Although intermodal transport is an efficient alternative for moving cargo in Mexico, daily operations face challenges that go far beyond the movement of containers, including: the balance between imports and exports, equipment availability, terminal capacity, and an increasingly demanding regulatory environment.

Alberto Castillo, Deputy Director of Warehouses and Foreign Trade at Grupo México Transportes (GMXT) , stated that in the last 12 months almost the entire customs framework in the country has been modified, just on October 23rd “they surprised us with a new provision in the Official Gazette of the Federation that is related to undervaluation.”

During his participation in the second day of Container Week organized by the Mexican Association of Intermodal Transport (AMTI) , he recalled that among the most relevant changes is the reform to the Customs Law published on November 19, 2025 , which came into effect on January 1, 2026, along with the new General Rules of Foreign Trade.

“We had high expectations not only for the control, but also for the facilitation of customs operations; however, controls were increased, but customs facilitation was reduced, because the more you control, the less you facilitate,” he said.

Subsequently, on February 23, 2026, the Customs Law Regulations were updated to establish in greater detail various operational procedures and obligations related to the presentation of information.

Also, starting April 1, a new requirement for Strategic Fiscalized Premises began to be applied, in addition to modifications related to the registration of carriers , reinforcing the requirements for those who participate in operations linked to customs clearance, to mention a few.

Castillo also commented that previously it was possible to make various changes to the customs declarations before customs clearance, “now that’s no longer the case, there are certain restrictions on doing so, and if you want to do it after clearance there are even more limitations.”

Regarding the implementation of the electronic value declaration, he mentioned that it will begin on November 1st, and will be implemented in stages: November 15th for the strategic bonded warehouse, December 1st for transits, December 15th for the bonded warehouse, January 1st, 2027 for temporary imports, and January 15th for definitive imports.

“It will have an impact, yes. I would hope not as much as at the beginning. The fact that the implementation of this declaration of value was postponed for so long allowed many companies to already have the technological means to do it quickly. Yes, there will be an impact, as with any new legislation, but little by little it will become more agile,” he explained.

Regarding undervaluation, Castillo indicated that in this case it will be the customs authority that “assumes” that certain merchandise is under such circumstance, “that is the problem and the sanctions are very high.”

The above is related to the fact that the Mexican Congress concluded the approval of the changes to the Customs Law, so the decree was published in the Official Gazette of the Federation on October 23, with an entry into force scheduled for January 1, 2027.

The modifications, focused on preventing undervaluation, strengthen the review of the declared value and eliminate the 50% threshold that conditioned the cause of precautionary seizure for differences in declared value at customs between similar goods.

Given this scenario, he indicated that it is necessary to monitor and map where each flow is dispatched, confirm that the carriers are registered with the authority, and require seals, customs declarations, among other documents.

Comment and follow us on LinkedIn:  @Evangelina del Toro  /  @GrupoT21

El cargo The challenges facing freight transport in Mexico apareció primero en T21.

Changes in customs regulations are presenting new challenges for companies involved in foreign trade . In addition to the operational demands that importers and carriers face daily, there is the need to accurately document the individual cost of cargo insurance , a process that can translate into increased administrative burdens, delays in customs clearance, and additional costs for supply chains.

One of the main challenges lies in the use of traditional transport policies , particularly those contracted annually, because companies need information that allows them to identify the insurance cost corresponding to each operation.

In an interview with T21, Milter López, head of Damages at CAE Insurance , explained that the new documentary requirements are forcing companies to review their internal procedures and strengthen the integration of their electronic files.

One of the main problems arises when companies do not have timely individual insurance calculations, a situation that can cause reprocessing and delays in preparing the documentation necessary for their operations, according to the specialist.

This occurs because annual policies, traditionally used to insure the movement of goods, require additional procedures to determine the cost corresponding to each shipment, which increases the administrative work of the companies.

The implications are not limited to documentary compliance. López warned that errors can also have economic consequences for companies , both in terms of potential fines and penalties and the expenses associated with goods remaining in customs facilities for longer periods.

In that regard, he noted that delays in the release of shipments can extend their effects to other links in the supply chain, compromising the planned delivery times for products and the development of commercial operations.

Digitization: efficiency or increased administrative burden?

Although the digitization of customs records seeks to strengthen transparency and fiscal control of foreign trade operations, its implementation is also demanding greater administrative and technological capabilities from companies.

According to López, these procedures are creating an additional workload, particularly due to the level of documentary accuracy required to support each transaction.

The challenge also extends to small and medium-sized importing companies (SMEs), which must adapt to the requirements and have mechanisms that allow them to correctly integrate the information related to the insurance of their goods .

Thus, customs compliance depends not only on having the commercial documentation of a transaction, but also on having accurate and timely information on the costs associated with the transfer of the products.

Faced with this scenario, CAE seeks to meet the needs of companies through insurance strategies that allow for a more accurate identification of the costs corresponding to their freight transport operations.

López explained that “one of the main approaches consists of anticipating and mitigating risks through solutions adapted to the characteristics of each client,” considering that not all companies require the same products or face the same operating conditions.

In particular, he highlighted the importance of having assurance mechanisms that facilitate the identification of the individual cost of each operation , instead of relying exclusively on traditional schemes that may require additional calculations and procedures.

The company works with small, medium and large companies, through cargo transport insurance in its land, sea and air modalities , both in operations related to foreign trade as well as in national movements.

