COMEX opens sanctioning process against 23 companies under the Inward Processing Relief scheme

The Minister of Foreign Trade ordered the opening of an administrative procedure against 23 companies benefiting from the Inward Processing Regime for failing to submit their Annual Operations Reports for the fiscal periods closing on December 31, 2023, 2024, and 2025. The decision is contained in resolution RES-DMR-0148-2026, dated September 8, 2026, at 8:50 a.m., and in resolution DAL-RES-ROD-0042-2026-01 / DAL-EXP-PPA-0002-2026, dated September 9, 2026, at 8:30 a.m., published in La Gaceta No. 186 on Friday, October 2, 2026 (Foreign Trade section, pages 200-205). If non-compliance is proven, the firms could be sanctioned with a fine or the cancellation of the regime.

The procedure is based on Article 182, subsections c) and k), of the General Customs Law, Law No. 7557 of October 20, 1995, and subsections h) and i) of Article 25 and subsections f) and g) of Article 49 of the Inward Processing Regime Regulations, Executive Decree No. 40198-COMEX-H of December 13, 2016. The regulation requires beneficiaries to submit to PROCOMER, within four months following the close of the fiscal period, an annual report with certification of net sales, income statements, and balance sheets. If the report is not submitted, PROCOMER grants 15 business days and then a final notice of 10 business days; Article 49, subsection f), orders the cancellation of the regime when the report is not submitted within six months following the close of the fiscal period.

According to the resolution, PROCOMER communicated the alleged non-compliance to COMEX through the initiation recommendation reports PROCOMER-SIAN-797-2024 (June 18, 2024), PROCOMER-DRE-EXT-0847-2024 (August 8, 2024), PROCOMER-SIAN-618-2025 (June 12, 2025), and PROCOMER-SIAN-467-2026 (July 22, 2026). The file indicates that the SIAN platform shows that both notices were issued without receiving a response. In five cases, due to seniority and inactivity, notification had to be carried out by fax and was delayed until May 27 and June 19.

The notified companies

The resolution identifies 21 legal entities and two natural persons, along with their legal or identity ID numbers:

• Grupo Mayjo JTV S.A. (formerly Inversiones Empresariales Mayjo IEMX, S.A.), 3-101-269319
• Implastic S.A., 3-101-244902
• Instalaciones Industriales M A & Asociados S.A., 3-101-233341
• Guiselle Del Carmen Chacón Rodríguez, 9-0088-0197
• Calidad Textil Internacional INT C.T.I. S.A., 3-101-183195
• Mecanizados Técnicos S.A., 3-101-174955
• Modas Mariell de Heredia, 3-101-231718
• Monoceros S.A., 3-101-245167
• Geoproductos de Costa Rica S.A., 3-101-650608
• HA Paper & Board Central América S.A., 3-101-385950
• Han Shuo S.A., 3-101-331149
• Industrias Atlanta Inatla S.A., 3-101-086654
• Industrias Textiles El Curú S.A., 3-101-062738
• Industrias Zona Trópico Ltda., 3-102-109339
• Inversiones Eduexpor, S.A., 3-101-293420
• Inversiones Mora Kinch, S.A., 3-101-229745
• Irazú Electronics, S.A., 3-101-391626
• Lacure Corporate And Leisure S.A., 3-101-366856
• Macaribe S.A., 3-101-128221
• Machinary And Industrial Services MYS S.A., 3-101-530731
• Manufacturera WR Alajuela S.A., 3-101-301059
• Mint Of Costa Rica S.A., 3-101-571572
• Lavon Von Wiellighle Roux, 8-0056-0408

The charge and possible sanctions

The only charge filed is non-compliance due to the failure to submit the Annual Operations Report for the periods ending December 31, 2023, 2024, and 2025. The resolution warns that the final act could impose administrative liability, with a fine or cancellation of the regime, depending on the severity of the offense and the degree of fault.

To determine the sanction, COMEX will assess the severity, the degree of fault or intent of the representatives of each company, and recidivism. A motion for reconsideration may be filed against the imposition of sanctions before the head of COMEX within five business days following notification.

Appearance and defense deadlines

The Directing Body of the procedure, led by María Vanessa Videche Muñoz, lawyer of the Legal Advisory Directorate, with Ana Gabriela Mora Castro as alternate, summoned the companies to an oral and private appearance:

• Tuesday, December 8, 2026, from 8:00 to 16:30 hours, for 16 companies.
• Wednesday, December 9, 2026, from 10:00 to 12:00 hours, for the remaining companies.
• Location: Appearance Room of the Legal Advisory Directorate of the Ministry of Foreign Trade, third floor of the Plaza Tempo Building, adjacent to Hospital CIMA, Escazú.
• The hearing may be conducted virtually with the express consent of the legal representative.
• Companies have three business days to offer exculpatory evidence and may provide it during the appearance.
• Motions for revocation and appeal may be filed against the resolution within 24 hours following notification.

The publication is made by edict, on three consecutive occasions, due to the impossibility of notifying the registered corporate address, in accordance with Article 241 of the General Law of Public Administration, No. 6227. The case affects textile, plastic, paper, and electronics firms, and puts at stake not only a potential fine, but the permanence in a regime that allows the importation of raw materials with exemptions and tax suspensions: cancellation would imply losing those benefits and closing the protected operations.

Source: La Gaceta No. 186, Friday, October 2, 2026, Foreign Trade section, pp. 200-205 (official reference: RES-DMR-0148-2026 / DAL-RES-ROD-0042-2026-01 / DAL-EXP-PPA-0002-2026).