Background

Mexican Secretary of Economy Marcelo Ebrard announced recently a decree that will restrict use of the IMMEX program for footwear imports and impose a minimum 25 percent tariff on many such imports. These measures are not yet in force but will take effect immediately upon publication of the decree in the Diario Oficial de la Federación.

IMMEX allows duty-free, VAT-free imports into Mexico of raw materials and components for export manufacturing. However, Mexican authorities have 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. According to the decree, this practice contributed to a nearly 13 percent contraction in the Mexican footwear industry between 2019 and 2024.

As a result, the decree will prohibit temporary imports of complete footwear under IMMEX and only legitimate components (e.g., soles, leather, fabrics) may qualify. In addition, imports of footwear from countries that do not have a free trade agreement with Mexico will be subject to a minimum duty of 25 percent. Mexican customs authorities are expected to scrutinize import declarations closely to prevent misclassification and evasion of these measures.

Importers and manufacturers should prepare for these restrictions by (1) reviewing tariff classifications and ensuring that only inputs are imported under IMMEX, (2) assessing cost structures for non-FTA footwear in light of the minimum tariff, and (3) maintaining robust documentation (bills of materials, supplier declarations, export records) to demonstrate compliance. Early compliance planning is essential to mitigate risk, avoid penalties, and adapt to the new import environment.

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

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