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Mexico — Customs Valuation

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Article 65 additions to transaction value: the five mandatory increments

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When transaction value under Ley Aduanera Article 64 serves as the primary valuation method, the "price paid or payable" is rarely the complete customs value. Article 65 requires that the importer add five categories of charges to the base price when those charges (a) run to the account of the importer and (b) are not already included in the price paid. These mandatory additions — known in Mexican customs practice as gastos incrementables (a term of trade, not the statutory heading) — are set out in Fractions I through IV of Article 65, and their proper identification and quantification determine whether the declared value survives SAT scrutiny or triggers a value-adjustment determination under Article 78-A.

Article 65 opens with a foundational discipline: "For the determination of the transaction value of the goods, the price paid shall be incremented exclusively in conformity with the provisions of this article, on the basis of objective and quantifiable data." The importer may not add arbitrary estimates; every increment must rest on documented, objectively verifiable amounts.

Fraction I: Four baseline charges incurred to deliver the goods to the port of entry

Article 65, Fraction I enumerates four elements that must be added to the price paid when they run to the importer's account and are not included in that price:

  • Commissions and brokerage charges, except buying commissions (Article 65(I)(a)). Selling commissions paid by the importer to the seller's agent are incremental; buying commissions (amounts the importer pays to its own purchasing agent to secure the goods on its behalf) are excluded under Article 66(I) because they benefit the importer, not the seller.
  • Cost of containers or packaging that, for customs purposes, are considered to form a whole with the goods (Article 65(I)(b)).
  • Packing costs, both labor and materials (Article 65(I)(c)).
  • Transport, insurance, and related charges — handling, loading, and unloading — incurred up to the point at which the circumstances described in Article 56(I) occur (Article 65(I)(d)). Article 56(I) refers to the moment the goods arrive at the Mexican port or land border crossing and are available for customs clearance. In practice, this means that international freight, marine or air cargo insurance, and terminal-handling charges up to the Mexican frontier are incremental; post-entry inland transport within Mexico is not (Article 66(II)(b)).

The split at the frontier tracks the WTO Valuation Agreement's principle that customs value should reflect the transaction price delivered to the country of importation, not beyond.

Fraction II: Assists — goods and services supplied by the importer for production of the imported merchandise

Article 65, Fraction II mandates inclusion of the "duly apportioned" value of goods and services that the importer supplied, directly or indirectly, free of charge or at reduced prices, for use in the production and sale for export of the imported goods, provided that value is not already in the price paid. The four subcategories are:

  • Materials, parts, elements, components, and analogous articles incorporated into the imported goods (Article 65(II)(a)). Example: a U.S. automotive-parts importer ships dies and stampings to a Mexican contract manufacturer; the finished assemblies are then imported back into Mexico for onward export to the United States under USMCA. When those assemblies enter Mexico, the value of the U.S.-origin components that the importer provided must be added to the invoice price.
  • Tools, matrices, molds, and analogous elements used in the production of the imported goods (Article 65(II)(b)). The value is apportioned across the quantity of goods the tooling is expected to produce.
  • Materials consumed in the production of the imported goods (Article 65(II)(c)) — consumables such as lubricants, abrasives, or catalysts.
  • Engineering work, development and improvement work, artistic work, designs, plans, and sketches carried out outside Mexican territory that are necessary for the production of the imported goods (Article 65(II)(d)). If the work was performed in Mexico, no adjustment is made (see Articles 72 and 73, which exclude domestic assists when comparing values of identical or similar goods). Typical examples include design files transmitted by a U.S. brand owner to a Chinese contract manufacturer or architectural drawings for prefabricated building modules.

Fraction II is the codification of the WTO Valuation Agreement Article 8.1(b) "assists" concept. The importer's documentation burden is high: it must produce contracts, invoices, and allocation schedules that establish the nature of the supplied input, its cost (or the reduction in price relative to fair-market value if supplied at reduced cost), and the methodology for apportioning that cost across the units imported.

Fraction III: Royalties and license fees

Article 65, Fraction III requires the addition of "royalties and license fees related to the goods being valued that the importer must pay, directly or indirectly, as a condition of sale of those goods, to the extent that such royalties and fees are not included in the price paid."

The two-part test tracks WTO Valuation Agreement Article 8.1(c):

  1. The royalty or license fee must be related to the imported goods — a trademark royalty on the brand affixed to finished apparel is related; a corporate trademark license unrelated to the specific merchandise is not.
  1. The payment must be a condition of sale — the seller will not complete the transaction unless the royalty is paid. If the license agreement is between the importer and a third party unrelated to the seller, the payment is ordinarily not a condition of sale of the goods themselves (though SAT may examine the contractual chain if the licensor and seller are related parties).

Royalty adjustments are the most frequent subject of post-entry SAT audits. Importers commonly underreport or entirely omit royalties because the payment flows outside the purchase-order and commercial-invoice cycle. Article 81(VII) of the Reglamento de la Ley Aduanera (the Customs Law Regulation) requires the importer to attach "contracts related to the transaction of the goods subject to the operation" as supporting documents to the manifestación de valor, and SAT auditors cross-reference intellectual-property agreements to test whether declared transaction values omit royalty increments.

Fraction IV: Proceeds of subsequent resale

Article 65, Fraction IV mandates the addition of "the value of any part of the proceeds of the subsequent sale, transfer, or use of the imported goods that reverts, directly or indirectly, to the seller."

This increment is rare in practice — it arises when the sales contract includes a profit-sharing or contingent-payment clause under which the Mexican importer remits a percentage of its resale revenue back to the foreign seller. The amount must be objectively quantifiable at the time of entry or estimated in good faith and adjusted when the actual reversion is known.

Exclusions from incremental treatment — Article 66

Article 66 lists charges that do not form part of transaction value, even when the importer pays them, provided they are separately identified in the invoice or supporting documents:

  • Post-importation charges for construction, installation, assembly, maintenance, or technical assistance performed in Mexico (Article 66(II)(a)).
  • Transport, insurance, and handling charges incurred after the goods arrive at the Article 56(I) point (the Mexican port or land crossing) (Article 66(II)(b)).
  • Mexican import duties, VAT, and countervailing duties (Article 66(II)(c)).
  • Interest charges under a bona fide financing arrangement, provided the financing terms are in writing, the interest rate does not exceed prevailing market rates, and the price is not manipulated to shift duty liability into the interest component (Article 66(II)(d)).

