This blog entry was updated December 11, 2025 to include mention of legislation passed that will tax imports, including significant categories in textiles, metals and automotive, from Asia and Brazil.
North Carolina manufacturers turned out in unusually high numbers for EDPNC and the NC MEP’s recent Tariff Strategies export education webinar. The session that EDPNC hosted, presented by celebrated international export educator Mike Alloca, provided practical guidance on managing duty exposure that affects sourcing, pricing, and competitiveness. Aimed at manufacturers of all sizes, many of whom do not maintain in-house trade compliance teams, the webinar discussed topics like classification practices, rules of origin, tariff-engineering options, duty-drawback procedures, and tools for modeling landed costs.
Tariff strategies for Mexico involve understanding how duties are calculated under the Ley de los Impuestos Generales de Importacion y Exportacion (LIGIE), how companies position their products under USMCA rules, and what mechanisms exist to reduce or defer duties. The practical strategies are very similar to the US for most companies and involve product classification, origin management, valuation, and special programs. The main strategy variations for Mexico versus the US are two-fold:
- Pay close attention to Mexico’s strategic sectors and what are the HS codes it is focused on (footwear, apparel, textiles, plastics, steel, chemicals and consumer goods; see update on new tariffs against non-FTA countries at the end of this post).
- Historically customs enforcement in Mexico has been opaque and inconsistent, which has created a lot of uncertainty for our exporters and their customers in Mexico. Exporters should take any signs of hesitation by importer counterparts, whether they be customers or distributors, as opportunities to discuss concerns on whether a product will make it into the country smoothly.
Fortunately, Mexico has been making policy changes related to its customs systems overall, often spun in the press as responses to policies of the US or to the practices of importers receiving goods from China. Those changes are discussed here. Ultimately, they are part of a broader cultural shift in government, one that recognizes the benefits to rule of law and, in turn economic competition, of transparency that is enabled by information and technology.
Background: still emerging from the legacy of a protectionist dictatorship
We discussed earlier this year Mexico’s extant protectionism. Our theory is that it stems from the 70+ years of PRI dictatorship that ended with the election of Vicente Fox of the PAN party, in the year 2000. Despite being the leadership who spearheaded NAFTA, enacted in 1994 and dramatically revolutionizing the Mexican economy, the PRI created and upheld a highly protectionist environment, its reign effectively unchallenged until the 1990s. It often feels like the government has not fully transitioned in culture nor doctrine from its paternalistic approach to writing and enforcing rules.
From a practical level, the law of the land on tariffs, LIGIE, is periodically updated to align with the Harmonized System. Indeed, Mexico’s LIGIE is due for a significant new update following legislation approved this month that in the eyes of many is aimed at enhancing Mexico’s role as a production anchor in the North American trade bloc. However, our experience with customs data for Mexico, recorded over decades, belies the assumption that duties applications have historically been enforced or enforced fairly. Mexican custom officials are on the watch for misclassification–often aggressively so–when it appears designed to avoid duties, but by the same token, records of products admitted into the country are routinely incorrect or incomplete.
This balance of hot and cold in terms of enforcement, combined with the inaccessibility of customs brokers to smaller or infrequent shippers, has lead to an aura of corruption and cuate-ism around Mexican imports processes. Indeed, many consumer brands decline to ship e-commerce to Mexico, precisely because of the lack of clarity around compliance and enforcement. As a result, it is still commonplace for smaller “importers” to have products shipped to Texas and crossed on foot or by car as personal possessions, without commercial declarations, into Mexico. Amazon, in that it has figured out how to bring small items into Mexico smoothly, has been a game-changer for consumers in this respect. Services like Border Free are a distant second but still helpful.
The workaround for B2B regarding customs, who enjoy a bit more support on the policy level from the Mexican government than consumers do, has been contract manufacturing or shelter programs, who can use the IMMEX program. This in itself has been misused in many cases, most notably textiles. In May 2025 news circulated that the bank accounts of eight textile companies were frozen due to habitual misclassification of imports for tax evasion.
IMMEX 4.0 and other changes
Mexico ultimately recognizes very well that inconsistent enforcement leads to unclear rules that undermine competition, and customs is no exception. While the Mexican government has framed recent updates to improve the situation as Morena party initiatives and, when speaking to Donald Trump, bending to the will of the US, in fact systemic changes have been evolving into reality for the last 5 years or so. Below is a list of policies being enacted that should make importing to Mexico less of a crap shoot, albeit with stricter enforcement that also comes at a cost (via more paperwork for importers and exporters).
