Mexico's General Climate Change Law (LGCC): What It Requires From Businesses

Mexico's General Law on Climate Change (LGCC) is the law that requires companies in Mexico to measure and report their greenhouse gas (GHG) emissions. Published on 6 June 2012 and last amended in April 2024, it is the legal basis behind the National Emissions Registry (RENE), the emissions trading system and the pollutant release and transfer register.

What article 87 of the LGCC establishes

Article 87 creates the National Emissions Registry and leaves it to the regulations to identify the sources that must report by sector, subsector and activity, the gases reported, the thresholds, the calculation methodologies and the monitoring, reporting and verification system. Article 88 requires the individuals and legal entities responsible for reportable sources to provide the information, data and documents on their direct and indirect emissions. The detail is in the LGCC Regulation on the National Emissions Registry, published on 28 October 2014, which is where the threshold, the deadlines and verification appear.

Who has to report

• 25,000 tonne CO2e threshold: article 6 of the regulation requires reporting from establishments whose direct and indirect emissions add up to 25,000 tonnes of carbon dioxide equivalent or more per year, adding all the establishment's stationary and mobile sources.
• Sectors covered: article 3 groups establishments into six sectors: energy (electricity and hydrocarbons), transport (air, rail, maritime and land), industry (chemicals, iron and steel, metallurgy, metalworking, mining, automotive, pulp and paper, printing, petrochemicals, cement and lime, glass, electronics, electrical, food and beverages, wood and textiles), agriculture and livestock, waste, and commerce and services (construction, retail, education, entertainment, tourism, health services, government and financial services).
• Gases reported: article 5 lists carbon dioxide, methane, nitrous oxide, black carbon or soot, chlorofluorocarbons, hydrochlorofluorocarbons, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, nitrogen trifluoride, halogenated ethers, halocarbons and their mixtures.
• Reporting window: article 12 sets filing between 1 March and 30 June each year, for the previous calendar year, through the Annual Operating Certificate (COA), quantifying each gas in tonnes and in tonnes of CO2 equivalent.
• Periodic verification: article 16 requires a verification report from an accredited and approved body to be attached every three years, filed between 1 July and 30 November of the relevant year and covering the emissions of the immediately preceding year.

What the regulation asks for beyond the report

Article 9 of the regulation lists the full obligations of a reportable establishment: identify its direct emissions from stationary and mobile sources and its indirect emissions from electricity and thermal energy consumption, measure or calculate them with the methodologies SEMARNAT sets, report them every year, have them verified and keep for five years the information, data and documents used, counted from the date SEMARNAT receives the certificate. If the establishment starts operating after 1 January, it reports an irregular period from the start date to 31 December.

Filing the certificate does not close the procedure either. SEMARNAT has 20 working days to check that it is properly completed and can require, once, that the information be completed, corrected or clarified within a maximum of 15 working days; if the request goes unanswered, the certificate is deemed not filed as far as greenhouse gases are concerned. An establishment that spots an error in what it already reported can correct it by notice before PROFEPA starts inspection proceedings.

The LGCC as a regulatory umbrella

The LGCC does not operate alone. It is the framework behind other mechanisms your company probably already interacts with: the RENE centralises the national emissions registry, the emissions trading system provided for in article 94 organises the allowance market, and the pollutant release and transfer register extends reporting to pollutants other than GHGs. Establishments below the 25,000 tonne threshold remain obliged to report to other federal or local registries where their rules require it. For the detail of the law itself, see the entry on the General Law on Climate Change.

What this means for your company

If your company already reports through the Annual Operating Certificate, it is already operating under the LGCC. The challenge is not the legal framework, which has existed since 2012, but execution: consolidating data from multiple plants or sites, classifying emission sources correctly and reaching the March to June window with verifiable information.

Risks of falling short

• Penalties: PROFEPA inspects and oversees reportable entities. Anyone receiving an information request has 15 working days to respond (article 112). Failing to deliver the requested information is punishable with a fine of 500 to 3,000 days of minimum wage (article 114), and false information or missed deadlines with a fine of 3,000 to 10,000 days (article 115); in case of recidivism the fine can be tripled. The law expresses these amounts in days of minimum wage, a reference now calculated in UMA.
• Weaker position for sustainable finance: without verifiable emissions data it is hard to access financing products linked to environmental criteria.
• Exposure in due diligence: investors and corporate clients increasingly ask for proof of compliance before closing contracts, ground that overlaps with Mexico's climate commitments and their effect on companies.

Manglai's platform automates that process: it reads energy invoices, classifies emissions by scope and centralises data from all your sites in one place, audit-ready. You can see it in Manglai's carbon footprint software.