In addition to meeting the documentary requirements, the specialist stressed that companies must consider the risks associated with the transport and storage of their goods, including theft and possible delays during customs processes.

Thus, in an environment of greater documentary requirements, the correct identification of insurance costs becomes a relevant element to avoid administrative setbacks and protect the continuity of logistics operations .

Comment and follow us on LinkedIn:  @Karina Quintero / @GrupoT21  

El cargo Customs changes demand greater precision in cargo insurance: CAE Insurance apareció primero en T21.

The reform to the Customs Law approved yesterday by the Chamber of Deputies maintained stricter controls against undervaluation , although it leaves the subsequent definition of goods and procedures for applying precautionary seizures to customs authorities. This adjustment introduces the possibility of differentiated treatment in response to warnings from manufacturers, importers, and customs brokers regarding cargo detentions, liquidity issues, and potential disruptions in supply chains.

The bill was sent to the Senate for review, discussion, and potential approval. The version approved by the Finance and Public Credit Committee proposes that the decree take effect on January 1, 2027 , instead of the day after its publication in the Official Gazette of the Federation (DOF), as initially proposed by the Executive branch.

The main change remains in Article 151, Section VII of the Customs Law: the requirement that the value declared in the customs declaration be 50% or more lower than the transaction value of identical or similar goods to trigger this ground for precautionary seizure is eliminated. The exception related to the provision of the guarantee stipulated in Article 86-A is also eliminated.

However, the ruling includes a second transitional provision stipulating that this provision will apply “to the goods and in accordance with the procedure determined in the regulations issued for this purpose by the competent customs authorities.” For goods other than those defined under this scheme, the authorities may establish a percentage difference in value that must be considered for proceeding with the seizure.

The provisions must be published in the Official Gazette of the Federation (DOF) no later than December 31, 2026. Until they are published, it remains to be seen which goods will be subject to the new controls without the current threshold, which will be subject to a percentage parameter, and how the procedure will be carried out. The transitional provision does not expressly establish a general exclusion for industrial inputs, capital goods, used goods, or temporary imports by IMMEX companies (manufacturing and export assembly companies that use a special customs regime).

This point partially addresses one of the main arguments presented during the commission’s previous meeting with foreign trade representatives : a price difference may be due to legitimate commercial conditions and does not necessarily indicate fraudulent activity. Participants requested that factors such as quality, brand, purchase volume, technical specifications, contracts, discounts, and condition be considered before impounding goods.

The automotive and auto parts industry warned that components classified under the same tariff heading can have different applications and prices. It was also pointed out that withholding a part can disrupt production lines that rely on synchronized deliveries, while deposits to replace an embargo tie up resources needed to maintain operations.

Other sectors, particularly footwear and alcoholic beverages, supported stronger tools against undervaluation, arguing that artificially low values ​​create unfair competition and harm formal production. The discussion, therefore, focused not on the need to combat tax evasion , but on the evidence and procedures required to justify an audit, seizure, and subsequent release of the cargo.

The ruling maintains the addition to Article 144, allowing authorities to initiate verification procedures ex officio when the declared value is lower than that of identical or similar goods, as determined in accordance with Articles 72 and 73 of the Customs Law. The second transitional provision specifically addresses the grounds for seizure under Article 151 and therefore does not modify that provision regarding the initiation of audits.

It also retains the embargo substitution scheme provided for in Article 154 for goods not subject to estimated prices. If the value difference is less than 20%, the interested party may request the substitution by means of a cash deposit or a customs guarantee account; if it is 20% or more, by means of a cash deposit. In both cases, the interested party will have 10 business days from the notification of the start of the administrative procedure to submit the request.

The amount will correspond to the contributions and countervailing duties that would be incurred due to the difference between the declared value and the value determined by the authority. Thus, although a way remains to replace the seizure of goods, the financial treatment will depend on the magnitude of the identified difference.

In parallel, Article 153 maintains the obligation to resolve cases immediately, without imposing penalties, when documentary evidence refutes the grounds for the seizure or proves that the value was determined in accordance with the law. In such cases, the return of the merchandise, the release of the guarantee, or the return of the cash deposit will be ordered . However, the text does not include a specific timeframe in days for carrying out the physical release, one of the requests made by operators during the discussion.

The proposal also maintains the reduction from 50% to 20% of the value difference threshold provided for in the presumption of infringement of article 177, section XII. This assumption corresponds to goods introduced under regimes that allow for the determination of duties without paying them and maintains the other legal conditions, including that, if they had been destined for definitive importation, the payment of foreign trade taxes or countervailing duties would have been totally or partially omitted.

Along with these changes regarding valuation, the ruling incorporates specific penalties for hydrocarbons and petroleum products. The additions to sections I, II, and III of Article 185 establish fines of 50% to 100% of the commercial value of the goods when the corresponding violations involve these products. The commission justified the differentiated treatment due to their economic and fiscal significance, as well as their use in smuggling and control evasion schemes.

The document indicates that the modifications to Article 185 and the transitional provisions stem from two reservations presented by Carol Antonio Altamirano, president of the Finance and Public Credit Committee, and approved by its members. To support the provision on seizures, the committee proposed strengthening a control model based on risk identification and management , focusing oversight on transactions with the greatest potential to affect the accurate determination and payment of taxes.

With its submission to the Senate, the reform enters a new legislative phase. Its review will encompass a text that retains the main powers proposed by the Executive branch, but whose differentiated application will depend on subsequent administrative regulations . For companies and logistics operators, these provisions will be crucial in determining when a discrepancy in value will lead to an audit or the seizure of goods, and how they can document their transactions.

