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Customs··12 min read

Importer of Record in Mexico: Why You Can't Clear in Your Name

·Last reviewed:

Current as of October 6, 2026. This guide explains Mexican rules in general terms. It is not legal or tax advice: confirm your case with the licensed customs broker handling your clearance and with a Mexican tax advisor before you ship.

You sold goods to a customer in Mexico and were told the shipment cannot clear customs in your company's name. In general, that is correct. This guide explains the rule, your options, and who answers to the authority in each.

The short answer

For a regular commercial import, the importer of record must be a taxpayer registered in Mexico and listed in the Padrón de Importadores, the importers' registry kept by the SAT, Mexico's tax administration. A foreign company with no Mexican establishment is, in general, not in that registry. A registered party must appear as the importer: your customer, your own Mexican entity, a manufacturer under Mexico's IMMEX export program, or a third party acting as importer of record.

Who can be the importer in Mexico

The Mexican customs declaration is the pedimento. Article 36 of the Customs Law (Ley Aduanera) requires whoever brings goods into the country under a customs regime to transmit one electronically. Importers normally file it through an agente aduanal, a licensed customs broker.

The SAT's procedure sheet 5/LA for enrollment in the registry (Annex 2 of the 2026 General Foreign Trade Rules, published January 12, 2026) lists Article 59, sections III and IV, of the Customs Law and rule 1.3.2 of those rules in its legal basis. Among other conditions, the applicant must:

  • Be registered and active in the RFC, the federal taxpayer registry (the Mexican tax ID).
  • Hold a valid e.firma, the electronic signature issued by the SAT.
  • Be up to date with its tax obligations.
  • Have a tax domicile whose status with the SAT is "located", and a validated buzón tributario (electronic tax mailbox).
  • Have at least one licensed customs broker, customs agency (agencia aduanal, a brokerage firm whose partners include licensed brokers) or legal representative.
  • Not appear on the lists the SAT publishes under Articles 69 and 69-B of the Federal Tax Code.

Some goods need a second registration: Annex 10 of the 2026 rules lists 16 sectors with their own importers' registry, among them footwear, textiles and apparel, steel, chemicals and automotive. See what Mexico imports.

The broker does not replace the importer. Under rule 1.2.6, it is the taxpayer registered and active in the registry, with a valid e.firma, that records electronically the mandate (encargo conferido) allowing a broker to act for it.

Why a foreign company generally cannot be the importer

A company with no establishment in Mexico normally has no active RFC with a Mexican tax domicile, so in practice it does not meet those conditions. The International Chamber of Commerce (ICC), in a document on national regulatory barriers to the Incoterms rules updated in January 2025, says of Mexico that "import clearance at Mexican customs must be carried out by a registered Mexican importer". The U.S. Department of Commerce guide for exporters, last published in February 2026, says all Mexican importers must register and be listed in the importers' registry. C.H. Robinson, a logistics provider, wrote in 2023 that Mexico does not allow foreign entities to act as non-resident importers.

There are exceptions. The last paragraph of Article 59 excludes imports made by passengers, by courier and parcel companies, and by post, when they clear under the simplified procedures of Articles 88 and 88 bis. For courier shipments, that is a simplified route for parcels handled by authorized courier companies; see parcel taxes in 2026 (in Spanish). For any other case, ask a licensed customs broker before you plan around an exception.

Your options, and who answers to the authority

OptionImporter on the pedimentoWho answers as importer for duties, value and complianceMain point to weigh
Your Mexican customer importsThe customerThe customerThe customer must be registered
Your own Mexican entityYour entityYour entityOngoing tax and compliance duties in Mexico
IMMEX or shelterThe Mexican program holderThe program holderDesigned for manufacturing and export
Third-party importer of recordThe third partyThe third partyYou depend on its registry and records

The third column names the importer, the party that Article 52 of the Customs Law obliges to pay and comply. This guide does not cover the liability the law may also place on other parties.

1. Your Mexican customer is the importer

The customer holds the RFC, the registry and the mandate with its broker, and you sell on an Incoterms rule that leaves import clearance to the buyer (such as DAP, explained below). C.H. Robinson (2023) describes this as often the more straightforward route, because the consignee usually has a Mexican broker in place.

Under Article 52 of the Customs Law, whoever brings goods into the country must pay the foreign trade taxes and comply with non-tariff regulations. Before shipping, check that the customer is registered, including the sector registry if the product needs it.

2. Your own Mexican entity

A branch or company in Mexico that obtains its RFC, e.firma and registry can import in its own name, with all of an importer's obligations. C.H. Robinson (2023) notes that this brings other tax implications and responsibilities in Mexico: a decision for your legal and tax advisors.

3. IMMEX and shelter, for manufacturing

IMMEX is an export-promotion program created by a decree published on November 1, 2006. According to SNICE, the Ministry of Economy's trade information service, it serves companies resident in Mexico that import goods temporarily for manufacturing, transformation or repair.

In the shelter modality (albergue), as the trade publication IDC described it in 2019 and the customs and logistics firm Joffroy describes it in 2026, foreign companies supply technology and production materials without operating the program themselves; the Mexican program holder makes the temporary imports (confirm the current terms). By design, IMMEX is a manufacturing and export program, not a general route for selling finished goods in Mexico. See relocating a production line to Mexico.

