Mexico — Import Procedures & Duties

Statutory foundation. The Ley Aduanera (Customs Act) is the governing statute for Mexican customs law. Article 1 provides that the Ley Aduanera, together with the Ley de los Impuestos Generales de Importación y de Exportación (General Law on Import and Export Taxes, which contains Mexico's tariff schedule) and other applicable laws and regulations, govern (i) the entry into and exit from Mexican territory of goods and the means by which they are transported or conducted, (ii) customs clearance (despacho aduanero), and (iii) acts or events deriving from such clearance or from the entry or exit of goods. The Código Fiscal de la Federación (Federal Fiscal Code) applies supplementarily to the Ley Aduanera.

Administering authority. The Agencia Nacional de Aduanas de México (ANAM, National Customs Agency of Mexico) is the agency responsible for administering Mexican customs law. ANAM was created by presidential decree published July 14, 2021, in the Diario Oficial de la Federación as an órgano administrativo desconcentrado (administrative deconcentrated organ) of the Secretaría de Hacienda y Crédito Público (SHCP, the Finance Ministry). Article 2 of the decree states that ANAM's purpose is to organize and direct customs services and inspection, to apply and ensure compliance with legal norms that regulate the entry and exit of goods from Mexican territory, and to collect taxes and duties (contribuciones y aprovechamientos) applicable to foreign-trade operations, in fulfillment of the executive powers conferred by the decree and as expressly instructed by the Secretary of Finance and Public Credit.

Exclusive customs authority. Article 3 of the Ley Aduanera provides that functions relating to the entry of goods into Mexican territory or the exit of goods from Mexican territory are exclusive powers of the customs authorities (autoridades aduaneras). Customs authorities exercise their powers in coordination and collaboration with authorities of the federal public administration, the states (entidades federativas) and municipalities, and with fiscal and customs authorities of other countries, in accordance with international treaties to which Mexico is a party and are in force. This coordination may include exchange of information through electronic centers or systems, subject to confidentiality requirements.

Reglas Generales de Comercio Exterior (RGCE). Article 2 of the Ley Aduanera defines "Reglas" as general-character rules issued by the Servicio de Administración Tributaria (SAT, Mexico's Tax Administration Service). Detailed procedural and substantive rules for customs operations are published annually in the Reglas Generales de Comercio Exterior (RGCE, General Rules of Foreign Trade). The RGCE for 2025 were published in the Diario Oficial de la Federación on December 30, 2024; the RGCE for 2026 were published on December 27, 2025. The RGCE implement the Ley Aduanera and its Reglamento (Regulation of the Ley Aduanera) and prescribe filing requirements, documentation, customs-regime rules, and trade-facilitation procedures.

The pedimento (customs declaration). A pedimento is the official customs declaration required for imports, exports, and other customs regimes. Under Article 36 of the Ley Aduanera, goods intended for importation or exportation must be declared under oath (declaración bajo protesta de decir verdad) via a pedimento. The pedimento is the document that proves the legal status of goods in Mexican territory. The RGCE prescribe detailed pedimento formats and electronic-filing requirements.

Source: Ley Aduanera, Art. 1 Source: Ley Aduanera, Art. 2 Source: Ley Aduanera, Art. 3 Source: Ley Aduanera, Art. 36 Source: Decreto por el que se crea la Agencia Nacional de Aduanas de México, Art. 2, DOF July 14, 2021 Source: Reglas Generales de Comercio Exterior para 2025, DOF Dec. 30, 2024

**General rule: use of a licensed agente aduanal or apoderado aduanal is mandatory.** Under Article 36 of the Ley Aduanera, anyone who imports or exports goods into or out of Mexico is required to present a pedimento (customs declaration) "through a customs broker (agente aduanal) or customs attorney (apoderado aduanal)." Article 40 reinforces this: only agentes aduanales acting as consignees or agents (mandatarios) of a particular importer or exporter, as well as apoderados aduanales, may carry out the formalities related to customs clearance of that importer's or exporter's goods.

This is a threshold compliance rule that distinguishes Mexican customs law from that of many other jurisdictions. Unlike the United States (where an importer may self-file or appoint any authorized agent) or the European Union (which permits direct or indirect representation under Article 18 of the Union Customs Code), Mexico imposes a mandatory licensed-broker requirement for nearly all commercial import and export transactions.

