Manifestación de Valor (Format E2) vs. COVE in Mexico: Rules 1.5.1 & Article 81 RLA
For US finance and trade compliance executives overseeing a Mexican manufacturing plant, few compliance changes in 2026 carry more audit risk than the transition to the Electronic Customs Value Declaration (Manifestación de Valor Electrónica, Format E2) via VUCEM, governed by Article 59, Section III of the Mexican Customs Law, Article 81 of the Customs Law Regulations (RLA), and RGCE Rule 1.5.1.
Two widespread misconceptions put US-owned subsidiaries at risk:
- Confusing the Manifestación de Valor with the COVE: Believing that because the customs broker already transmits an XML invoice (
COVE) for every shipment, the company’s customs valuation obligation is satisfied. - Relying on outdated postponement dates: Because SAT extended the electronic enforcement date several times, many importers have not built the internal document repository required to satisfy Article 81 of the RLA when the transitory window closes.
1. COVE vs. Manifestación de Valor (Format E2): Two Completely Different Filings
Both filings involve “value” and both are transmitted through Mexico’s Single Window (VUCEM), but they serve completely different legal functions:
| Dimension | COVE (Comprobante de Valor Electrónico) | Manifestación de Valor (Formato E2 del Anexo 1) |
|---|---|---|
| Statutory Basis | Article 59-A & Article 36-A, Sec. I, a) of the Customs Law; RGCE Rule 1.9.18 | Article 59, Section III of the Customs Law; Article 81 RLA; RGCE Rule 1.5.1 |
| Core Question It Answers | ”What items, quantities, and unit prices appear on the commercial invoice or shipping statement?" | "How did the importer legally calculate the Customs Value (Valor en Aduana), what valuation method applies, are the parties related, and what freight, insurance, royalties, or tooling assists were added?” |
| VUCEM Output Declared on the Pedimento | COVE... e-document number (declared in Table 505 of the pedimento) | Specific EDocument acuse for Format E2 (declared via identifier in the pedimento per Rule 1.5.1, Section III) |
| Who Possesses the Underlying Data? | The shipping/logistics department and the customs broker (from the invoice PDF/XML) | The Importer’s Finance, Tax & Legal Departments (intercompany contracts, wire payment receipts, royalty agreements, tooling assists, freight invoices) |
| Who Bears Primary Legal Liability? | Importer and Customs Broker jointly for invoice data transcription | Exclusively the Importer (the broker can be authorized via RFC to download Format E2, but cannot invent the company’s financial valuation records) |
2. The Three 2026 Deadlines in the Eleventh Transitory Article of the RGCE
Why have trade newsletters reported three different 2026 dates (March 31, September 30, and December 31)? Because SAT’s Eleventh Transitory Article of the 2026 RGCE (as amended by the Second Resolution of Modifications to the RGCE 2026) establishes three separate transition rules that do not expire on the same day:
| Expiration Date | What the Transitory Rule Allows | Practical Meaning for Your Compliance Team |
|---|---|---|
| 1. Until September 30, 2026 (Hard Switch on October 1, 2026) | Allows importers to continue complying with Article 59, Section III under the legacy 2025 transitory scheme (paper/digital signature workflow without mandatory per-operation VUCEM Format E2 transmission). | This is the master operational deadline. Starting October 1, 2026, transmitting Format E2 via VUCEM per operation under Rule 1.5.1 becomes mandatory. |
| 2. Until December 31, 2026 | Exempts importers from re-attaching the documents listed in Article 81, Sections II, III, and IV of the RLA (transport documents, origin certificates, and guarantee accounts) to Format E2, provided those documents were already digitized as e-documents with the pedimento under Article 36-A. | Prevents duplicate uploading of bills of lading and origin certificates during Q4 2026, but does NOT exempt Sections I, V, VI, or VIII (invoices, payment proofs, freight/insurance proofs, and incrementables). |
| 3. Until December 31, 2026 | Allows importers to submit Format E15 (“Information on Contracts Associated with the Manifestación de Valor”) instead of uploading the full text of commercial/intercompany contracts required under Article 81, Section VII of the RLA. | Gives corporate legal teams until year-end 2026 to summarize intercompany maquila, supply, and royalty contracts via Format E15 before full contract digitization applies in 2027. |
