On May 25, 2026, a monthly meeting was held with various authorities related to foreign trade operations, including representatives from the Tax Administration Service — SAT, the General Administration of Foreign Trade Audit — AGACE, the Ministry of Economy — SE, the National Customs Agency of Mexico — ANAM, the Agency for Digital Transformation and Telecommunications — ATDT, the Attorney General’s Office — FGR, and the Federal Consumer Protection Agency — Profeco. 

During the meeting, several relevant topics were addressed for companies carrying out foreign trade operations, particularly regarding registries, IMMEX, PROSEC and Eighth Rule procedures, NOM certifications, notices for the addition of tariff classifications, and certifications in the electronic customs system. 

Among the most relevant changes are the following: 

1. Requirements and penalties for errors or lack of updates in registries 

It was noted that the authority has detected errors and omissions in the notification of changes related to partners, shareholders and legal representatives, particularly in procedures linked to the Importers Registry, specific registries and sectorial registries. 

Among the main observations are the lack of timely updates, the use of expired identification documents, as well as inconsistencies between the person signing the procedures and the person registered as legal representative. 

Operational Impact: 
Companies should review that the information registered before the authority is current and matches the corresponding corporate and tax documentation, in order to avoid requirements, delays in procedures or possible penalties.

2. Follow-up on IMMEX, PROSEC and Eighth Rule procedures

It was reported that delays continue in the processing of procedures related to IMMEX, PROSEC and Eighth Rule programs. Response times remain prolonged, which may generate operational impacts and lack of certainty for companies that depend on these authorizations to continue their production processes and foreign trade operations.

However, recent progress in the response and approval times of certain procedures was also mentioned. Likewise, the authority indicated that, within the Single Window for Foreign Trade Procedures, resolution times will be monitored.

Operational Impact: 
Companies with pending procedures should constantly follow up on the status of their applications, keep evidence of filing and consider possible delays within their operational planning.

3. PAMA in temporary imports due to notices for the addition of tariff classifications

Cases were addressed in which administrative proceedings in customs matters have been initiated in connection with temporary imports by IMMEX companies, derived from notices for the addition of tariff classifications.

During the meeting, it was noted that this requirement corresponds to a notice and not to an authorization, and therefore it was considered inappropriate to support this type of measure solely on such basis.

Operational Impact: 
Companies facing similar situations, inspections or delays at local customs should properly document the issue, keep the background of their procedures and evaluate the corresponding response strategy based on each specific case.

4. NOM certificates and validation mechanisms

The need to strengthen the verification mechanisms for NOM certificates was discussed, in order to provide greater certainty regarding their authenticity and traceability.

Among the proposals discussed was the incorporation of a signature or information chain similar to that used in other validation schemes, such as CFDI, so that both authorities and prevalidators can more easily verify the issuance of each certificate.

Operational Impact: 
Companies should maintain greater documentary control over the NOM certificates used in their operations, verifying that they are authentic, traceable and correspond to the imported goods.

5. Pending notices for the addition of tariff classifications

It was reported that a relevant percentage of companies with VAT and IEPS Certification are pending the filing of notices for the addition of tariff classifications, so follow-up will continue in order to promote their regularization.

Operational Impact: 
Companies should review whether the tariff classifications used in their operations are duly authorized or informed, as applicable, especially when they hold certifications or authorizations linked to their foreign trade operations.

6. Certification and renewals in the electronic customs system

Finally, incidents within the electronic customs system were discussed, particularly in cases where the lack of certification of certain companies was incorrectly reflected.

It was reported that the identified cases were reviewed and addressed. Likewise, it was clarified that, in renewal official letters issued prior to March 2026, the list of authorized tariff classifications may not appear immediately, but rather until the next renewal process.

Operational Impact: 
Companies should review that their certifications, renewals and authorized tariff classifications are correctly reflected in the corresponding systems. If inconsistencies are identified, it will be important to have the official letters, acknowledgments and supporting documentation to clarify the situation before the authority.

Recommendation

We suggest that companies proactively review the information registered before the authorities, as well as the status of their procedures, certifications, registries, notices and authorized tariff classifications.

In particular, we recommend:

• Validating that partners, shareholders and legal representatives are updated before the authority.
• Reviewing that the official identification documents and powers of attorney of the legal representative are current.
• Following up on IMMEX, PROSEC and Eighth Rule procedures pending resolution.
• Confirming that the notices for the addition of tariff classifications have been properly filed, when applicable.
• Reviewing the authenticity and traceability of the NOM certificates used in import operations.
• Verifying that certifications and renewals are correctly reflected in the electronic customs systems.

Based on the foregoing, it is advisable to strengthen internal foreign trade controls and maintain sufficient documentary evidence to address possible requirements, clarifications or reviews by the authority.

J.A. DEL RÍO offers a wide array of specialized consulting services to assist you with these and other matters, in order to ensure that your project complies with the applicable characteristics  contained in this agreement.

If you have any questions, J.A. DEL RÍO can provide you with our experts to advise in matters concerning compliance with your legal and tax obligations. Once again, please let us know if we may be of any further assistance to you at: contacto@jadelrio.com.