RLFPPI 2026: Comparative Analysis vs. the 1994 RLPI
Article-by-article comparison of the new Regulation of the LFPPI (published April 28, 2026) vs. the 1994 RLPI. Substantive, procedural, and jurisdictional changes, removals, and additions.
Key Reading
The RLFPPI does not merely fill gaps: it redistributes. It replaces the 1994 RLPI after six years of operating as a supplementary framework for a law that had already surpassed it.
On April 28, 2026, the Mexican Official Gazette (DOF) published the new Regulation of the Federal Law for the Protection of Industrial Property (RLFPPI), just twenty-five days after the law itself was reformed in over two hundred articles. This text reorganizes administrative criteria, formalizes practices that operated for years without an express regulatory basis, and redistributes procedural burdens across patents, trademarks, contentious proceedings, digital enforcement, and technology transfer.
The consequence of this lag is documented in the comparative table accompanying this entry. The new regulation does not consolidate or attempt to hide gaps as in the past: it redistributes. It replaces the 1994 Regulation of the Industrial Property Law (RLPI), which for six years functioned as a supplementary framework for a law that had already largely outgrown it.
Those representing rights for patents, trademarks, industrial designs, appellations of origin, or layout designs with active files should not read this regulation as a mere normative update. It should be read as the moment when various administrative practices sustained by custom finally acquire an express formulation—or are partially unauthorized—and as a new starting point for litigation over discretion, procedural burdens, and regulatory limits.
Utility of the Analysis
This table is designed for three primary uses. First, to quickly identify the correlation between the prior and current articles when a pending case—substantiated under the RLPI by mandate of the Third Transitory Article—faces an authority act based on the updated rule.
Second, to detect implicit changes: those that a plain reading of the text does not reveal and that manifest as new burdens for the individual, expansion or restriction of IMPI's powers, or modification of technical criteria regarding evidence, formalities, and deadlines.
Third, to anticipate lines of constitutional challenge regarding regulatory provisions that exceed the scope of the law or improperly develop conduct that the law did not foresee.
Key Data
4 Entirely New Chapters
Online Infringement, Mandatory Patent Resolution, Technology Transfer Registry, and ADR.
⚠ Automatic Lapse
Art. 119 RLFPPI
Automatic lapse without prior declaration if a renewal requirement is not met within two non-extendable months.
Full Digital Blocking
Art. 170 RLFPPI
IMPI may order the complete blocking of digital media when an alleged infringer is unidentified. Compliance term: 3 days.
COMPARATIVE ANALYSIS: RLPI (1994, last reform 2016) vs. RLFPPI (Official Gazette 2026)
The following table compares, article by article, the 1994 Regulation of the Industrial Property Law (RLPI) against the Regulation of the Federal Law for the Protection of Industrial Property (RLFPPI) published on April 28, 2026. Each entry identifies the detected change, classifies it, and, where appropriate, exposes its operational impact on administrative practice and litigation strategy.
CHAPTER I — GENERAL PROVISIONS
Applications and Filings
| RLPI Art. | RLFPPI Art. | Subject | Detected Change | Type |
|---|---|---|---|---|
| 1 | 1 | Scope of Regulation | Adds that provisions are of "public order and general observance" and apply without prejudice to international treaties. Reinforces mandatory nature. | Substantive change |
| 2 | 2 | Definitions | RLPI only defined "Secretariat." RLFPPI incorporates 10 definitions: Agreement, Collaboration Agreement, Inter-institutional Agreement, Economic Development Centers for Well-being, Current International Classification, Electronic Media, Online Proceedings, Regulation, Secretariat, Electronic Services of the Institute. | Addition |
| None | 3 | Social Focus Programs, Differential Rates, Compliance Badge | Empowers IMPI to establish differential rates, provide training, and grant compliance badges. | Addition / Competence change |
| None | 4 | Inter-institutional Agreements in Trademarks | Enables IMPI to enter into agreements to leverage foreign office examinations and protect signs under Art. 173.VII LFPPI. | Addition / Competence change |
| 3 | 5 | Regulatory Authority of the Director General | Expands authority: now covers online proceedings, criteria, and guidelines. | Competence change |
| None | 6 | Recognition of Electronic Signatures | IMPI may recognize any electronic signature that complies with regulations. | Addition |
