The mandatory implementation of MVE represents a significant change in importers’ customs valuation processes. Its implementation requires companies to review and strengthen the internal controls for collecting, validating, documenting, and maintaining the records that support the customs value declared on imported goods.
Importers currently have an extension until September 30, 2026, to continue complying under the previous framework. This transition period provides an opportunity to strengthen internal processes before the MVE becomes mandatory.
Key Preparation Actions
- Map the information used to determine customs value.
It will be important to review the availability, traceability, and consistency of the commercial, financial, and logistics information that affects the determination of customs value. - Review contracts and supporting documentation.
Confirm that contracts, and other supporting records are consistent with the information to be reported in the MVE. Until December 31, 2026, importers may elect to submit Form E15, “Information on Contracts Associated with the Declaration of Value” setting forth the general information of the contracts related to the transaction, instead of submitting the contracts through the Digital Window (Ventanilla Digital). - Ensure consistency of commercial terms.
It will be particularly important to verify that the Incoterms applicable to each transaction are consistent with the actual commercial and logistics arrangements, as well as the with the documentation supporting each import transaction. - Assign internal responsibilities.
Companies should clearly define who prepares, validates, and approves the information included in the MVE, as well as who coordinates the information provided to the customs broker or customs brokerage company. The proper determination of customs value requires commercial and financial information that, in many cases, is only available to the importer. - Conduct tests before the mandatory implementation date.
We recommend that companies that have not yet implemented the MVE use the transition period to carry out pilot transactions, identify inconsistencies, and adjust their internal procedures.
More Than a Technology Change
The main challenge is not limited to transmitting the MVE. Importers must also have sufficient information and documentation to support the customs value determined for each transaction and demonstrate its consistency in the event of a customs audit.
Accordingly, we recommend using this transition period to review customs valuation processes, responsibilities, and controls, as well as the proper maintenance of the foreign trade compliance file.
At Cuesta Campos, we can assist companies in reviewing their customs valuation processes, supporting documentation, and internal procedures for the implementation of the MVE.
Contact
Alejandro Martínez
Ana Victoria Parra
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