Annex 24: Is Your Inventory Control Audit-Ready?
For an IMMEX company, Annex 24 should not be treated as just another administrative requirement.
The inventory control system is a key element to demonstrate the traceability of temporarily imported goods: entries, exits, discharges, returns, changes of customs regime, transfers, scrap, waste, fixed assets, and balances.
The problem is that many companies believe they are covered because they “have Annex 24.” But during a review, the question is not only whether a system exists.
The real question is: Does that system accurately reflect the operation?
Having a system does not mean having control
A system may exist and still fail to support an audit.
This happens when the information is incomplete, updated late, dependent on manual adjustments, or inconsistent with the physical inventory.
In an authority review, the risk is not only failing to have Annex 24. The risk may also be having an Annex 24 system that cannot explain the operation.
Warning signs
A company should review its Annex 24 if it identifies any of the following situations:
- The system balances do not match the physical inventory.
- There are pending discharges or manual discharges without clear traceability.
- Imports and exports are uploaded late.
- Rectifications, changes of customs regime, or transfers are not properly reflected.
- There is no clear control over temporarily imported fixed assets.
- The trade, warehouse, production, and tax teams work with different information.
- The system cannot reconstruct the relationship between the pedimento, material, finished product, and return.
- There are no reliable reports of current, expired, or soon-to-expire balances.
- The team depends on one single person to explain the system.
These situations do not always mean non-compliance, but they do indicate exposure.
And during an audit, documentary exposure can turn into observations, requests for information, or contingencies.
The key question
An IMMEX company should be able to clearly answer:
What goods did we temporarily import, where are they, how were they used, what was returned, and what balance remains pending?
If the answer depends on reviewing multiple files, requesting information from the customs broker, consulting different departments, or performing last-minute reconciliations, the control may not be ready for a review.
How can TradeWorks help?
At TradeWorks, we help IMMEX companies assess whether their Annex 24 accurately reflects their operation.
We can support with Annex 24 diagnostics, balance reconciliation, discharge reviews, gap identification, validation of documentary information, and strengthening of traceability.
The goal is not only to have a system, but to have updated, reconciled, and defensible information in the event of a review.
Does your Annex 24 withstand an audit?
Schedule a preventive review with TradeWorks and confirm whether your balances, discharges, and inventories are aligned with your actual operation.