| 4 | 7 | Calculation of Terms in Months/Years | Adds express paragraph for online filings and incorporates specific rule for the three-year term of Art. 233 LFPPI (trademark declaration of use). | Addition / Procedural change |
| None | 8 | Additional Terms (Arts. 117, 226, 279 LFPPI) | Clarifies calculation and non-extendable nature. Applicable to online filings. | Addition |
| 4 final para | 9 | Non-working Days | Adds authority to announce "any suspension of institutional operations." | Competence change |
| None | 10 | Official Forms | Full publication in the Gazette + Official Gazette (DOF) + institutional website. Previously (Art. 6 RLPI) only "free copies." | Procedural change / Addition |
| 5 | 11 | General Requirements for Applications | (1) Distinction between physical and electronic filing; (2) signature may be handwritten or recognized electronic; (3) obligation to provide email (Sec. V); (4) distinction between holder, successor, or lien beneficiary status; (5) dismissal for lack of signature; (6) dismissal for failure to exhibit proof of payment after request; (7) express exceptions for administrative declaration and opposition proceedings. | Substantive change + Procedural |
| 5 BIS | 12 | Place of Filing | Replaces "Secretariat delegations or sub-delegations" with "Economic Development Centers for Well-being in the states." Maintains certified mail and courier. | Competence change / Relocation |
| 5 BIS final para | 13 | Calculation of Terms by Filing Method | Maintained. Now with express rule for Development Centers. | Relocation |
| 5 TER | 14 & 15 | One Application per Proceeding + Single Filing for Changes | Split into two articles. Art. 16 mandates individual applications for each patent/registration in notoriety/fame and administrative declaration (nullity/lapse/cancellation/ownership claim) proceedings, and applications per alleged infringer in infringements, as well as per site or establishment if the infringer is unidentified. | Substantive change + New burden |
| None | 16 | Individual Application per Act/Party/Site in Contentious Proceedings | Significant economic burden: multiplies rates in cases with multiple alleged infringers or sites. | Addition / Substantive change |
| 7 | 17 | Receipt and Annotations | Removes Art. 7.d RLPI (date and time annotation). Adds electronic receipt rule. | Procedural change |
| 8 | 18 & 19 | Withdrawal and Non-Resumption | New Art. 18 regulates withdrawal (requires express power of attorney or no stipulation to the contrary, with 2 months to cure). Art. 19 maintains non-resumption rule but expands grounds (dismissed, withdrawn, abandoned, denied, or retracted) and allows exception by authority order. | Substantive change + Addition |
| 9 | 20 | Recordal of Transfers, Name Changes, Mergers | (1) Requires new email; (2) application must be filed by the new holder or representative (previously "any party"); (3) new co-ownership rules for trademarks under Art. 217 LFPPI. | Substantive change |
| 10 | 21 | Recordal of Licenses and Franchises | Maintains essentials. Also regulates "exploitation" (not just use). | Formal change |
| 11 | 22 | Simultaneous Recordal for Multiple Applications/Registrations | Expands catalog: now expressly includes representative accreditation, revocation, transformation of regime, and mergers. Requires certified copy in each file for representative accreditation. | Substantive change |
| 12 | 23 | Request for Non-Compliance in Recordals | Adds that partial responses lead to outright dismissal (not just for total omission). | Substantive change (stricter) |
Notices, Gazette, Representation, Files
| RLPI Art. | RLFPPI Art. | Subject | Detected Change | Type |
|---|---|---|---|---|
| 13 | 24, 25, 26, 27, 28 | Notices | Broken into five articles. Innovations: (i) express rule for Gazette notice as primary method for physical filings; (ii) detailed regulation of electronic notices via electronic board, taking effect upon consultation, and fictional notice on the 15th and last day of each month if not consulted; (iii) personal service at Institute offices, domicile, by court order, or "justified cause"; (iv) terms begin on the business day following service. | Substantive change + Procedural (high impact) |
| 14 | 29 | Gazette | Adds that the Director General will establish characteristics and specifications via Agreement. | Competence change |
| 15 | 30 | Gazette Content | Adds publication of "general interest information on industrial property." | Addition |
| None | 31 | Suspension of Operations in Case of Force Majeure | Enables Gazette publication before the Official Gazette (DOF). | Addition |
| 16 sec. III | 38 | Power of Attorney Accreditation by General Power Registry | Simplified: providing the registry number is sufficient (previously a copy of the certificate). | Procedural change |
| 16 sec. I, II, IV, V | None | Letters of attorney, general, special, authorized powers | Removed from the regulation. Subject to the LFPPI and supplementary law. | Removal |