Comment and follow us on LinkedIn:  @Enrique Duarte Rionda / @GrupoT21

El cargo Lawmakers approve customs reform; scope of seizures will be subject to new rules apareció primero en T21.

The repeal of Annex 4 of the Estimated Prices Resolution changed the treatment applicable to certain imports of textile and clothing products since September 15 , by eliminating the price reference that conditioned the presentation of an automatic import permit.

In response to concerns raised by transactions that were in the process of being finalized, the Ministry of Economy (SE) and the National Customs Agency of Mexico (ANAM) clarified the criteria that companies using consolidated customs declarations must apply.

The resolution repealing Annex 4 was published in the Official Gazette of the Federation (DOF) on September 14 and took effect the following day. The document states that the measure is part of a review of the estimated pricing system, within a context of strengthening risk analysis, oversight, and customs valuation mechanisms.

What was Annex 4?

Annex 4 was part of the resolution of the Ministry of Finance and Public Credit (SHCP) that establishes a mechanism to guarantee the payment of taxes on goods subject to estimated prices.

In practical terms, it established reference values ​​for certain goods in the textile and clothing sectors. When a good was imported below the corresponding estimated price, the mechanism was linked to the obligation to guarantee any differences in duties.

The scheme originated in a resolution published in 1994, which aimed to require importers to provide a guarantee against potential discrepancies in duty payments and contribute to combating undervaluation. In 2014, estimated prices for the textile and apparel sectors were specifically incorporated into Annex 4.

The repeal does not mean that the authority’s power to review the declared value of goods or combat undervaluation practices has been eliminated. The resolution itself indicates that the Customs Law maintains verification powers that allow the authority to safeguard the fiscal interest.

One of the direct effects of the elimination of Annex 4 is on the automatic import permit for textile and clothing products.

The Ministry of Economy explained that the requirement provided for in Annex 2.2.1, numeral 8 BIS, section II, was conditional upon the unit price of the goods being lower than the estimated price established in Annex 4.

With the elimination of that requirement, as of September 15, import operations for textile and apparel products are no longer subject to the presentation of that automatic permit for that specific reason. This does not eliminate other regulations and non-tariff restrictions that apply to each type of merchandise.

To determine the applicable provisions, the SE and ANAM pointed out that the dates provided for in article 56 of the Customs Law must be considered.

Consolidated customs declarations

The change becomes more complex for companies that started operations before September 15 through a consolidated customs declaration.

This mechanism allows for multiple transactions by the same taxpayer to be covered under a single customs declaration , in accordance with the provisions of the Customs Law. In certain transactions, goods may be imported in separate shipments and subsequently consolidated into a single customs declaration for final processing.

The Customs Law establishes that, for those who use this modality, the consolidated customs declaration must be transmitted to record the operations carried out during the corresponding period, in addition to complying with the obligations related to non-tariff regulations and restrictions.

The transition problem arises because a single order may contain shipments made before and after the repeal of Annex 4.

For these cases, the SE and ANAM established that if the first shipment was made before September 15, companies may submit the corresponding weekly or monthly consolidated customs declaration, taking the date of entry of the goods as that of the first shipment.

This means that the obligations applicable to the operation must be determined based on the provisions in force on the date of entry of the first shipment, even if subsequent shipments or the closing of the customs declaration occur after the repeal.

However, the exchange rate must be the one corresponding to the date on which the transaction is closed.

A sector with a significant flow of imports

The change affects a sector with a significant flow of foreign trade. According to the National Chamber of the Textile Industry (Canaintex) , total Mexican exports of textiles and apparel in 2025 amounted to $7.664 billion, compared to $13.271 billion in imports during the same period.

The size of these flows helps to understand why the regulatory transition may have operational implications for importers, customs agents, and companies that use remittance-based clearance schemes.

Furthermore, Annex 4 was not a recent provision. The estimated price mechanism for textiles and clothing had undergone several modifications since its inception, including an update in 2024, before its repeal in September 2026.

The clarification issued by the SE and ANAM seeks to prevent the modification of the estimated price framework from generating uncertainty about operations that had already begun under the previous rules; the aim is to provide certainty and maintain orderly customs management during the transition.

Comment and follow us on LinkedIn:  @GrupoT21

El cargo Repeal of Annex 4 changes rules for imports in the textile and clothing sectors apareció primero en T21.

A discrepancy between the price declared by an importer and the price of other goods could trigger an audit and lead to the seizure of cargo without reaching the currently established 50% threshold. This is the change that has placed the proposed reform to the Customs Law, linked to the 2027 Economic Package, at the center of discussion . During a meeting held yesterday by the Finance and Public Credit Committee of the Chamber of Deputies , representatives from productive sectors and foreign trade operators agreed on the need to combat undervaluation, but expressed differing opinions on the scope of the proposed controls and their effects on supply chains.

The Executive’s initiative proposes that when the value declared in a customs declaration is lower than the transaction value of identical or similar goods, the customs authority should initiate its verification powers ex officio. It also eliminates the 50% threshold for the grounds for precautionary seizure under Article 151 and the exception to that measure linked to the guarantee provided for in Article 86-A. The explanatory memorandum argues that the change would allow action against potential undervaluation practices “without modifying the valuation methods provided for in the Customs Law or attributing to said difference, in and of itself, the character of a definitive irregularity.”

