Renewal Resolutions for the Certified Companies Scheme Registry (RECE): Control and Updating of Authorized Tariff Classifications
Companies registered under Mexico’s Certified Companies Scheme Registry (Registro en el Esquema de Certificación de Empresas, RECE) have historically faced challenges in comprehensively identifying the tariff classifications authorized for the temporary importation of goods.
In practice, determining the full scope of authorized tariff classifications required consideration of the original certification application, any tariff classification addition notices filed during the validity of the certification, and, in the case of sensitive goods, the corresponding authorizations. This situation created a significant reconciliation burden for companies, particularly when assessing new import transactions.
As part of the 2026 renewal process, it has been observed that certain resolutions issued by the General Administration of Foreign Trade Audits (AGACE) of Mexico’s Tax Administration Service (SAT) include relevant information regarding the tariff classifications associated with the Certified Companies Scheme Registry (RECE).
In particular, these resolutions identify the tariff classifications recognized under the certification, as well as the reference numbers corresponding to previously submitted addition notices.
Addition Notices and Authorizations: Scope and Distinctions
Procedure Sheet 62/LA corresponds to the tariff classification addition notice provided for under Rule 7.2.1, Section X. This filing applies to both sensitive and non-sensitive goods, without distinction between raw materials and fixed assets, and must be submitted through the Digital Window at least one month prior to the introduction of the goods into Mexican territory.
Procedure Sheet 118/LA, on the other hand, corresponds to an authorization procedure applicable to the temporary importation of goods listed in Annex II of the IMMEX Decree or Annex 28 of the Foreign Trade General Rules (RGCE), depending on the circumstances of the particular case.
Correctly identifying the applicable procedure is particularly important, considering that failure to submit the notices required under Rule 7.2.1 constitutes grounds for cancellation of the RECE certification pursuant to Rule 7.2.4, Section A, Item II, in addition to any potential consequences related to the Importers Registry and, where applicable, sector-specific importers registries.
Implications for Certified Companies
The 2026 renewal resolutions provide an additional documentary basis for conducting a comprehensive reconciliation between the tariff classifications recognized by the authorities and a company’s foreign trade operations.
Accordingly, companies should consider:
- Reconciling the tariff classifications listed in the renewal resolution with those actually declared in customs entries, as well as with the company’s procurement and production plans.
- Identifying tariff classifications currently used or planned to be used that are not included within the authorized scope.
- Determining, for each tariff classification, whether the filing of an addition notice under Procedure Sheet 62/LA is required and, where applicable, obtaining the corresponding authorization through Procedure Sheet 118/LA.
- Considering the deadlines established under the applicable regulations and avoiding the introduction of goods when the required notice has not been duly filed or the corresponding authorization has not yet been obtained.
- Verifying that production processes adequately support the incorporation and use of the relevant goods.
Final Considerations
The information contained in the 2026 renewal resolutions represents a relevant tool for strengthening the internal compliance controls of certified companies. The information incorporated by AGACE provides a clearer documentary reference regarding the tariff classifications recognized under the certification and facilitates the identification of potential gaps between the authorized scope and a company’s actual customs operations.
At EC Rubio, we assist companies with the review of renewal resolutions, tariff classification reconciliations, identification of regulatory gaps, and the determination, preparation, and filing of the corresponding notices and applications before AGACE.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
