November 3, 2025

The Ministry of Economy published in the evening edition of the Official Gazette of the Federation on October 29, 2025, the “Agreement amending the one that establishes the goods whose importation is subject to regulation by the Ministry of Labor and Social Welfare (STPS)”.
This new Agreement updates the procedure established in February 2023, which aims to restrict the importation of goods produced wholly or in part through forced or compulsory labor, including child labor, in compliance with Article 23.6 of the United States-Mexico-Canada Agreement (USMCA).
The amended agreement strengthens the powers of the STPS, which may now initiate investigations ex officio or upon request, and simplifies the filing process, allowing applications to be submitted in person, by email, or through the Digital Window. It also clarifies the minimum requirements to initiate an investigation and the response timelines applicable to the authority, thus providing greater legal certainty to individuals or entities reporting the use of forced labor in the production of goods.
From a labor standpoint, this reform reinforces Mexico’s national and international policy to eradicate forced and child labor, consolidates the STPS’s role as an investigative authority in matters related to labor compliance and international trade, and requires importing companies to verify labor conditions throughout their supply chains, implementing labor due diligence practices.
The Agreement enters into force on October 30, 2025, and the STPS will have 180 calendar days to issue the necessary regulatory and administrative adjustments for its implementation.
The Labor and Foreign Trade Law Practice Groups remain at your disposal for any questions or comments regarding this communication.
This newsletter was prepared with the support of Ana Sofia Lazcano.
Sincerely,
Jorge A. de Presno Arizpe
jorgedepresno@basham.com.mx
David Eugenio Puente Tostado
dpuente@basham.com.mx
Luis Antonio Álvarez Cervantes
lalvarez@basham.com.m
Sergio Barajas
barajas@basham.com.mx