In recent years, the Mexican customs authority has accelerated the digitalization of foreign trade processes with a clear objective: greater traceability and stronger control over customs-value determination.
Within this process, one of the most relevant instruments is the Electronic Value Declaration, a document that has become central to supporting the legality of import operations.
Beyond being an administrative requirement, the Value Declaration establishes the documentary basis on which foreign trade duties and the importer’s responsibility before the authority are determined.
From operating requirement to key compliance document
The Value Declaration is the document through which the importer declares, under oath, the elements that make up the customs value of imported goods. This value is the basis for calculating:
- General Import Duty (IGI).
- Import VAT.
- Countervailing duties.
- Other applicable contributions.
Its legal basis is mainly found in Article 59, section III, and Articles 64 to 78 of the Mexican Customs Law, which regulate customs-value determination. The electronic version is part of the digitalization driven through the foreign trade electronic file, whose use has been consolidated through the General Foreign Trade Rules published since 2023.
The objective is clear: every import operation should have digital, verifiable and available documentary support for future reviews.
What it really means for the importing company
The Electronic Value Declaration requires the importer to document all elements that make up the price paid for the goods. This includes:
- Commercial invoice.
- Purchase contracts.
- Indirect payments to the supplier.
- Royalties or license fees linked to the product.
- Transportation and insurance costs.
- Commercial relationship between buyer and seller.
In practical terms, the importer must be able to reconstruct the documentary logic behind the price declared in the customs entry. If the authority detects inconsistencies between the commercial transaction and the declared value, verification procedures may lead to customs-value adjustments, omitted duties and administrative fines.
Responsibility is clearer than many companies believe
One of the most relevant aspects of the Value Declaration is the clear assignment of responsibilities. The obligation to provide information belongs to the importer or its legal representative. The customs broker transmits the customs entry based on the information provided, but is not responsible for determining the commercial value of the transaction.
For that reason, importing companies must ensure that the information used to prepare the Value Declaration is documented, consistent with the commercial transaction and aligned with applicable legal provisions.
Practical case 1: the hidden cost of indirect payments
Suppose a company imports industrial components from Asia. The commercial invoice is USD $120,000, international freight is USD $4,500 and insurance is USD $800. During a later review, the authority detects that the importer also pays a technology charge equal to 4% of the merchandise value as part of a license agreement with the supplier.
That payment was not considered in the customs value. Under Articles 65 and 66 of the Customs Law, certain payments related to the purchase of the goods may be considered additions to customs value. The potential consequence is a recalculation of customs value, omitted contributions and fines.
In these cases, the problem is not always the value itself. The real problem is the lack of integration between the commercial transaction and the customs documentation.
Practical case 2: related parties, greater scrutiny
A more sensitive scenario occurs when the import is carried out between companies from the same corporate group. For example, a Mexican company imports electronic components from its parent company in Asia. The invoice shows a price of USD $95 per unit, while comparable market transactions range between USD $100 and $110.
In this context, the authority may analyze whether the relationship between buyer and seller influenced the declared price. This analysis is contemplated in Article 68 of the Customs Law and in the principles of the WTO Customs Valuation Agreement.
If the authority concludes that the relationship affected the price, it may request transfer-pricing studies, additional financial information and market-comparison documentation. Related-party operations therefore require an even higher level of documentation within the Value Declaration.
How the electronic process works, step by step
Commercial transaction
↓
Document integration: invoice · contracts · commercial agreements · associated payments
↓
Preparation of the Value Declaration
↓
Integration into the foreign trade electronic file
↓
Customs entry transmission
↓
Document availability for future reviews
This scheme allows the authority to trace the economic logic behind each import operation.
The real shift: from procedure to strategic tool
Historically, many companies treated the Value Declaration as an operating requirement. Today, it has become a strategic document for tax and customs compliance. A well-structured declaration can support the declared value, reduce audit risk and strengthen legal defense in future reviews.
At Palos Garza, we work with companies that want to strengthen the documentary consistency of their foreign trade operations, including customs-value structures, electronic files, related-party operations and preparation of the Electronic Value Declaration.