| 17 | 38, 39 | General Power Registry and Validity | New Art. 39 expressly regulates that certificate validity matches the power of attorney; if not specified, it is subject to common law. | Addition / Substantive change |
| 18 | 32 | File Consultation | Reoriented to administrative declaration files (consultation only by parties and authorized persons), with a duty to preserve confidentiality. | Substantive change |
| 19 | 33 | Return of Original Documents and Objects | Adds express legitimacy for "persons specifically authorized to receive documents." | Procedural change |
| 20 | 34 & 35 | Certified and Simple Copies | (1) Expressly introduces "simple copies" in addition to certified; (2) adds delivery of public versions for classified or personal data; (3) for published applications, any person may obtain copies upon request and payment. | Substantive change / Addition |
| None | 36 | Electronic Certified Copies with E-Signature | Important innovation: electronic certifications have the same evidentiary value as handwritten ones. | Addition |
| 21 | 37 | File Preservation in Any Medium | Adds that IMPI may preserve via third parties, who are obligated to maintain integrity and confidentiality. | Addition / Competence change (possible confidentiality risk) |
CHAPTER II — INVENTIONS, UTILITY MODELS, INDUSTRIAL DESIGNS, AND LAYOUT DESIGNS
| RLPI Art. | RLFPPI Art. | Subject | Detected Change | Type |
|---|---|---|---|---|
| 36 | 40 | Priority Claim | Maintains requirements and adds that, upon failure to provide proof of payment, IMPI will request under Art. 106 LFPPI. Innovation: expressly regulates proof of payment for priority restoration under Art. 42 LFPPI. | Addition |
| None | 41 | Translation of Priority | Express obligation to exhibit Spanish translation. | Addition |
| 22 | 42 | Prior Art (Pending Prior Applications) | Expanded to industrial design registrations (not just patents and utility models). Specifies that denied, withdrawn, retracted, abandoned, or dismissed applications do not form part of the prior art unless already published under Arts. 61, 77, 107 LFPPI or by international treaties. | Substantive change |
| 23 | 43 | Application of Patent Rules to Utility Models | Separates the design regime (now has its own chapter in Arts. 44-46). | Systematic relocation |
| None | 44 | Industrial Designs Not New due to Reproduction of Official Emblems | New rule extending protection of flags, coats of arms, emblems, and names of organizations to designs. | Addition / Substantive change |
| None | 45 | Description of Industrial Design | Requires indicating references to traditional cultural expressions and related traditional knowledge. | Addition |
| 23 para 2 | 46 | Supplementary Application to Designs | Maintains application where appropriate. | No relevant change |
| None | 47 | Prior Disclosure (Art. 52 LFPPI) | New rule: mandates indicating date and means of disclosure upon filing and allows curing omissions during substantive examination. | Addition / Procedural change |
| 24 para 2 | 48 | Divisional Applications | Adds operational definition of "initial application" and requires it to be pending under Art. 102 LFPPI. | Substantive change |
| None | 49 | Divisional Mandated by IMPI | New rule: if IMPI orders division and it is not met, the subject matter is deemed unclaimed and no subsequent voluntary divisional may be filed for it. High litigation impact. | Addition |
| 25 | 50 | Data in Application and Clarifications | Removes the phrase "whose examination and valuation shall be at the Institute's discretion" (remains implicit). | Technical change |
| 26 | None | Exhibition of Specimen/Model of Invention | Removed from the regulation. | Removal |
| 27 | 51 | Formal Rules for Description/Claims/Abstract | Replaces "frames" with "tables." | Technical change |
| 29 | 52 | Claim Rules | (1) Detailed rules on dependent claims removed (Art. 29.VI and VII RLPI); (2) maintains rule for first independent claim and categories. Impact on patent drafting: greater flexibility but less certainty on dependency. | Substantive change (relevant) |
| 33 | 53 | Abstract | Expands preferred length from "100-200 words" to "100-400 words." | Technical change |
| 30 | 54 | Drawings | Expressly adds the possibility of substituting photographs for drawings (voluntary or by request) without adding new matter. | Addition / Procedural change |
| 31 | None | Provisional Drawings | Removed. Now governed by the general regime of Art. 54. | Removal |
| 32 | 55 | Drawings in Utility Models and Designs | No relevant change (updated legal reference). | Relocation |
| 37 | 56 | Biological Material Deposit Requirement | Adds "or set of microorganisms" to the case of the microorganism itself. | Technical change |
| 34 | 57 | Biological Material Deposit Certificate | (1) Removes specific 6-month term (now governed by Art. 111 LFPPI: 2 months); (2) regulates that if exhibited voluntarily or by request and the deposit was prior to filing, the filing date is preserved; otherwise, the exhibition date is recognized. | Substantive change |