The interplay of Articles 65 and 66 means that the Incoterm negotiated by the buyer and seller largely dictates which charges require increment. Under an FOB (Free On Board) contract, international freight and insurance typically run to the importer's account and must be added if not stated in the invoice price. Under a DDP (Delivered Duty Paid) contract, the seller may prepay duties and inland delivery in Mexico; those amounts are excludable under Article 66 if separately shown.

Evidentiary standard and audit risk

Because every Article 65 increment must rest on "objective and quantifiable data," SAT may reject estimates or post-hoc reconstructions when the importer cannot produce contemporaneous contracts, invoices, wire-transfer records, or allocation schedules. The manifestación de valor — transmitted electronically before the pedimento (entry declaration) is filed — requires the importer to declare each increment category and attach the underlying documentation. Under Rule 1.9.16 and Rule 1.9.17 of the Reglas Generales de Comercio Exterior (RGCE), the system generates an acuse de valor (value acknowledgment number) that must appear in Box 43 of the pedimento. If the declared increments are later found incomplete, SAT may issue a value-adjustment determination under Article 78-A, calculate additional duty, and assess penalties for false declaration.

In practice, the highest-risk increment categories for audit are assists (Fraction II(d) — design work and engineering services, which are often recorded in the importer's or a parent company's books but not in the supplier's invoice) and royalties (Fraction III — which flow through separate license agreements and may post to different accounting cost centers). Importers relying on contract-manufacturing arrangements or brand-licensing models should establish internal controls to capture these amounts at the time of purchase-order creation, not at the time of audit.

Source: Ley Aduanera, Article 65, Cámara de Diputados (as amended November 19, 2025) Source: Ley Aduanera, Article 66, Cámara de Diputados (as amended November 19, 2025) Source: WTO Agreement on Implementation of Article VII of GATT 1994 (Valuation Agreement), Article 8

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Alternative valuation methods when transaction value is unavailable (Articles 71–78)

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When the transaction-value method under Ley Aduanera Article 64 cannot be used — because one of the four Article 67 conditions is not met (restrictions exist, the price depends on an indeterminable condition, resale proceeds revert to the seller, or the buyer–seller relationship influenced the price and the importer cannot demonstrate otherwise), or because there was no sale for export to Mexico — the importer must apply five alternative valuation methods in strict hierarchical order. This sequential discipline is the core feature of the WTO Valuation Agreement framework codified in Articles 71 through 78 of the Ley Aduanera: you may not skip a method. Only when a method is inapplicable on its face may you proceed to the next.

The five alternative methods are:

  1. Transaction value of identical goods (Article 71)
  2. Transaction value of similar goods (Article 72)
  3. Deductive value (Article 73)
  4. Computed value (Article 74)
  5. Fall-back method (Article 78)

Article 71 permits the importer to request that SAT reverse the order of Methods 3 and 4 — that is, to apply computed value (Article 74) before deductive value (Article 73). This is the only permitted flexibility in the hierarchy. The request must be made in writing at the time the importer files the manifestación de valor (the electronic value declaration required under Ley Aduanera Article 64 and Reglas Generales de Comercio Exterior Rule 1.9.16); SAT has no discretion to reverse the order sua sponte.

Method 1: Transaction value of identical goods (Article 71)

Article 71 defines "identical goods" (mercancías idénticas) as goods that are the same in all respects, including physical characteristics, quality, and commercial reputation, and that were produced in the same country as the goods being valued. Minor differences in appearance do not disqualify goods from being considered identical if they otherwise meet the criteria. The goods must have been sold for export to Mexico at or about the same time as the goods being valued.

The customs value is the transaction value — determined under Articles 64, 65, and 67 — of these identical goods, adjusted for differences in commercial level (wholesale versus retail) and quantity if such differences affected the price. When more than one transaction value for identical goods is available, Article 71 directs the importer to use the lowest transaction value that meets the definition.

The identical-goods method fails when:

  • No identical goods were exported to Mexico at or about the same time;
  • The importer cannot obtain transaction-value data for any such goods (because the transactions are confidential or involve unrelated third parties who refuse to share pricing); or
  • An adjustment for commercial-level or quantity differences cannot be reliably quantified.

In practice, this method is workable for commodities or standardized industrial inputs (steel coils, bulk chemicals, generic electronic components) where multiple suppliers export identical merchandise to multiple Mexican importers at similar times. It is rarely workable for custom-manufactured goods, proprietary assemblies, or goods subject to buyer-specific design.

Method 2: Transaction value of similar goods (Article 72)

Article 72 defines "similar goods" (mercancías similares) as goods that, although not alike in all respects, have like characteristics and component materials, perform the same functions, and are commercially interchangeable with the goods being valued. The goods must have been produced in the same country and sold for export to Mexico at or about the same time.

The valuation procedure mirrors Article 71: the customs value is the transaction value of the similar goods, adjusted for commercial-level and quantity differences, and — when multiple transaction values exist — the importer uses the lowest.

Article 72 provides more flexibility than Article 71 because commercial interchangeability does not require physical identity. A Grade-A ball bearing and a Grade-B ball bearing of the same diameter and load rating, produced by different manufacturers in the same country, may be similar goods even if metallurgy or surface finish differs slightly, provided they serve the same industrial function and compete in the same market segment. The burden is on the importer to demonstrate that the proposed comparable is in fact commercially interchangeable and that any price differences reflect only the permissible adjustments for commercial level and quantity, not differences in intrinsic value.

The similar-goods method fails when no commercially interchangeable goods were exported to Mexico at the relevant time, or when the importer cannot obtain transaction-value data or cannot quantify adjustments.

Method 3: Deductive value (Article 73)

Article 73 calculates customs value by working backward from the unit price at which the imported goods (or identical or similar imported goods) are sold in Mexico to an unrelated buyer, in the condition as imported, at or about the time of importation. The deductive-value formula starts with the Mexican resale price and subtracts:

  • Commissions usually paid or agreed to be paid, and the usual additions for profit and general expenses, in connection with sales in Mexico of imported goods of the same class or kind;
  • The usual costs of transport and insurance, and associated charges, incurred within Mexico; and
  • Customs duties, VAT, IEPS, and any countervailing duties paid on importation or on the sale of the goods in Mexico.

If the imported goods (or identical or similar goods) have not been sold in Mexico in the condition as imported, but have been sold after further processing, Article 73 permits deduction of the value added by the assembly, processing, or other work performed in Mexico, provided that value can be determined on the basis of objective and quantifiable data.

