Introduction

Beginning December 9, 2025, importers in Mexico will be required to complete and submit the Electronic Value Manifest through VUCEM (Mexico’s Electronic Single Window). This measure increases the importer’s direct participation and responsibility in determining and declaring the correct customs value of imported goods. 

What is the Value Manifest?

The Value Manifest is an official format established by the Tax Administration Service that must be completed and signed under oath by the Mexican importer.  It includes all elements necessary to determine the correct customs value of the goods, such as:

• Importer information and the designated customs broker.
• Seller details and description of the merchandise.
• Transaction information relevant to valuation (e.g., relationship between the parties, restrictions, payments, royalties).
• Additions to the price (commissions, freight, insurance, loading, unloading costs).
• Deductions from the price (construction, assembly, domestic freight and insurance).
• Pedimento and invoice information (numbers, dates).
• Valuation methodology (transactions value, transaction value of similar or identical merchandise, unit cost, or computed value), including the justification for the method selected.  

Background: The Traditional Value Manifest

Until December 8^th, 2025, importers are obligated to complete, print and manually sign the Value Manifest Format E2.  This format must be maintained as part of the importer’s customs records, shared with the designated Mexican Customs Broker, and submitted to authorities only upon request.  

In practice, many companies relied heavily on their customs brokers to prepare and retain Format E2, along with supporting documentation such as invoices, proof of payment, contracts, incrementable costs, and other valuation evidence. 

Regulatory Changes Leading to the Electronic Filing

Beginning December 9^th, 2025, the manual process will be replaced entirely.  Importers must now log into the VUCEM and complete the designated electronic fields.  Although the required information remains substantially the same, the submitting method changes from manual to electronic, and the Value Manifest must now be submitted electronically before importation takes place.  

The shift to an electronic filing moved from discussion to reality on December 30, 2024, when Tax Administration Service (SAT) published the General Customs Rules for 2025 (Reglas Generales de Comercio Exterior para 2025) in the Diario Oficial de la Federacion (Mexican Official Gazette).  These rules included Transitory Article Fifth, requiring importers to electronically submit the Value Manifest within 90 days after its publication on VUCEM – though no further guidance was issued at that time.

On August 1, 2025, VUCEM published Informative Notice No. 08 announcing that the Value Manifest was available on the VUCEM platform and that electronic submission would become mandatory on December 9, 2025 (90 days after publication).  

Between August 1 to December 8, 2025, companies could voluntarily submit the Value Manifest through VUCEM as a transition period, during which errors would not trigger penalties.  Beginning December 9, 2025, electronic submission becomes mandatory, and any changes to the customs value, errors or omissions may result in sanctions.

What the New Electronic Value Manifest Requires

To comply with the new requirement, the importer must:

• Possess solid knowledge and experience in customs valuation.
• Have all documents necessary to support the customs value readily available, including invoices, payment records, contracts, incrementable costs (freight, insurance, royalties, commissions), and other evidence.
• Access VUCEM using the importer’s e.firma (certificate, private key, and password) and complete the Value Manifest electronically.
• Accurately complete all required files, including importer data (CURP/RFC), pedimento and customs broker information, invoice information, valuation method, transaction type, price paid, additions to price, INCOTERM, related-party information, payment date, currency, exchange rate, and other required elements.
• Ensure that all supporting documents are complete, consistent and accurate.  
• Verify that uploaded documents comply with VUCEM’s technical specifications (grayscale, under 3MB, 300 DPI, etc.).
• Generate and retain the VUCEM confirmation and acknowledgment, which must be declared in the corresponding pedimento.
• Coordinate internally with all relevant departments: customs, trade, finance, accounting, logistics, purchasing, legal, compliance, etc., and ensure they understand the importance of this filing.
• Coordinate with the Mexican Customs Broker to ensure that all information is ready for the preparation of other documents required for Customs clearance.
• Maintain all supporting documentation for the required retention period (typically 5 years).
• Address any additional requirements depending on the Customs regime, transaction type and any factors that affect Customs value of the goods.

