We at Hum are committed to keeping you informed about regulatory changes that impact your operations in the energy and transportation sectors. As a leading provider of GPS tracking technologies for rail assets, we wanted to bring to your attention a significant update from the Comisión Nacional de Energía (CNE) in Mexico. The full text of the regulation can be found here: https://www.dof.gob.mx/nota_detalle.php?codigo=5768321&fecha=23/09/2025
On September 23, 2025, the Diario Oficial de la Federación (DOF) published a new agreement establishing administrative guidelines for labeling and technical/interoperability requirements for global positioning systems (GPS) in vehicular units used for transporting petroleum products, liquefied petroleum gas (LPG), and petrochemicals by means other than pipelines. This regulation directly affects railcar shippers who transport applicable products in Mexico.
Overview of the New Regulations
The agreement aims to enhance visibility, traceability, and security in the transportation and distribution of hydrocarbons and related products. Key elements include:
Inclusion of Railcars: Railcars are explicitly defined as vehicular units covered under these rules when used for rail transport of hydrocarbons, petroleum products, or petrochemicals. This means your railcars shipping into Mexico must comply if associated with permitted activities.
Labeling Requirements: All covered units, including railcars, must feature permanent, visible physical markings on the body. These include QR codes that provide immediate verifiable identification of the permit holder, the product being transported, and the unit itself. Specifications vary by product type (e.g., petroleum products, LPG, petrochemicals) and are outlined in dedicated annexes (Annex I for petroleum products, Annex II for LPG, and Annex III for petrochemicals). The QR codes link to permit details and must be issued by the CNE through defined procedures for existing permits, new applications, and updates.
GPS System Mandates: Every vehicular unit, including railcars, must be equipped with an active GPS system for real-time monitoring. This requirement is intended to support verification of permitted activities, improves security against theft or diversion, and ensures traceability of routes, operation times, and loading/unloading points. GPS devices must operate at incredibly aggressive settings for unpowered railcars including updates every 30 seconds. Permit holders are required to provide continuous, unrestricted access to GPS data for CNE supervision, inspections, and vigilance. Records of geolocation data must be conserved and made available as specified, including to the general public.
System for Registration, Administration, and Control (SIRACP): Permit holders must use this platform for managing user profiles, notifying operational status, and ensuring compliance.
These measures are designed to strengthen oversight, prevent illicit activities like hydrocarbon theft, and align with broader national strategies for energy security and bureaucratic simplification. Non-compliance, such as denying access to GPS data or failing to implement the proper labeling, is considered a violation and may lead to sanctions, including permit suspension or revocation.
What This Means for Your Railcar Shipping Operations
As a railcar shipper transporting petroleum products, LPG, or petrochemicals into Mexico, you are classified as a "permisionario" if holding relevant permits from the CNE. This requires updating your railcars to include the mandated labeling (with QR codes) and installing compliant GPS systems. The regulations emphasize real-time monitoring to mitigate risks like unit theft, product diversion, and unauthorized use, which could directly benefit your operational safety and efficiency. However, failure to adhere could result in delays at borders, inspections, or penalties affecting your supply chain.
Recommended Actions and Timelines
To ensure smooth compliance, we recommend the following steps:
Review Your Permits: Immediately check your existing CNE permits for transportation/distribution activities. For ongoing permits, follow the procedures in Chapter 3 of the rule making to request QR code issuance and label implementation. Deadlines for existing permits, new applications, and permit updates are outlined in the regulation—aim to initiate within the specified periods to avoid disruptions.
Implement Labels: Apply the required physical markings and QR codes to your railcars as per the product-specific annexes. This must be done within the stipulated timelines to maintain permit validity.
Upgrade to Compliant GPS Systems: Equip all relevant railcars with GPS devices meeting the technical standards. Ensure systems allow for secure data sharing with authorities and maintain historical records. If your current setup does not comply, plan upgrades promptly. At Hum, we’re here to help guide you through that process.
Register with SIRACP: Create user profiles on the CNE's platform and notify operational statuses as required to facilitate monitoring.
Timeline Awareness: While specific deadlines vary by permit type (e.g., shorter for new solicitations), the regulation emphasizes prompt action. We advise completing assessments and implementations within 30-60 days of publication to stay ahead of enforcement. Consult the full DOF publication (available at https://www.dof.gob.mx/nota_detalle.php?codigo=5768321&fecha=23/09/2025) for precise details.
At Hum, we specialize in GPS technologies that align perfectly with these requirements. Our railcar-compatible systems offer real-time geolocation, secure data access for authorities, and compliance with international standards. We can assist with seamless integration, including API interoperability for SIRACP and customized monitoring dashboards to enhance your traceability. Contact our team today for a free compliance audit and tailored solutions to keep your operations running efficiently and legally.