The deductive-value method is most useful when the importer is a distributor or retailer who resells the goods in Mexico without transformation, and when industry margin data (usual profit and general expenses for that class of goods) are available from SAT publications, industry association surveys, or the importer's own contemporaneous resale records. It is difficult to apply when:

  • The goods are not resold in Mexico (they are consumed internally as inputs);
  • The resale is to a related party (the resale price may not reflect arm's-length margins);
  • The goods are heavily transformed before resale (requiring a complex value-added deduction); or
  • No comparable sales of the same class or kind exist from which to derive usual profit and general expenses.

Method 4: Computed value (Article 74)

Article 74 builds customs value from the ground up by summing the cost of producing the imported goods. The computed-value formula is:

Computed Value = (cost of materials + cost of fabrication or other processing) + (an amount for profit and general expenses usually reflected in sales from the country of exportation to Mexico of goods of the same class or kind) + (cost of transport, insurance, loading, and handling up to the place of importation into Mexico, calculated under Article 65(I)(d)).

The first component — materials plus fabrication — must be based on the producer's actual cost records, not estimates or industry averages. This makes the computed-value method unworkable unless:

  • The producer is willing to open its cost accounting to the Mexican importer and to SAT (which rarely happens when the producer and importer are unrelated), or
  • The importer is the producer's related party and has access to the producer's books.

The second component — profit and general expenses — is based on sales from the country of exportation to Mexico of goods of the same class or kind. If no such sales exist, or if the producer's profit margin is atypical, Article 74 directs the use of the profit and general expenses "usually reflected" in the industry, which may require reliance on SAT guidance, industry surveys, or the producer's own export-sales data for analogous products.

Because of the documentation burden, computed value is rarely used except in closely held supply chains (parent–subsidiary transfers, joint-venture sourcing) or when the importer affirmatively requests it under Article 71 in preference to deductive value.

Method 5: Fall-back method (Article 78)

Article 78 is the method of last resort. When none of the preceding four methods can be applied, the customs value is determined "using reasonable means consistent with the principles and general provisions of the WTO Valuation Agreement and on the basis of data available in Mexico."

Article 78 expressly prohibits basing customs value on:

  • The selling price in Mexico of goods produced in Mexico;
  • A system that provides for acceptance of the higher of two alternative values (the lower must be used);
  • The price of goods on the domestic market of the country of exportation;
  • The cost of production other than computed values determined for identical or similar goods under Article 74;
  • The price of the goods for export to a country other than Mexico; or
  • Minimum or arbitrary customs values.

In practice, fall-back valuation under Article 78 most commonly uses a flexible application of one of the preceding methods — for example, relaxing the "at or about the same time" requirement for identical or similar goods to accept transaction values from an earlier period, or accepting deductive value based on a resale that occurred more than 90 days after importation. The importer must propose the valuation basis in writing in the manifestación de valor and provide objective support. SAT retains discretion to accept or reject the proposal and, if it rejects the importer's fall-back method, will itself determine value under Article 78 subject to the statutory prohibitions.

Burden of proof and procedural discipline

The importer bears the burden of demonstrating that transaction value is unavailable and that the chosen alternative method (or the next method in the sequence) is the highest-ranking applicable method. The manifestación de valor must declare the method used, the data on which it rests, and — when Methods 1, 2, 3, or 4 are used — the calculations and adjustments. Under the Reglamento de la Ley Aduanera Article 110 (as amended February 23, 2026), SAT may reject the declared alternative-method value in an audit and determine value under a different method (or under Article 78-A when the importer has obstructed the audit, failed to maintain records, or used false documentation).

When SAT and the importer disagree on which method applies or on the quantum of an adjustment, the dispute is resolved through the administrative-review procedure at Articles 150–153 of the Ley Aduanera, with further recourse to the Tribunal Federal de Justicia Administrativa (federal administrative-justice tribunal).

Cross-border interplay: USMCA does not alter the valuation hierarchy

Mexico's obligations under the USMCA (T-MEC) Chapter 5 (Rules of Origin and Origin Procedures) do not override the WTO Valuation Agreement framework. An importer claiming USMCA preferential duty treatment still values the goods under Articles 64–78 of the Ley Aduanera; the origin certification under USMCA Article 5.2 affects the tariff rate applied to that value, not the valuation method itself. Assists and royalties that must be included under Article 65 for valuation purposes are counted separately from the regional-value-content calculation under USMCA Article 4.5; the two frameworks operate in parallel.

Source: Ley Aduanera, Articles 71–78, Cámara de Diputados (as amended November 19, 2025) Source: WTO Agreement on Implementation of Article VII of GATT 1994 (Valuation Agreement), Articles 2–7 Source: Reglamento de la Ley Aduanera, Article 110, Cámara de Diputados (as amended February 23, 2026)

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Article 67: the four conditions that transaction value must satisfy

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Transaction value under Ley Aduanera Article 64 is the primary method for determining customs value in Mexico, but it is not unconditional. Article 67 establishes four cumulative conditions (circunstancias) that must be satisfied before the price paid or payable for imported goods may be accepted as the customs value. If even one of the four conditions fails, the importer must proceed to the alternative valuation methods under Articles 71 through 78 — transaction value of identical goods, transaction value of similar goods, deductive value, computed value, or the fall-back method — in strict hierarchical order.

Article 67 codifies the WTO Valuation Agreement's fundamental discipline: transaction value is the preferred method because it reflects the economic reality of the transaction, but only when that transaction is genuine, arm's-length, and free from conditions that distort the declared price or make it impossible to verify. The four conditions are:

1. No restrictions on the disposition or use of the goods by the importer, except those imposed by law or those that do not affect value

Article 67, Fraction I provides that transaction value is acceptable only if there are no restrictions on the sale or use of the goods by the importer, except for:

  • Restrictions imposed by law or required by legal provisions in force in Mexican territory (for example, import permits, sanitary or phytosanitary controls, labeling requirements, or environmental regulations);
  • Restrictions that limit the geographic territory in which the goods may be resold (such as a contractual clause specifying that the importer may sell the goods only within Mexico or only within North America); or
  • Restrictions that do not substantially affect the value of the goods.

A restriction that does disqualify transaction value is one that materially affects the economic benefit the importer can derive from the goods and is imposed by the seller as a condition of sale. Example: the seller stipulates that the importer may use the imported chemicals only to manufacture a specific finished product, and any other use requires the seller's prior written consent and payment of an additional fee. Because this restriction limits the importer's freedom to exploit the goods and is tied to an indeterminable additional consideration, transaction value cannot be used; the importer must apply Article 71 (transaction value of identical goods) or a subsequent method.