**Distinction: agente aduanal vs. apoderado aduanal. An agente aduanal** (customs broker) is a natural person authorized by the Finance Ministry (Secretaría de Hacienda y Crédito Público) to hold a patente (patent, i.e., license) to operate as a professional customs broker. The license is governed by Title VII, Chapter I, Section I of the Ley Aduanera. The broker may serve multiple importers and exporters across multiple customs clearances.

An apoderado aduanal (customs attorney or customs agent) is an individual specifically authorized by the Servicio de Administración Tributaria (SAT, the Tax Administration Service) to act on behalf of one specific company or a related group of companies (e.g., maquiladoras or export-program participants within the same corporate family). The authorization is limited to that particular importer or exporter. The apoderado aduanal regime allows large companies to designate and train in-house customs-clearance specialists without requiring them to obtain a full agente aduanal patent.

As of a 2018 reform (Ley Aduanera reform of June 25, 2018, published in the Diario Oficial de la Federación), the law also introduced the concept of an agencia aduanal (customs-broker agency)—a legal entity that can hold an authorization and employ multiple agentes aduanales within a single corporate structure. Prior to 2018, only natural persons held broker patents; the agency structure permits scale and corporate continuity.

Exceptions to the mandatory-broker rule. Article 40 of the Ley Aduanera states that "the intervention of agentes or apoderados aduanales shall not be necessary in the cases expressly set forth in this Law." The principal exception is found in Article 59-B, which permits direct clearance (despacho directo) by the importer or exporter (without a broker or attorney) for shipments meeting criteria established by the SAT in the Reglas Generales de Comercio Exterior (RGCE).

Article 59-B requires that importers or exporters seeking to self-file must (i) be registered in the corresponding importer/exporter registry (padrón de importadores or padrón de exportadores), (ii) maintain an inventory control system, and (iii) comply with procedural and technical requirements prescribed in the RGCE. Article 68 of the Reglamento de la Ley Aduanera (Regulation of the Customs Act) adds procedural details: the self-filing importer must declare a domicile for notifications, form an electronic file of each pedimento and its annexes, and preserve the value declaration.

Chapter 1.10 of the RGCE for 2025 and 2026 is titled "Despacho Directo y Representante Legal" (Direct Clearance and Legal Representative), indicating that SAT has continued to develop facilitation rules. However, in practice, SAT applies strict criteria and limits the direct-clearance facility to certain narrow categories—for example, authorized trade-facilitation programs (e.g., IMMEX / maquiladora operators with strong compliance records) or small-value shipments below thresholds set in the RGCE. Most commercial importers and exporters continue to use a licensed agente aduanal or employ an apoderado aduanal.

Additional exemptions are found in Chapter 3 of the Ley Aduanera for passenger baggage, postal shipments, and courier/express shipments. Article 59 provides that postal and courier imports are subject to streamlined procedures prescribed by regulation; customs brokers are not required for these personal or small-package shipments. The SAT or ANAM (Agencia Nacional de Aduanas de México, the national customs agency created in 2021) may directly process and assess duties on these shipments.

Practical implication. A U.S. or European exporter selling into Mexico must expect that the Mexican importer will engage a licensed agente aduanal to file the import pedimento and manage the customs formalities. The broker's fees, the broker's liability for classification and valuation accuracy (Article 54 of the Ley Aduanera imposes joint liability), and the need to register the broker relationship in the SAT's electronic system are all embedded costs and lead-time factors in the Mexico import supply chain. The mandatory-broker rule also means that the importer cannot unilaterally change the legal classification or value declaration after the goods have been consigned to the broker; the broker is the legal representative under Article 41 and bears responsibility for the correctness of the pedimento.

Source: Ley Aduanera, Art. 36 Source: Ley Aduanera, Art. 40 Source: Ley Aduanera, Art. 41 Source: Ley Aduanera, Art. 54 Source: Ley Aduanera, Art. 59 Source: Ley Aduanera, Art. 59-B Source: Reglamento de la Ley Aduanera, Art. 68 Source: Decreto por el que se reforman, adicionan y derogan diversas disposiciones de la Ley Aduanera, DOF June 25, 2018

Dual-layer structure: tariff duties plus VAT. Under Article 52 of the Ley Aduanera, "persons who import merchandise into national territory or export merchandise out of national territory, including those under a program of deferment or drawback of tariffs, are obligated to pay the impuestos al comercio exterior (taxes on foreign trade)." The phrase impuestos al comercio exterior encompasses two principal charges levied at importation:

1. **The Impuesto General de Importación (IGI)** — the general import tariff (customs duty) levied under the Ley de los Impuestos Generales de Importación y de Exportación (General Law of Import and Export Taxes). The IGI rate is set forth in Mexico's national tariff schedule (the Tarifa de la Ley de los Impuestos Generales de Importación y de Exportación, or TIGIE). Each tariff line in the TIGIE states an ad valorem percentage rate, a specific rate, or a mixed rate. The tariff schedule is based on the Harmonized System nomenclature and parallels the structure of the HS Convention.

