Following the Decree reforming the Customs Law published on November 19, 2025, Mexico has implemented new enforcement practices effective January 2026. For ICT manufacturers and importers, “close enough” is no longer acceptable for NOM certification and customs documentation.
The Critical Shift: HS Codes and Data Matching
The most significant operational change involves the Harmonized System (HS) Codes. Under the new reforms, the HS Code listed on your NOM certificate must perfectly match the code used for importation.
Starting January 2026, Customs Agents (validators) are mandated to conduct a forensic review of all documentation. They will scrutinize the following data points to ensure an exact match between the certificate and the physical product:
- HS Code
- Certificate Holder
- Product Name, Brand, and Model
- Country of Origin and Country of Shipment
If any of these fields do not align—for example, if the HS code on your certificate differs from the one your Customs Broker assigns—the shipment will be flagged.
The Risks: Seizures and Fines
The consequences for non-compliance have escalated. Importers who fail to meet these stricter standards face higher sanctions. Shipments with labeling errors, missing NOM certificates, or data discrepancies are subject to:
- Immediate Retention: Goods held at the border indefinitely.
- Heavy Fines: Increased financial penalties for non-compliance.
- Seizure: Total loss of the shipment in severe cases.
Your Action Plan for Seamless Importation
To avoid disruptions in your supply chain to Mexico, we recommend the following immediate actions:
- Pre-Shipment Verification: Ensure all NOM labeling is applied to product packaging before the goods leave the factory.
- HS Code Alignment: Verify the correct, Mexico-specific HS code with your local importer or Customs Broker before finalizing certification. This code must appear on the valid NOM certificate.
- Data Audit: Confirm that all certificate information (Brand, Model, Origin) matches your shipping invoice exactly. If information has changed, request a certificate update immediately.
- Clarify Exemptions: If you believe your product does not require NOM compliance, do not assume Customs will agree. Obtain a Dictamen letter from an authorized Certification Body to prove exemption or clarify the NOM scope.
Don’t let a paperwork error stall your market access. If you are unsure about your product’s HS code classification or the status of your NOM certificates under these new rules, please contact our team immediately for a compliance review.
