Mexico Annex 2.4.1 Update: New HS Codes for Mobile Devices
Mexico Annex 2.4.1 Update: SE Adds Five HS Codes for Smartphones and Mobile Terminals to NOM-221 Customs Compliance
On September 28, 2026, Mexico's Secretaría de Economía (SE) published an agreement in the Diario Oficial de la Federación (DOF) that modifies the Acuerdo por el que la Secretaría de Economía emite Reglas y criterios de carácter general en materia de comercio exterior. The amendment targets numeral 1 of Annex 2.4.1, commonly known as the NOM Annex. This annex lists the tariff classifications whose products must show compliance with Official Mexican Standards (NOMs) at the point of import.
For the telecommunications sector, the most significant change is that five HS tariff codes under heading 8517 are now linked to NOM-221-SCFI-2017 and NOM-221/2-SCFI-2018. As a result, smartphones, other mobile phones and connected terminal equipment classified under these codes must demonstrate NOM-221 compliance when they clear Mexican customs.
Regulatory Background: Annex 2.4.1 and the NOM Annex
Annex 2.4.1 is the tool Mexico uses to enforce technical regulations at the border. When a tariff code appears in numeral 1 of the annex next to a specific NOM, importers must demonstrate compliance with that NOM for the goods to clear customs. The SE amends the annex regularly. Earlier modifications to the foreign trade rules were published in 2026 on February 12, April 2 and late May.
According to the SE, this latest amendment aims to close regulatory gaps in mass-market and industrial products. It is also intended to protect consumers and reinforce compliance with national standards. The agreement was reviewed by the Foreign Trade Commission (Comisión de Comercio Exterior) under Article 17 of the Foreign Trade Law.
Mexico Annex 2.4.1 Update: HS Codes Added to NOM-221
The agreement adds the following tariff codes to NOM-221-SCFI-2017 and NOM-221/2-SCFI-2018:
HS Code | General Product Scope |
8517.13.01 | Smartphones |
8517.14.91 | Other mobile/cellular telephones |
8517.18.99 | Other telephone sets |
8517.62.17 | Apparatus for reception, conversion and transmission of data (terminal equipment) |
8517.69.99 | Other transmission/reception apparatus |
What NOM-221 Requires
NOM-221-SCFI-2017 (Part 1) sets specifications for mobile terminal equipment that can use the radio spectrum or connect to telecommunications networks. It covers two areas:
The IMEI (International Mobile Equipment Identity) code
The FM broadcast receiver functionality
NOM-221/2-SCFI-2018 (Part 2) sets technical specifications for mobile terminals operating in the 700 MHz, 800 MHz, 850 MHz, 1900 MHz, 1700/2100 MHz and/or 2500 MHz bands.
Together, these standards help ensure that mobile devices sold in Mexico can be properly identified on networks and operate correctly in the country's authorized frequency bands.
Other Products Covered by the Same Agreement
The agreement also extends NOM enforcement to two non-telecom product groups:
NOM-033-ENER-2019 (energy efficiency): This covers air-cooled alternating-current electric motors with a rated output of at least 1 W and below 180 W. The affected codes fall under HS headings 8501.10, 8501.20, 8501.40 and 8501.51, in some cases limited to specific NICO subdivisions.
NOM-012-CONAGUA-2021 (water supply products): This covers PVC pipes, flexible tubes, rubber hoses, stainless steel sinks and washbasins, and multiple subheadings of 8481 covering valves, faucets and fittings for drinking-water installations.
Certification Impact Summary
Aspect | Before the Amendment | After the Mexico Annex 2.4.1 Update |
Customs linkage for HS 8517.13.01, 8517.14.91, 8517.18.99, 8517.62.17, 8517.69.99 | Not linked to NOM-221 in Annex 2.4.1, numeral 1 | Linked to NOM-221-SCFI-2017 and NOM-221/2-SCFI-2018 |
Point of verification | Compliance not checked at customs under these codes | NOM-221 compliance must be demonstrated at the point of entry |
Technical scope | Unchanged | IMEI, FM receiver functionality (Part 1); band-specific operation (Part 2) |
Effective date (NOM-221 provisions) | — | 30 business days after DOF publication (estimated early-to-mid November 2026) |
Effective date (all other provisions) | — | September 29, 2026 |
Risk of non-compliance | — | Shipments may be held or rejected at customs |
What This Means for Manufacturers
For mobile device manufacturers, brand owners and importers, the Mexico Annex 2.4.1 update turns NOM-221 from a product obligation into a customs clearance requirement for the listed HS codes. The main practical effects are:
Border enforcement is now explicit. Customs authorities can verify NOM-221 compliance at import for goods under the listed codes. Products without valid evidence of conformity may be delayed or refused entry.
HS classification becomes a compliance decision. A product's tariff code now determines whether NOM-221 applies at customs. Manufacturers should check how each SKU is classified, especially data terminals, modules, routers and hybrid devices that could fall under 8517.62.17 or 8517.69.99.
Existing type approvals are not enough on their own. Telecom type approval and NOM-221 conformity are separate evidence requirements. Manufacturers should confirm that their certification portfolio covers both where applicable.
Shipments near the deadline carry the highest risk. Goods in transit that arrive after the NOM-221 provisions take effect will be subject to the new requirement. The date of shipment does not matter.
Supply-chain coordination matters. Customs brokers, distributors and logistics partners need updated documentation and HS code mappings ahead of the deadline.
Timeline and Required Actions
Key Milestones
Date | Milestone |
September 28, 2026 | Agreement published in the DOF |
September 29, 2026 | Agreement takes effect (all provisions except NOM-221) |
November 9–10, 2026 | NOM-221-SCFI-2017 and NOM-221/2-SCFI-2018 provisions take effect (30 business days after publication) |
Required Actions for Manufacturers and Importers
Immediately (September–October 2026)
Review the product portfolio and identify all SKUs classified under HS 8517.13.01, 8517.14.91, 8517.18.99, 8517.62.17 and 8517.69.99.
Validate HS classification with your customs broker and document the rationale for each product.
Check whether valid NOM-221-SCFI-2017 and NOM-221/2-SCFI-2018 certificates exist for each affected model.
Before the NOM-221 effective date
Start certification with an accredited certification body for any affected model without valid NOM-221 evidence, allowing time for testing.
Confirm that each device meets the IMEI requirements, FM receiver functionality requirements (where applicable) and band-specific specifications.
Share certificates and updated HS code mappings with customs brokers and importers of record.
Review shipment schedules so goods arriving after the deadline are fully documented.
Ongoing
Monitor further amendments to Annex 2.4.1, which the SE updates several times a year.
Include HS classification reviews in new product introduction workflows for the Mexican market.
Conclusion
The Mexico Annex 2.4.1 update brings NOM-221 compliance to the customs border for smartphones, mobile phones and connected terminal equipment. Companies have a short window before the NOM-221 provisions take effect. Now is the time to audit classifications, close certification gaps and align supply-chain partners so that shipments to Mexico are not disrupted.
