On July 1, 2026, the first mandatory joint review of the United States-Mexico-Canada Agreement (USMCA) was completed. Because the agreement was not automatically renewed, it introduced a new level of regulatory uncertainty that will directly affect investment planning, the development of regional supply chains, and ultimately, the profitability of manufacturing operations in Mexico. For executives leading these operations, the question is: what are they doing today to prepare?
Regulatory complacency—reflected in fragmented controls, isolated spreadsheets, and decentralized compliance functions—has become a major operational risk. Companies operating in Mexico can no longer limit themselves to speculating about the outcome of trilateral negotiations. They must immediately assess their internal ability to demonstrate strict, traceable regulatory compliance in response to official requirements. Proactive preparation is the strongest defense against tax, customs, labor, and environmental risks that could jeopardize preferential access to the U.S. market.
When it comes to the USMCA, the Chief Financial Officer (CFO) is on the front line of protecting the company’s profit margins. The first action every CFO should immediately validate is the implementation of systematic preventive audits covering the company’s foreign trade operations from the past 24 months, with particular attention to the accuracy of the Certificates of Origin issued by the company.
Under the agreement’s self-certification framework, Certificates of Origin are formal declarations that require companies to retain and support the corresponding technical documentation for a minimum of five years, in accordance with Article 5.2 of the USMCA. An error in assigning the origin criterion or using an outdated tariff classification can result in fines ranging from 130% to 150% of the unpaid duties at Mexican customs, in addition to retroactive tariff assessments and interest in the United States.
The CFO must make sure the company can clearly show that its finished products meet the USMCA’s regional content requirements. This means keeping accurate records of how much of a product’s value comes from North America and documenting the calculation method used under the agreement.
At Prodensa, we provide specialized tax and customs compliance services, including preparation for internal and external audits, implementation of compliance standards, and management of tax and VAT reporting for manufacturing environments, with particular expertise in the IMMEX program.
For the Chief Operating Officer (COO), the priority during the USMCA’s ongoing review phase is to strengthen the physical and documentary traceability of the supply chain, ensuring the “materiality” of every transformation process carried out in Mexico. Modern customs authorities rely on data cross-checking and computerized risk analysis, which means documentation should no longer be organized only by individual customs transactions or import declarations. Instead, companies should maintain permanent, structured records by SKU or product family.
In addition, the COO should immediately oversee compliance with the specific rule of origin for steel and aluminum known as the “melted and poured” requirement. Under the agreement and recent U.S. trade measures issued in 2025 and 2026, industries that use metals in their production processes must certify through Mill Test Reports that the raw metal was originally melted and poured in North America in order to qualify for preferential tariff treatment or avoid Section 232 tariffs.
Labor and union compliance in Mexico is no longer just an HR issue—it can directly affect a company’s ability to export. Under the USMCA’s Rapid Response Labor Mechanism (RRLM), individual facilities in Mexico can be investigated when there are concerns about workers’ rights, including freedom of association and collective bargaining.
In some cases, these disputes can result in trade restrictions. Here some examples:
To reduce labor and outsourcing risks, executives should make sure that external and specialized service providers maintain an active REPSE registration. Working with an unregistered provider can expose the company to social security, housing, and tax liabilities. As a REPSE-registered provider, Prodensa supports companies with payroll and HR management while helping them remain compliant with Mexico’s labor and tax requirements.
Following the July 1, 2026 agreement and the shift toward annual USMCA reviews, companies should move from fragmented compliance controls to a more integrated, digital approach with direct oversight from the CFO and COO.
For executives looking to better understand these changes and prepare their organizations for what comes next, download “USMCA 2026: What Executives Need to Know (Before Everyone Else)” for a deeper look at the strategic, operational, and financial implications of this new phase of the agreement.
In an environment where every decision matters, having a strategic partner that understands Mexico’s regulatory landscape can make a significant difference. With four decades of experience across consulting, industrial real estate, and operations, Prodensa helps executives turn compliance from a potential risk into a sustainable competitive advantage.
Regional Value Content (RVC): The percentage of a product’s value that comes from North America and helps determine whether it qualifies for preferential treatment under the USMCA.
Certificate of Origin: A formal declaration used to prove that a product meets USMCA origin requirements. Companies must keep the supporting technical records for at least five years.
Annex 24: Mexico’s customs inventory control requirement for companies operating under IMMEX. It helps track temporary imports, material consumption, and inventory balances.
Rapid Response Labor Mechanism (RRLM): A USMCA mechanism that allows labor complaints involving specific facilities in Mexico to be investigated and, in certain cases, may affect their ability to export.
REPSE: Mexico’s registry for companies providing specialized services. Businesses should verify that their service providers maintain an active registration to reduce labor, social security, and tax risks.
CFOs should prioritize preventive audits of recent foreign trade operations, with particular attention to Certificates of Origin, tariff classifications, and Regional Value Content calculations.
Because customs authorities increasingly rely on data analysis and cross-checking. Companies need consistent records across ERP systems, Annex 24, physical inventory, and official customs data.
Under the USMCA’s Rapid Response Labor Mechanism, labor-rights concerns at a specific facility can trigger investigations and, in certain cases, trade restrictions.
Working with specialized service providers that do not have an active REPSE registration can expose companies to labor, social security, and tax liabilities.