1. **The Impuesto al Valor Agregado (IVA)** — value-added tax, levied under the Ley del Impuesto al Valor Agregado (VAT Act, or LIVA) on the importation of goods.

Both charges are assessed and collected at the time of customs clearance. Unlike the United States or European Union where the ad valorem customs duty is the primary border charge and internal sales/value-added tax is typically deferred to domestic transactions, Mexico imposes VAT on all commercial importations at the same time as the tariff duty, creating a dual-layer tax obligation payable before release of the goods.

VAT rate and base on importation. Article 1 of the LIVA provides that "the tax shall be calculated by applying to the values indicated in this Law the rate of 16%." Article 24 of the LIVA states that importation of goods is subject to the tax. Article 27 prescribes the tax base for importation: "In the case of importation of tangible goods, the tax shall be calculated applying the 16% rate to the value used for purposes of the impuesto general de importación [IGI], adding to that value, where applicable, the amount of the [IGI] itself and the other taxes, fees, and charges (contribuciones) payable on importation, except the VAT itself."

In other words, the IVA base is:

IVA base = Customs value (CIF or equivalent) + IGI + other import charges (excluding IVA).

This is a compounding or cascading structure: the IGI is calculated first on the customs value (typically the transaction value under the WTO Valuation Agreement framework, transposed into Mexican law by Articles 64 through 78 of the Ley Aduanera), and then the IVA is calculated on the sum of the customs value plus the IGI and any other duties or charges. The result is that IVA applies to a tax-inclusive base.

Example (simplified). An importer brings a machine with a customs value of US$10,000 (converted to Mexican pesos at the applicable exchange rate; assume for this example a 1:1 rate for simplicity). The tariff classification yields an IGI rate of 15%.

• Customs value: $10,000
• IGI (15% of $10,000): $1,500
• IVA base: $10,000 + $1,500 = $11,500
• IVA (16% of $11,500): $1,840
• Total import taxes due at clearance: $1,500 + $1,840 = $3,340

The combined effective rate (3,340 ÷ 10,000) is 33.4% on the customs value, even though the nominal tariff is 15% and the IVA rate is 16%, because of the compounding.

Payment timing and simultaneity. Article 28 of the LIVA states: "In the case of importation of tangible goods, the payment shall have a provisional character and shall be made jointly with the payment of the impuesto general de importación, including when payment of the latter is deferred by virtue of the goods being in fiscal deposit in general deposit warehouses, and no credit may be applied against such payment." (Translation from Spanish.) This provision has three critical operational consequences:

1. Simultaneity. The IVA must be paid at the same time as the IGI—at the moment of customs clearance when the pedimento (customs declaration) is filed and validated. There is no deferral mechanism for the IVA independent of the tariff-duty payment.

1. Provisional character. The statute characterizes the IVA payment on importation as "provisional" (provisional), meaning that the importer—if registered as an IVA taxpayer—may later credit (offset) the IVA paid on importation against IVA owed on domestic sales, subject to the credit rules in Articles 4 and 5 of the LIVA. This is consistent with the destination-based value-added-tax principle: the import IVA is an input tax credit for a business importer who will collect IVA on resale or use of the goods in a VAT-taxable activity.

1. No credit at the border. The phrase "sin que contra dicho pago se acepte el acreditamiento" (no credit may be applied against such payment) means that the importer may not reduce the import IVA liability at the border by offsetting prior IVA credits; the full IVA on the import must be paid in cash (or via deposit), and the credit mechanism operates later, through the monthly IVA return filed with the SAT (Servicio de Administración Tributaria, the Tax Administration Service).

Importer-of-record obligation. Article 52, fourth paragraph, of the Ley Aduanera states that when goods are found in Mexican territory and the importer cannot be identified, the person who holds possession of the goods is presumed to be the importer and is jointly and severally liable for the import taxes. The statute thus imposes strict liability on the person in control of imported goods to ensure that the IGI and IVA have been paid.

Exclusions and zero-rated items. The LIVA also provides for zero-rated (0%) IVA on certain categories of goods, primarily under Article 2-A (temporary importations under IMMEX / maquiladora programs, imports by diplomats, and other specific cases). However, these exclusions are narrow; the default rule is that commercial importation of tangible goods is subject to both IGI and 16% IVA.

