Mexico — temporary tariffs on textiles/apparel + IMMEX program restrictions (DOF 19 Dec 2024)

Mechanism

The decree is a dual-instrument escalation: a tariff layer (TIGIE modification) plus a customs-regime layer (IMMEX modification).

Tariff layer. The MFN duty on 138 finished-apparel tariff lines in Chapters 61 (knitted), 62 (non-knitted), 63 (made-up textile articles — blankets, towels, bed linen) and item 9404.40.01 is raised to 35%; 17 input-fabric lines in Chapters 52 (cotton), 55 (man-made staple), 58 (special woven), 60 (knitted/crocheted fabric) move to 15%. These rates are bound below Mexico's WTO ceiling for the affected lines, so the measure is WTO-consistent without a safeguard investigation; that's also why the FTA carve-out is automatic (FTA partners receive the preferential rate, only non-FTA suppliers face the 35% / 15%).

IMMEX layer. 302 tariff fractions in Chapters 61/62/63 are stripped from Annex II Section C (the list of items that may be temporarily imported duty-free under an IMMEX programme). This closes the "transshipment via maquiladora" channel that the Sheinbaum government publicly identified as the primary loophole — Asian-origin finished apparel was being imported into IMMEX bonded warehouses, lightly processed, and re-exported to the US under the IMMEX export commitment or sold domestically via the IMMEX 10%-domestic-sales window. After 19 Dec 2024 those flows must clear customs at the full 35% MFN rate.

Targeting. The decree is jurisdiction-neutral on its face but operationally targets China specifically: ~70%+ of Mexico's non-FTA apparel imports originate from China, with smaller volumes from Bangladesh, Vietnam, Indonesia and Cambodia. Western fast-fashion e-commerce platforms (Shein, Temu) that ship China-origin goods to Mexican consumers are the consumer-side target.

Downstream implications

• First sectoral tariff escalation under the Sheinbaum administration;

signals willingness to use TIGIE+IMMEX modifications as a defensive trade tool ahead of the USMCA review (scheduled 2026)

• Consistent with a broader "nearshoring with conditionality" posture —

Mexico wants to retain its USMCA tariff preference vis-à-vis Asia, not become a transshipment platform that triggers US §232 / IEEPA retaliation

• IMMEX changes create a 16-month adjustment window (until 23 Apr 2026)

— likely tracks the next USMCA review, suggesting the regime may be extended or made permanent depending on US side conversations

• Negative for Shein/Temu Mexico unit economics; positive for Mexican

domestic textile industry (Cámara Nacional de la Industria Textil has lobbied for this since 2022)

• No EU / Japan / Korea sourcing impact — all are FTA partners

Open questions

• Will the 35% rate be extended beyond 23 Apr 2026 or made permanent?
• Will US Trade Representative treat this as a USMCA-aligned move (good

faith signal to Washington) or contest the IMMEX changes that affect US-owned IMMEX operators?

• Does Sheinbaum follow with similar TIGIE+IMMEX measures in steel,

ceramics, footwear (sectors with similar Chinese-import concerns)?