IMMEX compliance for merch programs
The IMMEX program (Manufacturing Industry, Maquiladora and Export Services) is the foreign trade scheme most used by Mexican plants that produce for export. When an IMMEX company needs to produce merch — t-shirts, uniforms, kits — for employees, fairs or overseas clients, three regimes apply: return in the same state, temporary import and definitive export. This guide explains how each one operates, what pedimentos are used, what CFDI complements are issued and how it is accounted for in the IMMEX control kardex.
What the IMMEX program is
The IMMEX program is an instrument of Mexican industrial policy that allows companies to temporarily import goods to be used in a productive process that generates a product destined for export. It is regulated by the IMMEX Decree and the General Rules of Foreign Trade. Companies with the IMMEX program operate under a customs regime that allows them to defer tax payment at the time of temporary import, as long as the merchandise is returned within a determined period or exported as finished product.
For a merch company that produces t-shirts, uniforms or kits, IMMEX applies in two typical scenarios. The first is when the IMMEX company buys imported fabric to print t-shirts that are later exported as finished product. The second is when the IMMEX company imports finished merch (keychains, USBs, engraved thermoses) that is delivered to employees living in the United States or to clients at international fairs.
The three regimes that apply to merch
Return in the same state
Imported merchandise leaves the country without transformation, in the same state it entered. Applies when merch is imported for a fair or delivery to an employee overseas and returned later. Key pedimento: A1. Term: 6 months renewable.
Temporary import
Merchandise enters for a productive process and is exported as finished product within a determined term. Applies when imported fabric is transformed into t-shirts for export. Key pedimento: T1. Term: 18 months.
Definitive export
Merchandise leaves the country without return. Applies when merch produced in Mexico is sold to a foreign client. Key pedimento: A2 or B1. No return term.
Pedimentos, complements and CFDI
Each movement of merchandise under IMMEX requires a pedimento that is filed with customs. The pedimento carries the regime key, the importer or exporter RFC, the tariff description of the merchandise, the dollar value, the origin and the destination. Once filed, the pedimento is linked to the CFDI through the foreign trade complement (for exports) or to the transit CFDI with Carta Porte 3.0 (for internal movements).
For an IMMEX company that produces t-shirts, typical documents are: T1 temporary import pedimento for the fabric, CFDI of production to the Mexican workshop, foreign trade complement on the CFDI of sale to the foreign client, and definitive export pedimento when the t-shirt leaves the country. The IMMEX control kardex must match the pedimento balances.
IMMEX control kardex
Companies with the IMMEX program must carry a control kardex that records all merchandise entries and exits. The kardex is auditable by SE and SAT, and must match monthly the balances of the active pedimentos. For a merch operation, the kardex typically carries: entry date, origin pedimento, description, quantity, unit value, exit date, destination pedimento, final client.
When the merch is for internal use (plant uniforms, onboarding kits), the kardex carries the entry by T1 pedimento and the exit by internal consumption documented with CFDI 4.0 without foreign trade complement. When it is for fairs, the kardex carries the entry by T1 pedimento and the exit by return or by destruction.
IVA in IMMEX operations
IVA in IMMEX operations follows particular rules. Temporary import does not generate IVA at the time of entry; IVA is paid until the merchandise is nationalized or the benefit is lost. Definitive export transfers IVA but does not charge the foreign client; the Mexican exporter recovers creditable IVA through the SAT automatic refund procedure.
When an IMMEX company sells merch to another Mexican company, the CFDI carries normal 16% IVA. When it sells to a foreign client, the CFDI carries 0% IVA with foreign trade complement. When it imports fabric to produce export merch, the IVA on the fabric is credited against the IVA on domestic sales; when the fabric is lost or not exported, the corresponding IVA is paid.
Common mistakes in IMMEX operations
Five mistakes we see frequently. First, not renewing the IMMEX program on time — the authorization expires every year and, if not renewed, the operation falls and taxes must be paid on the non-returned merchandise. Second, not matching the kardex with the pedimentos — when SAT audits and finds differences, they are considered non-returned operations and taxes are charged with update and surcharges.
Third, misclassifying merch in the tariff — an engraved thermos with a generic description can fall in a tariff fraction with a different duty than a specific one. Fourth, not issuing the foreign trade complement on the CFDI — without the complement, SAT considers the export did not exist for fiscal purposes. Fifth, forgetting restrictions in the List of Restricted Merchandise — some fractions require prior permission from SE.
How Corp-Merch.MX can help
Corp-Merch.MX operates as a merch supplier for IMMEX companies for over a decade. We handle: temporary import of fabric and materials, production under T1 regime with auditable kardex, definitive export with foreign trade complement, return in the same state for fairs, and CFDI 4.0 invoicing that complies with SAT and SE requirements.
If you are an IMMEX company and need to produce merch for employees, for overseas clients or for international fairs, share your operation. We help you define the correct regime, prepare the pedimentos and keep the control kardex up to date.
Quote your IMMEX operation?
If you are an IMMEX company and need to produce merch for employees, fairs or overseas clients, share your case. We need description of the merchandise, quantities, dates and destination. We help you define the correct regime and prepare the documentation.
Corp-Merch.MX is a Mexican workshop that produces merch. Information about the IMMEX program is informational and reflects provisions in force at the time of publication. We recommend validating specific operations with your customs broker and with SE. Corp-Merch.MX is not a customs broker or foreign trade agency — when a case requires it, we work with specialized allies.