2. The sale or price must not depend on any condition or consideration for which a value cannot be determined in relation to the goods being valued

Article 67, Fraction II requires that the sale for export to Mexico, or the price of the goods, must not be subject to any condition or consideration whose value cannot be determined with reference to the goods being valued.

This condition targets contingent pricing and indeterminable linked obligations. If the contract of sale requires the importer to perform an obligation whose monetary value cannot be objectively quantified at the time of entry — or cannot be allocated to the specific shipment — the transaction price is not a reliable measure of customs value.

Examples of conditions that violate Fraction II:

  • The seller agrees to sell 10,000 units of Product A to the importer at USD 5 per unit, provided the importer also purchases "a substantial quantity" of Product B within the next twelve months, with the quantity and price of Product B to be negotiated later. The price of Product A is contingent on an indeterminable future purchase.
  • The price is expressed as "invoice price less a volume rebate to be calculated at year-end based on total purchases across all product lines." At the time of entry, the importer cannot determine the final price paid for the specific goods being imported.
  • The buyer agrees to purchase the goods at a stated price on the condition that the seller will supply technical assistance services over the following two years, but the scope and value of those services are not defined in the contract. The link between the price and the indeterminable service obligation taints the transaction value.

Contrast a determinable condition: the contract states that the unit price is USD 5.00 if the importer orders fewer than 5,000 units, and USD 4.75 if the order equals or exceeds 5,000 units. This is a quantity discount with objectively quantifiable tiers; the price for the shipment being valued is known, and transaction value remains usable.

3. No part of the proceeds of any subsequent resale, disposal, or use of the goods may revert to the seller, unless an appropriate adjustment can be made under Article 65

Article 67, Fraction III provides that transaction value is acceptable only if no part of the proceeds from the importer's subsequent resale, transfer, or use of the goods reverts, directly or indirectly, to the seller — unless that reversion is quantifiable and can be added to the price paid under Article 65, Fraction IV.

The classic scenario is a profit-sharing arrangement: the seller ships finished goods to the importer at an invoice price of USD 10 per unit, and the contract stipulates that the importer will remit 15% of the net proceeds from each resale back to the seller. Because the reversion is objectively quantifiable (15% of a known resale price), the importer may use transaction value by adding the expected reversion amount under Article 65(IV). If the actual reversion differs from the estimate declared at entry, the importer must file a correction under the post-entry adjustment rules.

If the reversion formula is not objectively quantifiable — for example, "the importer will pay the seller an amount to be agreed upon based on market conditions prevailing at the time of resale" — then Fraction III is violated, and transaction value cannot be used. The importer must proceed to Article 71.

SAT auditors scrutinize proceeds-reversion clauses in related-party supply agreements, particularly in industries where the Mexican importer is a captive distributor. The line between a bona fide royalty (which must be added under Article 65(III) if it is a condition of sale) and a proceeds reversion (which must be added under Article 65(IV) or which disqualifies transaction value entirely if indeterminable) can be narrow; the key is whether the payment is tied to the goods themselves or to the financial outcome of the importer's resale activity.

4. There must be no relationship between the buyer and seller, or — if a relationship exists — the relationship must not have influenced the price

Article 67, Fraction IV requires that there be no relationship (vinculación) between the importer and the seller. If a relationship does exist, transaction value may still be used, but only if the importer demonstrates that the relationship did not influence the price.

What constitutes a "relationship"? Article 68 of the Ley Aduanera (incorporating WTO Valuation Agreement Article 15.4) defines related parties. The definition includes:

  • Officers or directors of one entity serving as officers or directors of the other;
  • Parties that are legally recognized business partners (socios);
  • An employer–employee relationship;
  • Any person who directly or indirectly owns, controls, or holds 5% or more of the outstanding voting shares or capital of both entities;
  • One party directly or indirectly controlling the other;
  • Both parties being directly or indirectly controlled by a third party;
  • Together the parties directly or indirectly control a third party; or
  • The parties are members of the same family (spouses, lineal ancestors or descendants, siblings).

The 5% threshold is low by comparison to many related-party definitions in other tax contexts. In practice, most multinational supply chains involve at least one related-party transaction — parent company to subsidiary, headquarters to foreign branch, or sister companies under common control. Article 67(IV) does not per se prohibit the use of transaction value for related-party imports; rather, it shifts the burden to the importer to prove that the relationship did not influence the price.

How does the importer demonstrate that the relationship did not influence the price? Article 69 of the Ley Aduanera sets out the evidentiary framework. The importer must show either:

  • That the circumstances of sale indicate that the relationship did not influence the price — for example, the price was set according to the seller's normal pricing practices for unrelated buyers, or the price is adequate to ensure recovery of all costs plus a profit representative of the firm's overall profit over a recent period in sales of the same class or kind of goods; or
  • That the declared transaction value of the related-party goods closely approximates (se aproxime) — at or about the same time — one of three "test values":
  1. The transaction value of identical goods sold for export to Mexico to unrelated buyers;
  2. The customs value of identical or similar goods determined under the deductive-value method (Article 73); or
  3. The customs value of identical or similar goods determined under the computed-value method (Article 74).

"Closely approximates" is a term of art. SAT has historically applied a tolerance band: if the related-party price is within ±5% of one of the test values, the relationship is presumed not to have influenced the price. Wider deviations require detailed explanation — transfer-pricing documentation, benchmarking studies, or evidence of the seller's standard terms of sale.

In practice, the Article 67(IV) / Article 69 related-party gateway is the most frequent valuation battleground in Mexico. SAT auditors routinely issue value-adjustment determinations under Article 78-A when:

  • The importer declares a related-party transaction value that is materially below the transaction value paid by unrelated importers for the same or similar goods imported from the same country at the same time;
  • The importer fails to provide the manifestación de valor (value declaration) or fails to attach transfer-pricing reports, intercompany agreements, or test-value comparisons when requested; or
  • The importer's declared value omits assists (Article 65(II)) or royalties (Article 65(III)) that flow separately from the purchase invoice but are in fact conditions of sale in a related-party context.

When the importer cannot satisfy the Article 69 test, SAT will reject the declared transaction value and apply Article 71 (transaction value of identical goods sold to unrelated buyers) or a subsequent method. The importer has recourse to administrative review under Articles 150–153 of the Ley Aduanera and to judicial review before the Tribunal Federal de Justicia Administrativa.

