COMEX opens sanctioning process for 23 companies under the Active Improvement regime

The Ministry of Foreign Trade (COMEX) initiated an administrative procedure against 23 companies and natural persons benefiting from the Inward Processing Regime for failing to submit the Annual Operations Reports for the fiscal years ending December 31, 2023, 2024, and 2025. The opening is detailed in Resolution RES-DMR-0148-2026, dated September 8, 2026, at 8:50, signed by Minister Indiana Trejos Gallo and published in La Gaceta No. 187 on Monday, October 5, 2026 (reference IN202601127692). If the failure is proven, the beneficiaries 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 Foreign Trade Promoter of Costa Rica (PROCOMER) submitted four recommendation reports to initiate the procedure to COMEX: 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).

According to the resolution, PROCOMER’s Directorate of Special Regimes applied the two warnings from Article 25 in each case—a period of 15 business days and a final warning of 10 business days—without receiving a response from the companies. Article 49, subsection f), of the regulations empowers COMEX to cancel the regime when the report is not submitted within six months following the close of the fiscal period.

The cited beneficiaries

The resolution identifies the following companies and natural persons, along with their legal or identity ID:

• 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

Oral Appearance and Deadlines

The oral and private appearance will take place in the Appearance Room of the Legal Advisory Directorate of COMEX, third floor of the Plaza Tempo Building, adjacent to Hospital CIMA, on the Próspero Fernández Highway, Escazú:

• Tuesday, December 8, 2026, from 08:00 to 16:30 hours, with 18 staggered summons every 30 minutes.
• Wednesday, December 9, 2026, from 10:00 to 12:00 hours, with five summons.

Companies may appear in person or through a proxy and may request a virtual hearing. They are granted a period of three business days to offer exculpatory evidence, and the resources of revocation and appeal may be filed against the resolution within the following 24 hours of notification. The presiding officer is María Vanessa Videche Muñoz, Esq. (ID 1-0940-0705), with Ana Gabriela Mora Castro (1-0974-0358) as alternate.

Publication and Effects

The resolution is published because it was not possible to notify it at the registered social domicile with the Administration on three consecutive occasions, pursuant to Article 241 of the General Law of Public Administration, Law No. 6227. The full text of Resolution RES-DMR-0148-2026 and Resolution DAL-RES-ROD-0042-2026-01 / DAL-DAL-EXP-0002-2026 (8:30 on September 9, 2026) appears in the same edition.

The process is important because the Inward Processing Regime grants exemptions and customs facilities to exporters, and its cancellation would imply the loss of those benefits. Furthermore, the regulation provides that PROCOMER shall precautiously suspend the procedures and benefits of the regime as long as the company does not present the annual report in the required terms.

Source: La Gaceta No. 187, Monday, October 5, 2026, Foreign Trade Section, pages 176-183 (official reference: IN202601127692).