2026-10-13 · By Robert Katona
Moving a Production Line to Mexico: The Sequence, and Who You Hire at Each Step

Key takeaways
- Machinery brought in under IMMEX may stay for the life of the program, but unlike raw materials it pays Mexico's general import duty when it enters. Many machines carry a zero rate; universal lathes and hydraulic presses up to 1,000 tonnes carry 15 percent, and PROSEC, Regla 8a or USMCA origin can lower the bill.
- A used machine leaving a US or Canadian plant gets the USMCA rate only if it is an originating good with a certification of origin. A press built in Germany does not become North American by running in Ohio.
- A company with a building but no machinery can receive a three-month pre-operative IMMEX program, extendable once, to import machinery only. Raw materials follow once Economía confirms the line is installed.
- Power sets the schedule. CFE lists medium-voltage contracting at 12 to 50 days, but any network works sit outside that clock, so the request starts when the parcel is chosen, not when the machines ship.
- Seven specialists carry the move: an origin-side forwarder, a Mexican customs broker, a rigger and millwright, an electrical contractor with an inspection unit, an environmental consultant, labor counsel and a corredor público. Every specialized contractor on site needs REPSE registration.
Moving a production line into Mexico is a sequence more than a shipment. The machines cross only after the vehicle that will import them exists, the address they are going to is registered, and the duty and IVA position on each machine is settled. The line runs only after power, safety and environmental requirements are met on the Mexican floor. The relocation contractor is one of seven specialists the move needs, and each one is easier to choose once you know where they sit in that order.
What follows draws on the Ley Aduanera, the IMMEX Decree, SAT's 2026 foreign trade rules, Economía's foreign trade rules, US and Canadian export regulations, and STPS and CFE procedures, read on 12 and 13 October 2026. It is orientation, not legal or tax advice, and each rule is worth re-reading against the version in force on your filing date.
Which company imports the machines?
Two vehicles can carry the machinery, and the choice comes first because everything else hangs on it.
A shelter's program. Under the IMMEX Decree's shelter modality, the foreign company provides "la tecnología y el material productivo" while the shelter operates the program (IMMEX Decree, Art. 3). The shelter is the importer of record, and you keep title to the machinery. Article 183 of the income tax law protects you from a permanent establishment while you supply machinery this way, as our shelter or own entity guide explains.
Your own entity's program. Only a company resident in Mexico can hold an IMMEX program, with an active RFC, every operating address registered, and a positive tax compliance opinion (Decree Arts. 3 and 11). The application needs a lease with a one-year forced term and at least 11 months left at filing, and a fe de hechos from a corredor público authorized by Economía, issued within three months of filing, covering the premises and an inventory of the machinery with photos and proof of legal possession (Economía rule 3.1.1). Economía resolves within 15 business days, and silence counts as approval.
The on-ramp built for this move. If Economía's inspection finds only the building, it grants a pre-operative program for three months, during which you "podrá importar exclusivamente" machinery and equipment (Decree Art. 11, section V). The period can be extended once by the same term if installation is progressing, and raw materials follow once a new fe de hechos or visit shows the machinery installed (rule 3.2.23).
Either way, the machine needs a registered address before it moves. Adding an address to a program you already hold is covered in our guide to a second IMMEX plant.
What does Mexico charge on a used machine?
Machinery is the exception to the IMMEX duty deferral. The Ley Aduanera exempts temporary imports from foreign trade taxes, then excludes "108, fracción III" from that exemption, and Article 110 states that IMMEX companies "deberán pagar el impuesto general de importación ... al efectuar la importación temporal de la maquinaria y el equipo". SAT rule 1.6.10 has the duty calculated and paid on the temporary import pedimento (RGCE 2026). Once in, the machine may stay for the life of the program.