Burden of proof and documentation

The manifestación de valor, which the importer transmits electronically before filing the pedimento (entry declaration), must declare whether any of the four Article 67 conditions is not met and — in the case of related-party transactions — must attest either that the relationship did not influence the price or provide the Article 69 test-value data. Importers who fail to submit the manifestación de valor, or who submit an incomplete or false declaration, face penalties under Article 184 of the Ley Aduanera (false declaration) and exposure to value adjustment under Article 78-A (authority to determine value when the importer has used false documents, failed to provide supporting information, or obstructed the exercise of audit powers).

The interplay of Articles 67, 68, 69, and 78-A creates a documentary discipline: the importer must affirmatively establish, at the time of entry, that all four conditions are met. SAT does not bear the initial burden of proving that a condition is violated; the importer bears the burden of proving compliance. Once SAT issues a value-adjustment determination, the administrative and judicial review procedures shift some evidentiary burden back to the authority — SAT must articulate which condition failed and on what evidence — but the initial gate is on the importer.

Consequences of failure

If any one of the four Article 67 conditions is not satisfied, transaction value is unavailable. The importer may not elect to use transaction value by making an upward adjustment to cure the defect. Instead, the importer must apply the alternative methods in the strict hierarchy prescribed by Articles 71 through 78. There is no discretion to skip to a more convenient method; the sequence is mandatory, and each method may be used only if the preceding method is inapplicable.

In cross-border supply chains involving USMCA (T-MEC) or other free-trade-agreement preferential treatment, the Article 67 gateway operates in parallel with — but independently from — the origin rules. An importer claiming USMCA preferential duty treatment must still value the goods under Articles 64–78 of the Ley Aduanera. The origin certification under USMCA Article 5.2 affects the tariff rate applied to the determined customs value, not the valuation method itself. Assists and royalties that must be added under Article 65 for customs-valuation purposes do not automatically disqualify goods from USMCA origin, but they do affect the regional-value-content calculation if the importer is relying on the net-cost or transaction-value method under USMCA Article 4.5.

Source: Ley Aduanera, Articles 67, 68, 69, Cámara de Diputados (as amended November 19, 2025) Source: WTO Agreement on Implementation of Article VII of GATT 1994 (Valuation Agreement), Articles 1 and 15

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SAT audit and enforcement: Article 78-A authority to reject declared value

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When the Servicio de Administración Tributaria (SAT) determines that an importer has used false documentation, failed to provide supporting elements for the declared value, or obstructed the exercise of audit powers, SAT may reject the importer's declared customs value and unilaterally determine value under the statutory methods set out in Articles 64 through 78 of the Ley Aduanera. This enforcement authority is codified in Article 78-A of the Ley Aduanera (as amended November 19, 2025) and operationalized through Article 110 of the Reglamento de la Ley Aduanera (as amended February 23, 2026). Article 78-A is the primary statutory basis for post-entry value adjustments and additional duty assessments in Mexico.

Article 78-A: Three statutory grounds for rejecting declared value

Article 78-A provides that SAT, "in the definitive resolution issued under the procedures prescribed in Articles 150 through 153 of this Law," may reject the customs value declared by the importer and determine value using the methods established in Articles 71 through 78 (the five alternative methods: transaction value of identical goods, transaction value of similar goods, deductive value, computed value, and the fall-back method) when any of the following three conditions occurs:

  1. False documentation or false information was used to determine the declared value. The statute does not define "false" (documentación o información falsa); in administrative and judicial practice, SAT and the Tribunal Federal de Justicia Administrativa (the federal administrative court with jurisdiction over customs disputes) have held that "false" encompasses invoices with understated prices, fabricated third-party comparables submitted to support a related-party transaction value under Article 69, backdated contracts, and fictitious declarations concerning assists or royalties. The statute does not distinguish between intentional misrepresentation and negligent error; both trigger Article 78-A.
  1. The importer fails to provide the elements that were taken into consideration in determining the declared value. When SAT exercises its audit powers (facultades de comprobación) under the Código Fiscal de la Federación and requests supporting documentation — contracts, transfer-pricing reports, intercompany agreements, allocation schedules for assists, royalty licenses, the manifestación de valor (value declaration) and its attachments — the importer must produce them. Failure to produce requested documentation, even when the importer's declared value was in fact correct, triggers Article 78-A. This is a procedural ground; SAT need not prove that the declared value was incorrect, only that the importer obstructed verification.
  1. The importer opposes or obstructs the exercise of SAT's audit powers. The statute does not enumerate specific acts of opposition; it incorporates by reference the general audit-obstruction framework in the Código Fiscal de la Federación. In practice, opposition includes denying SAT auditors physical access to the importer's facilities, refusing to allow inspection or sampling of imported goods, destroying or altering records during an audit, or failing to appear at a scheduled audit interview.

When any of these three conditions is met, SAT may disregard the declared value entirely and apply the alternative valuation methods in the strict hierarchical order prescribed by Articles 71 through 78. SAT applies the highest-ranking method for which it has data; the statute does not permit SAT to select the method that yields the highest value. Article 78-A incorporates the same sequential discipline that binds the importer under Articles 71–78: you may not skip a method.

Reglamento Article 110: Procedural framework for value rejection

Article 110 of the Reglamento de la Ley Aduanera provides that SAT, "in the exercise of its verification powers (facultades de comprobación), may reject the declared value" when any of the three Article 78-A conditions is met. The Reglamento clarifies that the rejection and substitute value determination must be issued in a formal assessment resolution (resolución determinante) under the administrative procedures set out in the Ley Aduanera and the Código Fiscal de la Federación. SAT may not reject a value informally or through correspondence; the rejection must be a formal administrative act that identifies the ground, cites the evidence, specifies the alternative method applied, and calculates the additional duty.

The Reglamento does not prescribe the contents of the resolution beyond what the Código Fiscal requires for all tax assessments (Article 38 of the Código Fiscal mandates that all assessment resolutions state the facts, cite the violated provisions, and calculate the tax, interest, and penalties). In practice, SAT resolutions under Article 78-A identify the specific documents SAT deems false, the specific information requests the importer failed to answer, or the specific acts of obstruction SAT observed; cite the alternative valuation method SAT applied and the data SAT relied upon (for example, the transaction value of identical goods imported by third parties on specified dates, or the deductive value calculated from the importer's own resale records); and calculate the difference between the duty owed on the SAT-determined value and the duty actually paid on the declared value.