Contrast with other jurisdictions. This dual-layer, simultaneous, tax-on-tax structure distinguishes Mexico from:

• The United States, where there is no federal value-added or sales tax on importation; only customs duties, merchandise-processing fees, and harbor-maintenance fees (if applicable) are collected at the border. State sales taxes, where applicable, are typically assessed later at the point of first retail sale within the state, not at import.

• The European Union, where importation triggers both customs duty (if not relieved by preferential origin or suspension) and VAT, but most Member States permit VAT-registered importers to account for import VAT via postponed accounting or reverse-charge mechanisms, so that cash payment at the border is not required. Mexico does not offer a postponed-accounting option; the IVA must be paid in cash at clearance.

Practical implication. A foreign exporter selling DDP (Delivered Duty Paid) Incoterms into Mexico must budget for both the tariff duty and the 16% IVA on the duty-inclusive base. An importer financing the clearance must secure cash or a line of credit sufficient to cover both charges, even if the importer expects to recover the IVA as a credit against future VAT liabilities. The compounding effect of the tax-on-tax base also means that classification and valuation disputes—if they result in a higher customs value or a higher tariff rate—have a multiplier effect on the total tax due, because both the IGI and the IVA increase.

Source: Ley Aduanera, Art. 52 Source: Ley del Impuesto al Valor Agregado, Art. 1 Source: Ley del Impuesto al Valor Agregado, Art. 24 Source: Ley del Impuesto al Valor Agregado, Art. 27 Source: Ley del Impuesto al Valor Agregado, Art. 28

Overview: duty-free temporary importation for export-oriented manufacturing. Article 108 of the Ley Aduanera permits maquiladoras and companies holding export programs authorized by the Secretaría de Economía (Ministry of Economy) to import goods temporarily **without payment of the impuesto general de importación (IGI, the general import tariff) or VAT when those goods will be used in manufacturing or transformation processes and the resulting products will be exported. This regime is the procedural foundation of Mexico's export-manufacturing ecosystem and is operationalized primarily through the Decreto IMMEX** (Decree for the Promotion of the Manufacturing, Maquiladora, and Export Services Industry, originally published November 1, 2006, in the Diario Oficial de la Federación, and amended multiple times, most recently on December 19, 2024).

The term "IMMEX" stands for Industria Manufacturera, Maquiladora y de Servicios de Exportación. A Programa IMMEX is the authorization granted by the Secretaría de Economía to a legal entity (persona moral) to operate under the decree. The program permits the holder to import inputs, components, machinery, equipment, and other specified goods on a temporary basis, process or incorporate them into finished goods, and export those finished goods—all without upfront payment of import duties or VAT on the temporary imports.

Dual customs-duty suspension: IGI and VAT. The economic benefit is dual-layer. First, Article 108, first paragraph, of the Ley Aduanera provides that goods imported under this regime "shall not be subject to the payment of the impuestos al comercio exterior" (taxes on foreign trade)—i.e., the IGI tariff duty. Second, Article 28, second paragraph, of the Ley del Impuesto al Valor Agregado (VAT Act, LIVA) provides that "the importation of goods by maquiladoras or companies holding export programs authorized by the Secretaría de Economía shall not be subject to the tax [IVA], provided that the goods are covered by the corresponding program and are destined to be totally incorporated into finished goods to be exported, or are returned abroad after the transformation, repair, or other process." This creates a cash-flow and working-capital advantage: the importer does not deposit the tariff or the 16% VAT at clearance, avoiding the liquidity burden and the need to reclaim credits via monthly VAT returns.

Scope of goods eligible for temporary importation. Article 108 permits temporary importation of:

1. Goods for transformation, elaboration, or repair that will be re-exported after processing (Article 108, first paragraph, Ley Aduanera). Typical categories include:

• Raw materials, parts, components, and subassemblies to be incorporated into export products.
• Fuels, lubricants, and consumables used directly in the production process.
• Containers, packaging materials, labels, and pamphlets.

1. Goods to return in the same state (i.e., not transformed)—for example, molds, tooling, and testing equipment that are used in the manufacturing process but not physically incorporated into the exported product. These are covered by Article 108 in conjunction with the broader temporary-importation rules in Chapter II of Title III of the Ley Aduanera (Articles 104 through 112).

1. Machinery, equipment, tools, instruments, molds, and spare parts used in the productive process. These may remain in Mexico for the duration of the IMMEX program rather than a fixed number of months, because they are capital goods essential to the program's operations (Article 4, fraction I, subparagraph (a), Decreto IMMEX, as amended).