| 35 | 58 | Recognition of Deposit Institutions | (1) Replaces IMPI recognition under "internationally accepted criteria" with recognition "disclosed by WIPO"; (2) removes obligation to publish list in the Official Gazette (DOF). | Substantive change / Competence change |
| 28 | 59 | Description Rules | Aligned with Art. 96 LFPPI; regulates section headers. | Technical change |
| None | 60 | Disclosure of Genetic Resources and Traditional Knowledge | New rule of extreme impact: mandates disclosure of country of origin/source for genetic resources and peoples/communities/source for traditional knowledge when the invention is based on them. If unknown, a declaration under oath is required. | Addition (substantive) |
| None | 61 | Request for Failure to Disclose Genetic Resources | If detected during substantive examination that the invention is based on undisclosed genetic resources/traditional knowledge, a 2-month cure period is mandated. | Addition / Procedural change |
| 38 | 62 | Filing Date | Updated legal references and sections. Essence (filing date = date of meeting minimum requirements) is preserved. | Relocation |
| None | 63 & 64 | Provisional Patent Application | New rule aligned with Art. 105 Bis LFPPI. Regulates proof of payment requirement, 5-day cure period, and the rule that additional matter in the "definitive" application does not benefit from the date. | Addition (high operational impact) |
| 39 | 65 | Gazette Publication of Applications | Enriches mandatory content: number, dates, priority, international application, classification, title, abstract, inventor/applicant/representative data, and provisional application data. Includes rules for industrial designs. | Substantive change / Addition |
| None | 66 | Publication of Utility Model/Design Divisionals | New rule: publication only after passing formal examination; no early publication allowed. | Addition |
| 40 | 67 | Early Publication | Requires written request with file number and proof of payment. | Procedural change |
| 41 | 68 | Transformation of Applications | No substantive change; updated references. | Relocation |
| 42 | 69 | Substantive Examination | Adds "nucleotide or amino acid sequence listing" and "biological material deposit certificate" as elements to consider. | Substantive change |
| 43 & 44 | None | Foreign Examination Offices / Patent Granted Abroad | Removed express regulatory regime. Absorbed into LFPPI and inter-institutional agreements (Art. 4 RLFPPI). | Removal / Relocation |
| 45 | None | Specific Procedure for Novelty/Inventive Step | Removed. Replaced by general LFPPI regime. | Removal |
| None | 70 | Restoration of Rights (Art. 113 Bis LFPPI) | New rule: 5-day cure period for omissions; failure to cure leads to dismissal of the restoration petition. | Addition |
| 46 | 71 | Date of Patent/Registration Grant | Maintains primary rule and adds rule for when payment is made within the Art. 16 LFPPI term (5 days). | Procedural change |
| 47 | 72 | Publication of Patent or Registration | Adds that IMPI may provide an electronic link to the issued title. | Addition / Technical change |
| None | 73 | Renunciation of Patent/Registration Right | New rule: mandates express power of attorney (unless no stipulation to the contrary), with a 2-month cure period. | Addition |
| 48 | 74 | Changes in Text/Drawings of Title | Express prohibition added: if intended to expand the conferred protection, rectification is denied. | Addition (substantive) |
| None | 75 | Calculation of Days in Art. 131 LFPPI | Calendar days. | Addition / Clarification |
| None | 76 | Reasonable Delays | Defines what is considered a reasonable delay for Art. 132 LFPPI (compensation for grant delays): terms of eighteen and two months, and time between the end of said terms and the first substantive examination action. | Addition (high impact) |
| 50 | 77 | Compulsory License | Maintained. | Relocation |
| 51 | 78 | Compulsory License Application | Adds email to requirements. | Procedural change |
| 52 | 79 | Layout Designs of Integrated Circuits | No relevant change. | Relocation |
CHAPTER III — TRADEMARKS, SLOGANS, AND TRADE NAMES
| RLPI Art. | RLFPPI Art. | Subject | Detected Change | Type |
|---|---|---|---|---|
| None | 80 | Graphic Representation of Non-Traditional Marks: Sound | Rule for sound marks: representation in staff, description + sample in electronic format. | Addition (substantive) |
| None | 81 | Representation of Olfactory Mark | Chemical description + IUPAC name + physical sample. | Addition |
| None | 82 | Representation of Position Mark | Detailed description of the position on the product and graphic representation with dashed lines. | Addition |
| None | 83 | Representation of Movement Mark | Series of sequential images showing the animation or movement, with description. | Addition |
