Following industrial development and in order to prevent environmental contamination, Mexico began enacting laws and regulations to establish a framework for control and to create sources of information regarding industrial processes.
With the creation of the General Law of Ecological Balance and Environmental Protection (LGEEPA) in 1988 and the Pollutant Release and Transfer Register (RETC) in the mid-1990s – both federal jurisdiction regulations – the obligation to submit the Annual Operating Report, recognized by its Spanish acronym COA, was established.
Understanding COA reporting requirements in Mexico is essential for any company operating an industrial facility in the country.
The LGEEPA framework can be consulted through the official publication of Mexico’s Congress: diputados.gob.mx
This report is focused on the disclosure of atmospheric emissions and the transfer of pollutants (RETC), administered by Mexico’s environmental authority, SEMARNAT: gob.mx/semarnat — RETC
The Annual Operating Report (COA) is an environmental reporting obligation aimed at monitoring emissions and pollutant transfers generated by industrial activities operating in Mexico.
Industrial sectors whose processes involve the generation of atmospheric pollutants and the transfer of contaminants are required to submit the federally regulated Annual Operating Report. These may include, among others:
At the same time, each state within the country began developing its own regulations, which also included the obligation to submit the Annual Operating Report for similar environmental matters, but applied to industrial sectors not classified as federal.
Over time, and with the development of more specific regulations, the COA submission format has evolved. The federal COA is submitted through an online platform where information is reported regarding:
Official guidance and access to the federal COA platform are available through SEMARNAT: gob.mx/semarnat — COA
This information must be supported by discharge quality analyses, hazardous waste management manifests, and records of raw material and resource consumption, such as water, electricity, and fuels for the reporting year.
Regarding the state COA submission, most states have enabled online platforms to report information related to:
The obligation to submit the COA, both federal and state, is annual and subject to different submission periods:
In addition to serving as a regulatory requirement, the COA functions as a key environmental management and planning tool for companies operating in Mexico. The information reported allows authorities to monitor environmental performance, identify trends in pollutant generation, and design public policies aimed at reducing environmental impact.
For companies, maintaining accurate records and preparing the COA in a timely manner helps ensure compliance, avoid potential fines or sanctions, and demonstrate a commitment to sustainability and transparency. Proper preparation often requires coordination between environmental, operational, and administrative departments, as well as the support of accredited laboratories and specialized consultants.
As environmental regulations continue to evolve, companies operating in Mexico must stay informed of updates to reporting criteria, digital platforms, and technical guidelines in order to maintain full compliance with both federal and state environmental obligations.
Additionally, companies should consider implementing internal environmental monitoring systems throughout the year rather than gathering information only at the time of submission.
Maintaining monthly records of emissions, waste generation, water consumption, and fuel usage can significantly streamline the preparation of the COA and reduce the risk of inconsistencies in reported data. Many organizations also establish internal audits prior to submission to verify that laboratory analyses, manifests, and consumption records align with operational logs.
This proactive approach not only supports regulatory compliance but also helps identify opportunities to improve operational efficiency and reduce environmental impact. In some cases, the data collected for the COA can support corporate sustainability reporting and environmental compliance strategies.
As environmental oversight continues to strengthen in Mexico, meeting COA reporting requirements will remain a fundamental part of transparency, regulatory tracking, and responsible industrial development across both federal and state jurisdictions.
Nora Castillo – EHS Manager
