International Trade and Customs Alert - September 2025
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NEW CERTIFICATION PROCEDURE FOR AUTHORIZED ECONOMIC OPERATORS APPROVED
On Thursday, September 4, 2025, SUNAT published version 4 of the procedure that regulates the guidelines for obtaining certification as an “Authorized Economic Operator” (AEO), as well as other important issues related to such certification. This procedure will come into force on January 1, 2026.
As a reminder, AEO certification is voluntary and provides benefits related to the use of customs guarantees, streamlined procedures, and flexibility in customs controls.
Incorporation of new operators under AEO certification
This new version of the procedure highlights the incorporation of: (i) international freight forwarders and (ii) companies that provide international air transport, as new types of foreign trade operators that can choose to obtain AEO certification. With this, the Customs Administration seeks to ensure high security standards for almost all operators involved in the international supply chain.
It should be noted that, according to information available on the SUNAT website, to date, there are 430 companies certified as AEOs, as detailed below: 223 importers, 127 exporters, 61 customs agencies, 6 customs warehouses, 11 temporary warehouses, and 2 express delivery companies.
Requirements for access to the most demanding certifications
There is a greater demand for compliance with requirements for access to certification, especially in relation to accreditation of: (i) a satisfactory track record in compliance with current regulations and (ii) an adequate level of security. For example:
- Importers are required not to have any collections for value adjustments or other items within a 24-month period prior to the date on which they submit their application for guidance on compliance with AEO requirements (in the previous version of the procedure, this period was only 12 months).
- New obligations are incorporated in areas related to security planning, business partner security, and transport process security, among others.
- The concept of “cybersecurity” is introduced, regulating new obligations in this area.
- The list of violations considered for evaluating proper compliance with current regulations is expanded.
- The obligation to conduct annual self-assessments on the maintenance of the conditions and requirements for accessing certification is established.
NEW BENEFITS
In terms of new benefits, the following stand out: (i) the granting of a facilitation measure relating to the reduction of physical inspection in customs declarations of goods (DAMs) that are eligible for exemption under the Amazon Investment Promotion Law, Law No. 27037, and the benefit of the Protocol Modifying the Peruvian-Colombian Customs Cooperation Agreement; (ii) preferential processing in the issuance of chemical bulletins; and (iii) preferential processing of requests for DAM filing under any regime.
Companies that are already AEO certified must comply with the guidelines established in the new procedure by January 1, 2027.