To support the proposal, the Executive Branch reports 2,541 import transactions detected between 2025 and August 2026, with a combined commercial value of 1.5867 billion pesos , which did not trigger the seizure order because they fell below the current threshold. This figure represents the value of these transactions, not the amount of allegedly unpaid taxes. The initiative also indicates that in 2025 there were 44,232 definitive import transactions using customs guarantee accounts based on estimated prices, primarily in footwear, textiles, and apparel.

José Ignacio Zaragoza Ambrosi, president of the Confederation of Associations of Customs Brokers of the Mexican Republic (CAAAREM) , supported the revenue-raising objective but asked that the measure be directed where the problem is concentrated. “Combating undervaluation and protecting revenue is a legitimate priority for the customs brokers’ association,” he stated. His proposal consists of incorporating a due diligence standard for brokers into Article 54 , limiting the new criterion to sensitive final consumer goods, and replacing immediate seizure with a retention process with defined deadlines for notification, proof of value, and resolution. In this way, he argued, the friction would not extend to inputs and assets used by export manufacturing.

The discussion about what constitutes a valid comparison dominated much of the meeting. Virgilio Antonio Vallejo, of the Latin American Confederation of Customs Agents (CLAA) , argued that a price lower than that of another commodity is not sufficient to reject the declared transaction value. He requested a study of the proposal’s compatibility with Mexico’s international customs valuation commitments and warned that seizures and impoundments could affect liquidity, congest customs offices, and increase the number of appeals.

Zurisadai Cruz Jain, from the foreign trade consultancy TecMex , explained that even goods that appear similar can have different prices due to volume, quality, or commercial conditions; she also questioned why some reviews use prices from retail platforms as a reference for wholesale imported goods.

The contrasting view emerged from industries that consider themselves harmed by the undervaluation. Panambí Garcés, director general of the Commission for the Wine and Spirits Industry (CIVyL) , supported the elimination of the 50% threshold, arguing that it leaves room for irregular operations and puts formal businesses at a disadvantage. She called, however, for a procedure that compares equivalent beverages based on brand, origin, quality, aging, presentation, and market level. “We are not seeking to pay less; we are seeking better tax collection for the State,” she summarized.

Alberto Lerín, representing the footwear industry chambers of Guanajuato and Jalisco, and the National Chamber of the Textile Industry (Canaintex) , also advocated for greater tools for the authorities. He cited cases of imported footwear with declared values ​​of one cent per dollar and argued that the entry of merchandise at artificially low prices causes damage to domestic production that a subsequent warranty cannot repair. In his opinion, Articles 72 and 73 of the Customs Law already contain criteria for comparing identical or similar goods without equating products of different quality, brand, or function.

That response did not allay the automotive industry’s concerns. Hilda López Varela, speaking on behalf of the Mexican Automotive Industry Association (AMIA) , explained that two components with similar appearance or function can have different prices due to technical specifications, materials, or equipment. Alejandra Rosete, Director of Foreign Trade and Economic Studies at the National Association of Bus, Truck, and Tractor-Trailer Manufacturers (ANPACT) , added that the same tariff classification can include parts intended for vehicles of different classes . Both warned that withholding components would affect integrated operations with North American supply chains and production systems tailored to delivery times.

Gabriel Padilla Maya, director general of the National Auto Parts Industry (INA) , translated this difference into practical terms: components classified under the same tariff heading may not be interchangeable and may exhibit legitimate price variations. “The same tariff heading does not necessarily mean the same merchandise from a technical or commercial standpoint,” he pointed out. He requested comparability criteria based on application, materials, and market segment ; a mandatory timeframe for releasing goods once the fiscal interest has been protected; and a treatment that distinguishes automotive technical textiles from those intended for clothing and apparel.

Fernanda Padilla Rangel, representative of the National Council of the Maquiladora and Export Manufacturing Industry (Index) , requested explicit clarification regarding the treatment of temporary imports by IMMEX companies. She also pointed out that importers lack access to the values ​​of other transactions that the authorities would use to compare prices . Index proposed resolution and cargo release deadlines once the declared value is verified or a guarantee is established. This proposal is particularly relevant because the initiative reduces the threshold for a presumption of infraction, as stipulated in Article 177, from 50% to 20% for certain regimes that allow for the determination of duties without payment, provided that all other legal conditions are met.

Liquidity was another key focus of the discussions. The initiative retains the possibility of requesting the substitution of the embargo for goods not subject to estimated prices, but establishes different treatments: for a difference of less than 20%, it provides for a cash deposit or a customs guarantee account; for a difference of 20% or more, a cash deposit. Norma Angélica Solís Rosas, from Intrade Smart , and Georgina Noricumbo Aguilar, representative of Solución Integral al Comercio Exterior , pointed out that importers and customs brokers lack access to some of the third-party information necessary to anticipate these comparisons . Noricumbo warned that immobilizing resources and goods for even small differences could be especially burdensome for smaller companies.

From Concanaco Servytur , Jessica Morales requested that the authorities provide technical justification for any doubts regarding the value before seizing goods, distinguish between correctable errors and fraudulent operations, grant the importer a hearing, and make their comparison parameters transparent. Luis Alberto Gaitán Morales, representing the import sector, asked that the history of certified companies be considered to offer them an opportunity for clarification . Arturo Pérez Behr, a customs broker, proposed specific treatment for used goods, whose value depends on wear and tear, repairs, functionality, and remaining useful life.