| None | 84 | Representation of Multimedia Mark | Description + audiovisual sample in electronic format. | Addition |
| None | 85 | Representation of Three-Dimensional Mark | Front, side, top, and bottom views with dashed lines for unprotected parts. | Addition |
| None | 86 | Representation of Holograms | Images showing different viewing angles of the hologram. | Addition |
| None | 87 | Survey or Market Study for Acquired Distinctiveness (Secondary Meaning) | New rule of high evidentiary impact: detailed minimum elements: objective, methodology, sample size and representativeness, statistical analysis, market penetration data, digital platform positioning. | Addition (high evidentiary impact) |
| None | 88-91 | Letters of Consent | New rule. Regulates content, timing of presentation, and the rule that they can only be invalidated by court order. High litigation impact. | Addition |
| 54 | 92 | Legitimate Imports (Exhaustion) | Adds "authorized distributor" in addition to the holder and licensee. | Substantive change (expands parallel trade) |
| 55 | 93 | Economic Group of Common Interest | No relevant change. | No relevant change |
| 59 | 94 | International Classification (Nice) | (1) Mandatory specific class descriptions using Alphabetical List names; (2) introduces "Alphabetical List" and "Supplementary List of Products and Services." | Substantive change / Technical |
| None | 95 | Limitations and Precisions of Products/Services | New rule: holder may limit/specify at any time without increasing scope. Representative must have express powers. | Addition |
| None | 96 & 97 | Collective Mark | New rules: mandates articles of incorporation of the society/association + signed rules of use. | Addition |
| None | 98 & 99 | Certification Mark | New rules: mandates accrediting certification status + signed rules of use. | Addition |
| None | 100 | Survey or Market Study for Notoriety/Fame | New rule with detailed minimum elements: objective, methodology, sample, analysis, signature. | Addition (high evidentiary impact) |
| None | 101 | Rate for Notoriety Declaration | Payment per class. | Addition (economic burden) |
| 67 | 102 | Supplementary Application to Slogans | No relevant change. | Relocation |
| None | 103 | Accreditation of Trade Name Use | New rule: notary public document with specific data (owner, location, line of business, first use date, storefront photos). | Addition (high operational impact) |
| 67 | 104 | Supplementary Application to Trade Names | No relevant change. | Relocation |
| 56 | 105 | Data in Trademark Application | (1) Must indicate if mark includes indigenous/Afro-Mexican cultural heritage; (2) acquired distinctiveness must be expressly stated with proof; (3) translation for non-Spanish indigenous languages; (4) transliteration for non-Latin characters. | Substantive change / Addition |
| 56 para 2 | 106 | Reservation of Exclusive Use | Maintained; IMPI empowered to move/remove elements placed in wrong sections without modifying the mark. | Procedural change |
| None | 107 | Website as Business Location | New rule: allows signaling a website as location, with an oath stating no physical establishment. High e-commerce impact. | Addition |
| 57 | 108 | Indication of Products/Services | Express prohibition: products/services that constitute pending or registered trademarks cannot be indicated. Appropriation risk. | Addition (substantive) |
| None | 109 | Trademarks with Protected AO/GI | New rule: if mark includes protected Appellation of Origin/Geographical Indication, exclusive use is not reserved and is subject to Art. 268 LFPPI. | Addition |
| 58 | 110 | Use Rules for Co-owned Marks | Maintained; adds stipulations on limitations during use declaration and renewal, and withdrawal. Subsequent modification must be recorded to affect third parties. | Substantive change |
| 60 | 111 | Priority Recognition in Trademarks | Requires indicating country of origin, number, and date at filing (previously "when known"). | Substantive change |
| 59 BIS | 112 | Gazette Publication of Trademark Application | No relevant change. | Relocation |
| 59 TER | 113 | Incomplete Opposition | Maintains 5-day cure period. Innovation: dismissal also applies for partial or failed cures. | Substantive change (stricter) |
| 59 QUATER | None | Publication of Opposition List | Removed from regulation (remains in Art. 221 LFPPI). | Relocation |
| 59 QUINQUIES | 114 | Terms when Filed in Development Centers | Replaces delegations with Development Centers. | Relocation |
| None | 115 & 116 | Formal and Substantive Examination of Trademarks | New rules detailing order and content of examinations (formal first, then substantive, notice of impediments). | Addition |
| 61 | 117 | Sign Modification = New Application | Maintained; adds rule that IMPI may request removal of non-reservable elements without implying a new application. | Procedural change |
