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IMMEXRetentionSubcontracted manufacturingRAOCE

Operational intelligence · Ongoing compliance

Operational obligations and IMMEX retention periods: the calendar that protects the program

IMMEX compliance happens every day: knowing where goods are, when their deadlines expire, which third party processes them and what must be reported keeps temporary import authorization valid.

By the ADALCED TeamSeptember 26, 202610 min read

01 · OVERVIEW

An authorization supported by ongoing controls

The IMMEX Decree requires compliance with the authorized program, use of goods for approved purposes, timely returns, storage at registered premises and automated control. These tasks form an evidence chain covering goods, location, processing and destination.

Goods

What entered and under which authorization

Location

Where it is held or processed

Deadline

When it must return or change customs regime

Evidence

How each movement is evidenced

02 · RETENTION

The clock varies by type of goods

Article 108 of the Customs Law establishes general periods. Time must be tracked per operation and goods, accounting for corrections, transfers and the final destination that legally closes the temporary import.

18 months

Inputs, raw materials, parts and components

Includes consumables, containers, packaging, labels and leaflets in the cases covered by fraction I.

2 years

Containers and trailer boxes

Specific general period provided for this category.

Program validity

Machinery, equipment, tools, molds and other assets

Applies to goods covered by fraction III of article 108.

The 36- or 48-month benefits in the RGCE correspond to specific categories and classifications, such as certain AEO, Aircraft or SECIIT registrations. They must not be applied as a general extension for every IMMEX company.

03 · LOCATION

Goods must be locatable and accountable

Temporarily imported goods must remain at registered premises or be moved under the applicable procedure. The IMMEX Decree requires registration requests for changes to operational and subcontracted manufacturing premises at least three business days before the move.

Before

Verify that the premises and third party are registered and active.

During

Support the transfer with the document or notice applicable to the case.

Afterward

Update location, quantities and owner in inventory control.

04 · THIRD PARTIES

Subcontracted manufacturing must preserve traceability

When a third party performs part of production, the IMMEX company retains obligations over the goods. The third party must be registered under the applicable scheme, the process described and movements reflected in inventory control.

01

Registration

Identify the subcontracted manufacturer, its premises and the authorized process.

02

Delivery

Document quantities, part numbers, dates and destination location.

03

Transformation

Link consumption, finished product, shrinkage and waste.

04

Return

Verify the return or subsequent destination within the applicable period.

05

Reconciliation

Keep each third party’s balance aligned with inventory and documents.

05 · ANNUAL REPORT

May is an operational close as well as an administrative one

The annual report must be submitted electronically to the Ministry of Economy by the last business day of May, reporting the previous year’s sales and exports. The program also requires foreign sales exceeding USD 500,000 or exports representing at least 10% of total invoiced sales.

Last business day of May

Standard annual report deadline.

> USD 500,000

One option for meeting the annual export commitment.

≥ 10%

Alternative based on exports as a share of total invoiced sales.

Failure to report or meet verified requirements suspends temporary import benefits until remedied. If the failure continues through the last business day of August, the Decree provides for final cancellation from September 1.

06 · MANAGEMENT

A compliance calendar starting with each declaration

Assign an expiration date when recording each temporary import.

Generate preventive alerts by goods, declaration and premises.

Review balances nearing expiration and their return or regularization plans weekly.

Reconcile physical inventory, Annex 24, declarations and goods held by third parties monthly.

Track changes to premises, partners, shareholders and legal representatives.

Prepare sales and export information for the May report starting at year-end close.

The best alert leaves enough time before expiration to choose a return, transfer, regime change or another legal alternative.

07 · TRACEABILITY

Official sources

Special deadlines and procedures must be checked against the company’s specific authorization and current provisions.

Customs LawArticle 108 and related provisions · Chamber of DeputiesIMMEX DecreeObligations, annual report and subcontracted manufacturing · Ministry of EconomyCurrent General Foreign Trade RulesSpecific procedures and benefits · SATAnnex 24 of the current RGCEAutomated inventory control · SAT
Editorial note: informational content. It does not constitute legal, tax or customs advice or replace a review of current provisions and specific circumstances.

In this article

01Obligations map02Retention periods03Premises and transfers04Subcontracted manufacturing05Annual report06Control calendar07Sources
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