Changes to Mexico’s Customs Law: Obligations for Importers and How to Ensure Compliance
The decree issued on November 19, 2025, amends several provisions of Mexico’s Customs Law, which will come into force on January 1, 2026. This reform raises the standard for regulatory oversight and tightens validation requirements for stakeholders in foreign trade. Businesses will now need to adopt a proactive compliance approach by strengthening pre-shipment goods verification, regulatory conformity, and end-to-end document traceability.
In response to the recent Customs Law updates, QIMA has held both in-person and virtual events to inform and assist clients and partners, underscoring its commitment to regulatory awareness and compliance.
The most notable points gathered from these consultation forums—topics generating the highest interest—include:
Shared and Direct Liability: The exemption from liability previously granted to customs agents and brokers in certain value declaration scenarios has been eliminated. Now, both the importer and the customs agent share direct responsibility for the accuracy of documentation and the verification of supplier information.
Verification of Legal Existence: The reform targets tax evasion, avoidance and the use of shell entities through stricter traceability measures. Importers are now required to ensure that foreign suppliers have both the legal and physical capacity to supply goods, verified before the transaction.
Detailed Electronic File Requirement: A more comprehensive digital record is now mandatory, containing proof of the commercial relationship and the supplier’s legal compliance.
Stricter Penalties and Fines: Failure to comply, or providing inaccurate data on commercial transactions (including supplier identity), may result in fines of up to 300% of the goods’ value, and even possible revocation of licenses or authorizations.
These measures grant the Mexican National Customs Agency (ANAM) stronger authority to reject operations if the legal existence of the foreign exporter is not fully demonstrated. Companies will need to enhance their document traceability and NOM compliance efforts to ensure uninterrupted supply chain flows within Mexico.
Given the complexity of the law, confusion can be common. For this reason, QIMA and NYCE recently hosted the webinar “Customs Law: Implications and Solutions for Compliance with Technical Regulations”. In it, Nashielly Escobedo, General Director of the Latin American Confederation of Customs Brokers (CLAA), delved into the changes affecting importers, customs agents, and logistics operators.
The New Customs Reality for 2026
Below is a summary of these changes, particularly the new importer obligations and practical strategies to avoid delays, fines, and operational risks.
Removal of Liability Exemptions for Customs Agents
A significant change is the repeal of liability exemptions for customs agents previously stated in Article 54. Now, customs agents and importers share direct and joint responsibility for declared information, requiring importers to:
Provide evidence of the legal existence of suppliers (domestic or foreign), including documentation of incorporation, legal representation, and active operations.
Perform pre-verification of goods and their documentation.
Ensure alignment among the invoice, packing list, and physical goods.
Submit accurate technical and regulatory information.
Higher Fines and New Violations
This is one of the most debated changes, as fines will rise by 250%–300%, particularly for:
Declaring inaccurate data
Omitting non-tariff regulations and restrictions
Failing to respond to official requirements
Changes to Customs Regimes
Updates to temporary import deadlines include:
Small vessels: term reduced from 10 to 5 years
Adjustments to Article 108 for IMMEX companies
Stricter Administrative Procedures
Common errors and omissions will be targeted to create a more professionalized process. Failure to respond to official requirements will now be considered an immediate violation, requiring greater internal document organization.
Changes That Will Impact Your Import Operations
If some of your supply chain operations are in Mexico, it is essential to stay informed about these new obligations:
Comprehensive Validation of Information Prior to Clearance
Under reinforced joint liability rules, importers must ensure:
Accurate tariff classification
Verifiable technical documentation
Full compliance with tariff and non-tariff regulations (RRANAs)
Full consistency across all documents and physical goods
Conducting Pre-Verification at Origin (Previo en Origen)
Importers must check quantities, physical condition, packaging, codes, technical specifications, and alignment with commercial documentation. A Pre-Customs Clearance Inspection at Origin (Previo en Origen) helps identify discrepancies before goods are shipped.
Restrictions and Non-Tariff Regulations (RRANAs)
Technical regulation errors are now considered serious violations. Importers should review:
Applicable NOMs (Mexican Official Standards)
Required tests and certificates
Documentation accompanying the customs declaration
Validity of NOM certificates and sanitary regulations
Compliance with Updated IMMEX Guidelines
The IMMEX program allows temporary import of inputs or goods for manufacturing and export under customs and tax benefits. Under the reform:
Traceability requirements will be reinforced
Obligations for return or final destination will be tightened
Stricter inventory controls will be enforced
Usage, transformation, or return must be demonstrated upon request
Timely Response to Official Requests
Non-compliance with a request will be an immediate violation. This requires companies to:
Establish dedicated compliance teams
Maintain organized digital and physical filing systems
Implement rapid-response processes
Joint Liability with Customs Broker
Importers must ensure the accuracy of all information provided to their customs broker, since both parties will now be legally responsible for declaration errors.
How QIMA Helps You Avoid Risks, Fines, and Delays Under the New Legislation
The Customs Law changes require a more robust compliance model built on prevention and advance verification. Only timely information and proactive measures can ensure a reliable supply chain flow and reduce the inherent risks in logistics operations.
Verification of Legal Existence of Suppliers/Clients in Mexico and Abroad
QIMA’s Audit Services are designed to:
Validate the legal existence of suppliers and clients domestically and internationally
Review compliance documentation
Assess regulatory compliance
Analyze technical capabilities
Confirm operational substance (infrastructure, machinery, equipment, processes)
Implementing Pre-Shipment Document Controls
Importers must review invoices, packing lists, certificates, technical descriptions, classifications, and regulations. QIMA supports this through Pre-Shipment Inspection (PSI)—an on-site inspection of randomly selected units conducted when production reaches 80%–100%, enabling corrective action before packaging.
Adopting Pre-Customs Clearance at Origin (Previo en Origen)
This process mitigates crucial risks such as quantity discrepancies, incorrect goods, description errors, and misclassification for tariff purposes, acting as an early compliance validation tool for RRANAs. QIMA offers Previo en Origen inspections with global inspectors, immediate reporting, photographic evidence, full traceability, and document-by-document verification.
Early-Stage Technical Compliance for RRANAs and NOM Management
Mexican companies must now identify and fulfill applicable regulations before clearance to avoid penalties. QIMA and NYCE maintain accredited laboratories in over 100 countries, providing NOM testing, certifications, label reviews, regulatory validation for multiple industries, pre-verification at origin, and PSI. These solutions ensure operational efficiency and secure delivery of goods.
Centralizing and Digitizing Traceability
With increased documentary requirements from authorities, digital management is key. With myQIMA platform companies can store reports, certifications, inspections, regulatory documents, test results, and audits, allowing for quick responses to authorities and complete supplier data transparency—ensuring compliance under the new law.
Ongoing Advisory Support
Given regulatory dynamics, updated guidance is essential. QIMA offers continuous compliance and quality support, training and assisting supply networks globally, performing quality services when needed, and ensuring consistent quality standards.
QIMA’s solutions focus on preventing discrepancies and ensuring compliance with new technical regulations. We are your trusted partner for strengthening operational security across your entire supply chain.
All of these regulations will take effect in early 2026, so companies should immediately begin preparing processes, documentation, and invoicing aligned with the new requirements.
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