendar: permit expirations, annual report dates, and study frequency.
- Assign owners and budget: environmental compliance is ongoing, not a one-time project.
Frequently asked questions
Do all companies need environmental permits?
Practically all of them have some obligation, even if only at the municipal level (land use, sewer discharges, or waste management). Industrial companies usually have additional state or federal obligations.
What happens if I operate without an environmental permit?
Authorities can impose fines, order corrective measures and, in serious cases, shut down the facility partially or fully. In many cases there are programs to get into compliance, so it’s best to act before an inspection.
Who can carry out the lab studies?
Water, noise, and emissions studies must be performed by accredited laboratories and, where required, laboratories approved for the relevant standards, so that their results are valid before the authority.
How often should studies be renewed?
It depends on the permit and the standard. Some studies are annual; others depend on your permit conditions or process changes. An obligations calendar keeps them from expiring without you noticing.
Conclusion
Knowing which environmental permits and studies apply to you is the first step to operating without surprises, responding quickly to customers and authorities, and growing without regulatory roadblocks. This checklist gives you a starting point, but each company has a different combination of obligations depending on its activity, processes, and location.
At Total Consulting we carry out environmental compliance assessments, risk studies, waste management plans, and lab studies through our Sustainability and Compliance service. If you’re unsure what you’re missing or have an inspection or expansion coming up, schedule a free diagnostic session.
This article is for informational purposes and does not replace legal advice. Specific obligations depend on the federal, state, and municipal laws applicable to each facility.