3. The 8 Mandatory Evidentiary Attachments of Article 81 RLA
The true challenge of the Manifestación de Valor is not filling out the fields of Format E2 on VUCEM; it is assembling the eight statutory attachments mandated by Article 81 of the Customs Law Regulations (Reglamento de la Ley Aduanera, RLA):
| Art. 81 RLA Section | Mandatory Supporting Document | Why This Creates a Bottleneck for US-Owned IMMEX Plants |
|---|---|---|
| I | Commercial Invoice (Factura comercial or equivalent value document) | On consigned shipments where no commercial sale occurs, must match the pro-forma/customs valuation invoice and COVE. |
| II | Transport Documents (Bill of Lading, Air Waybill, Packing List) | Covered by the Art. 36-A carve-out through Dec 31, 2026 if already transmitted as pedimento e-documents. |
| III | Proof of Origin and Provenance | Required whenever preferential tariff treatment (TL USMCA, TLCUEM, CPTPP) or anti-dumping exemption is claimed. |
| IV | Customs Guarantee Account (Cuenta Aduanera de Garantía) | Applicable only to goods subject to SHCP estimated reference prices (precios estimados). |
| V | Proof of Payment for the Merchandise (Bank wire transfers, letters of credit, intercompany netting statements) | Major pain point: Most imports are bought on 30/60/90-day credit terms, operated through US parent treasury intercompany netting, or shipped on zero-cash consignment under a Maquila Contract! |
| VI | Documentation of Freight, Insurance, and Related Expenses | Invoices and payment proofs for foreign inland freight, ocean/air freight, cargo insurance, and Laredo cross-dock/loading charges up to the Mexican border crossing (Article 65, Section I, d) Customs Law). |
| VII | Contracts Related to the Transaction (Supply agreements, Maquila contracts, distribution or licensing agreements) | Can be satisfied via Format E15 through December 31, 2026; requires formal contract governance between US HQ and the Mexican subsidiary. |
| VIII | Documentation Supporting Incrementables (Article 65 Customs Law) | High audit risk: Proof of any US-supplied molds, dies, tooling, engineering assists, packaging materials, royalties, or license fees provided free of charge or at reduced cost by the buyer (Article 65, Sections II and III). |
How Consignment Maquiladoras Handle Section V (No Cash Payment) and Valuation Methods
In a pure consignment maquiladora where the US parent ships raw materials to Mexico without selling them:
- Valuation Method (Articles 64 and 71–78 Customs Law & Appendix 11 of Anexo 22): Because there is no sale for export to Mexico (no existe compraventa), strictly speaking the Transaction Value Method (Clave
1: Valor de Transacción) under Article 64 does not apply unless the goods were purchased for delivery to Mexico; consigned goods are valued under Clave6(Último Recurso: Fallback Method under Article 78) or the applicable secondary method (2to5), supported by the Maquila Contract and the foreign principal’s acquisition cost invoices. - Intercompany Relationship (Vinculación: Article 68 Customs Law): Format E2 requires explicitly declaring whether buyer and seller are related parties (existe vinculación) and, in buy-sell intercompany structures, affirming that the relationship did not distort the transaction price.
4. What Happens If Format E2 Is Incomplete or Inaccurate?
Under RGCE Rule 1.5.1 and Article 184/185 of the Customs Law:
- How to Correct an Error: You cannot “edit” an already transmitted Format E2. Under Rule 1.5.1, Section V, if the declared valuation information or attached documentation was incomplete or inaccurate, the importer must generate a new Format E2 in VUCEM. If the change alters the customs value declared on the pedimento, the importer must also file a Rectification Pedimento (
R1) under Rule 6.1.1. - When You Are Blocked From Correcting It: You cannot generate a new Format E2 once the automated selection mechanism triggers a red-light customs inspection (Reconocimiento Aduanero) until that inspection concludes, nor once SAT has initiated a formal audit (facultades de comprobación), except as part of a formal self-correction payment.
- Record Retention (Article 30 CFF): The importer must preserve the digital Format E2 and all Article 81 RLA attachments for 5 years under Article 30 of the Federal Fiscal Code.
