The global compliance storm is no longer centered on the United States alone. While CBP’s IOR crackdown continues to make headlines, two other major markets have quietly rolled out equally consequential rule changes. Mexico has made electronic customs valuation declarations mandatory for all imports. The European Union has enacted its most significant customs reform since 1968, making e-commerce platforms directly liable as importers. For exporters and freight forwarders, the compliance map has been redrawn.
1. United States: CBP IOR Enforcement as Background
On September 18, 2026, U.S. Customs and Border Protection began enhanced enforcement of Importer of Record identity data on Form 5106. Under the new policy, CBP can immediately void an IOR number if the information on file is inaccurate or incomplete. The physical address must be the importer’s actual business location—not a broker’s office, freight forwarder’s address, or P.O. box. Customs brokers must also hold a Power of Attorney executed directly with the importer.
The enforcement remains in effect, and importers with US-bound cargo should continue to audit their Form 5106 data. However, the more recent developments in Mexico and the European Union are equally urgent and deserve close attention.
2. Mexico: Electronic Value Manifest (MVE) Now Mandatory
Effective October 1, 2026, Mexico’s tax authority (SAT) and customs agency (ANAM) fully enforce the mandatory submission of the Electronic Value Manifest (Manifestación de Valor Electrónica, or MVE) for all import operations. The deadline had been extended multiple times—from an initial August 1 target to September 30, before the final October 1 mandatory date was confirmed.
What is the MVE?
The MVE is a digital document integrated into Mexico’s Single Window for Foreign Trade (VUCEM). It requires importers to declare the customs value of goods entering Mexico before entry. The MVE includes declared customs value, Incoterms, payment terms, contracts, and proof of payment.
Transitional facilitation measures:
Recognizing the operational burden of the new system, SAT and ANAM have introduced several transitional measures. Through December 31, 2026:
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Transport documents, certificates of origin, and guarantee account documents do not need to be transmitted through VUCEM, provided they are attached to the customs declaration.
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Importers may transmit Form E15 with general contract information associated with the MVE without submitting the contracts themselves through VUCEM.
Why this matters:
The MVE represents a fundamental shift in Mexico’s approach to customs valuation. By requiring importers to submit detailed valuation data electronically before goods arrive, Mexican authorities gain the ability to cross-check declared values against commercial documentation in real time. For exporters using DDP arrangements or relying on freight forwarders to handle Mexican customs clearance, this creates new compliance obligations that must be addressed before shipment.
3. European Union: Landmark Customs Reform Takes Effect
On September 19, 2025, Regulation (EU) 2025/2108 was published in the Official Journal of the European Union, establishing the new Union Customs Code. This is the most significant reform of European customs legislation since 1968, with direct impact on all businesses that import, export, or move goods within the EU.
Four pillars of the reform:
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EU Customs Data Hub: A centralized digital platform that will replace more than 111 national customs IT systems, providing a single point of electronic interaction between operators and authorities.
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EU Customs Authority: A new European body based in Lille, France, responsible for centralized risk management and coordination.
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Trust and Check trader status: A new designation for highly reliable operators, offering significant operational benefits including release of goods at the trader’s own premises.
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New e-commerce rules: Making platforms and online sellers liable as importers.
Platform liability and penalties:
Under the new rules, sellers and platforms facilitating distance sales of goods from non-EU countries directly to EU customers will be treated as importers. They will be responsible not only for tax-related requirements (tariff classification, origin, customs value, and duties) but also for all non-tax requirements applicable to goods, including product compliance, safety, health, environmental requirements, intellectual property rights, and restrictive measures.
Companies that systematically breach the rules may be subject to fines ranging from 1% to 6% of the total value of goods imported in the preceding 12 months. Customs authorities may also suspend, revoke, or annul their trusted trader or Authorised Economic Operator (AEO) status and flag them as high-risk operators. In the most serious cases, access to online platforms may be restricted.
The €3 duty and upcoming handling fee:
The customs duty exemption for goods valued at €150 or below has been abolished. Since July 1, 2026, a fixed customs duty of €3 per item has been in force for consignments covered by the Import One-Stop Shop (IOSS) regime or postal consignments. This transitional measure will remain in place until July 1, 2028, when the Common Customs Tariff will apply.
Additionally, the European Commission has introduced a €2 handling fee per item on distance-sold goods from non-EU retailers, effective November 1, 2026.
Extended responsibilities for importers and exporters:
Importers and exporters will now be responsible to customs authorities not only for compliance with tax-related requirements but also for all non-tax requirements applicable to goods. Indirect customs representatives will assume all the obligations of the importer or exporter and will be required to be established in the EU.
4. What This Means for Exporters and Freight Forwarders
The convergence of these regulatory changes creates a new compliance landscape for cross-border trade.
For Mexico-bound shipments:
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Prepare for MVE compliance. Ensure your Mexican importer has the capability to submit the MVE electronically before goods arrive. If you are using DDP terms, confirm who is responsible for MVE submission.
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Take advantage of transitional measures. Through December 31, 2026, certain documents can be attached to the customs declaration rather than transmitted through VUCEM.
For EU-bound shipments:
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Understand your new liability. If you are an e-commerce platform or seller facilitating distance sales to EU consumers, you are now legally the importer. This means responsibility for customs duties, product compliance, and all non-tax requirements.
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Budget for the new costs. The €3 per-item duty is already in effect. The €2 handling fee begins November 1, 2026.
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Prepare for the EU Customs Data Hub. The centralized digital platform will eventually replace national systems. Early preparation for data integration will reduce disruption when the transition occurs.
For US-bound shipments:
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Continue to audit IOR data on Form 5106. Ensure all information is accurate and belongs directly to your company.
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Verify your broker’s Power of Attorney and consider the Importer Identity Freeze Program.
Glovoyce Observation
The regulatory changes taking effect across Mexico and the European Union represent more than isolated policy adjustments. They signal a fundamental shift in how governments approach cross-border trade compliance: from self-declaration to active verification, and from entity-level enforcement to data-level enforcement.
For Mexico, the MVE creates a pre-arrival valuation transparency requirement that will catch discrepancies that previously went undetected. For the EU, the new Union Customs Code makes platforms directly liable and introduces penalties that scale with import volume. The US IOR crackdown, while still relevant, is now part of a broader global pattern.
Three practical implications for businesses:
First, compliance is no longer a back-office function. It is a board-level risk. An MVE filing failure or an EU customs breach can stop goods at the border, disrupt customer commitments, and trigger contractual penalties.
Second, the compliance burden is shifting upstream. With the EU making platforms liable as importers, exporters and sellers can no longer rely on intermediaries to absorb compliance risk.
Third, data accuracy is now the foundation of market access. Whether it is MVE in Mexico, the EU Customs Data Hub, or Form 5106 in the US, the common thread is that governments are demanding accurate, verifiable data about who is importing, what is being imported, and at what value.
For businesses navigating this new landscape, the priority is clear: verify your compliance position now, before a shipment is stopped at the border. Glovoyce can assist with MVE preparation, EU customs compliance structuring, IOR verification, and supply chain risk assessment. Contact your account manager for a compliance review.
This article is based on SAT/ANAM Joint Communiqué 53-2026, Regulation (EU) 2025/2108, CBP’s Federal Register notice (91 FR 53627), and publicly available industry guidance as of October 9, 2026. For specific compliance advice, please consult your Glovoyce account manager.