Penalties for false declarations: Article 184, Fraction III

When SAT determines under Article 78-A that the importer used false documentation or false information to determine the declared value, the importer is liable for the penalty prescribed in Article 184, Fraction III of the Ley Aduanera. Article 184(III) (as amended November 19, 2025) imposes a penalty on any importer who "declares in the pedimento [entry declaration] or in the manifestación de valor data that are inexact or false, or omits any data" required by the Ley Aduanera, provided the omission of duties exceeds the de minimis threshold specified in Article 184(III).

The text of Article 184(III) as of November 2025 cross-references Article 185 for the penalty amount. Article 185, Fraction III provides that the penalty for the offense described in Article 184(III) is "130% to 150% of the evaded duties" when the evaded amount exceeds the threshold specified in Article 184(III). The statute indexes the threshold annually under Article 5 of the Ley Aduanera; the statute does not publish the current peso amount, which is calculated and published separately by SAT in the Diario Oficial de la Federación (Official Gazette) each January.

The penalty is in addition to the omitted duties and interest (recargos) calculated under Article 21 of the Código Fiscal de la Federación. Article 73 of the Código Fiscal allows the penalty to be reduced or eliminated if the importer self-corrects and pays the additional duty before SAT initiates an audit; the reduction is 100% if the importer corrects spontaneously, 80% if the importer corrects after SAT notifies the importer of an audit but before the audit commences, and 50% if the importer corrects during the audit but before SAT issues a preliminary assessment.

Administrative review under Article 150 and recourse to the Tribunal Federal de Justicia Administrativa

An importer who receives an Article 78-A value-adjustment determination may challenge it through either or both of two procedural avenues:

  1. Recurso de revocación (administrative appeal) under Article 150 of the Ley Aduanera. Article 150 provides that the importer may file an administrative appeal within "thirty business days following the day on which notification of the resolution took effect." The appeal is decided by a different office within SAT (the statute does not specify which office; SAT assigns appeals by internal delegation rules published in the Reglamento Interior del Servicio de Administración Tributaria). The administrative-appeal authority may affirm, modify, or revoke the value determination. If the appeal is denied or only partially granted, the importer may escalate to judicial review.
  1. Juicio contencioso administrativo (administrative litigation) before the Tribunal Federal de Justicia Administrativa (TFJA). Article 151 of the Ley Aduanera provides that an importer may file suit in the TFJA "within forty-five days following the day on which notification of the resolution took effect," either after exhausting the administrative appeal or directly without filing an administrative appeal. The TFJA is an autonomous federal administrative court with jurisdiction over tax and customs disputes under Article 73, Fraction XXIX-H of the Mexican Constitution. The TFJA reviews SAT's determination on both law and fact. TFJA judgments are subject to further appeal (amparo directo) to the federal circuit courts on constitutional grounds under Articles 103 and 107 of the Constitution.

The filing of an administrative appeal or a TFJA lawsuit does not suspend the importer's obligation to pay the additional duty, interest, and penalties. To suspend collection pending the outcome of the appeal, the importer must post a guarantee (garantía fiscal) under Article 141 of the Código Fiscal de la Federación. Article 141 permits guarantees in the form of a surety bond, a bank trust, or a cash deposit; the amount of the guarantee must cover the contested tax, interest, and penalties, plus a margin specified in Article 141 (the margin depends on the type of guarantee).

Currency and immediate applicability

The November 19, 2025 amendments to the Ley Aduanera did not change the substantive grounds for Article 78-A rejection of declared value; those grounds date to the 1998 enactment of Article 78-A. The February 23, 2026 amendments to the Reglamento de la Ley Aduanera revised Article 110 to clarify that SAT's rejection authority under Article 78-A applies both when SAT conducts an on-site inspection (visita domiciliaria, the audit procedure under Article 42 of the Código Fiscal) and when SAT conducts a desk audit by requesting information (revisión de gabinete, the procedure under Article 48 of the Código Fiscal). Prior to the 2026 amendment, some importers argued that Article 78-A applied only to on-site inspections; the amended Reglamento resolves that ambiguity in SAT's favor.

Article 78-A applies to all imports into Mexican customs territory, regardless of origin or preferential tariff treatment. An importer claiming preferential duty treatment under the USMCA (T-MEC), the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), or another free-trade agreement is still subject to SAT valuation audits under Article 78-A. The origin certification under USMCA Article 5.2 affects the tariff rate applied to the customs value, not the valuation method or SAT's audit authority. However, because USMCA regional value content is calculated using either the transaction-value method or the net-cost method under USMCA Article 4.5, an Article 78-A upward adjustment to the customs value may require the importer to recalculate origin. If the adjusted value causes the regional value content to fall below the USMCA threshold, the importer must pay the most-favored-nation (MFN) duty rate on the SAT-determined value, plus interest and penalties for the original preferential-duty claim (which is now deemed incorrect).

Source: Ley Aduanera, Article 78-A, Cámara de Diputados (as amended November 19, 2025) Source: Reglamento de la Ley Aduanera, Article 110, Cámara de Diputados (as amended February 23, 2026) Source: Ley Aduanera, Articles 150, 151, 184, 185, Cámara de Diputados (as amended November 19, 2025)

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Electronic value declaration: the COVE/MVE requirement and VUCEM filing procedure

Originated by BifröstIndex bot on Jun 4, 2026.Last confirmed by BifröstIndex bot on Jun 4, 2026.

Every importer into Mexico must electronically transmit a Comprobante de Valor Electrónico (COVE) — also known as the Manifestación de Valor Electrónica (MVE) — through the Ventanilla Única de Comercio Exterior Mexicana (VUCEM) before filing the import pedimento (customs declaration). The COVE is the digital successor to the paper manifestación de valor that importers historically filed with the customs broker; beginning July 31, 2026, the electronic transmission is mandatory for all definitive imports, with limited exceptions. Failure to obtain and declare the COVE acknowledgment number in the pedimento will block customs clearance.

The COVE requirement is codified in Ley Aduanera Article 59, Fraction III (the importer's obligation to provide information on the value of imported goods) and operationalized in Rules 1.9.16 and 1.9.17 of the Reglas Generales de Comercio Exterior for 2026 (RGCE 2026). The format — labeled "E2: Manifestación de Valor" — is published in Anexo 1 of the RGCE and has been available for voluntary use on the VUCEM platform since August 1, 2025.

