Joffroy Global

Joffroy Global US & MX. North-American Based. Customs Brokers, Trade Compliance, Supply Chain & Storage Solutions.

Global logistics group of companies vertically integrated to offer effective & efficient supply chain solutions.

Free storage on an import at a Mexican recinto fiscalizado is two days. Working days. Counted from the day after the fac...
09/02/2026

Free storage on an import at a Mexican recinto fiscalizado is two days.

Working days. Counted from the day after the facility receives the goods. A Thursday landing can expire before anyone opens a Monday email.

What the law says:

Article 15, section V of the Ley Aduanera obligates the concessionaires and authorized operators of recintos fiscalizados to allow free storage for a defined period. Two days for import goods. Five days at recintos located at maritime customs offices. Fifteen days for exports, thirty for minerals.

Two details cost more than the headline number:

→ The count runs in working days and begins the day after receipt. For imports arriving by sea or air, it begins when the consignee receives notice that the goods entered the facility.

→ Free storage is not free handling. The same provision lets the operator charge for handling the goods and for the maneuvers required for reconocimiento previo during the window. Free means free of the storage line item. It never meant free of cost.

What happens when the window closes:

Storage becomes a metered charge set commercially between the facility and the cargo interest. The rate is not in the law. It sits in a tariff schedule the operations team has usually never read, and it typically escalates with time and volume.

That is the shape of the exposure for anyone who owns the number: an unbudgeted, uncapped daily charge on the one shipment the plant is waiting for, accruing while the internal thread is still about whose fault it is.

Across more than 190,000 customs operations a year at 39 or more ports, the operations that absorb a hold without drama are the ones carrying storage expiry as a standing data field, not as a number someone calculates during the incident.

Reconstructing the full cost of a recent hold, layer by layer, is the kind of review a Joffroy expert can run with you.



Can your team produce the free storage expiry, computed in working days, for every shipment sitting in a recinto today?

El nearshoring no se resuelve rentando una nave industrial.Nuestro CEO, Eduardo Joffroy, conversó con PLAYERS of Life so...
08/31/2026

El nearshoring no se resuelve rentando una nave industrial.

Nuestro CEO, Eduardo Joffroy, conversó con PLAYERS of Life sobre lo que realmente define si una operación binacional funciona.

"Desde afuera, el nearshoring se ve como una empresa que renta una nave industrial y anuncia que 'ya está en México'. Desde nuestra oficina se ve distinto. La nave es el 10% del problema."

El otro 90% es el mapa regulatorio: permisos, disponibilidad de infraestructura, cumplimiento normativo, energía, esquemas aduanales y la integración entre ambos países.

Una manufacturera textil que se instaló en Coahuila no nos pidió una bodega. Nos pidió que le dibujáramos el camino regulatorio completo antes de mover el primer contenedor. Ese es el trabajo.

Llevamos desde 1904 en esto, cuarta generación al frente, y seguimos operando bajo la misma premisa: el comercio entre México y Estados Unidos nunca fueron dos procesos. Es uno solo.

Entrevista completa en la edición de agosto de PLAYERS of Life Monterrey. Liga en el primer comentario.

TRADE. UNDER CONTROL.

¿If you are evaluating a First Sale program right now, one fact belongs in the model. On February 11, 2026, Senators Bil...
08/31/2026

¿If you are evaluating a First Sale program right now, one fact belongs in the model.

On February 11, 2026, Senators Bill Cassidy and Sheldon Whitehouse introduced the Last Sale Valuation Act, S.3841 in the 119th Congress. It would amend the Tariff Act of 1930 to require that transaction value be determined on the basis of the last sale occurring before exportation to the United States. If enacted, First Sale would no longer be available.

As of August 28, 2026, the bill remains with the Senate Finance Committee, where it was referred on the day of introduction, with no further action and no scheduled consideration.

It is also not the first attempt. In 2008, CBP proposed by rulemaking to require the last sale as the basis of transaction value, and that proposal did not take effect.

We are not going to predict what happens. Two planning conclusions follow regardless, and both are useful.

First, model the program on a payback horizon you can defend rather than assuming indefinite availability. A First Sale program that breaks even over five years is a materially different decision from one that pays for itself in twelve months. The setup cost is the same either way; what changes is how much runway you are assuming.

Second, build the documentation to a standard that holds no matter what happens to the bill. The records that prove a bona fide sale, a destination and an arm's-length price are the same records that answer a related-party inquiry, a value verification, or a post-entry review under any valuation basis. That work is not contingent.

The instrument may or may not survive. The file is useful either way.

If you are modeling a First Sale program, what payback period are you assuming?

