This Chapter addresses the gradual progression of Mexico’s approach to private international law, as charted through three distinct phases. First, as dictated by the concept of absolute territorialism, Mexico applied the same legal standards to foreigners as to Mexican nationals, up until 1932. Second, pursuant to the Civil Code of 1932, Mexico adopted a policy of "absolute territorialism" regarding the application of any foreign law within its borders. Finally, beginning in the 1970’s, Mexico started its journey towards the "Americanization" of its laws. However, it was not until the 1988 Amendments that Mexico changed its policy of absolute territorialism.

This belated third phase, starting in 1988, allowed for the application of foreign law by adopting explicit rules on conflict of laws in Mexico, such as Article 12. Further, with the amendments of 1988, the status of natural persons, movable and immovable assets, and legal acts and contracts were all provided with judicial notice of foreign law through Article 14. Mexican judges could now apply foreign law "as the corresponding foreign judge would." So long as there existed an analogous legal institution in Mexico, no identical institution needed to be present. However, problems do arise in the areas of judicial notice and the novelty of applying foreign law to the nature of the Mexico’s legal system.

Two special areas of mention remain: first, interstate conflicts seem to have not been distinguished from their international counterparts, according to Article 14. Thus, these two categories should be treated much in the same manner. Second, there remain two exceptions to the application of foreign law in Mexico: (1) when it is deemed to be "fraud on the law"; and (2) when "public order" necessitates otherwise.