COMEX opens sanctioning process against 23 companies under the Inward Processing Regime

The Ministry of Foreign Trade (COMEX) has opened an administrative procedure against 23 beneficiaries of the Inward Processing Regime for failing to submit their Annual Operations Reports for the fiscal periods ending December 31, 2023, 2024, and 2025. The opening is detailed in resolution RES-DMR-0148-2026, issued at 8:50 a.m. on September 8, 2026, signed by the Minister of Foreign Trade, Indiana Trejos Gallo, and published in La Gaceta No. 188 on Tuesday, October 6, 2026. If the non-compliance is proven, the companies could be sanctioned with a fine or the cancellation of the regime.

The imputed charge and its legal basis

The only charge imputed is non-compliance due to the failure to submit the Annual Operations Report for the periods with fiscal closing on December 31, 2023, 2024, and 2025. The resolution invokes articles 182 paragraphs c) and k) of the General Customs Law, Law No. 7557 of October 20, 1995, as well as paragraphs h) and i) of article 25 and paragraphs f) and g) of article 49 of the Regulations of the Inward Processing Regime, Executive Decree No. 40198-COMEX-H of December 13, 2016.

According to these regulations, beneficiaries must submit an annual operations report to PROCOMER within four months following the close of the fiscal period; if they fail to do so, the Promoter grants a period of 15 business days and, subsequently, a final notice of 10 business days. The resolution indicates that, although it is recorded in the SIAN platform that both notices were issued, the companies did not respond.

The case file is based on four recommendation reports from PROCOMER:

• PROCOMER-SIAN-797-2024, dated June 18, 2024 (2023 period).
• PROCOMER-DRE-EXT-0847-2024, dated August 8, 2024.
• PROCOMER-SIAN-618-2025, dated June 12, 2025 (2024 period).
• PROCOMER-SIAN-467-2026, dated July 22, 2026 (2025 period).

The notified companies

The resolution orders the initiation of the procedure against the following beneficiaries, along with their corporate or identity IDs:

• 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.

Appearance, deadlines and defense

The Directing Body of the procedure is María Vanessa Videche Muñoz, Esq. (ID 1-0940-0705), attorney of the Ministry’s Legal Advisory Directorate, with Ana Gabriela Mora Castro, Esq. (1-0974-0358) as alternate. Resolution DAL-RES-ROD-0042-2026-01 (DAL-EXP-PPA-0002-2026), dated September 9, 2026, summons the companies to an oral and private appearance in the Hearing Room of the Legal Advisory Directorate, third floor of the Plaza Tempo Building, adjacent to the CIMA Hospital, on the Próspero Fernández Highway, Escazú.

• Tuesday, December 8, 2026: staggered appointments from 08:00 hours (Grupo Mayjo JTV S.A.) until 16:30 hours (Lacure Corporate and Leisure S. A.).
• Wednesday, December 9, 2026: Macaribe S. A. (10:00), Machinary and Industrial Services MYS S. A. (10:30), Manufacturera WR Alajuela S. A. (11:00), Mint of Costa Rica S.A. (11:30) and Lavon Von Wiellighle Roux (12:00).

Companies have three business days to offer exculpatory evidence and may appear personally, through a proxy, or via virtual hearing. Motions for reconsideration and appeal may be filed against the resolution within 24 hours following its notification.

Scope of the measure

The resolution warns that PROCOMER will precautiously suspend the processing of all procedures covered by the regime—transit or transfer of materials and goods, exemptions, and other operations—and will communicate this to the Control Customs and the General Directorate of Finance, without prejudice to the eventual revocation of the regime. It also orders that the resolution be communicated to the Ministry of Finance and PROCOMER, and that the Central Bank of Costa Rica be granted electronic access to the annual operations report for statistical purposes.

The case affects a group of textile, metal-mechanical, agro-industrial, and service companies that have been under the regime since 1992, several of them with decades of operation. The eventual cancellation of the regime would imply the loss of the exemptions under Article 20 of the Free Trade Zone Regime Law, Law No. 7210, with a direct impact on the investment and employment commitments that these beneficiaries maintain with PROCOMER.

Source: La Gaceta, No. 188 of October 6, 2026, Foreign Trade section, pp. 169-176 (official reference: RES-DMR-0148-2026 / IN202601127692).