Every definitive cuota compensatoria you pay has an expiry date, and there is a published notice warning you it is comin...
08/28/2026

Every definitive cuota compensatoria you pay has an expiry date, and there is a published notice warning you it is coming.

Article 70 of the Ley de Comercio Exterior: definitive cuotas are eliminated after five years counted from their entry into force, unless before that period ends the Secretaría has initiated either an annual review or an examen de vigencia, the sunset review.

If neither proceeding has started, the Secretaría publishes a notice in the DOF announcing the elimination.

And Article 70-A adds the part that makes this usable: the Secretaría publishes a notice about the upcoming expiration of a cuota's validity, before it lapses.

Most trade-remedy monitoring is built to catch new charges. This is the other direction, and it has money in it.

Here is the check:

For every cuota compensatoria your operation currently pays, write down the date it entered into force. Add five years. That is your list.

If you cannot produce that date for each one, the monitoring is not happening, whatever the process document says.

Two things fall out of that list. Charges approaching a date at which they may simply disappear, which belongs in next year's cost model. And charges heading into a sunset review that could keep them alive for another cycle, which belongs in your sourcing conversation now rather than in twelve months.



Could you produce the entry-into-force date for every cuota compensatoria you pay, today?

Almost everything on a pedimento feels fixable. File the correction, fix the field, move on. The clave de pedimento is t...
08/26/2026

Almost everything on a pedimento feels fixable. File the correction, fix the field, move on.

The clave de pedimento is the exception, and the instructivo says so directly.

In the rectifications section of Anexo 22: rectification of the clave de pedimento is not permitted when it implies a change of regime.

Read what that rules out. A wrong tariff fraction can be rectified. A wrong value can be rectified. A key that put your goods into the wrong customs regime cannot simply be corrected on a second filing, because the correction would change what the operation legally was.

What remains is a different and slower route. Usually a regularización under key A3, the procedure for bringing an already irregular situation back into compliance, with the contributions and consequences that carries.

Which is why the two characters in field 3 deserve more attention than their size suggests. They are not a dropdown choice. They are the declaration of what the operation is, and every document, deadline and duty consequence downstream follows from them.

And most mis-keying is not ignorance of the appendix. It is inheritance. A key chosen correctly for one operation, turned into a template, and left in place while the business changed underneath it. A plant that used to export everything starts selling domestically. An IMMEX operation buys equipment instead of leasing it. The template does not know any of that happened, and nothing in the clearance process asks.

So the audit here is not a training session. It is a periodic reconciliation between what the operation actually does and what the two characters say it does.



When your business last changed shape, did anyone go back and check the keys?

What changed on January 1 is who reads it first, and what a mismatch now costs. What did not change:Article 59 of the Le...
08/25/2026

What changed on January 1 is who reads it first, and what a mismatch now costs.

What did not change:

Article 59 of the Ley Aduanera has required automated, permanent inventory control, kept current at all times, since long before this reform. Anexo 24 has been the specification just as long. None of that is new.

Your Anexo 24 obligation reads almost the same as it did last December.

What did:
The reform published in the DOF on November 19, 2025, in force January 1, formalized ANAM as the enforcement authority and reinforced that language.

The point most coverage blurred:
The new real-time monitoring and interoperable-access requirements fall on recintos fiscalizados, under Articles 14, 14-A and 14-D. They are not a new obligation on every IMMEX plant.

So on paper, your obligation looks the way it did in December. In practice, the reconciliation you could once let slip for a quarter is now the first thing a formalized enforcement body pulls, in a system where a temporary import that cannot prove where it went is treated as a definitive one: deferred contributions due, surcharges on top.

The obligation is the same. The cost of a descuadre (a mismatch between what your system says and what the pedimentos say) is not.

Across more than 190,000 customs operations a year at 39+ ports, the operations that never face an Anexo 24 crisis are not the ones with the best software. They are the ones that reconcile on a cadence, before anyone asks.

Full breakdown in the comments ↓



Which reading is your team working from right now, the December one or the January one?

Most trade content treats a customs value determination as something that happens to you. Article 78-C of the Ley Aduane...
08/24/2026

Most trade content treats a customs value determination as something that happens to you.

Article 78-C of the Ley Aduanera says otherwise.

When the authority rejects a declared value and determines it using the confidential information of third parties, typically the operations of other importers used as identical or similar merchandise, the importer has the right to designate up to two representatives to access that information, in the terms of Articles 46 and 48 of the Código Fiscal de la Federación.

Read what that means in practice.

If a determination rests on comparable operations you have never seen, that access is the only way to test whether the comparables were genuinely identical or similar in the sense the law requires. Same country of production. Same physical characteristics, quality and commercial prestige. Same commercial level. Similar quantities. Sold at the same time or within the ninety-day window Article 76 defines.

