Mexico Issues New Guidelines for Non-Pipeline Transportation and Distribution of Hydrocarbons

Mexico's National Energy Commission (Comisión Nacional de Energía or CNE) on Sept. 23, 2025, published in the Federal Register (Diario Oficial de la Federación or DOF) the "Order issuing General Administrative Provisions setting the Guidelines for Labeling and the Technical requirements for the Global Positioning System of vehicular units registered under hydrocarbons transportation and distribution permits, by means other than pipelines, of petroleum products and liquified petroleum gas" (the Order).

Background

Following the Order, the CNE seeks to 1) establish a permanent and visible labeling under a quick response (QR) code, 2) ensure the use of global positioning systems (GPS) and 3) enable interconnexion with CNE systems for real-time monitoring and supervision of units, thereby strengthening security and combating the illicit fuel market.

Obligated Parties and Scope of the Order

The new guidelines apply to holders of transportation or distribution hydrocarbon permits by means other than pipelines of petroleum products and liquefied petroleum gas. This includes all vehicular units registered under such permits (tank trucks, rail tank cars, delivery vehicles, tractors, among others) as follows:

• Labeling and QR Code. Each unit should display labeling consisting of high-durability reflective seals that include, among others, a unique QR code to be issued by the CNE to identify the permit holder, vehicle and product transported. Moreover, the Order establishes that the QR code shall be readable by standard mobile devices.
• GPS and Interconnexion. All units shall be equipped with GPS devices that remain active at all times, enable real-time data monitoring and are readable with CNE systems. Consequently, through GPS data, QR code request and the supervisory system (collectively Registry, Management and Control of Permit Holders or Sistema de Registro, Administración y Control a Permisionarias or SIRACP), the CNE seeks to facilitate the identification of the ownership, possession and origin of the product transported, as well as the validity of the permit and the relevant route.
• Sanctions. The Order establishes that the following situations constitute a violation subject to sanctions pursuant to Title Four, Chapter I of the Hydrocarbons Law: operating without labeling, a QR code or GPS, or tampering with or falsifying a QR code, blocking real-time access to information or providing misused data. Accordingly, permit holders may be subject to fines and, in severe or repeated cases, revocation of their permits.
• Entry into Force. The Order entered into force the day after its publication (i.e., Sept. 24, 2025). Therefore, permit holders should, within 15 business days, submit to the CNE, through the Electronic Filing Office (Oficialía de Partes Electrónica or OPE), a request to update their permit in accordance with the Order.

Once permit holders submit the requested information, the CNE should issue and notify, through the OPE, the QR code and the updated permit within 45 business days following receipt of the required information. Likewise, the Order establishes that liquified petroleum gas distribution permit holders who do not have GPS installed will have 30 business days from the entry into force of the Order to incorporate it in all of their units.

Compliance Authorities and Other Reports

The Order also grants the CNE the authority to verify compliance with the guidelines at any time. Hence, the CNE may conduct verification visits, scheduled or not, field appraisals or documentary reviews through information requests in order to confirm the proper incorporation of labeling, compliance of QR codes, operation of GPS and general compliance with the obligations set forth therein.

Furthermore, the CNE may require direct access, whether in real time or historically, to information generated by the GPS of vehicular units, either remotely or during verification visits. To exercise these authorities, the CNE may also enter into cooperation agreements with other federal authorities to coordinate inspection actions, information exchange and joint supervision.

On the other hand, the Order also provides for a mechanism of citizen participation by allowing any individual to scan the QR code from a standard mobile device to consult the basic information of the vehicular units and, where appropriate, submit reports or complaints through the SIRACP.

Final Comments

In the authors' view, the Order represents a relevant change for hydrocarbon transportation and distribution activities, other than by pipelines, of petroleum products and liquified petroleum gas, as it subjects the operation of permit holders to monitoring of their units through the incorporation of labeling, QR codes and GPS.

Accordingly, it will be important for permit holders to verify compliance across all their units under the Order, while ensuring that their GPS providers and related service suppliers certify compliance with the security standards set forth therein.

Most likely, the new requirements in the Order will force permit holders to carry out additional investments to comply with it, as well as reinforce the compliance programs governing their units for the transportation and distribution of hydrocarbons.

For more information or assistance regarding the scope, implementation and full compliance of the Order, contact the authors.

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