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Customs valuation in Mexico: transaction value, what to add, related party imports, the digital value statement and undervaluation risk

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Last verified: 2026-10-26 · Status: Changing

Import duty, the customs processing fee and import VAT are all built on the customs value, which is normally the transaction value: the price paid plus commissions, packing, freight, insurance and handling to the point of entry, assists supplied by the buyer, royalties paid as a condition of sale and proceeds that revert to the seller. Transaction value can be used between related parties (5 percent voting ownership is enough to be related) only if the relationship did not influence the price; otherwise the secondary methods apply in a fixed order. For every import the importer must file a value statement (formato E2) through the Ventanilla Digital and declare its e-document in the pedimento; the transitional option to comply under the 2025 rules ended on 30 September 2026, and a price 50 percent or more below identical or similar goods can lead to seizure and suspension from the importers register.

USD conversions use MXN 18.5026 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 16 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Mexican customs converts foreign currency values at the rate set under the customs rules, which differs slightly. Conversions are for orientation only.

Key facts

Basis of customs value	Transaction value including transport, insurance and handling to the point of entry (CIF basis) Ley Aduanera arts. 64 and 65, as of 2026-10-26 · in force
Voting ownership that makes parties related for valuation	5 %Ley Aduanera art. 68, section IV, as of 2026-10-26 · in force
Value gap versus identical or similar goods that allows precautionary seizure	50 %Ley Aduanera art. 151, section VII, as of 2026-10-26 · in force
Term of the estimated price guarantee if no audit	12 monthsLey Aduanera art. 86-A, section I, as of 2026-10-26 · in force
End of the option to file the value statement under the 2025 transitional rule	2026-09-30 dateRGCE 2026 transitory Eleventh, amended DOF 22 September 2026, as of 2026-10-26 · in force

The rule

1. Transaction value is the default. The tax base of the general import duty is the customs value, which is the transaction value: the total price paid or to be paid, directly or indirectly, by the importer to or for the benefit of the seller, for goods sold for export to Mexico, adjusted under art. 65. Where transaction value cannot be used, the base is set under art. 71.Ley Aduanera, DOF 15 December 1995 (last reform DOF 19 November 2025), Art. 64, 1995-12-15 official text · verified 2026-10-26

2. What must be added. When borne by the importer and not included in the price: commissions and brokerage (except buying commissions); containers and packing treated as one with the goods and packing labor and materials; transport, insurance and related handling, loading and unloading up to the point of entry; the apportioned value of materials, parts, tools, dies, molds, consumables and engineering, design and plans made outside Mexico that the importer supplied free or at reduced cost (assists); royalties and license fees related to the goods that the importer must pay as a condition of sale; and any part of the proceeds of resale or use that reverts to the seller. Additions must rest on objective, quantifiable data.
Example: FOB price MXN 1,000,000 plus freight and insurance to Manzanillo MXN 60,000 and a royalty of 5 percent of the price payable as a condition of sale (MXN 50,000): customs value MXN 1,110,000. / FOB price USD 54,046 plus USD 3,243 freight and insurance and USD 2,702 royalty: customs value about USD 59,992.Ley Aduanera, DOF 15 December 1995, Art. 65, 1995-12-15 official text · verified 2026-10-26

3. What can be left out. Provided they are shown separately from the price in the CFDI or equivalent invoice: costs of construction, installation, assembly, maintenance or technical assistance after import; transport, insurance and handling after arrival in Mexico; Mexican taxes and countervailing duties; and payments to the seller such as dividends that are not directly related to the imported goods.Ley Aduanera, DOF 15 December 1995, Art. 66, 1995-12-15 official text · verified 2026-10-26

4. Related parties. Transaction value is accepted only if there are no restrictions on the buyer's use of the goods (other than legal, territorial or value neutral ones), the price is not subject to conditions that cannot be valued, no proceeds revert to the seller beyond the art. 65 adjustment, and either the parties are not related or the relationship did not influence the price. Persons are related if, among other cases, one holds directly or indirectly 5 percent or more of the voting shares of both, one controls the other, both are controlled by a third person, they are officers of each other's businesses, partners, employer and employee, or family. If asked, a related importer that cannot show the relationship did not affect the price loses transaction value (art. 78-A, section III).Ley Aduanera, DOF 15 December 1995, Arts. 67, 68 and 78-A, section III, 1995-12-15 official text · verified 2026-10-26

5. Secondary methods, in order. If transaction value cannot be used, customs value is determined successively by: (I) transaction value of identical goods; (II) transaction value of similar goods; (III) deductive (unit sale price) value; (IV) computed (reconstructed) value; (V) a flexible method under art. 78. The importer may choose to reverse the order of methods III and IV.Ley Aduanera, DOF 15 December 1995, Arts. 71 to 78, 1995-12-15 official text · verified 2026-10-26