The potential effects wouldn’t end at the customs office. Antonio de la Rosa, of Agencia Aduanal de la Rosa , warned about the physical capacity to store more seized merchandise and proposed strengthening subsequent audits. José Aguilar Méndez, of DHL Express Mexico , urged leveraging the information already being shared by shipping lines, carriers, freight forwarders, and customs brokers to identify high-risk operations. Eréndira Hernández, president of the National Association of Bonded Warehouses (Anafac) , linked the debate to saturation and storage costs; she also suggested reviewing the framework for granting concessions and authorizations for these facilities to ensure the continuity of long-term investments.

Samuel Ortiz, a researcher at the Faculty of Economics of the National Autonomous University of Mexico (UNAM) , called for linking customs enforcement with a policy for developing domestic suppliers. Representing the garment industry, Juan Manuel Curi Ramírez and Alejandro Acalco supported combating unfair imports but expressed reservations about embargoes as a general response. Georgina Estrada, from the Confederation of Industrial Chambers (Concamin) , requested that industry participate in defining valuation criteria for sensitive sectors . The presentations showed that even among sectors affected by undervaluation, there are differences of opinion regarding when to detain merchandise and when to allow its release with a guarantee.

At the close of the legislative session, Patricia Flores Elizondo, of the Citizens’ Movement, argued that the price difference could justify an alert, but requires a technical procedure before passing on the cost of a seizure to the importer . Jericó Abramo Masso, of the PRI, asked for an analysis of the conditions in each sector and announced that he would seek a counterproposal to the ruling. Héctor Saúl Téllez Hernández, of the PAN, warned that the text has a general scope even though part of the justification focuses on sensitive goods; he stated that his party would present reservations. Héctor Pedroza Jiménez, of the PVEM, supported continuing the working groups to incorporate the experience of those who operate daily in customs.

On behalf of the Morena party, Representative Carlos Palacios highlighted the requests to define due diligence for customs brokers, differentiate between fraud and legitimate errors and variations , review operating costs, and consider international valuation rules. Representative José Narro Céspedes requested that the analysis include the effects of agricultural imports on domestic producers. In closing, the Chairman of the Finance and Public Credit Committee, Carol Antonio Altamirano, announced that the report would be sent to the Ministry of Finance and that the legislative process would continue.

The pending legislative decision thus goes beyond simply eliminating a percentage. The commission must determine what evidence justifies reviewing a transaction, under what conditions merchandise can be seized, and how long it must be released if the importer proves its value . Whether the new controls address the undervaluation practices reported by the industry without extending their costs to the regular flow of supplies, equipment, and consumer goods depends on this precision.

Comment and follow us on LinkedIn:  @Enrique Duarte Rionda  /  @GrupoT21

El cargo Customs reform sparks dispute over the cost of combating undervaluation in Mexico apareció primero en T21.

With the aim of promoting greater efficiency in logistics and foreign trade operations, the Mexican Intermodal Transport Association (AMTI) met with representatives of the National Customs Agency of Mexico (ANAM) to discuss various strategic issues, including the cancellation of Annex 29 of the General Rules of Foreign Trade (RGCE) of the Tax Administration Service (SAT) , a measure that would simplify procedures, avoid duplicate processes and expedite the flow of goods in the country.

Yolanda Esquivel, general director of AMTI, specified that they held a meeting with the authorities on August 12 to review several issues.

“One of them is Annex 29, where what we are seeking is the cancellation of this document to streamline the customs process; we have agreed that it will be done digitally, we are continuing along this path with ANAM and they are open to discussing this issue. The same applies to Annex 23,” he explained during their monthly meeting.

AMTI has been working with ANAM since September 2024 on various technical working groups and tests aimed at digitizing Annex 29 .

However, based on the analysis carried out during this process, it was considered important to rethink the objective and consider eliminating Annex 29 instead of continuing to dedicate efforts to its digitization, “since the required information is already largely contained in other documents and foreign trade systems available to the authority, such that other customs offices operate without this document.”

Therefore, the agency seeks to analyze the legal and operational feasibility of eliminating this requirement , removing duplication and administrative burdens without affecting traceability or the control powers of the customs authority.

He indicated that, for the reference of the areas that will follow up, the latest chain of communications on the Annex 29 application was shared, where the background and progress made so far can be found.

Regarding Article 23/Annex 29, the aim is to standardize and eliminate the requirement. At the meeting on August 12, AMTI also noted that a similar problem arises under different names depending on the customs office.

In Veracruz, the requirement is operationally identified as Article 23 , while in other operations it is handled as Annex 29.

Beyond the terminology used at each customs office, whether rail or maritime, AMTI’s approach is to comprehensively review both processes , identify the information that is currently requested in duplicate, and analyze the legal and operational feasibility of eliminating these requirements when the authority already has the corresponding information through other means.

Annex 29 specifies the goods that cannot be temporarily imported for processing, transformation or repair, nor destined for regimes such as bonded warehouse, bonded area or strategic bonded area.

These products include jet fuel; petroleum or bituminous mineral oils; butane and propane, mixed together, liquefied; biodiesel and its mixtures, without petroleum or bituminous mineral oils or with a content of less than 70% by weight of these oils, and others, according to the Official Gazette of the Federation (DOF) .

Annex 29 is based on the Customs Law and is important for importers, exporters and customs agents, avoiding penalties and ensuring that foreign trade operations are carried out in accordance with the law.