| None | 118 | Correction of Errors in Title | New rule: IMPI may correct obvious or formal errors, ex officio or upon request. | Addition |
| None | 119 | Term to Cure Renewal Request | New rule of HIGH IMPACT: 2 non-extendable months; failure = automatic lapse without prior declaration. | Addition |
| None | 120 | Declaration of Use (Arts. 233 & 237 LFPPI) | New rule: IMPI may request product/service precision and removal of non-specific indications. Failure leads to dismissal. If limited, notice on which products/services protection continues. High impact on portfolio maintenance. | Addition |
| 62 | 121 | Effective Use of Trademark | Adds paragraph on accreditation: commercial transactions in relevant numbers, not sporadic or apparent, external acts of sale/distribution/commercialization/storage. High litigation impact. | Substantive change |
| 63 | 122 | Ratification of Voluntary Cancellation | Adds sec. III: "in cases where the Institute deems it necessary." | Addition (discretionary) |
| 64 | 123 | Indications on Licensed/Franchised Products | No relevant change. | Relocation |
| 65 | 124 | Information to Provide in Franchises | Expanded catalog: master contract, ROI amounts and times, number of company-owned and franchised units, number of units opened, relocated, transferred, and closed. High impact on COFI. | Addition |
| None | 125 | Dissolution of Linked Trademarks | New rule: express consent required to dissolve linkage under Art. 254 LFPPI, with identification requirements. | Addition |
| None | 126 | Nullity Grounds due to Violation (Art. 258.I LFPPI) | New rule delimiting impediments whose violation generates nullity: Arts. 12 and 173 sec. I to XVII and XIX to XXII LFPPI. High litigation impact. | Addition |
| 66 | None | Classification in Slogans | Removed (absorbed in general provisions). | Relocation |
| 68 | None | AO Use Authorization Request | Relocated to Ch. IV (AO/GI). | Relocation |
CHAPTER IV — APPELLATIONS OF ORIGIN AND GEOGRAPHICAL INDICATIONS
| RLPI Art. | RLFPPI Art. | Subject | Type |
|---|---|---|---|
| None | 127 & 128 | Delegation of AO/GI Protection — IMPI may delegate protection and defense actions to third parties when unable to exercise them directly. | Addition / Competence change |
| None | 129 | Maintenance of Geographical Link — link, quality, characteristics, reputation, natural and cultural factors. For GI, more limited link. | Addition |
| None | 130 | Generic Terms — criteria to determine if a name is common or generic (dictionaries, trade, official standards, significant imports). | Addition |
| None | 131 | Recognition of Foreign AO/GIs and Common Terms — IMPI will publish list in Gazette. | Addition |
| None | 132 | Translation/Transliteration of Free-Use Generic. | Addition |
| None | 133 | Coexistence of Homonymous Names. | Addition |
| None | 134 | Unprotected Descriptive/Generic Elements. | Addition |
| None | 135 | Transformation Request (Art. 280 LFPPI). | Addition |
| None | 136-138 | AO/GI Oppositions — 10 business days to cure oppositions; dismissal if partial or uncured. | Addition |
| None | 139 | IMPI Unilateral Investigations — express authority for unilateral investigation results. High evidentiary impact. | Addition |
| None | 140 | Suspension due to Prior or Related Issue. | Addition |
| None | 141 | Validity of Accreditation Certificate — valid until cancelled. | Addition |
| None | 142 | AO/GI Infringement Procedure — administrative declaration procedure applies (physical or online) where appropriate. | Addition / Relocation |
| None | 143 & 144 | Suspension of Effects due to Certification Agency Change — Gazette notice, suspension of pending filings, preservation of authorizations. | Addition |
| 68 | 145 | AO Use Authorization Request — relocated and adapted: adds email, original/certified power of attorney. Certificates within prior 6 months. | Relocation / Procedural change |
| None | 146 | Renewal of Use Authorization. | Addition |
| None | 147 | Lapse without Declaration — lapse occurs without declaration. High impact. | Addition |
| None | 148 | Authorized User Associations. | Addition |
| None | 149 | DOP/IGP Legends on Labels — prominent and legible in Spanish; translation allowed. | Addition |
| None | 150 | Voluntary Cancellation. | Addition |
| None | 151 & 152 | Agreement Allowing AO/GI Use — agreement requirements and voluntary cancellation. | Addition |
| None | 153 | Verification of Compliance by Distributors. | Addition |
| None | 154 | Recordal of Changes. | Addition |
| None | 155-159 | Declaration Request, Cessation of Effects, Recognition of Foreign AO/GIs, Opposition to Foreign Recognition, Voluntary Cancellation. | Addition |
CHAPTER V — ADMINISTRATIVE DECLARATION PROCEDURE
| RLPI Art. | RLFPPI Art. | Subject | Detected Change | Type |
|---|---|---|---|---|