The bill depends on the tariff line. In the tariff law as last reformed on 29 December 2025:
| Machine | Tariff line | General import rate |
|---|---|---|
| Machining centres | 8457.10.01 | Exempt |
| Injection moulding machines for thermoplastics, up to 5 kg | 8477.10.01 | Exempt |
| Other machines not elsewhere specified | 8479.89.99 | Exempt |
| Universal lathes, up to 4.5 m between centres | 8458.11.01 | 15 percent |
| Hydraulic presses up to 1,000 tonnes | 8462.61.01 | 15 percent |
Rule 1.6.11 lets you pay the lowest rate you qualify for: the general rate, a PROSEC rate with that registration, the Regla 8a rate with that authorization, or a treaty rate for an originating good with proof of origin. A decree of 23 April 2026 changed rates on 185 tariff lines, according to IDC, so have your broker confirm each rate on the pedimento date. Raw materials and components are different: they keep the duty deferral described in our guide to tariffs on Asian inputs.
Origin follows the machine, not the plant. The USMCA rate needs an originating good and a certification of origin (USMCA Chapter 5). A press built in Germany or Japan does not qualify because it ran for a decade in Ohio or Ontario. For a North American machine, the exporter can certify on the basis of documents or the builder's written representation.
Regla 8a was written for this. With Economía's authorization, a registered manufacturer can bring a disassembled machine in several shipments, through several customs offices, and have it treated as one complete article, provided it is used "para ampliar una planta industrial, reponer equipo" or to build a product in Mexico.
IVA is a separate question. IMMEX temporary imports carry the 16 percent IVA, covered by a 100 percent credit only with SAT's certification (Ley del IVA, Art. 28-A). A new program can request a registration limited to fixed assets for up to six months plus three, which converts to the full registration after an AGACE visit (rule 7.1.2), or cover the machinery with a 30-month guarantee (rule 7.4.7). Our IVA certification guide covers the full registration.
What do you file on the way out?
Leaving the United States. Electronic Export Information is not required for a Schedule B line worth US$2,500 or less (15 CFR 30.37), so assume it for every machine, and at any value when a licence is required. The US exemption for shipments to Canada has no Mexican equivalent. A truck's filing is due "no later than one (1) hour prior to the arrival of the truck at the United States border" (15 CFR 30.4), and a forwarder filing for you needs your written authorization. Most production equipment is EAR99, which needs no licence "in most situations", but precision machine tools can carry a controlled classification, so ask the builder for each machine's ECCN and screen every party against the Consolidated Screening List (BIS).
Leaving Canada. Commercial goods valued at CAD 2,000 or more are declared to CBSA, mainly through the CERS portal with a BN15, and a highway export is reported "immediately before" the truck crosses (CBSA Memorandum D20-1-1).
A carnet does not fit. Mexico takes ATA carnets only for professional equipment, exhibitions and samples, with re-export within six months (RGCE rule 3.6.2).
Are there restrictions on used machinery?
Industrial machinery faces three checks.
- Permits. Economía's prior-permit list for used goods covers vehicles, tariff headings 8701 to 8706, and only on definitive import.
- NOMs. NOM certificates are waived on IMMEX temporary imports (Economía rule 2.4.11). A definitive import of a used machine in a NOM-listed line needs a certificate stating it is used (rule 2.4.10), which matters if a machine later changes to definitive import.
- SEDENA. Machining centres, lathes, presses and injection moulders appear on SEDENA's list, with a permit required "únicamente" when they are used to make arms, ammunition or explosives. The sectoral importers' register follows the same test (Anexo 10).
Every machine also enters your Anexo 24 fixed-asset module by brand and model against its pedimento, so the rigger's disassembly inventory doubles as your customs record.
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What has to be true before the first part runs?
Power. CFE's medium-voltage contracting procedure runs in three steps, application, formal contracting with an electrical inspection report, and the meter visit, listed at 12 to 50 days in total (Ventanilla Única, procedure 638). Once CENACE orders a connection, the distributor signs within 10 business days and connects within 72 hours (Ley del Sector Eléctrico, Art. 48). The construction of any network works sits outside both clocks, which is why our state incentives guide asks for CFE's written position on a named parcel.
Environment. Oil, petrochemical, chemical, steel, paper, sugar, cement and power projects need SEMARNAT's prior impact authorization, resolved within 60 days of receiving the impact statement and extendable for complex projects; other plants are assessed by the state, often inside the land-use or construction permit (LGEEPA, Arts. 28 and 35 Bis). Plants in the federal air-emission sectors, including automotive, metallurgy, glass, paints and chemicals, need an operating licence when their process falls in a listed subsector, decided within 30 business days of a complete file, and an annual report filed between 1 March and 30 June (air regulation, Arts. 18 to 20). Hazardous-waste generators register with SEMARNAT.