Comment and follow us on LinkedIn:  @Evangelina del Toro  /  @GrupoT21

El cargo AMTI reiterates to ANAM the request to eliminate Annex 29 to expedite the movement of goods apareció primero en T21.

The entry into force of the new provisions of the Customs Law in 2026 did not create new risks for Mexican importers, but it did make the consequences of lacking robust documentation processes much more visible. In an environment where the authorities demand greater traceability and verification capabilities, digitization ceased to be a competitive advantage and became an operational requirement.

This was stated by Iván Hernández, general director of QIMA LATAM , who explained that the main change lies in the strengthening of the authority’s verification powers and in the increase of sanctions for inconsistencies in foreign trade operations.

“It’s not that the reform has invented new obligations, but rather that today the fines, sanctions and co-responsibility between importers and customs agents make the risk much more evident,” he commented in an interview.

One of the most important changes is the elimination of the customs agent’s exclusive responsibility , which increases scrutiny of importers, who must now more easily demonstrate the legality and traceability of each of their operations.

Hernández explained that, for years, many companies implemented processes to get to know their suppliers as a good business practice, mainly to avoid fraud or working with non-existent companies.

However, with the entry into force of the electronic declaration of value (MVE) and the obligation to integrate electronic files , these practices are now part of the legal defense strategy of companies.

“Before, compliance was enough; now, proof is required. If the authorities request proof of a supplier in China, India, or Vietnam, the importer must have documentary evidence to support the entire transaction,” he stated.

This involves proving aspects such as the physical existence of the supplier, its address, legal representative, production capacity and the materiality of the operations that gave rise to the import.

Digitization is no longer optional

The executive stated that the digitization of the supply chain has gone from being a tool to improve efficiency to becoming an indispensable element for complying with regulations.

In this context, he stressed that companies need to have digital files that integrate contracts, purchase orders, audits, inspections, and documentary evidence available in real time.

“Commerce as we knew it, based on physical files and paper, is over. Digitalization is here to stay, and the authorities are not going to back down,” he said.

Although the new regulatory framework promotes digitization for legal reasons, Hernández highlighted that companies also obtain significant operational benefits.

Among them, he mentioned greater visibility over production, better control of suppliers, reduction of fraud, real-time tracking of purchase orders, and greater certainty that the merchandise shipped corresponds to that declared to the authority.

He also highlighted that preventive audits allow for the detection of inconsistencies before the merchandise leaves the country of origin , avoiding delays, additional costs, and inspections at Mexican ports.

“We often find suppliers who have changed their address, modified their information, or even companies that simply don’t exist. Detecting this before shipping prevents much bigger problems,” he explained.

Another effect observed after the reform is an increase in physical inspections carried out by customs agents, who now seek to reduce their exposure to penalties arising from shared responsibility.

In response, the company has strengthened its prior inspections at origin, inspections carried out before shipment to verify quantities, labeling, compliance with non-tariff regulations and container conditions.

According to Hernández, these reviews allow customs agents to have advance information to prepare the shipment and reduce stay times in port.

“Today, a labeling error or a discrepancy in the merchandise can cause significant delays . Verifying the cargo at the point of origin allows us to correct deviations before the container arrives in Mexico,” he stated.

Despite the regulatory changes, Hernández believes there is still a widespread lack of awareness among small and medium-sized enterprises about the new obligations .

While large corporations have been working under compliance and audit schemes for years, many importers still do not grasp the importance of having complete digital records.

“The recommendation is very clear: know your supplier, don’t take anything for granted, and document everything. Trust is no longer enough; now you have to be able to verify every transaction,” he emphasized.

Comment and follow us on LinkedIn:  @Jennifer Galindo  /  @GrupoT21

El cargo Customs Law Reform Accelerates Digitization of Supply Chains: QIMA apareció primero en T21.

TIJUANA, BC.- The reform to the Customs Law that came into effect in 2026 not only modified operational processes in Mexican foreign trade; it also altered the logic under which authorities, customs agents, carriers, logistics integrators and IMMEX companies – maquiladora and export manufacturing companies with a special customs regime in the country – interact .

Under a renewed regulatory environment – for importers, exporters and their logistics chain – marked by greater documentary requirements, reinforced traceability and a new approach to compliance , the participants in the panel “Customs, compliance and risks in increasingly demanding borders”, held during the ETYL Cali-Baja 2026 of Grupo T21, agreed that the logistics chain is currently facing one of its most complex moments in decades.

Moderating the discussion, Héctor Landeros, partner at HXLA Customs & Trade , argued that the major challenge lies in the new paradigm that attempts to balance trade facilitation and customs control . However, he cautioned that the authorities still don’t seem to fully understand how to achieve both objectives simultaneously. “Facilitation is an act in which I (the government), as customs, allow goods to flow while still maintaining control,” he explained, noting that risk management should be the mechanism for distinguishing compliance profiles and avoiding widespread overregulation.

This paradigm shift was evident in the operational experience of IMMEX companies. Gabriela Fernández, Trade & Logistics Manager at TACNA Services , described the radical transformation that foreign trade has undergone in the last 25 years, from improvised operations with Excel spreadsheets and radio communication, to a hyperconnected ecosystem where traceability has become a regulatory requirement . “Before, you’d say ‘bless’ to the driver and you’d never know if he’d actually crossed the border,” she recalled.