| None | 160 | Guidelines by Director General Agreement | Director General may issue guidelines on administrative declaration procedures via Agreement. | Addition |
| 69 | 161 & 162 | Data in Declaration Request | (1) Adds RFC (tax ID) and CURP (unique ID); (2) expands location to "physical, virtual or electronic establishment, platform, profile or digital account"; (3) IMPI may accept provided address references. | Substantive change (high impact on digital infringements) |
| None | 163 | Dismissal for Lack of Validity or Untimeliness | New rule formalizing dismissal grounds at start of proceeding. | Addition |
| 79 | 164 | Fees for Inspection/Verification | Key rule: payment per company, negotiation, physical establishment, as well as per search or login on digital platforms, email address, profile, or digital account. High economic impact. | Substantive change |
| None | 165 | Ocular Inspections | Payment per object, document, analog support, or electronic medium. | Addition |
| 71 | 166 | Inspection Visit — Rules | (1) Credential must specify issue date and validity + name of issuing official; (2) order signature may be handwritten or electronic; (3) no substantive change to inspected party's rights. | Procedural change |
| 70 | None | Copy for Counterparty | Removed (absorbed into LFPPI). | Relocation |
| None | 167 | Request for Provisional Measures | Complies with same requirements as declaration request. | Addition |
| 72 | 168 | Asset Seizure | (1) Custodian must communicate any situation affecting the mandate and merchandise; (2) aid of federal, state, or local police + civil or armed institutions allowed. | Substantive change |
| None | 169 | Suspension of Free Circulation (Customs) | Applicant provides customs info and all expenses are at applicant's cost. High impact on anti-counterfeiting. | Addition |
| None | 170 | Blocking of Virtual/Digital/Electronic Media | New rule aligned with Art. 344.VII LFPPI: blocking of the specific part where violation exists; if infringer unidentified, full media blocking. 3-day term to comply. High impact on online strategy. | Addition |
| None | 171 | Counter-bond | Counter-bond equal to original bond + 40%. | Addition |
| 73 | 172 | Lifting of Seizure | Adds sec. V: by agreement between parties. | Addition |
| None | 173 | Return of Seized Assets Upon Lifting Measures | 10 business days for the custodian. | Addition |
| None | 174 | Bond Destination Upon Lifting Provisional Measures | New rule regulating bond destination based on proceeding outcome. | Addition |
| None | 175 | Destruction of Assets (Art. 366 LFPPI) | Facilitates destruction and materials handling. | Addition |
CHAPTER VI — INFRINGEMENTS, SANCTIONS, AND CRIMES
| RLPI Art. | RLFPPI Art. | Subject | Detected Change | Type |
|---|---|---|---|---|
| 75 | 176 | Calculation of Fines | Replaces "daily general minimum wage for Mexico City" with "Unit of Measure and Update (UMA)." Constitutional alignment. | Substantive change |
| 76 | 177 | Temporary/Permanent Closure | No relevant change. | Relocation |
| 77 | 178 | Execution of Temporary Closure | No substantive change. | Relocation |
| 78 | 179 | Additional Fine | Establishes 15 business days for the infringer to demonstrate cessation (previously unspecified). | Procedural change |
| None | 180 | Coordination with Tax Authorities | New rule for inter-institutional coordination for fine collection. | Addition |
| None | 181 | Damage Claims Before IMPI | New rule: procedure before IMPI, request and response requirements. High litigation impact. | Addition |
| None | 182 | Technical Opinion (Art. 405 LFPPI) | IMPI may take additional trademark registrations into account. | Addition |
| None | 183 | Term Extension for Technical Opinion | New rule regulating requests for term extensions to issue technical opinions. | Addition |
CHAPTER VII — ONLINE ADMINISTRATIVE DECLARATION OF INFRINGEMENT
| RLFPPI Art. | Subject | Type |
|---|---|---|
| 184 | Online Infringement: at the request of the interested party, with infringer consent for online or physical processing. | Addition |
| 185 | Chronological electronic file. | Addition |
| 186 | File access with advanced e-signature; evidentiary value of digitized docs; oath on integrity; 24/7 service. | Addition |
| 187 | IMPI-recognized electronic signature. | Addition |
| 188 | Electronic notices via electronic mailbox (15th and last day of month for fictional notice). | Addition |
| 189 | Electronically served resolutions with same effects. | Addition |
CHAPTER VIII — MANDATORY RESOLUTION OF PATENTS OR REGISTRATIONS
| RLFPPI Art. | Subject | Type |
|---|---|---|
| 190 | Mandatory resolution procedure request. | Addition |
| 191 | Non-computable terms (5 cases: applicant actions/omissions, additional terms, periods not attributable to IMPI, non-working days, force majeure). High impact. | Addition |
| 192 | Responsible official's report. | Addition |
CHAPTER IX — TECHNOLOGY TRANSFER RECORDAL
| RLFPPI Art. | Subject | Type |
