In brief
On 1 August 2025, the Tax Administration Service (SAT) uploaded to the Mexican Foreign Trade Digital Window (VUCEM) the electronic prescribed form for the “Customs Value Declaration”. This form also triggers the effectiveness of the obligation set forth in Article 81 of the Regulations to the Customs Law, which had been dormant since publication in 2015.
The transmission of the Electronic Customs Value Declaration, along with its annexes, will be mandatory starting on 9 December 2025.
Although the form and its date of entry into force have been announced, practical usefulness has been questioned due to its complexity and the documentary burden it entails.
Below are key elements and recommendations.
Key elements of the new obligation
The entry into force of the Electronic Customs Value Declaration brings several critical points that importers must consider, such as:
- High documentary burden: Each foreign trade operation must be accompanied by multiple documents supporting the value of the goods.
- Operational impact: Companies must adjust their internal processes to ensure all information is accurate and up to date.
- Fines for errors: Incorrect or incomplete declarations may result in penalties ranging from MXN 2,330 to MXN 3,310 (USD 125.94 to USD 178.91 considering an exchange rate of MXN 18.5 per Dollar) per document.
Progress in reform implementation and expected scenarios
Implementation of the Customs Value Declaration and its annexes through VUCEM starting 9 December 2025 anticipates an increase in rigorous audits focused on verifying that the data recorded in the customs declaration is correct and that the attached documents are properly linked. This will allow SAT to perform broader and more precise data cross-checks. Additionally, it is expected that additional documents will be requested, some of which may contain information classified as confidential for commercial purposes.
It should be noted that the additional documents to be presented as annexes to the Customs Value Declaration, are also listed among the additional documents to be transmitted with the import declaration (Pedimento) in accordance with the recently approved amendments to the Customs Law.
Recommendations
Given the imminent entry into force, it is essential for companies to conduct a thorough review of their internal processes. Proper organization, validity, and document linkage will be key elements to ensure regulatory compliance and avoid administrative contingencies or future penalties.
In this new regulatory environment, companies must adopt a proactive and strategic stance to ensure compliance with their customs and tax obligations. It will be essential to implement continuous review mechanisms and internal audits that systematically verify the correct documentary and operational integration of foreign trade processes. A solid structure and well-defined procedures will facilitate adaptation to the new requirements and will be fundamental to prevent observations from the authority and avoid penalties resulting from formal or material non-compliance.
In this context, having specialized guidance can make a difference. At Baker McKenzie, we have professionals who combine technical and legal expertise in foreign trade, allowing us to approach these types of reforms with a comprehensive vision.
