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.
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.
Registration
Identify the subcontracted manufacturer, its premises and the authorized process.
Delivery
Document quantities, part numbers, dates and destination location.
Transformation
Link consumption, finished product, shrinkage and waste.
Return
Verify the return or subsequent destination within the applicable period.
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.
Next articles