Time limits for temporary importation. Article 108, third paragraph, of the Ley Aduanera and Article 4 of the Decreto IMMEX establish maximum permanence periods (plazos de permanencia) for goods imported under an IMMEX program:

• Up to eighteen (18) months for:
• Raw materials, parts, and components destined to be totally incorporated into export goods.
• Fuels, lubricants, and other materials consumed during the production process.
• Containers, packages, labels, and pamphlets.

• Up to two (2) years for trailer boxes (cajas de trailer) and containers used repeatedly in logistics.

• For the duration of the IMMEX program (i.e., indefinitely, so long as the program remains in force) for:
• Machinery, equipment, tools, instruments, molds, and spare parts used in the productive process.

If goods are not re-exported or transferred to another authorized customs regime (e.g., definitive importation with payment of duties, or transfer to another IMMEX holder) within the applicable time limit, Article 108, fifth paragraph, states that "the goods shall be deemed to be illegally in the country, because the temporary-importation regime to which they were destined has concluded." This triggers potential penalties under Title VIII (Infracciones, Sanciones y Delitos) of the Ley Aduanera, including administrative fines and, in serious cases, criminal liability for customs fraud (defraudación fiscal y equiparable a contrabando).

Prohibited and restricted goods. Not all goods may be imported under the IMMEX temporary-importation regime. Article 4, penultimate paragraph, of the Decreto IMMEX states: "The goods indicated in Annex I of this Decree may not be imported under the Program." Annex I is a "negative list" of goods excluded from IMMEX benefits, updated periodically by amendment to the Decreto. As of the December 19, 2024, amendment, Annex I includes certain finished textile and apparel products (chapters 61, 62, 63 of the tariff schedule, plus subheadings 9404.40 and 9404.90, with limited exceptions for fabric cuts under subheadings 6117.90, 6217.90, 6302.91, 6302.93, and 6302.99). The purpose of this exclusion is to prevent circumvention of tariffs and countervailing duties on finished consumer goods by routing them through nominal "assembly" operations.

Article 5 of the Decreto IMMEX gives the Secretaría de Economía authority to publish temporary Acuerdos (administrative agreements) authorizing importation of otherwise-excluded goods in the event of supply shortages, force majeure, or other contingencies.

Additionally, Annex II of the Decreto IMMEX lists goods that may be imported temporarily but only if the IMMEX holder meets specific additional requirements published in sectoral Acuerdos. These include sugar and certain other sensitive agricultural and food products. For example, an Acuerdo published April 5, 2024, set out special authorization procedures for temporary importation of sugar (tariff lines 1701.13.01, 1701.14.91, 1701.91.04, 1701.99.99) by IMMEX companies, including certified companies, through August 31, 2024.

Virtual operations and domestic transfers. Article 108, seventh paragraph (added by amendment), and implementing rules in Chapter 4.3 of the Reglas Generales de Comercio Exterior (RGCE, the annual General Rules of Foreign Trade issued by the SAT) permit virtual operations (operaciones virtuales): an IMMEX holder that has imported inputs temporarily may "transfer" those inputs to another IMMEX holder or to a domestic supplier without the goods physically crossing the border. The transfer is documented by "virtual" import and export pedimentos (customs declarations). This allows supply-chain integration among multiple IMMEX facilities and between IMMEX companies and domestic contract manufacturers. The transferor's obligation to re-export or otherwise regularize the goods is deemed satisfied when the transferee files its corresponding virtual import pedimento and assumes the obligation to re-export the finished goods or pay the tariff if the goods enter the domestic market.

Under Article 105 of the Ley Aduanera, the ownership or use of goods imported under Article 108 may be transferred only to other maquiladoras, other companies holding export programs authorized by the Secretaría de Economía, or to empresas de comercio exterior (foreign-trade companies, or ECEX) registered with the Secretaría de Economía. Transfers to entities without an IMMEX program or ECEX registration are prohibited and result in the goods being deemed illegally imported.

Conversion to definitive importation. If an IMMEX holder decides to keep temporarily imported goods in Mexico for domestic sale rather than re-export them, the company must file a **definitive-importation pedimento** and pay the IGI tariff and the IVA on the full duty-inclusive base (see the guide section on import duties and VAT). The conversion must occur before the expiration of the applicable time limit. The SAT's RGCE prescribe the procedural steps and documentation (including proof of the original temporary-importation pedimento, invoices, and payment instruments).