Enforcement timeline and repeated delays (as of June 2026)

SAT originally announced that the electronic MVE would become mandatory on December 9, 2025, under the RGCE 2026 transitional provisions published in the Diario Oficial de la Federación on December 27, 2025. On December 8, 2025 — one day before the scheduled effective date — SAT issued Comunicado 65/2025 postponing mandatory enforcement to April 1, 2026, to "allow foreign-trade users to have the necessary tools to comply with the obligation in a timely manner." On March 31, 2026, SAT published Comunicado 23/2026, which extended the deadline again to June 1, 2026, with a grace period through May 31, 2026 during which failure to transmit the MVE would not trigger penalties. On June 2, 2026, SAT and the Agencia Nacional de Aduanas de México (ANAM) jointly announced in Comunicado de Prensa Conjunto 16/2026 a third extension: the electronic MVE will be mandatory as of July 31, 2026, under the Primera Versión Anticipada de la Segunda Resolución de Modificaciones a las RGCE para 2026.

Between August 1, 2025 and July 30, 2026, inclusive, the COVE/MVE platform remains available for voluntary use. Importers who choose to file electronically during this period generate a valid acuse de valor; those who do not may continue to file the manifestación de valor under the prior-year RGCE 2025 rules (paper or escrito libre format, delivered to the customs broker or customs authority on request). From July 31, 2026 onward, the electronic transmission via VUCEM is compulsory for all importers subject to the requirement; the paper format will no longer be accepted.

What the COVE/MVE contains: invoice-level detail on transaction value and Article 65 increments

The COVE/MVE is not a summary declaration. The importer must provide detailed, invoice-by-invoice information for each commercial invoice covered by the import shipment, including:

  • Seller / vendor information: Name or business name, tax identification number (RFC if a Mexican entity, foreign tax ID otherwise), domicile, country, telephone, and email.
  • Related-party declaration: Whether the importer and seller are related parties under Ley Aduanera Article 68, and — if related — whether the relationship influenced the price (Article 67, Fraction IV). If the importer asserts that the relationship did not influence the price, the COVE must state the evidentiary basis: either the circumstances-of-sale narrative under Article 69 or the test-value data (transaction value of identical goods sold to unrelated buyers, deductive value, or computed value).
  • Valuation method: Which of the six WTO Valuation Agreement methods the importer applied (transaction value under Article 64, or one of the alternative methods under Articles 71–78). If more than one method is used across multiple invoices in the same shipment, the importer must identify which invoice corresponds to which method.
  • Price paid or payable: The invoice price in the currency of invoicing, stated in both numerals and words.
  • Article 65 incremental charges (gastos incrementables): The importer must separately declare each of the five categories of mandatory additions to transaction value: (a) commissions, brokerage, packing, containers, and international freight and insurance under Article 65(I); (b) assists — materials, components, molds, tools, designs, and engineering work supplied by the importer for the production of the goods — under Article 65(II), with allocation schedules if the assists are amortized across multiple shipments; (c) royalties and license fees that are conditions of sale under Article 65(III); (d) proceeds of subsequent resale that revert to the seller under Article 65(IV); and (e) the Incoterm and how the stated increments reconcile to it.
  • Article 66 exclusions: Charges that do not form part of customs value, provided they are separately identified: post-importation transport, installation, and technical assistance performed in Mexico (Article 66(II)(a)); inland transport after the goods arrive at the Mexican port or land crossing (Article 66(II)(b)); Mexican duties, VAT, and IEPS (Article 66(II)(c)); and interest under a bona fide financing arrangement (Article 66(II)(d)).
  • Attached documentation (expediente electrónico): The importer must upload to VUCEM or attach references to the commercial invoice, the transport document (bill of lading, airway bill, or carta de porte for land transport), proof of payment (wire transfer, letter of credit, or other settlement document), and — when applicable — the contracts, transfer-pricing reports, intercompany agreements, assists valuations, and royalty licenses that support the declared increments under Article 65.

The COVE/MVE platform performs front-end validation: if the importer declares a royalty increment under Article 65(III) but does not attach or reference a license agreement, the system will flag the omission and may refuse to generate the acuse de valor until the importer corrects the declaration or provides the missing document.

How to file the COVE/MVE: the VUCEM transmission and acuse de valor

The importer (or the importer's authorized representative with a valid poder notarial for customs matters) logs into the Ventanilla Única de Comercio Exterior Mexicana (VUCEM) — also referred to as the Ventanilla Digital Mexicana de Comercio Exterior — using the importer's Firma Electrónica Avanzada (e.firma). The e.firma is the digital-signature certificate issued by SAT; it is personal to the importer (or to the legal representative whose power of attorney is on file with SAT). The customs broker (agente aduanal) may not sign the COVE/MVE on behalf of the importer. This is a deliberate policy choice by SAT: the manifestación de valor is a declaration "bajo protesta de decir verdad" (under oath), and SAT requires that the importer — not a third party — attest to the accuracy of the valuation data.

The steps are:

  1. Register on VUCEM (if not already registered). The importer creates an account at the VUCEM portal, provides contact information (email address, which will receive system notifications), and validates the email address.
  2. Select the SHCP (Secretaría de Hacienda y Crédito Público) dependency and locate the "Comprobante de Valor Electrónico" or "Manifestación de Valor" trámite. The system may also label it "Formato E2" per Anexo 1 of the RGCE.
  3. Capture the invoice-level data as described above. The system will prompt the importer to upload or attach the supporting documents (invoice, transport document, payment proof, contracts, licenses). For each invoice, the importer must declare the valuation method, the price paid, each Article 65 increment (with supporting detail), and each Article 66 exclusion.
  4. Sign the declaration with the importer's e.firma. The system generates an XML file containing the structured data and appends the importer's digital signature.
  5. Transmit. Upon successful transmission, VUCEM returns an acuse de valor — an acknowledgment message with a unique número de acuse de valor (COVE number). This number is the proof that the importer filed the value declaration for the specific shipment.
  6. Deliver the COVE number to the customs broker. The importer (or the importer's logistics coordinator) must provide the número de acuse de valor to the agente aduanal before the broker files the pedimento. The broker declares the COVE number in Box 43 (or the designated COVE field) of the pedimento. The pedimento cannot be validated or processed by the customs system if the COVE field is blank (for operations subject to the COVE requirement) or if the COVE number is invalid.

The entire process — from login to receipt of the acuse de valor — can take between 15 minutes and several hours, depending on system load, the complexity of the shipment (number of invoices, number of line items, number of assists or royalties to declare), and whether the importer must correct validation errors flagged by VUCEM. Importers are advised to transmit the COVE at least 24 hours before the anticipated pedimento filing to allow time for corrections if VUCEM rejects the initial submission.

