Mexico is living a contradiction that many people in trade and manufacturing can feel in real time: the country invites companies to relocate (nearshoring), but at the same time, it tightens enforcement so much that it can scare investment away.
That “regulatory scare” became very visible when authorities suddenly canceled a large number of IMMEX programs for administrative and compliance reasons. For many companies, IMMEX is not a “nice-to-have.” It is a core tool that makes export manufacturing viable: it allows firms to import inputs temporarily with tax benefits as long as the finished goods are exported.
When cancellations happen at scale, the message to the market is not just “comply.” The message is: your operation can stop fast if your paperwork, reporting, or controls are weak. And for investors who are deciding where to put capital, uncertainty is expensive.
At the same time, the SAT’s focus has shifted toward a concept that is now changing everything in customs and tax enforcement: materiality.
Materiality is a simple idea with big consequences: it is not enough to declare an operation. You must be able to prove it was real, with consistent evidence across customs, tax, accounting, and operations.
This is why the conversation is no longer only about “How do you import?” It is now: “Can you prove the operation existed exactly as you reported it?”
The New Center of Gravity: SAT “Materiality”
In practical terms, SAT materiality means the authorities want strong, organized proof of:
- The commercial reality (contracts, invoices, payments)
- The operational reality (capacity, equipment, people, production flow)
- The accounting reality (book entries, reconciliation, traceability)
- The technical reality (specs, BOM logic when needed, transformation evidence)
So, customs compliance is no longer only a “customs file.” It becomes a full evidence case.
This is where many companies get nervous, because building that level of proof requires discipline, systems, and internal controls. But from the government’s perspective, this is how they attack fake operations, shell suppliers, and paper-only transactions.
The Customs Broker’s Role Is Changing: From “Service Provider” to “Risk Gatekeeper”
This shift hits the agente aduanal directly.
Before, the broker was often seen mainly as the person who “gets the shipment cleared.” Now, the broker becomes a risk gatekeeper, because authorities expect stronger client verification and stronger support for what is declared.
In simple terms, the broker is being pushed into a role closer to a compliance manager, a documentation architect, and a first filter against non-material operations.
Why This Creates a “Regulatory Scare”
For the market, a regulatory scare happens when companies feel:
- Rules can tighten fast, without enough transition time
- Enforcement can pause operations overnight
- The cost of mistakes can be extreme
- The standard is moving from “paper compliance” to “proof compliance”
When companies do not know what enforcement will look like next quarter, they may delay expansion decisions, IMMEX applications, production moves, or new supplier onboarding. That delay is the silent killer of nearshoring momentum.
Practical Recommendations
Below are bullet points your editor can use to expand into sections, examples, and quotes. They are written in a clear, simple style, but the strategy is serious enough for executives and trade specialists.
Recommendations for IMMEX Companies (Operations & Compliance)
- Treat compliance like operations, not like paperwork. If a missing report or outdated company address can trigger major consequences, then compliance is a “production line” too.
- Make your evidence easy to find. Keep contracts, invoices, payments, and customs records organized in one logic. If it takes days to find proof, you’re already losing.
- Control inventories like money. IMMEX depends on disciplined inventory control (what entered, what was used, what left, what was returned, what was regularized). Weak inventory control is a top risk.
- Run internal audits before the authorities do. Monthly or quarterly reviews can catch errors early: mismatches in inventory, wrong declarations, missing documents, expired permits, or supplier issues.
- Build “materiality packages” per operation type. For each flow (import, virtual transfer, return, transformation), define the minimum evidence set and keep it consistent.
Recommendations for Customs Brokers (Agentes Aduanales)
- Upgrade your client onboarding into real KYC. Don’t just open the account—verify the business exists, has capacity, and matches what it claims it will import/export.
- Standardize the client file. Build a checklist and enforce it the same way for every client. Consistency protects you.
- Move from “clear shipments” to “clear shipments + defend files.” Your value is not only speed. Your value is being able to defend the operation if audited.
- Use technology to reduce errors and improve traceability. Digital workflows, document portals, audit trails, and standardized templates reduce mistakes and speed up proof-building.
- Educate clients early and bluntly. Many problems start because clients don’t understand the risk. If they treat compliance as optional, they can drag you down with them.
Recommendations for Nearshoring Projects (Executives & Investors)
- Do regulatory due diligence before you buy land or hire staff. Labor cost is not the only factor. Compliance cost and enforcement risk can change your ROI fast.
- Design compliance from day one. Set up systems, controls, and document discipline as part of the factory plan—not as an afterthought.
- Choose partners for reliability, not only for price. The cheapest customs process can become the most expensive if it cannot survive an audit.
- Assume the question will be: “Can you prove it?” If your supply chain depends on weak suppliers, fake invoices, or unclear service evidence, you are building on sand.
- Join industry groups and stay informed. Collective dialogue matters. Investors want certainty. Mexico wants jobs and exports. Both sides need stable rules and clear guidance.
Closing: The Opportunity Is Real, but the Standard Has Changed
Nearshoring is still one of Mexico’s biggest opportunities in decades. But the game is changing. The country is not only asking companies to bring factories. It is asking them to bring serious compliance, strong evidence, and real traceability.
For companies and investors, this doesn’t mean “don’t come.” It means come prepared.
Because in this new cycle, success won’t belong only to the fastest manufacturer. It will belong to the manufacturer that can answer one simple question—with confidence and proof: Can you prove this operation was real?
Why TradeFlex?
Strategic decision-making and collaboration are crucial for navigating these challenges and ensuring growth and success in the globalized supply chain. With careful management and informed policy decisions, there are opportunities for growth and success in the complex landscape of global manufacturing.
Here at TradeFlex, we can guide and help overcome the possible issues that may arise in the future and provide a long-lasting partnership that will help overcome any obstacle. With our El Paso and Valley locations, we deliver the best dedicated and reliant teams no matter your location. We are always ready to share a helping hand. Visit us at https://trade-flex.com/ for more details.
