Mexico's Apparel Estimated Prices Are Gone. The Value File Now Carries the Weight.

An apparel importer filing in Mexico this week does not post a deposit for declaring below a reference price. There is no published reference price for those goods anymore. That is a real working capital release, and it is the least consequential thing that happened on September 14, 2026.

On that date, the SHCP (Mexico's treasury ministry) published in the DOF (Diario Oficial de la Federación, Mexico's federal gazette) the Resolución que deroga el Anexo 4 de la diversa que establece el mecanismo para garantizar el pago de contribuciones en mercancías sujetas a precios estimados. One Artículo Único, one transitory article, in force the following day. Anexo 4 was the annex that had carried estimated prices for the textile and apparel sectors since December 29, 2014.

The same day, SAT (Mexico's tax authority) published on its portal the Fifth Anticipated Version of the Second Modification to Anexo 22, the instructions for filling out the pedimento (Mexico's customs declaration). In that text, the identifiers that state whether an entry posts a guarantee point to Anexo 2, Anexo 3 and Anexo 5 of the Resolución de precios estimados. Anexo 4 appears in neither of them.

Two instruments, two authorities, one day. This is not a Treasury resolution that the operational rules will catch up with in a few weeks. The substantive rule and the filling instructions moved together, which means the change was built to be operative on your next entry rather than announced and phased.

What the September 14 package actually did

Three things, and they are easy to collapse into one another.

It withdrew the reference, not the obligation. The 1994 Resolución set up a mechanism for importers to guarantee the contributions that foreign trade merchandise may be subject to on definitive importation, in order to counter the effects of undervaluation. Under Article 86-A, fracción I of the Ley Aduanera, an importer who declares a value below the published estimated price guarantees the difference in a cuenta aduanera de garantía (a customs guarantee account) and waits twelve months for it to cancel, longer if the authority has begun exercising its verification powers. Derogating Anexo 4 removes the published figure that triggered that deposit for textile and apparel fracciones arancelarias. It does not touch Article 59 of the Ley Aduanera, which is where the obligation to support declared value actually sits.

It left the rest of the mechanism standing. The 1994 Resolución is intact. Anexo 2, Anexo 3 and Anexo 5 remain in force and still carry estimated prices for vehicles, footwear, and lighting and sporting goods, and Anexos 3 and 5 were updated as recently as February 2026. An importer who reads September 14 as the end of estimated prices in Mexico will misfile the first non-apparel line that reaches their desk.

It moved the pedimento instructions on the same day. The EX identifier, exención de cuenta aduanera de garantía, and the GA identifier, cuenta aduanera de garantía, are what state entry by entry whether the guarantee applies. In the September 14 version of Apéndice 8, the cases that turn on the Resolución de precios estimados reference Anexo 2, Anexo 3 and Anexo 5. We walked through how that table sorts an entry in our piece on the EX and GA identifiers, and the sorting logic has not changed. What changed is the timing. In our work across the corridor, a substantive instrument and the instruction set that operationalizes it rarely reach the filing desk on the same date.

Twelve years, twelve modifications, and the reason the authority gave

Anexo 4 was not a neglected instrument. Published on December 29, 2014, it was modified twelve times before it was withdrawn: January 30, 2015; January 6, March 15 and May 10, 2016; November 17, 2017; April 29, 2019; March 3 and December 24, 2020; December 7, 2022; July 26 and August 29, 2023; and June 17, 2024. Almost twelve years of maintenance, and then a single-article resolution.

The considerandos say why. SHCP grounds the derogation in the dynamism of foreign trade operations, in the strengthening of risk analysis, audit and customs valuation mechanisms, and in the implementation of specific measures to prevent and combat undervaluation and other practices that could affect revenue and competitive conditions in the market. The final considerando is the one to read twice: the Ley Aduanera and other applicable law establish the authority's verification powers, which safeguard the fiscal interest and provide alternatives for continuing to combat undervaluation in the textile and apparel sector, described in that same paragraph as causing serious harm to the treasury.

