Mexico Reverses Policy on Use of IMMEX Program for Footwear Imports

Mexico has reversed a months-old policy imposing significant restraints on imports of finished footwear.

In August Mexico announced a decree restricting use of the IMMEX program for footwear imports and imposing a minimum 25 percent tariff on many such imports. IMMEX allows duty-free, VAT-free imports into Mexico of raw materials and components for export manufacturing. However, Mexican authorities had detected misuse of this program, with companies importing fully-finished footwear under IMMEX and diverting it to Mexico’s domestic market without paying applicable duties.

As a result, the decree prohibited temporary imports of complete footwear under IMMEX and only legitimate components (e.g., soles, leather, fabrics) could qualify for the program. In addition, imports of footwear from countries that do not have a free trade agreement with Mexico were subjected to a minimum duty of 25 percent.

This change had a significant impact on ecommerce companies importing finished footwear from Asia into Mexico solely to fulfill orders in other markets, which had been duty-free under IMMEX.

However, Mexico published Oct. 29 a resolution that authorizes for one year the resumption of imports of finished footwear under IMMEX provided certain criteria are met. The resolution does not alter the minimum tariff requirement, though that will expire at the end of 2026.

Companies wishing to take advantage of this exception must (1) be up to date in fulfilling their obligations under IMMEX, (2) have at least $500,000 (or its equivalent in national currency) in monthly exports, (3) prove that 100 percent of their temporarily imported goods register an inventory turnover of more than twice a year, and (4) have a plan to promote the substitution of imports by national production. Specific documentation showing that the company meets these criteria must accompany applications for the exception.

The impact of the change is expected to be limited. While it restores flexibility under IMMEX and may therefore offer some logistical benefits, it does not provide meaningful duty relief. The only potential beneficiaries may be those performing minor processing operations in Mexico, where the labor cost differential compared to the U.S. could still yield a lower dutiable value.

As a result, companies should carefully evaluate whether the logistical advantages justify the added complexity, particularly as the elimination of duty-free treatment for de minimis shipments into the U.S. has largely eroded the original economic incentive behind these operations.

For further guidance on IMMEX compliance or restructuring supply chains, please contact Juan Moreno at (415) 490-1402 or via email.