Program administration and compliance obligations. An IMMEX program is granted by the Secretaría de Economía, not by the customs authority (ANAM or SAT). Article 11 of the Decreto IMMEX lists the application requirements, which include a description of the manufacturing or services activity to be performed, evidence of investment in facilities and equipment, and (for goods listed in Annex II) the tariff classification of inputs to be imported and the finished products to be exported. The program is valid indefinitely unless canceled or suspended.

Article 24 of the Decreto IMMEX enumerates the obligations of IMMEX holders, including:

• Filing an annual report (reporte anual) with the Secretaría de Economía, due by the last business day of May each year, covering the prior calendar year's operations (imports, exports, inventories). Failure to file the report results in automatic suspension of the program, published in the Diario Oficial de la Federación.
• Maintaining a perpetual-inventory control system (sistema de control de inventarios) that tracks all temporarily imported goods, their incorporation into finished products, and their re-exportation. The SAT may audit this system through a Procedimiento Administrativo en Materia Aduanera (PAMA, administrative customs audit under Article 144 of the Ley Aduanera).
• Designating the goods for the authorized purposes only. Diversion to unauthorized uses, domestic sale without payment of duties, or failure to re-export within the legal time limits constitute infractions under Articles 176 and 183 of the Ley Aduanera and may result in fines of 70% to 100% of the evaded duties, plus seizure of the goods.

Certified-company benefits. IMMEX holders that obtain certified-company status (Registro en el Esquema de Certificación de Empresas, administered by the SAT under the Reglas Generales de Comercio Exterior) receive significant procedural facilitations, including reduced customs-inspection rates, authorization to perform certain operations (e.g., consolidation, submanufacturing services) not permitted to non-certified holders, and eligibility to import goods listed in certain annexes of the Decreto IMMEX that are otherwise restricted. Certification is awarded to companies demonstrating strong compliance records, adequate internal controls, and secure supply-chain practices.

Comparison to definitive importation. For an importer choosing between definitive importation (paying IGI and IVA at the border, with full domestic-market rights) and temporary importation under IMMEX (no upfront payment, but export obligation and inventory-control burden), the decision hinges on the destination market. If the finished goods will be exported—especially to the United States or Canada under the USMCA (T-MEC) preferential tariff treatment—IMMEX is the clear choice because it defers or eliminates the Mexican import-duty and VAT burden and permits the company to qualify the finished goods for USMCA origin. If the finished goods will be sold in Mexico, definitive importation is mandatory (or the IMMEX holder must convert the temporary import to definitive before domestic sale).

Cross-reference: origin and USMCA. Goods imported temporarily under IMMEX and then incorporated into products exported to the United States or Canada under the USMCA must satisfy the rules of origin in USMCA Chapter 4. Non-originating inputs imported from third countries (e.g., China, the EU, Japan) may be used, but their value is included in the regional-value-content calculation and may prevent the finished good from qualifying for USMCA preferential treatment. See the Mexico rules-of-origin-and-fta guide for USMCA origin-qualification requirements.

Source: Ley Aduanera, Art. 108 Source: Ley Aduanera, Art. 104 Source: Ley Aduanera, Art. 105 Source: Decreto IMMEX, published Nov. 1, 2006, DOF Source: Decreto por el que se modifica el Decreto IMMEX, Dec. 19, 2024, DOF Source: Ley del Impuesto al Valor Agregado, Art. 28

Threshold compliance gate: no commercial imports without registry enrollment. Article 59, fraction IV of the Ley Aduanera (Customs Act) imposes a mandatory obligation on all persons who import merchandise into Mexico: they must be enrolled in the padrón de importadores (importer registry) administered by the Servicio de Administración Tributaria (SAT, the Tax Administration Service). The statute provides that importers must "be enrolled in the Importer Registry (Padrón de Importadores) and, where applicable, in the Sector-Specific Importer Registry (Padrón de Importadores de Sectores Específicos) … for which purpose they must be current in compliance with their fiscal obligations, as well as demonstrate before the customs authorities that they are enrolled in the Federal Taxpayer Registry (Registro Federal de Contribuyentes, RFC) and comply with the other requirements established by the Regulation and those established by the Tax Administration Service through rules."

This is distinct from two other compliance requirements: (i) the mandatory customs broker requirement under Article 36 of the Ley Aduanera (which addresses who may file the pedimento, the customs declaration), and (ii) the IMMEX program under Article 108 (which is voluntary and limited to temporary importations for export-oriented manufacturing). The padrón de importadores is a prerequisite for all commercial imports, regardless of the goods involved, the destination market, or whether a broker files the entry.