That is not the language of a sector being released. It is the language of a sector being moved from one control to a different one. The authority did not say the risk went away. It said it has better instruments than a price list.

Why this lands on the compliance desk and not the treasury desk

The release is easy to see, and it will be seen first by whoever tracks restricted cash. That is the wrong desk to leave it on.

A guarantee account is a bounded exposure. The amount is calculable before the goods move, because the reference is published. The term is twelve months under Article 86-A. The trigger is arithmetic, and it reaches every importer of the same fracción arancelaria identically. It is expensive, and it is predictable.

What sits in its place is neither bounded nor scheduled. An undervaluation finding reached through verification powers is sized by the audit rather than by a table, it arrives on the authority's timing rather than at the moment of entry, and it reaches the importers that risk analysis selects rather than everyone in the sector. The exposure did not disappear along with the annex. It stopped being denominated in pesos on a deposit slip and started being denominated in the quality of the file that supports the declared value.

Two obligations make that concrete, and neither moved on September 14.

Regla 1.3.3 of the RGCE still lists, among the grounds for suspension of the Padrón de Importadores and the sector padrones, a determination that the value declared on the import pedimento runs 50% or more below the average price of identical or similar merchandise imported within the ninety days before or after the operation. That ground has never depended on whether an estimated price annex covered the sector. For apparel, it is now the screen that operates without a published number standing in front of it.

Article 59 of the Ley Aduanera and the Manifestación de Valor built on it are equally untouched. The transitional window for complying under the previous scheme closes on September 30, 2026, which means that for apparel importers the month that removed the deposit is the same month that closes the transition on the document that justifies the value.

Quick check. Pull the apparel entries you filed in the last twelve months that carried a GA identifier. For each one, ask whether the file behind the declared value would stand on its own if the reference price had never existed. That is the file you are now filing against.

What to run before your next apparel filing

1. Separate apparel from the rest of your catalog before you change anything. The derogation reaches the fracciones arancelarias that Anexo 4 covered and nothing else. Any line that sits in Anexo 2, Anexo 3 or Anexo 5 continues exactly as before, and an operation with mixed catalogs is the one most likely to over-apply the change.
2. Re-run the identifier logic on the apparel lines, per line. The instruction that has been copied forward on those entries for months was correct when it was set. Confirm what the September 14 version of Apéndice 8 actually calls for on each of them rather than inheriting the previous filing.
3. Rebuild the value support on the lines the deposit used to cover. Transaction documentation, related party analysis where it applies, the additions and deductions the Ley Aduanera requires under Articles 64 to 66, and the evidence that ties the invoice to the payment. This is the work the reference price was quietly substituting for, and it is now the only thing standing between a declared value and a determination.
4. Put the September 30 Manifestación de Valor date on the same calendar as this change. The two land in the same month and they concern the same underlying obligation. Treating them as separate projects is how a compliance calendar ends up with one of them handled and the other missed.

Across more than 190,000 customs operations a year at 39 or more ports, the pattern we see after a control is withdrawn is not that operators ignore the change. It is that they read it as an ending. The deposits stop, the identifier gets updated, and the file that the deposit was standing in for never gets rebuilt, because nothing in the resolution instructs anyone to rebuild it. That gap does not surface at the border. It surfaces two years later, in a desk audit, with interest running.

There is one question this resolution does not answer, and we are treating it separately: what happens to guarantee accounts constituted before September 15 on goods that were covered by Anexo 4. The text is silent on it, and the answer belongs in the Ley Aduanera and the RGCE rather than in a reading of the derogation.

If your catalog includes apparel fracciones arancelarias, talk to a Joffroy expert about a customs valuation file review before your next filing cycle, with the September 30 Manifestación de Valor date in the same scope.

So the deposit is gone. Can your operation answer, line by line, what is now carrying the weight it used to carry?

TRADE. UNDER CONTROL.