4. A third-party importer of record

Some providers sell this as "importer of record as a service". A Mexican company that holds the registry acts as the importer. C.H. Robinson (2023) describes it as an agency agreement with a Mexican company, typically a trading company (comercializadora), which assumes the role of importer of record.

The importer named on the pedimento is the party that Article 52 obliges to pay the foreign trade taxes and comply with non-tariff regulations; as noted above, this guide does not cover the liability of other parties. Points to weigh:

  • The importer answers, on your data. The importer is responsible for the value declaration and the information in it. Article 59, section V, requires its electronic file to hold, among other documents, the commercial invoices, proof of payment, transport and insurance costs, and the contracts behind the transaction.
  • Its registrations and documents must fit your product. Under Article 54, the broker must make sure the importer holds the documents that prove compliance with non-tariff regulations.
  • You depend on its standing. The law firms Braumiller and White & Case, both in 2024, describe a registry suspension as a complete stop to a company's imports.
  • The broker must vet it. Article 162, section VI, obliges brokers to make sure clients are fully identified, have infrastructure and meet their tax and customs obligations.
  • Cost and tax effects. C.H. Robinson (2023) advises considering the effect on profit margins. Article 1 of the VAT Law taxes whoever imports goods, at 16%. Whether that VAT is recoverable, and how the goods are then invoiced to your customer, are questions for a tax advisor.

This article describes the structure; it neither recommends nor advises against it, and it is not an offer of importer-of-record services.

Why DDP into Mexico is a problem

Under DDP (Delivered Duty Paid), the seller is responsible for all customs formalities, including import. The ICC Academy notes this "may be difficult for a foreign seller" and that, where local rules require the local importer to clear the goods, "DDP cannot be used, and DAP would be the appropriate Incoterms® rule".

The ICC document adds that parties in Mexico sometimes still use DDP: the Mexican importer gives the foreign exporter its customs registration information and the help of its customs broker, and the parties adapt their sale contract. In that arrangement, the clearance still relies on the Mexican importer's registration.

The alternative the ICC Academy points to is DAP (Delivered at Place): you deliver to the agreed place, and the buyer carries out and pays for import clearance. If you quote "all-inclusive, door to door" into Mexico, state in writing whose name goes on the pedimento. See Incoterms 2020: who pays what (in Spanish).

What the importer pays and answers for

The importer pays the general import duty (IGI), which depends on the tariff classification and the origin of the goods; the customs processing fee (DTA); and VAT. Some products and origins also carry antidumping or countervailing duties (cuotas compensatorias). The importer must also meet the product's non-tariff regulations, such as permits and NOM standards (Mexican official standards). Our guides, in Spanish, cover how import taxes are calculated and antidumping duties.

In 2026, three changes matter:

  • Tariffs. A tariff decree published on December 29, 2025 took effect on January 1, 2026. A second, published on April 23, 2026 and in force since April 24, covers 185 tariff lines at rates of 5% to 35%. Goods originating in countries with a trade agreement keep preferential treatment if they meet the requirements. See our 2026 tariff guide (in Spanish).
  • Electronic Value Declaration (MVE). The SAT's advance version of September 30, 2026 (not yet in the Official Gazette as of October 6) keeps the previous scheme until October 31, 2026. The MVE then becomes mandatory by customs regime, on dates that run from November 1, 2026 to January 15, 2027; the last date applies to definitive imports (goods that enter to stay). The importer is responsible for the information in the MVE. See our MVE guide (in Spanish).
  • Customs Law reform. Published on November 19, 2025 and in force since January 1, 2026. Article 54, as amended, holds the broker and the customs agency responsible for the accuracy of the data, the tariff classification and the taxes determined. PwC and EY report that the reform removed the previous exclusions of liability.

How Kold Gold handles this

Kold Gold is a Mexican logistics company. We coordinate ocean, air and ground freight, with customs clearance handled by a licensed customs broker. Two working criteria are stated on our site:

  • The importer question comes first. When a DDP quote does not say who the importer of record will be, we raise it at quote stage, not at the port (English home page).
  • Classification before scheduling. We confirm the registry requirement from the product's tariff classification before scheduling the shipment (customs brokerage).

Our track record includes fabric, apparel, footwear and uniforms, a sector in which the sector-specific importers' registry is one of the controls. The registry and any permit belong to the importer.

Request a freight quote and tell us who the importer will be.

Frequently asked questions

Can a foreign company be the importer of record in Mexico?

In general, no. The importer must be registered and active in the RFC, hold a valid e.firma and be listed in the Importers' Registry. A company with no establishment in Mexico normally does not meet those conditions. Exceptions exist, such as parcels cleared by authorized courier companies under a simplified procedure.

Can I sell DDP to a customer in Mexico?

In practice, only when a registered Mexican importer appears on the customs declaration. The ICC Academy notes that where local rules require the local importer to clear the goods, DAP is the appropriate rule. Agree in writing who the importer is before you quote.

Is the Mexican customs broker the importer of record?

No. The broker acts under a mandate, the encargo conferido, that the registered importer records with the SAT. The importer remains obliged to pay the taxes and comply with the regulations; the broker is jointly liable for the taxes on the operations it handles.

Sources

Consulted on October 6, 2026.

Last reviewed: October 6, 2026.

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