Small gaps in Mexico’s maquiladora program are turning into large settlements. Here is where the risk builds, and how to get ahead of it.
For three decades, IMMEX has been the quiet engine of North American manufacturing. The program allows companies to temporarily import materials, components and equipment into Mexico without paying duties or value added tax up front, as long as every input is tracked, transformed and exported on time.
That bargain has not changed. What has changed is how closely Mexico enforces it.
The enforcement environment has shifted
Mexico’s tax and customs authority, SAT, has become more data-driven and more willing to act. Programs and import registrations can be suspended quickly. Invitation letters that once could be answered slowly now escalate into formal audits. Mexico’s 2026 Customs Law raised liability for importers and customs brokers alike, and higher tariffs on inputs from countries without a trade agreement with Mexico have raised the cost of every mistake.
At the same time, nearshoring has put more volume through Mexican plants than ever before. More volume means more pedimentos, more inventory movements and more chances for small errors to compound.
Where companies run into trouble
In our work, the issues are rarely dramatic. They tend to fall into a few categories:
- Inventory control gaps. Annex 24 records that don’t reconcile with what was imported, transformed and exported.
- Expired temporary imports. Goods that stayed in Mexico past their legal deadline become definitive imports, with duties, VAT, surcharges and penalties attached.
- Virtual transfers. Goods moved between IMMEX companies without a clean documentary trail.
- Workforce structures. Mexico’s 2021 reform banned most outsourcing of core personnel. Companies that never revisited how their plant workers are employed may face lost deductions, non-creditable VAT and certification problems.
- Lost IVA certification. Without it, the 16% VAT on temporary imports becomes a real cash cost on every shipment.
Any one of these can sit unnoticed for years. When SAT reviews a prior period, the bill arrives all at once, and public companies may have to disclose it.
A practical approach: Diagnose, Stabilize, Restore, Sustain
At Intermestic Partners, we help companies get ahead of these issues before they become settlements:
- Diagnose. A fixed-scope review of program status, Annex 24 controls, pedimentos and SAT correspondence to pinpoint exposure.
- Stabilize. Keep goods moving while issues are addressed with SAT and the Secretaría de Economía.
- Restore. Recover suspended privileges and obtain or renew IVA/IEPS certification and OEA status.
- Sustain. Internal controls and documentation discipline so problems do not return.
Both sides of the border
Compliance in Mexico does not stop at the Mexican border. A clean IMMEX operation should line up with CBP requirements at U.S. ports, including CTPAT and FAST. Our founder, Marco A. López, Jr., served as Chief of Staff of U.S. Customs and Border Protection, overseeing a $13 billion budget and more than 60,000 personnel. Our Mexico City team works directly with SAT, ANAM, Economía and the customs broker community.
We have helped numerous companies resolve issues with Mexican customs and SAT, including restoring suspended import privileges on an expedited basis. Every engagement is confidential, and we are glad to sign an NDA before reviewing any data.
Let’s talk about your Mexico operations. Contact Marco A. López, Jr. at marco@intermestic.com.