- Strengthened operational control by SAT and ANAM
Customs oversight increased following the full operational separation of ANAM (Agencia Nacional de Aduanas de Mexico) from SAT in 2021. SAT, Mexico’s IRS, aka Hacienda, continues to lead fiscal audits, while ANAM has tightened port-of-entry controls, physical inspections, and verification of origin. Importers report more frequent document reviews, especially for steel, textiles, chemicals, and electronics. - Digitalization and procedural reforms (IMMEX 4.0)
Progress continues on replacing legacy VUCEM components as Mexico modernizes electronic systems for customs filings. The electronic pedimento de importación format has incorporated new data elements for origin, valuation, and transport. Implementation timelines vary across ports, causing temporary inconsistencies in document requirements. Here is a great summary in English of IMMEX 4.0, the name of the initiative under the Sheinbaum administration, from late last year. - Increased use of risk-based inspections
Customs has expanded automated risk filters to trigger red-light inspections based on importer history, tariff chapters, and declared values relative to reference prices. Importers with repeated anomalies are more often moved into enhanced review status, resulting in delays and additional documentation. - Classification and valuation scrutiny
Audits increasingly focus on tariff classification accuracy, declared values, and the treatment of assists and royalties. SAT has issued more post-clearance reviews to verify whether declared transaction values properly include dutiable elements. Sectors with complex assemblies (automotive, electronics, medical devices) have seen expanded requests for technical descriptions and engineering files. - IMMEX regimen tightening
IMMEX companies face closer monitoring of inventory controls and compliance with Annex 24/31 systems. Authorities have increased requirements for reconciling import balances, validating virtual operations (transferencias virtuales), and demonstrating export links for temporarily imported goods. Non-compliant firms have faced suspension of importer permits until discrepancies are corrected. - Increased attention to USMCA origin claims
ANAM and SAT have intensified verification of origin for US and Canadian goods claiming preferential tariff treatment. Requests for supplier affidavits, bills of materials, and RVC calculations have risen. Auto-sector USMCA requirements remain a priority area for enforcement, especially where producers use mixed-origin materials. - Sector-specific enforcement actions
Steel and aluminum imports continue under heightened surveillance through sectoral rules published by the Secretaría de Economía, requiring advance notices, mill certificates, and country-of-origin documentation. Footwear, textiles, apparel, and plastics remain targets for misclassification and undervaluation checks. - New security and port-facility requirements
Ports including Manzanillo, Veracruz, and Lazaro Cardenas have applied stricter container-movement controls and traceability measures due to security-related incidents. This includes expanded scanning, GPS requirements on certain routes, and closer coordination with naval authorities that now manage several customs sites. - Ongoing antidumping reviews and duties
Several antidumping investigations have been initiated or extended this year, especially in steel products, textiles, certain chemicals, and consumer goods. Companies importing affected products face renewed normal-value requirements and expanded document requests during clearance. - Broker accountability and permit renewals
Customs brokers are subject to narrower tolerances for procedural errors. Renewal of customs licenses and importer registries (Padron de Importadores and sector-specific pads) increasingly requires documented internal controls, Mexican taxpayer compliance, and evidence of operational traceability.
All in all, Mexico is overhauling its customs enforcement doctrine to be more precision-oriented, but we think also more fair. It will be good for the consumer and B2B markets alike in the long-run.
[December 11, 2025 Update:
Tariffs of up to 50 percent, affecting products from non-FTA countries on 1400+ HS codes, were approved on December 10 by both of Mexico’s legislative chambers. This follows an initiative introduced by the Secretaría de Economia and announced by Sheinbaum in September and has implications for the regional industrial alignment Mexico is hoping to reinforce in next year’s formal review of the USMCA. Countries affected include China, South Korea, India, Indonesia, Russia, Thailand, Turkey, Taiwan, and Brazil.
While the official list has yet to be published in the Diaro Oficial de la Federación, the business magazine Expansión summarized the products affected, translated below. The largest blocks include significant volumes of inputs that feed Mexican manufacturing, while categories like appliances or footwear correspond to completed imported goods.
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Textiles – 398 tariff lines
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Clothing – 308
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Steel products – 248
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Auto parts – 141
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Plastics – 79
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Footwear – 49
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Paper and cardboard – 47
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Toys – 37
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Furniture – 28
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Glass – 25
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Soaps, perfumes, cosmetics – 24
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Aluminum – 21
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Household appliances – 18
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Leather goods – 18
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Motorcycles – 8
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Light vehicles – 13
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Trailers – 1
Worth noting is the number of abstentions in both legislative chambers from these votes. Roughly 25 percent of congress members and senators voted neither for nor against the tariffs, citing hasty passage of the bill and observers citing likely interests in the affected countries.]