The 2026 Customs Reform Changed Who Can Operate Your Recinto Fiscalizado Estratégico

As of January 1, 2026, a shipment cannot enter a Recinto Fiscalizado Estratégico (RFE, Mexico's strategic bonded facility regime), have that regime concluded, or be withdrawn for sale in the domestic market, unless the customs agency handling the operation holds a current registration in Mexico's certified-company registry. That single requirement, added to the Ley Aduanera (Customs Law) by the reform published in the Diario Oficial de la Federación (DOF, Mexico's federal gazette) on November 19, 2025, quietly redrew the map of who is legally allowed to move RFE cargo. Most companies operating under the regime have not yet confirmed whether their agency sits on the right side of that line.

What the requirement actually says

The reformed Article 135-B of the Ley Aduanera is direct: the clearance of goods destined to the RFE regime, the conclusion of the regime, and the withdrawal of the goods must be carried out through an agente aduanal or agencia aduanal (customs agent or customs agency) that holds a current inscription in the registry of certified companies under Article 100-A of the same law.

The shift is easy to underestimate. Before the reform, any active customs agent could process RFE movements. The license itself was sufficient. Now the license alone does not qualify the agency to touch the cargo. The certified-company registration is the gate, and it applies to all three moments that define an RFE operation: bringing goods in, closing the regime, and taking goods out.

The RFE regime itself is the introduction, for a limited time, of foreign, national, or nationalized goods into a strategic bonded facility for handling, storage, custody, exhibition, sale, distribution, or productive processing (Arts. 135-A to 135-D of the Ley Aduanera). When the goods are destined for the domestic market, the regime closes through a definitive import. For a facility that is not adjacent to a customs precinct, that closure is documented with pedimento clave G9 (Anexo 22, Apéndice 2 of the Reglas Generales de Comercio Exterior, the general foreign-trade rules), processed as a virtual operation with two linked pedimentos rather than a physical presentation at the border.

The dates that matter

This is not a proposal still working its way through committee. The decree was published in the DOF on November 19, 2025, and entered into force on January 1, 2026, with specific provisions deferred by transitory articles.

One of those deferred provisions matters directly for RFE operators: the obligation to guarantee the applicable contributions through a customs guarantee account (including authorized letters of credit) when goods are destined to RFE for handling, storage, custody, exhibition, sale, or distribution takes effect three months after the reform's entry into force. So the operating picture in 2026 is layered. The certification requirement governing who can move the cargo is already live, and a second wave of obligations around financial guarantees and reinforced inventory control phases in through the first part of the year.

The trap most operators have not checked

On paper, the importer holds the RFE authorization and assumes the operation continues exactly as it did in 2025. In practice, the legal capacity to clear, conclude, and withdraw now depends on the agency's certification status, not on the importer's own authorization. That gap is the trap.

A company can be fully compliant in its own RFE authorization and still be unable to legally move a single unit out of the facility, simply because the agency processing the operation lapsed in its certified-company registration or never held it for this specific regime. The exposure does not announce itself until the moment a conclusion or withdrawal has to happen.

It helps to be precise about what the registry is, because the requirement is often repeated loosely as "only OEA agencies can do it," and that is not quite what the law says. The certified-company registry (Registro en el Esquema de Certificación de Empresas) under Article 100-A has four modalities defined in RGCE regla 7.1.1: IVA e IEPS, Comercializadora e Importadora, Operador Económico Autorizado (OEA, the authorized economic operator program), and Socio Comercial Certificado (SCC, the certified trade partner). For a customs agency, the relevant paths are SCC and OEA, both aligned to the World Customs Organization's SAFE Framework. OEA is the highest tier, internationally recognized through mutual-recognition arrangements, and the RGCE even contemplates a dedicated OEA rubro for the RFE regime (regla 7.1.4). The legal minimum is a current certified-company registration; OEA is the strongest form of it.

Consider a consumer-goods importer running a non-adjacent RFE in northern Mexico. It assumed its long-standing agency would handle the early-2026 operations the way it always had. The agency's certified-company registration had quietly lapsed mid-renewal. The importer discovered this the same week it needed to withdraw units for the domestic market, with the goods already committed to buyers. The regime could not be concluded until the certification question was resolved. Nothing in the importer's own file was wrong. The problem lived entirely on the agency side, where the operator had never thought to look.

Quick check: Pull your agency's certified-company registration status and its modality (OEA or Socio Comercial Certificado), and confirm both are current and cover the RFE regime. If your team cannot produce that confirmation in five minutes, that is your gap.

The operational plan to close the gap

Four moves close the exposure, and none of them require waiting for a regulatory clarification.

1. Verify that your customs agency's certified-company registration under Article 100-A is current, and identify the modality it holds.
2. Confirm the registration actually covers RFE operations, not just a general certification. The regime-specific scope is what the reform points to.
3. Map your upcoming RFE conclusions and withdrawals against the certification's validity window, so no scheduled operation falls inside a renewal lapse.
4. Build the documentary trail the reform now demands around the regime: technical and accounting evidence that the goods were genuinely subject to the declared process, an Anexo 24 inventory control system that is updated and operating permanently, and, for a non-adjacent RFE, transport handled through a carrier listed in the empresas transportistas registry.

In our work across the corridor, the operations that absorb a change like this without a stopped withdrawal are the ones whose agency was already certified before the law required it. Joffroy operates under OEA certification, the highest tier of the Article 100-A registry, across 39+ ports and more than 190,000 customs operations a year. The certification was never a marketing badge for us; it was the operating standard that the 2026 reform has now written into the law for anyone who wants to move RFE cargo.

The reform turned a credential most importers never asked about into a precondition for moving their own goods. From 2026 forward, the question your operation answers before every RFE conclusion is no longer only whether the duties were calculated correctly. It is whether the agency touching the cargo is certified to do so today. Build that check into the routine, and the regime keeps moving.

Talk to a Joffroy expert about confirming your RFE certification readiness before your next conclusion or withdrawal.

TRADE. UNDER CONTROL.