What documents could a Texas purchaser use to prove that multiple items were exported to its Mexican maquiladora?

Plain-English summary

The requester bought goods in Texas for export to a maquiladora in Tamaulipas and had trouble obtaining item-level export identification. The letter confirmed that the maquiladora permit was issued to the Mexican counterpart, not the Texas counterpart.

The Comptroller required specific proof of export. The letter identified U.S. Customs certifications and Mexico's formal entry document, the Pedimento de Importaciones. Because the Pedimento listed weight and value but not a goods description, the letter suggested incorporating truck manifests or invoices as attachments.

For goods valued below $1,000, a properly completed Manifesto could also serve as proof, but its quantity and merchandise descriptions had to be specific.

What this means for you

General evidence that goods crossed the border was not enough. The documentation needed to connect the Texas-purchased items to the export transaction with specific descriptions and quantities.

Common questions

Who held the maquiladora permit? The Mexican counterpart.

Could a Pedimento support the export claim? Yes, potentially with manifests or invoices attached to supply item descriptions.

When could a Manifesto be used? For goods valued under $1,000, according to the letter.

Citations and references

The letter cited no numbered Texas statute or rule.

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/9107L1122B13

Original ruling text

July 24, 1991

Dear *:

This is written in response to our telephone conversation Friday,
July 19, 1991, regarding purchases in Texas by *, for export
into Mexico to your maquiladora plant (**) in *,
Tamaulipas, Mexico.

It is correct information that the Mexican counterpart of the
maquiladora is issued a maquiladora permit, not the Texas counterpart.

You explained to me that * is encountering problems
obtaining proper identification of exports containing multiple
items (to take back to suppliers for tax refunds). And U.S.
Customs only requires items over $2,500 to be listed on the
Shippers Export Declaration.

The Comptroller's office does not wish to impose unreasonable
burdens on any industry, but we are limited by the parameters of
the law itself. The law requires very specific documents to prove
export. The U.S. Customs certifications are one, which you say
you have been using, and import documents such as Mexico's formal
entry document, the "Pedimento de Importaciones". The "Pedimento"
seems the most likely one of your situation.

The "Pedimento de Importaciones" gives the weight and dollar
value, but not a description of the goods. Possibly, customs
officials could work directly off the truck manifest and/or your
invoices and incorporate that as an attachment to the
"Pedimento".

Another alternative is a properly-completed "Manifesto" which is
acceptable proof of export to Mexico for goods valued at less than
$1,000. You should make certain that the "Cantidad de Mercancias"
and the "Especificacion de las Mercancias" describe the quantity
and merchandise purchased in Texas. The description must be very
specific.

If the acceptable methods above do not work then I will be open to
discuss any other variation which may be acceptable to us both.

This opinion is based on the facts that you presented. If there
are additional or different facts, this opinion may change.

If you have any questions or need more information, you may call
me toll-free at 1-800-532-5441, extension 5-0330. The regular
number is 512/463-4600, or write Tax Administration Division.

Sincerely,

Bettie U. Peterson
Tax Administration Division