Safety. NOM-004-STPS requires a written risk study for the machinery, a safety program for its operation and maintenance, and operator training (NOM-004). A relocated Category III boiler or pressure vessel needs a new STPS notice "antes de ponerlos nuevamente en funcionamiento" (NOM-020, numeral 16.2), filed at least five business days ahead under the STPS procedure of August 2026. The building needs an internal civil protection program (Ley General de Protección Civil, Art. 40), and land use and construction licences come from the municipality.
People. Training is an employer obligation, and above 50 workers a joint training commission is required (Ley Federal del Trabajo, Arts. 153-A and 153-E). What that workforce costs is in our labor rate guide.
The sequence
- Choose the vehicle: a shelter, your own entity, or a shelter first and your own entity later.
- For your own entity: incorporate, register the RFC, and obtain the e.firma and a positive compliance opinion.
- Secure the site with a qualifying lease, register the address, and confirm municipal land use.
- Open the CFE request on the named parcel.
- Scope the environmental filings, federal or state, before construction or operation.
- Obtain the corredor público's fe de hechos, then file for IMMEX; if the inspection finds only the building, Economía grants the pre-operative program. Under a shelter, the address goes onto the shelter's program.
- Settle the IVA position: certification, the fixed-asset registration, a guarantee, or cash.
- Build a file per machine: tariff line, the lowest duty rate you qualify for, NOM and SEDENA status, ECCN, photos and proof of ownership.
- Mandate the brokers on both sides and set up the Anexo 24 fixed-asset module.
- Disassemble, match-mark and crate; file the US or Canadian export declaration; cross on the temporary import pedimento, paying duty where the rate is above zero.
- Install, pass the electrical inspection, connect, complete the NOM-004 study, the NOM-020 notices and the civil protection program, then hire and train.
- Convert the pre-operative program and the fixed-asset IVA registration, obtain your customers' approval of parts from the new site (PPAP in automotive), and run old and new lines in parallel until the new one is approved.
Who you hire at each step
| Specialist | When | Questions worth asking |
|---|---|---|
| Export broker or forwarder, origin side | Steps 9 and 10 | Will you file EEI or the CERS declaration as our agent, and what written authorization do you need? Who confirms each machine's ECCN? |
| Mexican customs broker | Steps 6 to 10 | Is your patent active and recertified within three years, and are you clear of ANAM's published list? How will you set the duty on each machine: general, PROSEC, Regla 8a or USMCA? |
| Rigger and millwright | Steps 10 and 11 | Will your disassembly inventory give brand, model, serial number and photos per machine? Who files the NOM-020 notice before restart? Are you registered in REPSE? |
| Electrical contractor and inspection unit | Steps 4 and 11 | Have you taken a medium-voltage request through CFE to a budget for network works, and what did those works cost and take? Is the inspection unit independent of the installer? |
| Environmental consultant | Step 5, then yearly | Is our process federal or state? Which hazardous-waste category are we, and who owns the annual report calendar? |
| Labor counsel | Steps 1 and 11 | Which on-site contractors need REPSE, and which work stays with our own employees? How do we keep seniority if we move from a shelter to our own entity? |
| Corredor público | Step 6, again at conversion | Are you on Economía's list for this location, and can you issue the fe de hechos within three months of filing and again once the machinery is installed? |
Every specialized contractor working on your site needs REPSE registration and a written contract stating the services and approximate headcount, and you are jointly liable for their workers (Ley Federal del Trabajo, Arts. 13 to 15). The Reglamento de la Ley Aduanera has ANAM publish the brokers whose patents are suspended, cancelled or extinguished, so that check takes no inside knowledge.
The bottom line
A line move into Mexico succeeds on order. The vehicle and the registered address come before the machines, the duty and IVA position on each machine comes before the pedimento, and power, safety and environmental filings come before the first part. Machinery pays Mexico's import duty at entry, often at zero, and a used machine counts as North American only if it was built there. Start the CFE request with the parcel, keep one file per machine that serves customs, the corredor and the rigger at once, and hire each specialist against the step they own.
