Suspensions of Importers’ Register

Three months into the year, the suspensions of the Importers' Registry exceed 70% of the total suspended taxpayers for the entire year of 2023.¹

Currently, there are a total of 47 reasons for which the Mexican authorities are permitted to suspend taxpayers from the Importers' Registry and/or Importers' Registry of Specific Sectors. These reasons are outlined in Rule 1.3.3.² of the General Rules of Foreign Trade issued by the Tax Administration Service (SAT). They range from simple omissions, such as not having a valid e-signature or not notifying the SAT of relevant changes in companies' general data, to more complex issues, such as when an importer, who had applied for a tariff preference, fails to rectify their tax situation based on a resolution that denies preferential treatment resulting from an origin verification procedure.

Given the multitude of reasons for which the Importers Registry can be suspended, it is likely that in day-to-day operations, importers may fall under one of the 47 scenarios, and, therefore, potentially be subject to suspension.

It should be noted that, as a rule, merely falling under any of the situations outlined in Rule 1.3.3., results in the immediate suspension of the Importers Registry, whether general or sectoral, without prior opportunity for importers to make arguments to remedy or refute the possibility of suspension.

Risks

Registration in the General and/or Sectoral Importers Registry is a prerequisite for any person who wishes to import goods into Mexico. Without this registration, imports to the national territory cannot be carried out.

Thus, the main risk of a person being suspended from the General and/or Sectoral Importers Registry is being completely unable to import goods, resulting in most cases in a total halt of the commercial operations of companies, delays in production operations, significant economic losses, among others.

Preventive Actions

To avoid the suspension of the Importers Registry, it is recommended to carry out periodic reviews to ensure that companies do not fall under any of the circumstances outlined in Rule 1.3.3.

Likewise, it is of utmost importance to have Foreign Trade Certifications that allow companies to "protect" their registration in the Importers' Registry. There are certain certifications that grant taxpayers the benefit of having a period to make arguments to remedy or refute the cause of suspension warned before their registration is suspended.

_{1 Source: SAT data bases of taxpayers suspended from January 1, 2023 to April 8, 2024.
2 Available in: https://www.dof.gob.mx/nota_detalle.php?codigo=5712945&fecha=28/12/2023#gsc.tab=0}