5. Immediate Action Plan for US Headquarters & Mexican Compliance Teams
- Register Your Customs Brokers’ RFCs in VUCEM for Format E2 Access: Under Rule 1.5.1, Section II, decide whether your internal team will transmit Format E2 directly and authorize your customs brokers’ RFCs in VUCEM to query/download the
EDocument, or how the pre-dispatch workflow will operate without delaying trucks at the border. - Audit Your Valuation Method Code (
1vs.6in Appendix 11) and Incrementables (Art. 65): Stop allowing customs brokers to default every shipment toValoración = 1 (Valor de Transacción)with$0.00 Incrementablesif your plant operates on consignment or uses US-owned molds/assists (Art. 65, Sec. II). - Prepare Your Format E15 Contract Inventory Now: Have corporate legal compile all active intercompany Maquila Contracts, Supply Agreements, Bailment (Comodato) Agreements, and Royalty Agreements so they are ready for Format E15 and Article 81, Section VII.
- Standardize Proof of Freight & Incrementables (Art. 81, Sec. VI & VIII): Create a monthly or per-shipment digital binder linking US freight forwarder invoices, marine/cargo insurance policies, and US treasury payment confirmations to the corresponding Mexican import pedimentos.
Frequently asked questions
What is the Manifestación de Valor in Mexico?
The Manifestación de Valor (Customs Value Declaration) is the sworn legal declaration required under Article 59, Section III of the Mexican Customs Law and RGCE Rule 1.5.1 in which the importer explains and substantiates to SAT how the customs value (valor en aduana) of imported merchandise was determined, including the valuation method used (Articles 64 to 78), the relationship between buyer and seller, and all dutiable additions (incrementables under Article 65) or exclusions (decrementables under Article 66). Under the electronic mandate, it is transmitted via VUCEM using Format E2 of Annex 1.
Is the Manifestación de Valor the same thing as the COVE?
No. COVE (Comprobante de Valor Electrónico, governed by Article 59-A) is simply the XML transmission of the commercial invoice or shipping statement data (item descriptions, quantities, and unit prices). The Manifestación de Valor (Format E2, governed by Article 59, Section III and Rule 1.5.1) is the legal valuation declaration that proves why that price is the valid customs value, whether the parties are related (vinculación), how freight/insurance/royalties/tooling assists were added under Article 65, and how the goods were paid for.
What are the three 2026 compliance deadlines for the electronic Format E2 under the RGCE Transitory Rules?
Under the Eleventh Transitory Article of the 2026 RGCE (as amended by the Second Modification Resolution), there are three distinct cutoff dates: 1) Through September 30, 2026, importers may continue complying via the legacy 2025 transitory scheme (making October 1, 2026 the hard enforcement date for electronic Format E2 via VUCEM); 2) Through December 31, 2026, importers are exempted from re-transmitting the attachments in Article 81, Sections II, III, and IV of the Customs Law Regulations (RLA) with Format E2 if those documents were already transmitted as e-documents with the pedimento under Article 36-A; and 3) Through December 31, 2026, importers may file Format E15 (Contract Information Summary) in lieu of uploading full commercial contracts under Article 81, Section VII.
What supporting documents must be attached to the Manifestación de Valor under Article 81 of the Customs Regulations (RLA)?
Article 81 of the Reglamento de la Ley Aduanera (RLA) requires eight categories of attachments: I) Commercial invoice; II) Bill of lading, packing list, or air waybill; III) Proof of origin and provenance; IV) Customs guarantee account documents (when applicable); V) Bank wire receipts or proof of payment for the merchandise; VI) Invoices and proof of payment for freight, insurance, and related incrementables; VII) Contracts related to the transaction; and VIII) Documentation supporting any additions to value (such as royalties, assists, molds, or commissions) under Article 65 of the Customs Law.
Are IMMEX temporary imports or Certified Companies (RECE / OEA) still exempt from the electronic Manifestación de Valor?
Careful: While legacy rules historically exempted certain temporary imports or Rubro AAA/OEA companies from handing a paper Manifestación de Valor to the broker prior to dispatch, under the reformed RGCE Rule 1.5.1, Section VII, only four narrow statutory return/temporary scenarios (under Articles 103, 106, and 116) and automotive fiscal deposit operations (Rule 4.5.31, Section XVIII) are expressly exempted from transmitting Format E2. Every IMMEX importer must verify its exact transaction types against current Rule 1.5.1.
Does your operation have a case this page does not resolve?
This page explains the framework; it cannot decide your case. Describe the concrete situation and we will tell you what to ask, what to document and — where it applies — what kind of specialist or tool to look for.
AMMEX is an independent platform operated by Heberey LLC. We review your inquiry internally; any possible sharing with an external provider requires your prior authorization.