A significant change was made to Annex 24, introducing a “Section C” in inventory control requirements. This section mandates that companies implement an automated inventory control system that allows for electronic registration of catalogs, entries, exits, materials used, and fixed assets within 48 hours. Additional information must be transmitted at the time of duty payment.

Additionally, companies must provide the General Administration of Foreign Trade Audits with a username and password for online access to Section C through a formal request. This provision has faced criticism in the sector, as it is considered a violation of constitutional rights, imposing an obligation on companies to grant continuous access to their automated systems without prior justification. This measure could lead to direct audits and sanctions, including the suspension or cancellation of the RECE, infringing on the right against self-incrimination.

Companies with pending applications or with current registration in the RECE (in Value Added Tax and Special Tax on Production and Services modalities, A, AA, AAA categories, Authorized Economic Operator importer and exporter, and Certified Business Partner) must comply with the current requirements by implementing Section C no later than November 15, 2024.

At Calderón Marín, we are available to address any questions or concerns that this new measure may raise. Furthermore, if deemed unconstitutional or non-compliant, we can analyze possible defense strategies against these regulatory changes to safeguard your interests.

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