The Pedimento Field That Can Tie Up Your Cash for Twelve Months

Two importers file the same fracción arancelaria on the same day, at the same declared value, and that value sits below the reference price Mexico publishes for those goods. Both shipments clear. One of them moves on. The other has just committed capital to a deposit it will not see again for twelve months.

Nothing about the goods decides which importer is which. One field on the pedimento does.

On September 14, 2026, SAT published on its portal the Fifth Anticipated Version of the Second Resolution of Amendments to the Reglas Generales de Comercio Exterior for 2026, together with the Second Modification to Anexo 22, the pedimento filling instructions. The Manifestación de Valor dates most of the market has been tracking did not move. Apéndice 8, the identifier table that decides which of those two importers posts a guarantee, did.

Two cost paths for the same declared value

Article 86-A, section I of the Ley Aduanera sets the mechanism. An importer who makes a permanent import and declares a value in the pedimento below the estimated price published by the Secretaría must guarantee, through a deposit in a cuenta aduanera de garantía (a customs guarantee account opened at an authorized credit institution or brokerage house), the contributions and any antidumping or countervailing duties corresponding to the difference between the declared value and the reference price.

That amount is not a penalty and it is not a duty. It is the gap, financed by the importer until the clock runs out. The same article sets the clock. The guarantee is cancelled twelve months after the import, unless the customs authority has begun exercising its verification powers, in which case the period runs until a definitive resolution issues. Where omitted contributions or countervailing duties are determined, they are collected against the guarantee itself.

On paper, both shipments cleared the same day under the same rules. In practice, one operation financed a twelve month position and the other did not, and the entry that separated them was made before the cargo moved.

This is why the identifier carries more weight than its size suggests. A declared value below the reference price can be entirely correct. Correct is not the same as exempt, and the pedimento is where the difference has to be stated.

What the September 14 version changed on the pedimento

Apéndice 8 of Anexo 22 lists the identifiers declared on the pedimento. Two of them govern this decision, and both are declared at pedimento level rather than line level.

EX, exención de cuenta aduanera de garantía. This is the identifier that states an exception to posting the guarantee for goods subject to a reference price. In the September 14 text, its first complement enumerates the qualifying cases. The base case is a declared value equal to or above the reference price under the second paragraph of regla 1.6.29. Two parallel cases cover values equal to or above the reference price under Anexo 3 and under Anexo 5 of the Resolución de precios estimados. A separate case covers goods exempt from the General Import Duty (IGI) under the trade agreements Mexico has in force, pointing to section V of that same rule.

A long block of the table is devoted to vehicles: units not described in Anexo 2 of the Resolución de precios estimados because the fracción arancelaria and NICO are not listed or the model year falls outside it, imports under diplomatic franchise, special or adapted vehicles for personal use, operations by companies that dismantle used vehicles, units at or below 8,864 kilograms gross vehicle weight whose serial number or model year is thirty years or older than the current model year, and permanent imports under the used vehicle regularization decree. One of those cases carries its own second complement: the registration key of the foreign supplier that sold the vehicle.

GA, cuenta aduanera de garantía. This is the identifier that states the guarantee was posted. Its complement is narrower. It covers merchandise listed in Anexo 2, Anexo 3 and Anexo 5 of the Resolución de precios estimados, plus one regime case we return to below.

Apéndice 9 changed in the same document. Clave C1, the key for non-tariff regulations and restrictions administered by the Secretaría de Economía, was rewritten to cover prior import permits and automatic import permits for the fracciones arancelarias in numerals 1 section I, 3, 4, 8 BIS and 8 TER of Anexo 2.2.1 of that Secretaría's foreign trade rules, together with the corresponding notice. Its entry into force does not follow the resolution's general rule. It follows the sole transitory article of the amendment to those rules published in the DOF on May 28, 2026.

One further provision in the same resolution will matter to anyone facing numeral 8 TER. A new sixth paragraph to regla 3.1.2 allows importers to bring in up to two kilograms of each merchandise classified in the fracciones arancelarias and NICO listed in that numeral, as samples, for the purpose of obtaining the attestation report or compliance report those rules require. The pedimento has to carry a statement under oath declaring that purpose, and the remaining conditions of the samples rule still apply.

