Podcast — Episode 2: IMMEX for merch operations
In this second episode we sit down with a customs broker specialized in the maquiladora sector to discuss how the IMMEX program works when applied to merch. We cover the three regimes that apply most often — temporary import, return in the same state, and definitive export — and how each one translates into pedimentos, CFDI with foreign trade complement and kardex entries. The guest walks us through a real maquiladora that produces branded apparel for North American clients and explains where the operational risks sit. The conversation is thirty-six minutes long and is available in audio plus an edited transcript.
About this episode
Our guest is Roberto Aguirre, a licensed customs broker with twenty-two years of experience in the maquiladora sector in northern Mexico. Roberto runs a brokerage that serves twenty-three IMMEX clients in Chihuahua, Nuevo León and Tamaulipas, with combined monthly pedimento volume of roughly 1,800. He has lived through the 2007 customs reform, the 2014 IMMEX reform and the 2020 foreign trade complement rollout, and he speaks from operational experience rather than theory.
The conversation covers the three regimes that apply most often to merch — temporary import for fabric that becomes merch, return in the same state for samples and trade show booths, and definitive export for finished merch shipped to a foreign client. We also discuss the role of the Annex 24 report, the reconciliation of the IMMEX kardex, and the most common audit findings when the SAT reviews an IMMEX corporate with merch operations.
What you will learn
Six concrete operational ideas. The first is that the IMMEX regime is not a tax exemption: it is a deferral of the import taxes until the merchandise is exported or returned, and the corporate remains liable if the merchandise is not properly traced. The second is that the Annex 24 report is the spine of the operation: every entry, every exit and every balance has to be reflected in the report, and any discrepancy between the report and the pedimentos is a finding waiting to be discovered in an audit.
The third is that the foreign trade complement on the CFDI is the link between tax and customs: when the SAT reviews a merch exporter, it cross-references the CFDI complement with the pedimento data, and any mismatch is a red flag. The fourth is that trade show booths benefit enormously from the return regime: shipping 200 kilos of branded merch to a Las Vegas convention, using it for three days and returning it costs a fraction of the definitive export that nobody would have claimed back anyway.
The fifth is that small batches rarely justify a full pedimento: for samples, prototypes and one-offs, the consolidated pedimento or the return with simplified declaration is usually the right tool. The sixth is that the kardex control is not a document you prepare at audit time: it has to be updated in real time, with each movement reflected within twenty-four hours.
Edited transcript: the highlights
(00:00) Corp-Merch.MX: Roberto, what is the first thing a corporate should understand about applying IMMEX to merch?
(00:38) Roberto Aguirre: That merch is not the typical IMMEX product. Most IMMEX training is built around electronics or automotive parts — high value, long lifecycle, few SKUs. Merch is the opposite: hundreds of SKUs, low individual value, fast turnover. The same fiscal logic applies but the operational rhythm is completely different.
(05:12) Corp-Merch.MX: Which regime do you see most often for merch?
(05:24) Roberto Aguirre: Definitive export. A maquiladora in Juárez produces 5,000 t-shirts for a Dallas client and ships them across Laredo. The pedimento is A2 or B1, the CFDI carries the foreign trade complement, and the merchandise crosses without return. About sixty percent of the IMMEX merch operations I handle are definitive export.
(14:18) Corp-Merch.MX: And the trade show case?
(14:30) Roberto Aguirre: Return in the same state. The maquiladora sends a booth kit to CES in Las Vegas, the kit comes back in ten days, no import taxes paid. The pedimento is A1 with a six-month return window. It saves a corporate thousands of dollars per show, and it is one of the cleanest applications of IMMEX in the merch sector.
(26:42) Corp-Merch.MX: One final piece of advice for a corporate starting an IMMEX merch operation.
(26:55) Roberto Aguirre: Hire a customs broker who has done merch. Not one who does electronics and is willing to learn — those are the operations that end up with audit findings. Find someone who has actually filed a pedimento for a t-shirt shipment and knows how to handle the SKU proliferation. The right broker is the difference between an IMMEX program that works and one that becomes a fiscal headache.
Listen to the next episode
Episode 3 covers the maquiladora sector at scale, with a plant manager who oversees 4,000 employees and the merch programs that support them. Subscribe to receive it as soon as it goes live, along with the transcript and the operational notes we publish alongside each episode.
Roberto Aguirre is a fictional persona created for editorial purposes. The opinions, criteria and frameworks described do not represent any real person or company. The transcript was edited for clarity and is published under editorial license. Corp-Merch.MX has no commercial, equity or sponsorship relationship with any customs brokerage mentioned in this episode.