Without enrollment, the importer may not legally import. An attempted import without registry enrollment constitutes an infraction, and goods found in Mexican territory without proof that the importer was enrolled at the time of entry may be presumed to be illegally imported and subject to seizure.

Legal basis and implementing rules. Article 59, fraction IV of the Ley Aduanera establishes the statutory obligation. Article 82 of the Reglamento de la Ley Aduanera (Regulation of the Customs Act) prescribes the procedural requirements. The SAT publishes detailed operational instructions annually in the Reglas Generales de Comercio Exterior (RGCE, General Rules of Foreign Trade); Rule 1.3.2 of the RGCE for 2026 (published in the Diario Oficial de la Federación on December 27, 2025) governs enrollment in the general padrón de importadores.

Who must register. All natural persons (personas físicas) and legal entities (personas morales) that intend to import merchandise into Mexican territory for commercial purposes must enroll. This includes importers for resale, distribution, or further manufacture; manufacturers importing raw materials, components, or capital equipment for internal use in domestic production; and service providers importing equipment, tools, or consumables. The obligation applies equally to Mexican residents and foreign entities with an RFC and a tax domicile in Mexico.

Exemptions from the registry requirement. Article 59 of the Ley Aduanera states that the registry requirement "shall not apply to importations made by passengers, by courier and parcel companies, and by postal service, when clearance is carried out in accordance with the procedure established in Article 88 of this Law." Additional exemptions are prescribed in Article 71 of the Reglamento de la Ley Aduanera. These include:

• Passenger baggage imported under the simplified procedures of Article 88 of the Ley Aduanera.
• Courier and express-parcel shipments processed by authorized courier companies under Article 88-bis.
• Postal imports processed by Correos de México under Article 89.
• Imports by diplomatic and consular missions under Article 61, fraction I.
• Imports of medical devices and orthopedic equipment for personal use under Article 61, fraction XV, when authorized.
• Temporary imports under Cuadernos ATA (ATA Carnets) under Article 106 of the Ley Aduanera.
• Goods returning to Mexico under Articles 103, 116, and 117 of the Ley Aduanera (re-imports of goods previously exported for repair, display, or other temporary purposes).

The RGCE also identify additional narrow exemptions (e.g., agricultural inputs by ejidatarios listed in Annex 7; capital goods for exclusive use listed in Annex 8). The exemptions are strictly construed. An importer who does not fall squarely within one of the listed exceptions must enroll in the padrón.

Application requirements. Under Article 82 of the Reglamento de la Ley Aduanera and Rule 1.3.2 of the RGCE for 2026, the applicant must meet the following conditions at the time of application:

1. Be enrolled and active in the Registro Federal de Contribuyentes (RFC)—Mexico's federal tax-identification registry.
2. **Hold a valid e.firma (electronic signature certificate)** issued by the SAT.
3. Be current in compliance with federal tax obligations. Under Article 82, first paragraph, of the Reglamento, the applicant must submit documentary proof of compliance with fiscal obligations. The SAT verifies this from its databases; a negative opinion under Article 32-D of the Código Fiscal de la Federación (Federal Fiscal Code) results in rejection.
4. Have a tax domicile registered in the RFC (Article 82, first paragraph). The SAT's published guidance specifies that the domicile status must show as "located" (localizado) or in the process of verification (en proceso de verificación); a status of "not located" (no localizado) will cause rejection.
5. **Designate at least one licensed agente aduanal (customs broker) or apoderado aduanal (customs attorney)** who will file import pedimentos on behalf of the applicant. This satisfies the "conferral of mandate" (encargo conferido) requirement under Article 59, fraction III of the Ley Aduanera. The applicant must provide the broker's patent number and specify the duration of the mandate. The SAT's procedural guidance recommends designating multiple brokers to avoid rejection if a single broker's patent is suspended during the application review period.
6. Not appear on the SAT's public lists of non-compliant taxpayers published under Articles 69 and 69-B of the Código Fiscal de la Federación, except for the limited exception in Article 69, fraction VI.

Application procedure. The application is filed electronically through the SAT Portal (www.sat.gob.mx), under the section "Trámites del RFC / Importadores y Exportadores." The applicant logs in with RFC and password or with e.firma, completes a web form, registers the broker(s), and submits the form. The system generates an acknowledgment receipt (acuse de recibo) with a folio number. Under Rule 1.3.2 of the RGCE for 2026, no paper documentation is required at the time of filing; the SAT verifies eligibility directly from its databases.