The case that splits one regime in two

The most consequential line in the updated table is not about value at all. It is about what you intend to do with the goods once they are inside.

Merchandise destined to the Strategic Bonded Facility regime (Recinto Fiscalizado Estratégico, or RFE) for processing, transformation or repair sits in the EX table. Merchandise destined to the same regime for handling, storage, custody, exhibition, sale or distribution sits in the GA table.

Same regime. Same facility. Same reference price. Opposite treatment, decided by the activity declared for the goods inside.

For an operation running mixed activity in an RFE, that puts a working capital variable inside a decision usually made for logistics reasons. A line that shifts from repair to distribution does not only change the workflow. It changes whether that shipment carries a guarantee.

The rest of the sort is mechanical, and it reduces to three questions asked in order. Does the merchandise appear in the Resolución de precios estimados at all, and in which Anexo, because the Anexo decides which case applies. Is the declared value at or above the reference price for that Anexo, which is the base exemption. And if it is below, does one of the specific cases reach the operation, whether the trade agreement exemption, one of the vehicle cases, or the RFE processing case.

An operation that cannot answer those three questions per line before the pedimento is filed is not choosing between EX and GA. It is defaulting into whichever one gets inferred on its behalf.

Talk to a Joffroy expert about a reference price exposure review across your fracciones arancelarias before your next filing cycle.

What did not move, and why that matters this month

The Manifestación de Valor dates in this resolution are unchanged from the Third Anticipated Version published on July 31. Importers may continue complying under the transitional scheme through September 30, 2026. Through December 31, 2026, the documentation referred to in Article 81, sections II, III and IV of the Reglamento de la Ley Aduanera does not need to be transmitted, provided it is transmitted under Article 36-A of the Ley. Through that same date, importers may opt to transmit format E15, carrying the general data of the contracts associated with the transaction.

We covered those dates, and the rule that makes them usable, when they were published. What is worth restating in the middle of September is the arithmetic. The transitional window closes at the end of this month. The two December elections do not.

The resolution has still not been published in the Diario Oficial de la Federación. Under regla 1.1.2, the benefits it contains apply from the moment they are made known on the SAT portal. That is what makes the September 30 date and the December elections usable today, and it is also why version history is an operational matter rather than a bibliographic one. A compliance calendar built on the Second Anticipated Version is still showing a July 31 date that has now been superseded twice.

Across more than 190,000 customs operations a year at 39 or more ports, the failure we see when a table like Apéndice 8 is amended is rarely a misreading. It is that nobody re-opens a classification settled months ago. The identifier was correct when it was chosen, the operation kept filing it, and the table moved underneath the decision.

What to run before your next filing

Pull your reference price exposure first, not your identifier history. Start from the fracciones arancelarias you file most and check them against the Resolución de precios estimados and its Anexos. Volume decides where the money is, and the Anexo a fracción sits in decides which EX or GA case applies to it.

Re-run the EX and GA logic on any line you have been filing the same way for months. The lines at risk are not the complicated ones. They are the routine ones where the identifier was set once and has been copied forward since.

If you operate inside an RFE, map activity to identifier explicitly. Processing, transformation and repair fall on one side of the table; handling, storage, custody, exhibition, sale and distribution fall on the other. Anyone who can move a line between those activities needs to know that the move has a financing consequence.

Check whether numeral 8 TER reaches your catalog. If it does, the rewritten clave C1 and the new two kilogram sample route are both live questions for you, and the C1 entry into force follows the Secretaría de Economía transitory article rather than this resolution's.

The field decides where the cash sits

The goods clear either way. What changes is whether your money crosses with them or waits a year in a deposit account.

That outcome is settled in a table most operations never open, in a field most executives never see, by a decision taken before the truck reaches the gate. Twelve months of committed capital is not a compliance detail. It is a financing line, and unlike most financing lines, every input to it is published.

If you want that sort run against your own lines, with the September 30 Manifestación de Valor window closing at the same time, talk to a Joffroy expert about a combined readiness review this month.

TRADE. UNDER CONTROL.