The Electronic Customs Value Declaration, which will become mandatory as of December 9, 2025, is not simply a change in format, but a transformation in customs compliance in Mexico.
Historically, the Customs Value Declaration was physically filled out and kept in the importer’s file subject, where applicable, to possible requests by the tax and customs authorities in a Tax Audit. The transition to an Electronic Customs Value Declaration marks a structural change, whereby the document is no longer an archival support for importers but now becomes an obligation to submit information in connection with the customs value of imported goods prior to their customs clearance, using Form “E2” (available in the VUCEM since August 2025).
Although the Electronic Customs Value Declaration is designed to facilitate automated reviews and cross-checks by customs authorities, in practice it places an additional operational burden on importing companies, who will have to prepare, validate and submit the information related the value of their goods before the customs clearance of each import operation. This requirement will increase the time and internal coordination needed to comply with this obligation, creating potential friction points in operations of companies with high import volumes or time-sensitive logistics chains. The result is a more efficient enforcement environment for customs authorities, but with a direct impact on the operational agility of the import sector.
I. Main Changes and the New Audit Environment
The implementation of the Electronic Customs Value Declaration establishes a new compliance standard based on immediate auditing.
- Real-Time Audit: The most significant change is that the customs authorities will be able to immediately review and reconcile the information provided in the Electronic Customs Value Declaration. The information will be compared in real time with the data included in the import manifest (pedimento), electronic invoices, and the Value and Commercialization Document (DVC).
- Sole Responsibility of the Importer: The responsibility for determining the customs value of imported goods rests exclusively with the importer. The Electronic Customs Value Declaration must be digitally signed with the importer’s e-firma, strengthening its legal validity.
- No Intervention by the Customs Broker: In working sessions held with the Ministry of Finance and Public Credit, it has been indicated that the IP addresses from which the Electronic Customs Value Declaration is generated will be monitored to ensure that such declarations are indeed issued by the importer, seeking then to avoid “simulated acts and acts lacking materiality.”
- Errors in the Electronic Customs Value Declaration: Once the Electronic customs Value Declaration has been submitted by the importer, it cannot be modified. Therefore, if an error is detected, the only option for the importer will be to rectify the customs import manifest (pedimento) and process a new value declaration linked to the operation.
II. Documental Obligations and Operational Implications
The new process involves a double administrative burden and reactivates regulatory obligations that had been dormant in practice since 2015. The requirements and documents that the VUCEM demands to generate the Electronic Customs Value Declaration correspond exactly to those provided in Article 81 of the Customs Law Regulations, which operational application had been marginal for years.
Rule 1.5.1 of the Foreign Trade General Rules for 2025 revives this obligation by expressly linking the Customs Value Declaration to such Article, requiring importers to attach all the information evidencing the declared customs value of their goods.
Consequently, as of December 9, 2025, importers must obtain, organize, submit, and retain documentation that was not previously required at this stage of the process, such as commercial agreements, payment receipts, transportation documents, commercial correspondence, among others. Rather than complementing the Customs Value Declaration, these attachments become an additional administrative burden, while also increasing operating costs and the risk of logistical delays on each import operation.
Recurring Risks and Penalties
Filling out the Electronic Customs Value Declaration in the VUCEM carries inherent risks of error that can systematically affect importers. This is due to the fact that the system itself requires the date of payment of incremental or decremental expenses to be entered as a mandatory field, which, in some cases, have not been paid at the time of shipment, nor is there any certainty as to the exact date on which they will be paid, depending in many cases on the supplier. The same applies to the price to be paid for the goods. This design will induce the importer to declare uncertain or materially inaccurate information, placing the importer in a situation of legal uncertainty, since meeting the formal requirement would necessarily involve providing information that does not correspond to the operational reality.
Moreover, it is important for importing companies to take into consideration that the aforementioned Rule 1.5.1 establishes fines for errors, inaccurate data, or incomplete documentation in the Electronic Customs Value Declaration that range between MXN $2,330 to $3,310 pesos per import operation. Therefore, given that the system will require the capture of data that, by definition, the importer cannot know with certainty at the time of the customs clearance of its goods, there is a real risk of recurrent and inevitable fines, particularly for companies with a high volume of import operations.
The result is a system that requires the transmission of prior information, incorporates mandatory fields that are outside operational practice, and activates penalties immediately, creating an excessive punitive scenario with a high probability of structural error for importers.
III. Obligated Companies and Loss of Benefits
As of December 9, 2025, electronic transmission of the Customs Value Declaration becomes a mandatory requirement for all importers. This regulatory adjustment redefines traditional benefits: companies with IMMEX programs and VAT and IEPS certification are no longer exempt and, if they wish to maintain this preferential treatment, they must additionally obtain certification as an Authorized Economic Operator (OEA) with Mexican Customs. In contrast, the exceptions applicable to the terminal automotive industry and regarding the return to the country of temporarily exported goods referred to in Article 116 of the Customs Law, remain unchanged.
IV. Recommendations and Action Plan
In conclusion, the implementation of the Electronic Customs Value Declaration requires importing companies to immediately review their internal processes for documenting, submitting and controlling the customs value of their imported goods. The technical complexity of the new Electronic Customs Value Declaration, together with its operational and penalty implications, makes it essential for importers to seek professional advice from their foreign trade consultants to accurately assess the real impact on their operations, identify risks and define compliance strategies to avoid any contingencies and preserve logistical continuity in compliance with this new customs regulatory framework.
************
We hope you find this information useful. Should you have any questions or require further clarification regarding any aspect of this article, please do not hesitate to contact a member of our Foreign Trade and Customs Practice Group.
International Trade
Salvador Garza / salvador.garza@ecrubio.com
Alejandro Montes / alejandro.montes@ecrubio.com
Arturo J. Bañuelos / arturo.banuelos@ecrubio.com
Carlos Enríquez / carlos.enriquez@ecrubio.com
César Holguín / cesar.holguin@ecrubio.com
David Fujii / david.fujii@ecrubio.com
Eduardo David / eduardo.david@ecrubio.com
Edmundo Hernández / edmundo.hernandez@ecrubio.com
Fernando Holguín / fernando.holguin@ecrubio.com
Felipe Mendoza / felipe.mendoza@ecrubio.com
Juan Carlos Partida / juan.partida@ecrubio.com
Alexa Araiza / alexa.araiza@ecrubio.com
Claudio Vázquez / claudio.vazquez@ecrubio.com
Esmeralda Chávez / esmeralda.chavez@ecrubio.com
Jaime Ogushi / jaime.ogushi@ecrubio.com
Luis Delgado / luis.delgado@ecrubio.com
María Gutiérrez / maria.gutierrez@ecrubio.com
Miguel Torres / miguel.torres@ecrubio.com