However, technological advancements have brought new obligations that, from her perspective, have significantly increased the pressure on companies. The executive pointed out that one of the most sensitive issues is the new requirement to share sensitive information related to contracts, labor costs, and production processes, something that has generated particular concern among foreign companies operating under shelter schemes . “What guarantee can you give them that all this information we’re uploading tomorrow won’t be hacked and shared with the competition?” she asked.

Fernández also warned that the regulatory impact is not uniform . While large companies have the capacity to invest in technological infrastructure, automation, and servers, small and medium-sized enterprises face real difficulties in complying. “Small businesses are praying and crying that they don’t get audited because it’s truly difficult for them to comply,” he stated, explaining that many don’t even have sufficiently structured processes to generate documents like waybills or maintain robust traceability systems.

Furthermore, the pressure no longer falls solely on importers and exporters. Jacinto Romero, general director of the Romero Galaviz Customs Agency , maintained that the new environment has transformed the customs broker into a kind of “compliance officer” obligated not only to review documentation but also to verify its authenticity and substance. “We have just been given the responsibility of verifying and confirming that all the documents the client gives us are indeed genuine,” he explained.

The problem, he added, is that the new regulations are significantly increasing the administrative and technological burden on logistics providers. He even revealed that recent regulatory changes already require photographs of offices, machinery, and products, which increases the need for information storage and data transmission in ever-shorter timeframes. “ Just -in -time is becoming increasingly difficult and increasingly expensive,” he concluded .

Romero also anticipated that the real impact is only just beginning, due to the growing capacity of authorities to cross-reference information between agencies such as Mexico’s National Customs Agency (ANAM) and the Tax Administration Service (SAT) . From his perspective, the next step will be much more aggressive and automated electronic audits 

Meanwhile, Adrián Salinas Rangel, VP of Enterprise Sales Intermodal at STG Logistics , explained that logistics integrators have been forced to strengthen internal controls and validation mechanisms to avoid errors that could lead to delays or penalties at the border. “We must always be very vigilant, stay up-to-date with the information, and share it with the client,” he stated.

For Salinas, the central problem is that digitization and automated data matching by the authorities virtually eliminate the margin for documentary inconsistencies. Incorrect information can translate into operational delays , inspections, or direct impacts on the carrier. “If I or the client fails to provide certain information, the carrier could face problems at the border crossing,” he warned.

Speaking from the trucking industry, Alfonso Esquer Millán, vice president of the Northwest region of the National Chamber of Freight Transportation (Canacar) , described a scenario where the loss of productivity is beginning to become a severe financial risk. He explained that crossing times for trucking are increasing, while operating costs remain under commercial pressure . “What we used to sell for a certain amount of money for a two-hour trip, people now want to buy for the same price in four hours or more of service,” he stated.

The transport leader was even more critical, pointing out that the new regulatory approach seems to be based on a presumption of guilt toward the private sector. “When they made the rule, they thought we were all fraudsters,” he stated, noting that fines and liabilities have grown disproportionately compared to the actual profit margins of the transport industry.

Beyond sectoral differences, the panel revealed a common concern: the speed at which new regulatory requirements are advancing contrasts sharply with the operational and technological capacity of much of the logistics chain to adapt. In this tension between control and trade facilitation , the risk is that the Mexican border will end up becoming an increasingly bureaucratic, costly, and slow space for those who do seek to comply.

Comment and follow us on LinkedIn:  @Enrique Duarte Rionda  /  @GrupoT21

El cargo New Customs Law strains border operations in Mexico apareció primero en T21.

Five months after the reform to the Customs Law came into effect , foreign trade in Mexico is undergoing a profound adjustment process. The operation has become slower, more expensive, and above all, stricter, but also more precise, experts agree.

For Magaly Cavazos, customs agent and vice president of the Association of Metropolitan Customs Agents (AAADAM) , the change has been structural: “you can no longer operate as in 2025; it is a new way of understanding customs . ”

Beyond operational adjustments, the reform implies a fundamental change in the foreign trade model. According to what was stated at a conference of the Mexican Institute of Foreign Trade Executives (IMECE) , the new regulatory framework has shifted a significant burden onto the customs broker , who, without being an authority or owner of the merchandise, has become the central figure in verifying compliance.

This shift has been supported by industry stakeholders. Felipe Miguel González Jaimes, former president of the Latin American Confederation of Customs Agents (CLAA) , noted that the role of the customs agent has expanded beyond simply clearing goods to encompass a comprehensive audit of the taxpayer . “Today it’s: customs agent, know your importer,” he summarized.

THE TRUE IMPACT

One of the main effects has been the tightening of processes. The elimination of room for interpretation and the expansion of responsibilities have forced the entire chain to raise its standards.

Today, no transaction can proceed without a complete file. “It’s become a very clear line: there’s no green light if the entire file isn’t ready,” Cavazos explains. This includes everything from technical documentation to physical evidence of the transactions , which has required conducting client visits and strengthening compliance areas.

In this respect, the General Rules for Foreign Trade have formalized this requirement by mandating the validation of everything from the client’s operational capacity to their tax status. In practice, risk assessment has shifted to the beginning of the supply chain.

Comment and follow us on LinkedIn: @Jennifer Galindo / @GrupoT21

El cargo Foreign trade under scrutiny: the real impact of customs reform apareció primero en T21.