Frequently asked questions
Do we pay import duty on our machines if we bring them in under IMMEX?
Yes. Article 110 of the Ley Aduanera requires an IMMEX company to pay the general import duty when it temporarily imports machinery and equipment, and SAT rule 1.6.10 has it calculated and paid on the pedimento. You may use the lowest rate you qualify for: the general tariff, a PROSEC rate, the Regla 8a rate, or a treaty rate with proof of origin. Many machines carry a zero general rate; universal lathes and hydraulic presses up to 1,000 tonnes carry 15 percent in the tariff text last reformed on 29 December 2025. Have your broker confirm the rate on the date of the pedimento.
Our presses were made in Germany but run in our Ohio plant. Do they qualify for the USMCA rate?
No. The USMCA rate requires a good that is originating under the agreement's rules of origin, backed by a certification of origin (USMCA Articles 5.2 and 5.3). A machine built outside North America does not become originating by leaving a US plant. PROSEC or Regla 8a are the routes to a lower rate for it.
Can we ship the machines before our IMMEX program is approved?
Not as an IMMEX temporary import. If Economía's inspection finds only the building, it grants a three-month pre-operative program, extendable once by the same term if installation is progressing, during which you may import only machinery and equipment (IMMEX Decree Article 11, section V, and Economía rule 3.2.23). Raw materials and components follow once a new fe de hechos or visit shows the machinery installed.
Can we use an ATA carnet to move the equipment?
No. Mexico accepts ATA carnets for professional equipment, exhibitions and commercial samples, and goods entered on a carnet must be re-exported within six months (RGCE 2026 rule 3.6.2). A line that stays needs an IMMEX temporary import or a definitive import.
Do we need a permit to import used machinery into Mexico?
Not from Economía for industrial machinery: its prior-permit list for used goods covers vehicles only, and only on definitive import. NOM certificates are waived on IMMEX temporary imports, but a definitive import of a used machine in a NOM-listed tariff line needs a certificate stating it is used. Machining centres, lathes, presses and injection moulders appear on SEDENA's list, with a permit required only when the machine is used to make arms, ammunition or explosives.
Do we pay 16 percent VAT on the machines?
IMMEX temporary imports are not exempt from IVA. You avoid paying it in cash in three ways: SAT's IVA and IEPS certification, which gives a 100 percent credit; a registration limited to fixed assets that a new program can request for up to six months, extendable once by three; or a 30-month guarantee (Ley del IVA Article 28-A; RGCE 2026 rules 7.1.2 and 7.4.7).
How early do we file the export paperwork?
From the United States, Electronic Export Information is required for any Schedule B line over US$2,500, or at any value when a licence is required, and for a truck it is filed at least one hour before the truck reaches the border (15 CFR 30.37, 30.2 and 30.4). From Canada, goods valued at CAD 2,000 or more are declared through CERS, and for highway exports immediately before the truck crosses (CBSA Memorandum D20-1-1).
How long does it take to get power to the new line?
CFE lists its medium-voltage contracting procedure at 12 to 50 days and asks for an electrical inspection report. Once CENACE orders a connection, the distributor signs the contract within 10 business days and connects within 72 hours (Ley del Sector Eléctrico Article 48). Any network works fall outside both clocks, and no official duration exists for them, so start the request when you choose the parcel.
Our boilers and air receivers are moving too. Is anything different for them?
A Category III boiler or pressure vessel that is relocated needs a new notice to STPS before it runs again (NOM-020-STPS-2011, numeral 16.2). Under the STPS procedure signed on 17 August 2026, file at least five business days before operation; STPS resolves in five business days.
What do the contractors working on our site need in Mexico?
Specialized contractors such as riggers, millwrights and electrical contractors must be registered in REPSE and work under a written contract that states the services and the approximate number of workers, and you are jointly liable if they default on their workers (Ley Federal del Trabajo Articles 13 to 15). Production operators are your core activity, so they are your employees or the shelter's.

Robert Katona is the founder of Calder & Vale, a cross-border advisory firm working across all of North America. He advises operators, investors, and institutions on market entry, partner selection, and growth strategy throughout the region.
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