Summary
On 9 September 2025, in parallel with the formal submission of the 2026 Economic Package, the President of Mexico presented to the Chamber of Deputies two major trade-related initiatives:
- A proposal to amend the Customs Law (Ley Aduanera), introducing stricter compliance obligations, expanded use of digital tools, and enhanced liability for customs brokers and importers.1
- A reform to the General Import and Export Tariffs Law (LIGIE), which would increase import duties on 1,463 product classifications across multiple sectors, including automotive, textiles, footwear, steel, chemicals, furniture, plastics, toys and other consumer goods.2
Taken together, these initiatives mark a significant shift in Mexico's trade and industrial policy, reflecting the administration's emphasis on import substitution, industrial strengthening and tighter customs enforcement as part of the broader "Plan México" for 2025–2030.
Background context
Mexico's customs framework has undergone only one major overhaul in the last three decades. The 1995 Customs Law reform, enacted in the context of NAFTA and Mexico's WTO accession, established the foundations of the current system—introducing valuation rules, import/export regimes, and the compliance structures that remain in force today.
Since then, reforms have been incremental, focusing on digitalization, trade facilitation, and oversight. Notably, the creation of the IMMEX program (in 2006) reshaped temporary imports for export manufacturing, and more recent changes (in 2013–2020) emphasized electronic tools for customs compliance and risk management.
Against this backdrop, the pending 2025 Customs Law reform, presented as part of the 2026 Economic Package, is widely viewed as the most significant update since 1995. Together with the proposed tariff increases on 1,463 product classifications, the initiative signals a profound policy shift toward stricter customs enforcement, industrial protection, and digital transformation.
On the other hand, tariff increases have been taking place on MFN (Most Favored Nation) basis, exempting imports originating from countries with which Mexico has Free Trade Agreements (see White & Case previous trade alerts: "Mexico reinstates tariff hikes ranging from 5% to 50% on over 544 goods"; Mexico Imposes Temporary Import Duties up to 25% on more than 588 non-FTA Tariff Items")
These initiatives must still undergo legislative review and approval but, if enacted, they would introduce substantial compliance, cost and operational impacts for companies engaged in cross-border trade.
Overview
1. Tariff Reform – 1,463 Product Classifications Impacted
The accompanying initiative to reform the LIGIE proposes tariff increases across 1,463 product classifications in the Mexican tariff schedule. This is a marked expansion compared to last year's tariff hikes on ~500 tariff lines. The new measures permit duties ranging up to 35% (and in some cases 50%) on imports from countries without a free trade agreement with Mexico.
It is important to note that the initiative—subject to a detailed review of each product classification—reiterates approximately 41% of the tariff increases already implemented through the 2024 decrees, while the remaining 59% of included product classifications are being newly implemented through the new law.3
Main sectors affected include:
- Automotive and auto parts
- Plastics and chemicals
- Footwear and leather goods
- Textiles and apparel
- Steel and aluminum
- Furniture, wood products, paper and cardboard
- Toys, sporting goods and household goods
The government justifies these increases as part of the Plan Nacional de Desarrollo 2025–2030 and Plan Mexico to promote domestic industry, support SMEs and reduce import dependency.4
2. Customs Law Reform – Key Proposed Changes
The proposed amendments to the Ley Aduanera focus on tightening control mechanisms and broadening liability in customs operations. Among the most relevant provisions:
- Increased liability for customs brokers and importers. Brokers (agentes aduanales) would face expanded joint liability with importers/exporters for tax and customs compliance.
- Digitalization and technology integration. Mandatory use of biometric controls, electronic seals and artificial intelligence systems for risk assessment and cargo traceability.
- Patents for customs brokers. Currently indefinite, patents would shift to a ten-year renewable term, subjecting brokers to stricter oversight.
- IMMEX program. The reform specifically targets the monitoring of IMMEX operations, limiting perceived abuses. Authorities seek to ensure that goods temporarily imported under IMMEX are effectively transformed and re-exported, rather than diverted into the domestic market. This includes restrictions on certain finished goods (e.g., footwear) from being processed under IMMEX.5
Legislative Process and Timeline
Both initiatives were formally submitted on 9 September 2025 and were sent to the Chamber of Deputies for review in committees. As part of the Economic Package, there is political pressure to approve these measures before 15 December 2025, when the current ordinary session closes. Approval would likely require consequential amendments to related legislation and secondary regulations (the Customs Law Bylaw, or the General Rules of Foreign Trade) If passed, the Customs Law reforms could enter into force as early as 1 January 2026, aligning with the fiscal year, and the tariff increases could take place earlier.6
Our international Trade Team will continue to follow Congress discussions and updates to both initiatives.
1 Law initiative published in the Mexican Parliamentary Gazette available here.
2 Decree initiative published in the Mexican Parliamentary Gazette available here.
3 Unlike the 2024 measures, which were enacted directly by the Executive under its constitutional powers and thus temporary in nature, the 2025 proposal has been submitted to Congress as a legislative initiative. This shift reflects both the breadth of the measure—covering more than 1,500 tariff lines across multiple sectors—and the government's intent to give the increases greater legal certainty by embedding them in the LIGIE. Although the initiative itself provides that the new tariffs will remain in force until 31 December 2026, Congressional approval would still remove the purely executive and discretionary character of the 2024 decrees, strengthen their legal foundation against procedural challenges (such as amparos against executive decrees), and align the measure with the broader Plan México for reindustrialization and import substitution.
4 On 13 January 2025, the President of Mexico presented the "Plan Mexico" a long-term plan aimed at promoting the regional development of the country. The plan comprises 13 goals and includes a portfolio of national and foreign investments totaling USD277 billion. Regarding foreign trade, it is noteworthy that the "Plan Mexico" has the following missions: (i) import substitution to increase national and regional content, and (ii) increasing higher value local supply. This strategy includes tax incentives and financing plans to encourage investment in strategic sectors, with the aim of generating an additional 1.5 million jobs and positioning Mexico among the world's top ten economies.
5 Although the Government announced, as part of the Mexico Plan, an "IMMEX 4.0" program intended to integrate and streamline tax certifications, no concrete legal instrument implementing that promise has been published to date. IMMEX companies remain subject to the strict SAT controls in force since October 2024.
6 As stated in the proposed decree: "30 days after its approval and publication in the official gazette"
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