|---|---|---|
| 193 | Technology Transfer Registry: licenses, assignments, NDAs, R&D, consulting, research sponsorship, MTAs, JV, spinoffs, startups. Not a validity requirement, but required for opposability against third parties. High substantive impact. | Addition |
| 194 | Recordal under Art. 21. | Addition |
| 195 | Public version with basic data. | Addition |
| 196 | Catalogs of free-use technologies and transfer publicity. | Addition |
CHAPTER X — ALTERNATIVE DISPUTE RESOLUTION (ADR)
| RLFPPI Art. | Subject | Type |
|---|---|---|
| 197 | Conciliation within administrative declaration procedures; IMPI participation in TFJA ADR. | Addition |
| 198 | Principles: voluntariness, confidentiality, good faith, legality, impartiality, equity, flexibility, party autonomy. | Addition |
| 199 | Physical meetings or via secure video-conferencing/digital platforms. | Addition |
| 200 | Conciliation at any stage before final resolution. | Addition |
| 201 | Written agreement (physical or electronic) with binding effects and administrative res judicata status. | Addition (high impact) |
| 202 | Minimum agreement content. | Addition |
Transitory Provisions
| Aspect | RLFPPI (2026) |
|---|---|
| Entry into force | 60 business days after publication in the Official Gazette (April 28, 2026). Effective date: approx. July 2026. |
| Online Procedure (Ch. VII) | Enters into force with the publication of an Agreement (max. 18 months later). Online infringement system could take until October 2027. |
| Pending Cases | Substantiated under provisions in force at filing. Exception: pending cases may access ADR provided in the new regulation. |
| ADR in TFJA | From the entry into force of the new regulation. |
| Abrogation | 1994 RLPI and reforms abrogated. RLPI loses formal validity, though applies to pending cases. |
Frequently Asked Questions
- What changes with the new Regulation of the Federal Law for the Protection of Industrial Property (RLFPPI) published in 2026?
The RLFPPI published on April 28, 2026, replaces the 1994 RLPI and reorganizes IMPI's administrative criteria into ten chapters. It introduces express regulation for electronic notices, non-traditional marks (sound, scent, position, motion, multimedia), mandatory disclosure of genetic resources and traditional knowledge in patents, a technology transfer registry, alternative dispute resolution (ADR), and a full chapter on online infringement featuring digital media blocking.
- What new obligations does the RLFPPI 2026 impose on owners and applicants?
Key new obligations include: providing an email address for all filings, submitting individual applications per alleged infringer or site in contentious proceedings, disclosing the country of origin for genetic resources and traditional knowledge when an invention is based on them, meeting two-month non-extendable deadlines for trademark renewals under risk of automatic lapse, and providing signed rules of use for collective and certification marks.
- What additional powers does IMPI have under the RLFPPI 2026?
IMPI gains the authority to establish differential rates and grant compliance badges, enter into inter-institutional agreements to leverage foreign office examinations, recognize electronic signatures, preserve files through third parties, order the full blocking of digital media when an infringer is unidentified, delegate protection actions for AO/GIs, and participate in ADR proceedings before the TFJA.
- What are the relevant deadlines in the RLFPPI 2026?
Key deadlines: two non-extendable months to cure trademark renewal requests (failure leads to automatic lapse); five days to cure provisional patent applications; two months to cure genetic resource disclosure omissions; three days to comply with digital media blocking orders; ten business days to return seized assets; and specific timelines for electronic notices with a fictional notice rule on the 15th and last day of each month if the dashboard is not consulted.
- Which 1994 RLPI provisions were removed in the RLFPPI 2026?
Removals include: detailed regulation of letters of attorney and general/special powers, the exhibition of specimens or models of inventions, detailed rules for dependent claims, provisional drawings, the express regulatory regime for foreign examination offices and patents granted abroad, the paragraph on arbitration for pharmaceutical linkage ownership disputes, and the obligation to publish the list of biological deposit institutions in the Official Gazette (DOF).
- When does the RLFPPI enter into force and what happens to pending cases?
The RLFPPI enters into force 60 business days after its April 28, 2026, publication. Ch. VII online proceedings will enter into force following a subsequent Agreement, no later than 18 months thereafter. Pending matters will be handled under the rules in force at their filing date, unless parties choose to use the new ADR mechanisms.