Mexico: New regulation on the identification, visibility, and traceability of transport and distribution units for petroleum products, petrochemicals, and liquified petroleum gas

On September 23, 2025, the National Energy Commission (CNE) published in the Official Gazette of the Federation (DOF) the resolution issuing the general administrative provisions that establish the guidelines for marking (visual identification of cargo transport units, which consists of placing the alphanumeric characters corresponding to their license plate number on the sides and other parts of the vehicle), as well as the technical and interoperability requirements that must be met by the global positioning system of vehicle units registered in transport and distribution permits by means other than pipelines, of oil products, liquefied petroleum gas, and petrochemicals.

The resolution is mandatory for permit holders who carry out transportation and distribution activities by means other than pipelines for petroleum products, liquefied petroleum gas, and petrochemicals, and who have vehicles associated with their permits. Specifically, it establishes the technical guidelines that must be observed to ensure the visibility and traceability of these vehicles, including requirements for markings that identify the permitted activities and the technical and interoperability characteristics that the GPS installed in them must meet.

Identification and marking of vehicles

Permit holders must implement comprehensive and permanent marking on all vehicles associated with their permits, which must include the QR code issued by the CNE in accordance with the terms and elements established in the resolution.

The preservation, integrity, and legibility of the marking is the sole responsibility of each permit holder. Vehicle units covered by one permit cannot be simultaneously linked to another permit.

• Marking specifications 
  
  
• Reading and generating the QR code

The QR code notified by the CNE must be readable by standard mobile devices for the purposes of immediate verification by the CNE and other authorities of the legitimate ownership, possession, and origin of the products being transported, the validity of the permit, and the traceability of the products through the Permit Holder Registration, Administration, and Control System (SIRACP).

The SIRACP is the CNE's electronic system through which the information of permit holders will be managed, as well as the generation and obtaining of the corresponding QR codes. These codes will be generated solely by the CNE and their content will be personalized and non-transferable. The CNE must make user profiles available to permit holders and authorities for access to the information and functionalities of the SIRACP.

The CNE shall generate and deliver, through its Electronic Filing Office (OPE), the corresponding QR codes to permit holders who have valid permits for the aforementioned activities. Notification of the QR codes shall be made within a maximum period of 15 business days from the entry into force of the provisions. In the case of permits issued after the resolution’s entry into force, the QR code must be indicated as part of the annexes to the respective permit title.

On the other hand, permit holders are required to print and label their vehicles within a maximum period of 20 days from the day after the QR code notification takes effect at the OPE. Failure to do so may result in penalties. Updates to the registration or deregistration of the vehicle fleet associated with the permit must also be made through the OPE.

• GPS system

All vehicles associated with such permits must have and maintain an active and valid GPS system that allows the CNE to monitor and geolocate them in real time at all times. They are required to ensure the uninterrupted operation of the system by reporting any failures or signal losses to the SIRACP.

• Permit holders' obligations

  • Place applicable markings and maintain them in  visible, legible, and good condition signage, including the QR code on each unit.
  • Notify the CNE within a maximum of 48 hours of any incident, theft, accident, or similar event that affects the integrity or functionality of the QR code or GPS system.
  • Keep the information on authorized vehicles in each permit up to date.
  • PAllow and facilitate physical and documentary verification of the signage, QR code, and GPS system by the CNE at all times.
  • Refrain from using the QR code on a permit other than the one assigned.

  
  Failure to comply with the provisions shall be punished in accordance with the provisions of Title Four, Section I of the Hydrocarbons Sector Law.

• Additional considerations
  • For the specific purpose of permits that include tanker trucks and that were issued prior to the entry into force of the resolution the permit holder will have 15 business days to submit to the CNE a request to update the respective permit, accompanied by the corresponding information.
  • Upon entry into force of the resolution, the electronic form with the requirements for updating the vehicle fleet of their permits will be made available to permit holders via the OPE.
  • Permit holders for the distribution of liquefied petroleum gas who do not have a GPS system will have a period of 30 business days to implement it.
  • It is important to review the annexes to the resolution detail to be clear about the technical specifications required for the marking applicable to each product.
  • The resolution entered into force on September 24, 2025, one day after its publication in the DOF.