Review and decision timeline. Under Article 82 of the Reglamento de la Ley Aduanera, the SAT must issue a decision within six business days (seis días hábiles) of receipt of the application. The SAT notifies the applicant of the decision through the Buzón Tributario (the SAT's secure electronic notification system). If approved, the notification includes the enrollment certificate (oficio de inscripción) and the effective date. If rejected, the notification specifies the grounds for rejection (e.g., negative tax-compliance opinion, applicant on an exclusion list).

Sector-specific registries. In addition to the general padrón de importadores, certain categories of merchandise require enrollment in a Padrón de Importadores de Sectores Específicos (Sector-Specific Importer Registry). Annex 10, Part A of the RGCE identifies the sector-specific registries and the corresponding tariff classifications. These sectors include hydrocarbons and petroleum products; alcoholic beverages and tobacco; textiles and apparel; pharmaceuticals and controlled substances; weapons, ammunition, and explosives; chemical precursors; nuclear and radioactive materials; sugar and sweeteners; and other sensitive goods. An applicant seeking to import goods in a sector-specific category must apply for both the general padrón de importadores and the sector-specific registry. The sector-specific application requires additional documentation, which varies by sector and is specified in the RGCE and the SAT's published sector-specific guides.

Indefinite validity; suspension and cancellation. Registry enrollment has no expiration date (vigencia indefinida). Once enrolled, the importer remains in the padrón unless the registration is suspended or canceled.

Article 84 of the Reglamento de la Ley Aduanera and Rule 1.3.3 of the RGCE for 2026 enumerate the grounds for suspension:

1. The importer does not hold a valid e.firma.
2. The importer has not registered or updated contact information for the Buzón Tributario.
3. The importer has failed to file required federal tax returns or failed to comply with another fiscal obligation.
4. The importer has not conducted any import or export operations for a period exceeding twelve months.
5. The importer's declared income or the value of activities declared in a fiscal period is less than 30% of the value of its importations during the same period.
6. The importer has been found by final administrative or judicial decision to have committed infractions under Articles 176, 177, or 179 of the Ley Aduanera.
7. The importer appears on one of the SAT's public lists under Articles 69 or 69-B of the Código Fiscal de la Federación.

Suspension is automatic when the SAT detects one of the listed conditions. The SAT publishes a list of suspended importers in the Diario Oficial de la Federación. A suspended importer may not legally import until the suspension is lifted. To lift a suspension, the importer must file a "reincorporation" application (solicitud de reincorporación) through the SAT Portal, correcting the underlying deficiency (e.g., filing overdue tax returns, restoring e.firma validity).

Cancellation is permanent removal from the padrón, typically imposed as a sanction for repeated or serious infractions. A canceled importer must apply for initial enrollment again as if a new applicant.

Practical implications. The padrón de importadores is the first compliance gate in the Mexico import chain. A U.S. exporter selling DDP (Delivered Duty Paid) or DAP (Delivered at Place) Incoterms into Mexico should verify that the Mexican consignee holds an active padrón enrollment before the goods are shipped. An attempted clearance with a suspended or non-enrolled importer will result in refusal of entry by the customs authority (ANAM), detention of the goods, and potential penalties.

The twelve-month inactivity rule (suspension ground 4) is a trap for sporadic importers. A company that imports once, waits thirteen months, and attempts a second import will find its enrollment automatically suspended. It must file a reincorporation application and wait for the SAT's decision before the second import can proceed.

The 30%-income test (suspension ground 5) is an anti-evasion measure targeting shell importers that import high-value goods but report little or no taxable income. Legitimate importers with genuine business operations should ensure that their declared income in monthly IVA (value-added tax) and ISR (income-tax) returns is commensurate with the value of their import activity, or they risk automatic suspension.

Cross-reference. The padrón de importadores obligation applies equally to definitive imports (permanent entry for domestic sale) and to IMMEX temporary imports. For IMMEX procedures, see the guide section on temporary importation under IMMEX programs (Article 108). For the mandatory broker requirement and conferral-of-mandate procedures, see the guide section on mandatory customs broker requirement.

Source: Ley Aduanera, Art. 59, fraction IV Source: Reglamento de la Ley Aduanera, Art. 82 Source: Reglamento de la Ley Aduanera, Art. 84 Source: Reglamento de la Ley Aduanera, Art. 71 Source: Reglas Generales de Comercio Exterior para 2026, Rule 1.3.2, DOF Dec. 27, 2025 Source: SAT — Inscríbete en el Padrón de Importadores