Exemptions and Special Rules

Under current regulations, all imports into Mexico must completely provide and maintain the Value Manifest (Format E2).  Exemptions apply to the automotive industry and IVA-IEPS Certified companies.

Under the new Electronic Value Manifest, exemptions apply to:

• Certain temporary imports under special programs.
• Temporary imports made by OEA-certified companies.
• Specific operations in the automotive industry.

Each exemption carries detailed conditions that must be carefully evaluated to ensure proper compliance.

Key Practical Challenges for Importers

• The importer becomes directly responsible for each filing.
• Filing requires the importer’s e.firma, which many companies are reluctant to share with third parties due to its legal implications.
• The importer must have all required documents before Customs clearance.
• Personnel must be trained in valuation methodology, INCOTERMS, and related criteria.
• If valuation errors or changes arise after submission, such as price or exchange rate adjustments, the Value Manifest must be corrected through VUCEM.  Please note that inaccuracies may result in fines.
• Many brokers have indicated they will no longer complete the Value Manifest on behalf of importers unless additional fees are paid – or will not prepare it at all.   Under the new Mexican Customs law – taking effect on January 1, 2026, Mexican customs brokers will assume increased responsibility with limited waivers for errors.  

Outstanding Questions and Ongoing Uncertainty

Companies have expressed uncertainty about how to correctly complete and submit the Value Manifest through VUCEM, as several practical scenarios remain unaddressed.  Common questions include:

• Are low-value shipments exempt?
• Can a pedimento be processed if the Value Manifest contains errors?
• What price should be declared as price paid, payable price or compensation if there is no transaction value?
• If price adjustments are made after importation – an ordinary and legal practice by many industries – will this trigger penalties?
• How should value be declared for temporary imports?
• Do virtual importations require a Value Manifest?
• Which exchange rate should be used? 
• Does a purchase order or invoice qualify as a “contract”?

Companies expect SAT to publish a notice clarifying several frequently asked questions.  Without such clarification, many questions will remain unanswered, increasing uncertainty and concern regarding potential sanctions. 

Recommendations for Importers

Some practical recommendations include:

• Designate and train internal personnel responsible for preparing and submitting the Manifest, ensuring they understand both VUCEM and customs valuation rules.
• Become familiar with the VUCEM platform and the specific fields for the Value Manifest.
• Collect all supporting valuation records in advance: invoices, payments, contracts, incrementable costs, packing list, etc.
• Coordinate internally among Customs, trade compliance, finance, accounting, legal, purchasing, and logistics, etc. to ensure consistency and accuracy.
• Maintain ongoing communication with Mexican Customs Brokers to facilitate compliance and the preparation of other documents for Customs clearance. 
• Continuously monitor operations to ensure ongoing compliance.
• Review how your Value Manifest has historically been prepared and verify past valuation practices.
• Review all E2 prepared within the last 5 years to ensure they are complete, signed, accurate and properly stored in your records.  

Conclusion

The transition to the Electronic Value Manifest emphasizes the importance of accurate valuation practices and the importer’s active participation in this process.  Importers remain fully liable for the correctness of the declared Customs value. The electronic system provides immediate and easier access to information, enabling one to quickly detect discrepancies that may result in violations and penalties.  

Giving this increased visibility, companies should prepare for these changes, understand their expanded responsibilities, and implement robust processes to ensure full compliance.

Disclaimer

The information contained in this document is provided for general informational purposes only. It does not constitute legal advice, does not create an attorney-client relationship, and should not be used as a substitute for professional legal consultation. While every effort has been made to ensure the accuracy of the information at the time of publication, the author assumes no responsibility for errors, omissions, or subsequent regulatory changes.

Readers and companies should verify all requirements directly with the applicable laws, regulations, and official government publications, and should consult qualified legal counsel before making decisions or taking action based on the contents of this document. The author, publisher, and any affiliated parties expressly disclaim all liability for any actions taken or not taken based on the information provided herein.