6. Digital value statement (formato E2). For each operation, importers must transmit through the Ventanilla Digital the value statement format E2 with its supporting documents, declare the resulting e-document in the pedimento, keep it for the CFF record keeping period and may authorize their broker to consult it; an incomplete or inaccurate E2 must be replaced by a new one and, where the declared value changes, the pedimento rectified. The Second Resolution of Amendments to the 2026 rules extended until 30 September 2026 the option to comply under the 2025 transitional rule, and until 31 December 2026 relieves importers from transmitting the art. 81 sections II to IV documents through E2 if sent under art. 36-A and allows a summary of related contracts (format E15).Ley Aduanera art. 59, section III; Reglas Generales de Comercio Exterior para 2026, DOF 27 December 2025; Second Resolution of Amendments, DOF 22 September 2026, RGCE rule 1.5.1; transitory Eleventh of the RGCE 2026 as amended, 2026-09-22 official text · verified 2026-10-26 · changed: Rule 1.5.1 was amended by the First Resolution (DOF 14 May 2026) and the transitional period was moved by the Second Resolution (DOF 22 September 2026): the option to comply under the 2025 rules ended on 30 September 2026, and partial relief for supporting documents and contracts runs until 31 December 2026.

7. Undervaluation consequences. Customs may seize goods as a precaution when the declared value is 50 percent or more below the transaction value of identical or similar goods, unless the importer gave the guarantee of art. 86-A for goods with published estimated prices. Customs may also reject the declared value in an audit when the importer keeps no accounts or documents, gives false data, cannot show a related party price was unaffected, or declares false supplier or importer details. Importers that declare below an estimated price must deposit a guarantee in a customs guarantee account (or a bank letter of credit) for the difference, cancelled after twelve months if there is no audit.Ley Aduanera (reform DOF 19 November 2025), Arts. 78-A, 86-A, section I, and 151, section VII, 2025-11-19 official text · verified 2026-10-26 · changed: Decree DOF 19 November 2025 reworded art. 86-A: a bank letter of credit may replace the guarantee account deposit, the twelve month cancellation rule of section I took effect on 1 February 2026, and a new guarantee for goods entering strategic bonded zones (section III) took effect on 1 April 2026 (transitory First).

Item	Treatment	MXN	USD
Invoice price (FOB origin port)	Included (price paid)	1,000,000	54,046
Buying commission paid to own agent	Excluded (art. 65, section I, a)	0	0
Ocean freight and insurance to Manzanillo	Added (art. 65, section I, d)	60,000	3,243
Royalty of 5 percent payable as a condition of sale	Added (art. 65, section III)	50,000	2,702
Inland freight Manzanillo to warehouse, invoiced separately	Excluded (art. 66, section II, b)	0	0
Installation in Mexico, invoiced separately	Excluded (art. 66, section II, a)	0	0
Customs value	Base for IGI and DTA	1,110,000	59,992

Building the customs value of one import, verified 26 October 2026 against Ley Aduanera arts. 64 to 66. MXN figures; USD at MXN 18.5026.

Worked example

A Mexican subsidiary imports machine parts from its German parent, which owns 100 percent of it and is therefore related (art. 68). The invoice price is MXN 1,000,000 FOB Hamburg; the subsidiary also pays MXN 60,000 of freight and insurance to Manzanillo and a 5 percent technology royalty, MXN 50,000, that the parent requires as a condition of selling the parts.
The customs value is MXN 1,110,000 (about USD 59,992): price plus freight and insurance plus royalty (art. 65). With a 10 percent duty the IGI is MXN 111,000 and the DTA MXN 8,880; a later royalty audit that finds the royalty was left out would assess the omitted duty plus a fine of 130 to 150 percent of it (art. 178, section I).
Because the parties are related, the subsidiary keeps a transfer pricing file showing the price was set as between independent parties, so it can show under art. 78-A, section III that the relationship did not influence the price.

Step by step

1. Map every payment to the foreign seller and to third parties for each product line: price, commissions, freight, insurance, packing, assists, royalties and post import services.
2. Have suppliers show post import services, inland freight and Mexican taxes separately on the invoice or CFDI so they can be excluded (art. 66).
3. For related party imports, align the customs value with the transfer pricing documentation and keep evidence that the relationship did not affect the price.
4. File the E2 value statement in the Ventanilla Digital for each operation, authorize the broker to consult it and declare its e-document in the pedimento (rule 1.5.1).
5. If a product has a published estimated price and you declare less, deposit the art. 86-A guarantee before clearance.
6. Correct errors by issuing a new E2 and rectifying the pedimento before any physical inspection or audit starts (rule 1.5.1, sections V and VI).

Common traps

Leaving royalties out of the customs value. Royalties tied to the imported goods and paid as a condition of sale are part of the value (art. 65, section III) and are a frequent audit finding in related party imports.
Inconsistent customs and transfer pricing values. A year end transfer pricing adjustment that raises the price of imported goods can change the customs value of past imports.
Bundled invoices. Installation or inland freight that is not shown separately from the price cannot be excluded (art. 66, last paragraph).
Treating the E2 as paperwork. Since 1 October 2026 the 2025 transitional route is closed; a missing or inaccurate value statement is a breach of art. 59, section III.
Very low prices. A value 50 percent or more below identical or similar goods allows seizure of the goods (art. 151, section VII) and suspension from the importers register (RGCE rule 1.3.3, section XX).

Sources

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