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.

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The recent reform to the Customs Law once again highlighted the gap between regulatory intent and the actual operation of foreign trade . At the Customs Law panel discussion during the 20th Annual Convention of the Mexican Institute of Foreign Trade Executives (IMECE) , specialists agreed that the new regulatory framework—promoted under the guise of control, traceability, and digitalization—threatens to push the customs system toward a silent paralysis if implemented without risk assessment, infrastructure, and operational clarity.

Felipe Miguel González Jaime, CEO of Corporación México Express and moderator of the panel, summed it up with a phrase that set the tone for the debate: “I no longer call him the joint customs broker, but the solitary customs broker .” With this, he illustrated the disproportionate increase in responsibilities, fines, and operational burdens placed on an actor who, for all practical purposes, has no total control over the merchandise or the accuracy of the information he receives.

The starting point was Article 42, which was formally unchanged, but which in practice carries significant weight by mandating a level of exhaustive review that contradicts the philosophy of facilitation. Zaira Padilla, president of the Association of Strategic Bonded Warehouses (ARFE) , warned that the obligation to inspect each shipment with millimeter precision negates the purpose of risk analysis and threatens to overwhelm the operational capacity of the warehouses . “We will be juxtaposing this issue of digitization and prior information with the operational reality,” she noted, recalling that in Manzanillo alone, there are reportedly more than 15,000 abandoned containers. If every shipment must be inspected 100%, she said, the entire system will be caught between the regulation and the practical impossibility of complying with it. Her diagnosis was clear: without a balance between compliance and facilitation, Mexican customs will revert to mass control schemes that have already proven inefficient.

From a logistical perspective, Juan Pablo Pacheco, former president of the Mexican Association of Freight Forwarders (Amacarga) and liaison in Mexico for the International Federation of Freight Forwarders Associations (FIATA) , defended the role of the freight forwarder as a pre-filter and key player in origin verification. He noted that the industry has developed traceability and security tools—including progress toward the Authorized Economic Operator (AEO) program for freight forwarders—that could be integrated into the system to strengthen advance inspections . “The customs broker is not alone; we can work together,” he stated. However, he emphasized the incongruity between the demand for detailed information and the authorities’ limited capacity to utilize it. “We send the information to the SAT (Tax Administration Service), and they don’t do any analysis,” he complained, highlighting a critical gap: the system already receives data that it doesn’t use to assess risks, leading to duplicate inspections and redundant processes.

The importer’s perspective, presented by David García, president of the Foreign Trade Commission of the Mexican Employers’ Confederation (Coparmex) in the State of Mexico, was the most stark. He recounted cases of fraudulent import permits, such as the container of copper that arrived full of sandbags despite having received “the blessing of all the customs saints.” For him, the reform reinforces the customs broker’s responsibility but omits the importer’s central role as the primary source of information . “We, as importers, are primarily responsible for knowing what goods we are bringing in,” he emphasized. But he also warned that the current system is not designed to effectively contain fraud or to address the complexity of sectors dominated by micro, small, and medium-sized enterprises (MSMEs) that lack the technical knowledge to comply with the required standards. His conclusion was damning: the regulatory framework is moving toward excessive demands without simplification, without infrastructure, and without a functional one-stop shop.

In this context, the discussion surrounding the Authorized Economic Operator (AEO) program emerged as a point of contention. Zaira Padilla insisted that certification should be made more accessible and accompanied by tangible benefits . “These details need to be reviewed so that risk management facilitates customs clearance,” she stated, noting that the process currently takes between a year and a half and two years and lacks basic clarity, such as the definition of “certified customs broker” or “certified transport,” concepts that the authorities have yet to define despite requiring them. Pacheco added that the cost of some certifications, such as ISO 27000 or 28000, could create monopolies and drive smaller players out of the market. “If implementation is expensive, we will lose competitiveness,” she warned.

The case of the State of Mexico reflected another structural problem: the limited—and even fearful—use of the strategic bonded warehouse due to state tax criteria that, since 2003, have required the payment of 16% VAT on transactions interpreted as sales within the national territory . “Eight out of every ten audited taxpayers had to pay,” said David García, recalling that even transactions involving merchandise acquired abroad were treated as local sales simply due to a lack of awareness and inconsistent criteria, which hindered the use of the RFE (Strategic Bonded Warehouse) as a logistical tool.

The panel concluded with a shared message: without interoperability between the Mexican Tax Administration Service (SAT) and the National Customs Agency of Mexico (ANAM) , without effective use of transmitted data, without clear manuals, and without risk criteria to distinguish reliable actors, customs reform will be incapable of modernizing anything. Zaira summarized it with a complaint: “We have an electronic customs system, but there is no communication at the central level .” David encapsulated the urgency from a business perspective: “Ask me for whatever you want, but give me what you ask for,” demanding clear rules, defined processes, and a functional single window. And González Jaime offered the final reflection: the authorities cannot revert to the customs practices of the 1980s for fear of non-compliance; if there is advance information, certified actors, and traceability, “most goods are reliable.” The challenge is not to tighten regulations for the sake of tightening them, but to use intelligence, technology, and risk management to ensure trade flows smoothly without sacrificing control. Because, as he warned, “in the end, we will all be the ones who suffer.”

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El cargo Mexican customs, between total control and paralysis apareció primero en T21.

ALTAMIRA, TAMPS.- To meet the growing import of meat by sea, the company Multimodal Altamira inaugurated the expansion of its inspection point and crossdock in this port with an investment of 30 million pesos.

The facility doubles the firm’s capacity to meet the trade flows that occur during peak seasons, such as the current end-of-year season, where imports of chicken, pork and beef from Brazil have increased significantly to supply the northeast region of the country.

“With this new investment we double our operational capacity from six to 12 doors and will allow for the annual inspection of up to 200 thousand tons of temperature-controlled foreign trade products,” said Enrique de Hita Sánchez, Chairman of the Board of Directors of Multimodal Altamira.

The new facilities are part of the company’s multi-year plan to focus its vocation on the customer , designing solutions to specific logistics needs that have allowed it to achieve growth of around 20% this year compared to the results of the previous year, CEO Kai Schmersahl told T21.

In addition to allowing the inspection of meat products by the National Service for Health, Safety and Agri-Food Quality (SENASICA) , the inaugurated facilities make crossdock logistics operations possible by transferring goods from the refrigerated maritime container to a truck box that takes them to their final destination.

This logistical work is carried out by Multimodal Altamira with the benefit of maintaining the quality of the cold chain and reducing the high costs that the use of maritime containers represents for customers, explained Adrián Sánchez Cortés, operational manager of the company.

This is an operation that the Mexican Meat Council (Comecarne) itself has recognized to the Tamaulipas logistics operator, for its contribution to the efficiency of the logistics chain .

De Hita Sánchez also reaffirmed before authorities from the state government, municipality and the National Port System Administration (Asipona) Altamirathe confidence of his company in the port and in the state of Tamaulipas, which is demonstrated by the creation of 300 new direct and indirect jobs generated by the new investment.

During 2025, the company’s investments will continue in the creation of a Strategic Bonded Area on an eight-hectare territorial reserve area and the growth of its trucking line.

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El cargo MULTIMODAL ALTAMIRA PUTS ITS MONEY ON THE GRILL apareció primero en T21.