Letter from the table: A threshold must not become an exemption

RC/TR/2026/T.8 · Letter from the table

To the members of the Trade Council,

I read Lucía’s letter from Lima as an argument that small traders should be protected from new import charges by a size-based threshold. I understand why she asks for that protection. I oppose a blanket exemption from duties or tariffs based only on the size of the importer. It would not solve the problem I keep in my diary: the cost is not only the charge itself. It is finding out, too late, what the charge will be and what steps are required to clear the goods.

On 4 March, I asked for a landed-cost estimate for a small shipment. The invoice value, converted into pesos for my planning, was MXN 61,200. I set aside MXN 11,600 for the import charges shown in the estimate. On 11 March, after the documents had been reviewed, I was told to prepare MXN 18,900. The revised figure was not accompanied by a clear breakdown that let me reconcile the difference. I had to ask which amounts were duty, which were taxes, and which were service or handling charges. The final cost was not a single surprise; it was several unanswered questions arriving together.

In Mexico, the duty depends on the tariff classification and, where relevant, the origin of the goods and the rules that apply to that origin. The import VAT is generally 16%, with its taxable base affected by the customs value and other applicable amounts. A customs broker prepares the import declaration, or pedimento, through the customs process. Depending on the goods, permits or supporting documents may also need to be handled through the VUCEM single window. I do not claim that every small importer faces the same rate or the same documents. That is exactly why a useful estimate must show the assumptions it uses.

I tried to make the estimate usable. I sent the commercial invoice and the product description again, asked whether the tariff classification had been confirmed or was provisional, and requested the exchange-rate basis and a line-by-line account of duties, taxes, broker charges and other fees. I also asked what document, if any, was still missing. The answers came in fragments. I could make a payment decision only after comparing messages and doing my own arithmetic, without knowing whether I had understood the same basis as the broker.

Lucía’s concern is real, but exempting small importers from a charge because they are small could create a second problem. Two traders importing the same goods under the same conditions could face different tariff treatment because one crossed a business-size line and the other did not. A threshold may also create an incentive to split orders or shipments. And if the relief applies only to the duty, the small trader may still be left with the documentation, VAT, broker charges and uncertainty that make a shipment difficult to plan. I do not want our answer to promise protection and then leave the hardest part untouched.

I would support thresholds for administrative requirements where the law allows them, along with plain-language guidance and a phase-in when new rules take effect. But I oppose using a size threshold as a general exemption from the tariff itself. The Trade Council should keep those ideas separate in its draft. A small-trader standard can ask authorities and service providers to explain what applies, when it applies, and how the estimate was calculated without claiming that every small business should pay a different duty.

For forwarders and customs brokers, the practical change should be specific. A landed-cost estimate should identify the date and assumptions; the declared customs value and currency basis; the proposed tariff classification and whether it is confirmed; the origin basis used; estimated duty and taxes as separate lines; service and handling charges; and any missing documents or unresolved decisions. If the estimate changes, the customer should receive the reason and the revised calculation before being asked to pay, except where a legal deadline or immediate customs decision makes that impossible. The estimate should say plainly what is known, what is provisional and who must confirm it.

A phase-in should also give a small trader time to act. If a new tariff, document or filing requirement begins, guidance should be available before the effective date, with a reasonable transition for shipments already ordered or in transit where legally possible. This would not remove a valid charge. It would let a trader price an order, decide whether to proceed, and avoid learning the rule only when the goods are already moving.