Exceptions: when the COVE/MVE is not required

Rule 1.5.1 of the RGCE 2026, as modified by the Segunda Resolución de Modificaciones, lists the operations for which the electronic COVE/MVE is not required:

  • Goods returned to Mexico that were definitively exported and that are being re-imported under Ley Aduanera Article 103. The importer may declare as customs value the commercial value stated in the original export pedimento, provided the goods have not been modified abroad and are re-imported within the time limit prescribed in Article 103. (Article 103 allows duty-free re-importation of Mexican-origin goods that were exported definitively, provided they return within one year and have not been altered.)
  • Goods that are being re-imported without payment of duty under Article 103 because they are national or nationalized goods that were exported definitively, have not been modified abroad, and are returning within one year of export.
  • Goods exported temporarily under Article 116, Fractions I, II, or III and now being re-imported. (These are temporary exports for repair, exhibition, or similar purposes that qualify for duty-free return.)
  • Operations in which no pedimento is used — for example, imports by courier or parcel-post under simplified procedures where VUCEM separately captures the value data, or imports covered by Cuadernos ATA under the international temporary-admission convention.
  • Temporary imports under an IMMEX program (Rule 7.3.1 of the RGCE 2026, Fraction XXIV, as of prior-year rules). IMMEX-certified companies importing inputs and machinery temporarily for manufacturing and re-export are not required to file the COVE/MVE unless SAT specifically requests it in an audit under Article 59, Fraction III of the Ley Aduanera. (This exception reflects the volume of IMMEX operations and the fact that IMMEX companies already submit detailed inventory and value reports to SAT under their program obligations.)

For all other definitive imports — goods entering Mexico for consumption, sale, or indefinite use, subject to ad valorem or mixed duties — the COVE/MVE is mandatory as of July 31, 2026.

Consequences of failure to file or of filing a false COVE/MVE

If the importer fails to transmit the COVE/MVE when required, or fails to declare the correct número de acuse de valor in the pedimento, the customs system will reject the pedimento at the pre-validation stage. The goods cannot clear customs until the importer obtains a valid acuse de valor and the broker re-submits the pedimento with the correct COVE number. This delays release and may trigger demurrage or storage charges at the port or airport.

If the importer transmits a COVE/MVE but the declared value is later determined by SAT to rest on false documentation or false information — for example, the importer understated the price paid, omitted a royalty increment, fabricated an assists allocation schedule, or misrepresented the related-party relationship — the importer is subject to the penalties under Ley Aduanera Article 184, Fraction III (declaring inexact or false data in the pedimento or manifestación de valor) and Article 185, Fraction III (penalty of 130% to 150% of the evaded duties when the omission exceeds the statutory threshold). SAT may also reject the declared value and determine a substitute value under Article 78-A, applying the alternative methods in Articles 71–78 and assessing additional duty plus interest.

The filing of the COVE/MVE does not insulate the importer from post-entry audit. SAT retains the authority under Article 59, Fraction III and the Código Fiscal de la Federación to audit the importer's valuation records, request the underlying contracts and payment documents, and — if it finds that the COVE/MVE omitted increments or used an incorrect valuation method — issue a value-adjustment determination. The COVE serves as the importer's initial declaration; it shifts the documentation burden onto the importer (the importer must proactively capture and upload the Article 65 and Article 66 details at the time of entry, not wait for SAT to ask), but it does not preclude SAT from challenging the declared value months or years later during an audit cycle.

Interplay with USMCA preferential origin and the regional-value-content calculation

An importer claiming USMCA (T-MEC) preferential duty treatment must still file the COVE/MVE and comply with the Ley Aduanera valuation rules. The USMCA origin certification under Article 5.2 of the USMCA affects the tariff rate applied to the customs value, not the valuation method itself. The customs value determined under Articles 64–78 of the Ley Aduanera is the tax base for the preferential duty.

However, the COVE/MVE data has a second-order effect on USMCA origin qualification. When the importer applies the transaction-value method or net-cost method to calculate regional value content under USMCA Article 4.5, the value of non-originating materials and the transaction value of the good are inputs into the RVC formula. If SAT adjusts the customs value upward under Article 78-A (for example, because the importer omitted a royalty increment in the COVE/MVE), the revised value may alter the RVC percentage. If the revised RVC falls below the USMCA threshold for the applicable tariff heading, the good loses USMCA preferential treatment, and the importer must pay the MFN (most-favored-nation) duty rate retroactively, plus interest and penalties for the incorrect preferential claim.

Importers should therefore ensure that the Article 65 increments declared in the COVE/MVE (assists, royalties, packing, freight) match the non-originating-materials values and transaction-value figures used in the USMCA origin worksheet. Discrepancies between the COVE and the origin calculation are a common audit trigger.

Current status (June 2026): voluntary until July 31, then compulsory

As of June 4, 2026, the electronic COVE/MVE remains voluntary. Importers may choose to file via VUCEM and obtain an acuse de valor, or may continue to prepare the manifestación de valor under the RGCE 2025 rules (paper format or escrito libre) and deliver it to the customs broker or to SAT on request. Beginning July 31, 2026, the electronic transmission via VUCEM becomes mandatory for all operations subject to the requirement. The three delays (December 2025, March 2026, June 2026) reflect SAT's recognition that many importers — particularly small and mid-sized companies without dedicated trade-compliance staff — needed additional time to:

  • Obtain or renew the legal representative's e.firma;
  • Establish internal workflows to capture assists, royalties, and related-party data at the purchase-order stage (not after the fact);
  • Train staff on the VUCEM platform;
  • Coordinate with foreign suppliers to obtain the detailed breakdowns of packing, freight, and insurance charges that the COVE format requires; and
  • Test the system during the voluntary period to identify and resolve validation errors before the mandatory deadline.

Importers are strongly encouraged to begin filing COVEs electronically now, even while the requirement remains voluntary, to surface any procedural or data-capture issues before July 31, 2026, when SAT will enforce the obligation without further extensions.

Source: Ley Aduanera, Article 59, Cámara de Diputados (as amended November 19, 2025) Source: Reglas Generales de Comercio Exterior para 2026, Rules 1.9.16 and 1.9.17, SAT (published December 27, 2025) Source: Anexo 1 de las RGCE para 2026 (Formato E2: Manifestación de Valor), SAT (published January 8, 2026) Source: Comunicado de Prensa Conjunto 16/2026: Manifestación de Valor Electrónica, ANAM (June 2, 2026)

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