Understanding Annex 24 in Mexico’s Foreign Trade Compliance

When talking about foreign trade compliance in Mexico regarding raw materials and fixed assets on a temporary basis, one of the key references is Annex 24 of the General Rules of Foreign Trade (Reglas Generales de Comercio Exterior). While the name may sound technical, Annex 24 is essentially about how companies must control their temporary inventories electronically when operating under special programs like IMMEX and/or VAT Certifications. 

This system must register in detail (among other points):

• Goods temporarily imported into Mexico (such as raw materials, parts, or machinery). 

• How those goods are transformed, used, transferred, or returned abroad (mainly through BOMs and customs declarations, these also know as “pedimentos”). 

• The final destination of those goods (whether they stay in Mexico under a different regime, or are exported again directly to another country or using virtual transactions shipping them to a place within México). 

Some of the most common mistakes when managing an Annex 24 system are: 

• BOMs not updated. 

• Importing raw material on a temporary basis that will not be controlled using BOMs. 

• Not using the data stage reports sent by the government on a monthly basis to make sure the information used in the Annex 24 is correct, such as customs declarations, Mexican HTS Codes, dates, among others. 

• Lack of trained and experienced personnel to manage the system. 

• Importing spare parts and other accesories as consumables under temporary importations. 

Without proper compliance, a company is exposed to significant risks, such as fines or penalties from customs authorities and cancellation of their IMMEX authorizations.