The Strategic Fiscal Zone (RFE) customs regime in Mexico faces a turning point that highlights the gap between the new regulatory framework and its operational viability. The entry into force of the reform to the Customs Law on January 1, 2026—and, more specifically, the activation of Article 86-A, Section III , on April 1—introduced an obligation that, in practice, cannot be fulfilled: guaranteeing duties through customs guarantee accounts or letters of credit without a functional financial mechanism in place. The result has been an immediate disruption to the operation of a system that, prior to the reform, functioned as a key component for logistics, distribution, and the integration of production processes in Mexico.

“Currently, there is no financial instrument that we, as Strategic Fiscal Entities (ARFE), can use to comply with this article,” warned Zaira Padilla, president of the Association of Strategic Fiscal Entities (ARFE) , in an interview with T21, describing a problem that is not limited to a technical adjustment but has escalated into an operational standstill. “From April 1, 2026, to the present, these services have been paralyzed , since there are no secondary guidelines (…) the banks say, ‘I don’t know how to use it.’”

The impact is particularly concentrated in facilities dedicated to handling, storage, and safekeeping , which constitute the majority of the country’s RFE (Regional Economic Facilities) and play a critical role in supply chains. Unlike RFE focused on manufacturing, processing, or repair—where the impact of Article 86-A is not direct—these facilities operate as logistics centers that allow for the labeling of goods, compliance with regulations such as Mexican Official Standards (NOMs), cargo deconsolidation, avoidance of port costs, and the redistribution of products to different markets.

Historically, their role has been to provide flexibility to the system. “These other facilities, those that handle, store, safeguard, display, sell, and distribute goods, are the most numerous throughout the country , and we serve as an operational and logistical outlet. For example, a distribution center in Monterrey, where merchandise arrives from abroad, can offer pick and pack services , labeling, and you can combine products from different countries and then disperse your distribution,” Padilla explained, detailing the operational logic that is currently disrupted.

As of January 16, 2026, the Tax Administration Service (SAT) had a record of 61 RFE administrators (industrial parks) that house 54 RFE operators (companies).

The underlying problem lies not in the obligation itself, but in its incompatibility with the dynamics of the system. Unlike other scenarios where financial guarantees are already used—such as estimated prices or transit—the RFE (Register of Excise Duties) involves complex merchandise flows, with multiple entries, partial exits, and inventory replenishment. “The financial instrument of a customs guarantee account and a letter of credit does exist in banks; however, they are not specifically designed for RFE . We can have multiple entries and multiple exits. That customs declaration might be combined with eight other declarations from the same client, and we make a withdrawal of three pallets. We asked the banks, and they said, ‘No, I don’t have a mechanism to use this scheme that exists in the banking system and is commonly used for these other operations. I don’t have those mechanisms to use with you under this different arrangement.’”

The lack of operational implementation has resulted in a disconnect between authorities, the financial sector, and operators. Although the industry anticipated the problem and held working groups prior to its implementation, the rollout was not on time. “ We have been constantly meeting with different authorities at these working groups to express our concerns about the problem, precisely because we had already spoken with the banks and they told us, ‘We are requesting feedback from the authorities; we don’t have a statement ready, we don’t yet have the specific product required to operate.’”

In parallel, the reform introduced other adjustments that have also strained operations, such as the requirement to operate only with customs brokers certified as Authorized Economic Operators (AEOs) or registered carriers—registrations that are not fully available at all customs offices or that do not explicitly consider the nature of the RFE (Registered Freight Forwarder). However, even with these restrictions, the industry has continued to operate. The difference, in this case, is that the financial obligation has proven materially impossible to meet.

“ We have RFE literally at a standstill operationally , because, although we want to comply with what is established in the (Customs) Law, there is no financial mechanism to be able to do so, that is, materially I cannot comply with what the law says, it is really a problem that we are seeing in the day-to-day dynamics,” said Padilla, emphasizing that the problem is not one of resistance to compliance, but of practical unfeasibility.

The impact is already being felt in the reorganization of logistics operations and in disruptions to various productive sectors. “Customers across all industries, for example, from different types of industries that use or were using these RFE schemes until recently, are seeing their supply chains affected ; we are impacting supply chains because there are many customers, for example, in the automotive industry, we have retail customers , we have customers who are the end consumer.”

The paradox is that the regime currently facing these limitations is, at the same time, one of the most closely monitored within the Mexican customs system. “We have been complying with the requirements for strategic bonded warehouses for many years; we have control and security guidelines , cameras, and inventory control systems linked to the authorities, so we should at least receive a balanced treatment in terms of obligations,” he argued.

From the sector’s perspective, the problem isn’t strengthening controls, but rather the lack of balance with facilitation. ” Control (by the authorities) isn’t bad, nor is review , but we must have a balance between customs facilitation and customs control. We have to find that balance and, above all, consider risk management.”

The tension even extends to the regulatory design itself. The country incorporated the RFE (December 2002) as a tax deferral scheme, but at the same time, the current reform to the Customs Law imposed an operational burden that now limits its use.

Ultimately, what is at stake is not only the operation of the facilities, but the viability of a figure that has been key to attracting investment and the country’s logistical competitiveness .

For now, the sector maintains a dialogue with the authorities, hoping that implementation will find a balance that allows operations to resume without weakening control objectives. “It’s not that we don’t want to comply, it’s simply that the financial mechanism and guidelines to do so simply don’t exist, ” Padilla concluded, in a statement that encapsulates the current gap between the law and its implementation.

Comment and follow us on LinkedIn:  @Enrique Duarte Rionda  /  @GrupoT21

El cargo Reform to the Customs Law halts the operation of the Strategic Fiscal Zone apareció primero en T21.