Those are not soft criteria. They are the standard the secondary methods are built on, and a comparable that fails them should not be carrying the determination.

The right has to be offered. It also has to be exercised, and that is where it usually dies. Two representatives is a small ask. Not naming them is a large concession.

Across more than 190,000 customs operations a year at 39+ ports, the pattern in value disputes is consistent: the outcome tends to turn less on the price that was declared and more on whether anyone tested the basis used to replace it.



If a value determination landed tomorrow, would your team know it could ask to see the comparables?

Two programs. One annual report. Two different deadlines.And a single calendar entry can put one of them at risk.Many op...
08/21/2026

Two programs. One annual report. Two different deadlines.

And a single calendar entry can put one of them at risk.

Many operations manage the RAOCE with one reminder set for the last business day of May, because that is the IMMEX deadline under Article 25 of the IMMEX Decree.

But PROSEC does not follow the same calendar.

Article 8 of the PROSEC Decree requires program holders to report the previous fiscal year’s foreign trade operations to the Secretaría de Economía. For PROSEC, the deadline is the last business day of April.

The difference is only one month, but the consequences can be much greater.

If the PROSEC report is not filed by the April deadline, the program may be suspended even while IMMEX is still within its own compliance window.

The company continues operating, but the preferential tariff rate no longer applies. The problem is often discovered weeks later, when it surfaces on a pedimento nobody expected to have an issue.
What we see in practice is rarely negligence.

It is one calendar entry trying to cover two separate obligations.

The solution is simple: separate the controls.

→ April for PROSEC
→ May for IMMEX
→ A clearly identified owner for each obligation

In both cases, the report is filed through the Ventanilla Única, but that does not mean they share the same deadline.

Failing to file on time does not merely create a delay. If the issue is not cured within the period published by the Secretaría, the program may be cancelled. Recovering it would require a new registration not a simple correction.

August is not filing season, but it is a good time to review the process, assign ownership and correct the calendar before the next cycle.

Looking ahead to next year, who owns the April deadline in your operation by name?

T1 is not a transit key. The letter suggests it. The catalog does not. In Apéndice 2 of Anexo 22 of the Reglas Generales...
08/20/2026

T1 is not a transit key.

The letter suggests it. The catalog does not.

In Apéndice 2 of Anexo 22 of the Reglas Generales de Comercio Exterior, T1 sits in the definitive regime and covers imports and exports by courier and parcel companies, under the simplified procedure of regla 3.7.5.

The actual transit keys are elsewhere:

→ T3, internal transit
→ T6, international transit through foreign territory
→ T7, international transit through national territory
→ T9, transmigrant transit

This is worth more than a trivia correction, because of what the instructivo says about fixing a key once it is filed. Rectification of the clave de pedimento is not permitted when it implies a change of regime. A wrong tariff fraction can be rectified. A wrong value can be rectified. A key that put your goods in the wrong regime cannot simply be corrected on a second filing.

Two characters. They decide the regime, the documents, the deadlines and the exposure, and they are the hardest thing on the pedimento to take back.

Most mis-keying we see is not ignorance of the appendix. It is inheritance: a key chosen correctly once, turned into a template, and left in place while the business changed underneath it.


When did someone on your team last open Apéndice 2, rather than the clave the system defaults to?

Apéndice 2 of Anexo 22 has around ninety claves de pedimento, the two-character keys that declare what your customs oper...
08/19/2026

Apéndice 2 of Anexo 22 has around ninety claves de pedimento, the two-character keys that declare what your customs operation legally is.

Reading it key by key is how people give up on it. Read it by family and it collapses into something a team can hold in its head.

There are eight:

→ Definitive, for goods entering to stay or leaving for good, plus the corrections attached to that permanence
→ Virtual operations, for movements that happen on paper between authorized parties without cargo crossing anything
→ Temporary, for goods entering or leaving for a defined period and purpose
→ IMMEX, its own block for manufacturing under the program
→ Bonded warehousing, or depósito fiscal, covering both introduction and extraction
→ Strategic bonded facility, the recinto fiscalizado estratégico regime
→ Transit, for movement under customs control between customs offices
→ Administrative, the two keys that sit outside all of it: R1 for rectifications, CT for the complementary pedimento

Locate the family first and the number of plausible keys drops from ninety to a handful. That single step is most of the work.

One warning that comes with the map. Read the cases listed under each key, not the key's title. Most mis-keying survives because a title sounds right and the detail underneath does not match. T1 is the clearest example: the letter suggests transit, and the appendix places it in the definitive regime, covering courier and parcel shipments.

Full map in the image. Worth keeping.



How many distinct keys did your operation use in the last ninety days? The ones that appear once or twice are the ones nobody has verified.

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