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Beginning yesterday, November 1, 2026, Mexico has started to phase in a new requirement that importers file an electronic valuation declaration (“EVD”) for each customs entry (pedimento), replacing the current paper-based valuation declaration. The requirement rolls out by customs regime through January 15, 2027, and will significantly increase the valuation information and documentation that must accompany every entry. Because values and commercial data must now match across multiple electronic filings, discrepancies may trigger audits, assessments of duties, taxes, and penalties, and even the "precautionary seizure" of goods.
Background
By way of background, Mexico has long required that commercial data, including value, be transmitted electronically as annexes to the pedimento. Article 36-A of Mexico’s Customs Law (“MCL”) applies to customs brokers, customs agencies, and any person who brings goods into or out of Mexico under a customs regime. These parties must transmit specified information to the customs authority as electronic or digital documents annexed to the pedimento, and the information is deemed transmitted and presented only when the electronic customs system issues its acknowledgment of receipt.
With respect to customs valuation specifically, Article 59, Section III of the MCL requires importers to provide the customs authority with a valuation declaration and the information supporting the declared customs value. The declaration allows the authority to verify the valuation method applied and the price used to calculate import duties and taxes. Under the current paper-based format, the importer must state the valuation method used and the price actually paid or payable. That paper-based format is now being replaced by the EVD.
What the New Rules Require
The new rules (Rule 1.5.1 of the General Foreign Trade Rules issued by the Tax Administration Service (“SAT”) and Article 81 of Mexico’s Customs Regulations (“MCR”)) take effect in phases between November 1, 2026, and January 15, 2027, and will require importers to file, per entry, an EVD supported by the relevant information and documentation. The EVD must be completed electronically through the government's Single Window for Foreign Trade (Ventanilla Única de Comercio Exterior, “VUCEM”) and must include, among other items, the valuation method used (transaction value or another valuation method), the price paid or payable, and any additions to the customs value. Specifically, the importer must:
- File Form E2 (the EVD) through VUCEM for each foreign trade operation, together with the related information and documents;
- Optionally designate, by Federal Taxpayer Registry number (RFC), the customs broker or customs agency authorized to view and download the EVD;
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Declare the corresponding e-document number of the EVD in the pedimento; and
- Retain Form E2 and its annexes in digital form for the record-retention period set out in Article 30 of the Federal Tax Code (“CFF”).
Article 81 of the MCR lists the documents the importer must attach to the EVD:
- Digital tax receipt (CFDI) or commercial invoice;
- Bill of lading, packing list, air waybill, or other transport documents;
- Proof of origin, where applicable;
- Evidence of a guarantee posted in a customs account under the estimated-price rules, where applicable;
- Proof of payment, such as an electronic transfer or letter of credit;
- Freight, insurance, and related expense documents;
- Contracts and/or purchase orders related to the transaction;
- Support for the additions to the price required under Article 65 of the MCL;
- Credit notes or other documents recording cash or in-kind discounts applicable to the sale; and
- Any other information needed to determine customs value.
Although the obligation to submit these documents per entry is phased in beginning November 1, 2026 (see the schedule below), importers must already keep all these documents in their records and make them available to the customs authority on audit.
Important note for OEA companies: Companies certified as Authorized Economic Operators (“OEA”) that are exempt from per-entry transmission of the EVD should still collect the information and keep it in their records in case the authority requests it.
Key Compliance Risks
Companies importing into Mexico under the customs regimes listed below should keep the following key compliance risks related to the EVD and customs valuation in mind:
1. The transition period is ending. Under the transitional provisions, importers may continue to use the current valuation compliance method until October 31, 2026. After that date, mandatory per-entry transmission of Form E2 through VUCEM takes effect by customs regime, as follows:
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November 1, 2026: Bonded warehouse
- November 15, 2026: Strategic bonded warehouse
- December 1, 2026: Transit
- December 15, 2026: Customs warehousing
- January 1, 2027: Temporary importation
- January 15, 2027: Definitive importation
Companies should therefore be ready to prepare and submit the EVD electronically for each entry and confirm that all supporting documentation is available, accurate, and ready for electronic submission.
2. The EVD applies to all customs valuation methods. The value information transmitted under Article 36-A of the MCL applies only when transaction value is used. Importers using another valuation method must still declare and support the customs value under Article 59, Section III of the MCL, and Article 81 of the MCR.
3. Data must match across documents. Values and commercial data must be consistent across the invoice or CFDI, the Article 36-A e-document, Form E2, and the pedimento. Any discrepancy may trigger an audit, potential assessment of duties, taxes, and penalties, as well as the precautionary seizure of goods.
4. Customs brokers and importers share exposure. If the importer does not authorize the customs broker to access Form E2, the importer must deliver the form digitally to the broker who cleared the goods. Brokers must also keep the value declaration in their records. Accordingly, importers and brokers should clearly allocate responsibility in their contracts.
Recommended Steps for Importers
While importers and brokers should consult with their customs counsel as to what specific steps to take, the list below should serve as a useful starting point for discussions around how to prepare for the EVD requirement:
1. Map each import operation to its go-live date. Identify which customs regimes your operations use (bonded warehouse, strategic bonded warehouse, transit, customs warehousing, temporary importation, or definitive importation) and confirm the date on which per-entry Form E2 filing becomes mandatory for each.
2. Confirm VUCEM access and broker authorization. Decide whether to designate your customs broker or customs agency by RFC to view and download the EVD. If you do not, establish a process to deliver Form E2 digitally to the broker who cleared the goods.
3. Build an entry-level documentation checklist. Confirm that the Article 81 documents (CFDI or commercial invoice, transport documents, proof of origin, proof of payment, freight and insurance documents, contracts or purchase orders, support for Article 65 additions, credit notes, and any estimated-price guarantee) can be gathered and transmitted for every entry.
4. Reconcile data before filing. Implement a pre-filing review to confirm that values and commercial data match across the invoice or CFDI, the Article 36-A e-document, Form E2, and the pedimento.
5. Review entries valued under methods other than transaction value. Confirm that the customs value of these entries is declared and supported under Article 59, Section III of the MCL and Article 81 of the MCR.
6. Update record-retention procedures. Retain Form E2 and its annexes in digital form for the period set out in Article 30 of the CFF, and keep the supporting documents available for audit now, even before your regime’s go-live date.
7. Revisit agreements with customs brokers. Clearly allocate EVD preparation, transmission, and recordkeeping responsibilities, since importers and brokers share exposure.
8. OEA companies should not stand down. Even if exempt from per-entry transmission, continue to collect and maintain the EVD information in case the authority requests it.
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