A guide for U.S. companies with an IMMEX plant or subsidiary in Mexico. The short answer: the Ministry of Economy suspended 441 IMMEX programs on June 30, 2026 for not filing the 2025 annual foreign-trade operations report, gave until the last business day of August to file it, and published in the Official Gazette (DOF) of September 29, 2026 the list of programs cancelled for good as of September 1. If your program is on that list, a short clock is running on the temporarily imported goods, and VAT, excise tax and the certification depend on what you do now.
What happened and on what basis
- Annual report: article 25 of the IMMEX Decree requires the report on the previous year's foreign-trade operations every May. If it is not filed, the program is suspended; if it is still missing on the last business day of August, the program is cancelled as of September 1.
- Suspension notice: DOF of June 30, 2026, listing 441 programs suspended over the 2025 report.
- Cancellation notice: DOF of September 29, 2026, listing the programs that had not filed by the end of August or did not meet article 11, section III of the Decree (registered, active addresses with the SAT).
- While suspended: the company could not import temporarily; with the cancellation it also loses the program going forward.
What changes for the goods sitting in the plant
The cancellation does not make the inputs, machinery or packaging that entered under the program disappear. What changes is that they no longer have a customs regime. Article 28 of the IMMEX Decree sets 60 calendar days from notice of the cancellation to return them abroad, change them to definitive import with taxes paid, or transfer them to another company with a program. One extension of up to 180 days can be requested, before the 60 days run out. Whatever is left unresolved is exposed to the SAT's audit powers: assessments for omitted taxes, inflation adjustment, surcharges and fines, plus the customs procedure that applies.
What to check, in order
- Confirm in the DOF list and in the Ventanilla Digital whether the program shows as suspended, cancelled or active. Some companies filed in August and remain active.
- Date the cancellation notice: the 60 days run from there.
- Close the Annex 24 inventory as of that date: which temporary goods are still in the country, under which pedimentos, and what deadline each line carried on its own.
- Decide line by line: return, change of regime or transfer, and quantify the import duty, VAT and, where they apply, excise tax and antidumping duties.
- Review the VAT and excise certification and any other registration tied to the program (PROSEC, sector registry, certified-company registration), since some require a valid IMMEX.
- Decide whether a new program is worth applying for and what must be in order first: active addresses, a positive tax-compliance opinion, reports up to date.
What the U.S. parent usually asks
- Can we keep exporting? Exporting, yes; importing temporarily without taxes, no. Every entry of inputs becomes a definitive import with taxes paid until a new program exists.
- Does it affect the U.S. customer relationship? Not by itself, but the cost of entered goods and the return deadlines affect price and delivery.
- Who is liable? The Mexican company that held the program and, depending on the case, its legal representatives before the tax authority.
Frequently asked questions
Can I file the annual report now and get the program back?
After the definitive cancellation of September 1, a late report does not reactivate the program. The path is to regularize the goods within the deadline and, if the operation justifies it, apply for a new program meeting every requirement of the Decree.
What happens to temporarily imported machinery?
The same rule as inputs: within the 60 days it must be returned, changed to definitive import with taxes paid on its value, or transferred to a company with a valid program.
Do I lose the VAT and excise certification?
The certification is tied to the existence of a temporary-import program. Without a valid program the benefit has no object, and pending goods pay VAT with its accessories within the periods the rules set.
General information, updated October 2026. It does not replace legal advice for a specific case.
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