A company's environmental compliance is not summed up by having an authorization on file. It depends on the activity, location, emissions, discharges, waste, resource use and specific conditions imposed by federal, state or municipal authorities. In 2026, the General Circular Economy Law is added, whose implementation introduces new questions about extended responsibility and environmental claims. An effective system connects requirements with operations and available evidence. It is informational material and does not constitute legal advice.
Build an applicability matrix
The first step is to describe facilities, processes, inputs, products, waste, emissions, discharges and works. On that basis, it is determined which level of government intervenes and whether an impact assessment, operating license, annual filing, registrations or management plans, hazardous-waste authorizations, concessions, discharge permits, land-use planning or forestry rules apply. Not all obligations apply to all companies, and a generic list can hide gaps. The matrix must cite the legal basis, authority, facility, condition, frequency, owner and evidence. It must also incorporate changes of capacity, address, process or company name, because a valid authorization may cease to cover the actual operation if the project is modified without the corresponding notice or permit.
Turn conditions into controls
Each authorization usually contains its own limits, monitoring, reports, maintenance and notices. Those conditions must be translated into operational tasks with a date, owner and support: laboratory results, manifests, logs, photographs, invoices, calibrations and acknowledgments. The company must reconcile what is reported with production, purchases and waste movements, since simple inconsistencies can erode the defense. The Annual Operating Filing, where applicable, requires integrated information and a specific annual window; preparing it only at the end increases errors. Internal audits by facility and walkthroughs with plant managers help verify that practice matches the permit. Findings require priority, cause, correction and evidence of closure, not just an observation.
The circular-economy layer
The General Circular Economy Law, published on January 19, 2026, sets out bases for circularity, extended producer responsibility and circular management. Its concrete impact depends on the sector, product, the general agreements implementing extended producer responsibility, the program and the applicable regulatory provisions. It is therefore advisable to avoid two extremes: ignoring it until an inspection arrives or assuming detailed obligations that do not yet apply. To prepare, producers and importers should map materials, useful life, recovery, suppliers and commercial messages, and monitor official publications. Expressions such as recyclable, circular or sustainable must have a methodology and verifiable evidence: Article 43 prohibits generating or using false information about the environmental characteristics of products or about processes supposedly aligned with the circular economy, as well as using labels or badges that may confuse consumers. This front must be integrated into the existing system, not managed as an isolated campaign.
Key points
- Environmental applicability depends on specific processes, location and impacts.
- The conditions of each permit must be turned into controls and evidence.
- The reported data must be reconciled with the actual operation of each facility.
- The circular economy adds responsibilities and risk regarding environmental claims.
What to review
- Create a matrix per facility with legal basis, authority, date and required evidence.
- Audit permits and reports against processes, volumes and conditions observed at the plant.
- Review products and environmental messages in light of the General Circular Economy Law.