Peru Updates Electronic Transport Documentation

Summary

• Major reform of electronic waybills (GRE): SUNAT Resolution 108‑2026 modernises the “Guía de Remisión Electrónica” regime, aligning obligations with digital processes and operational realities in foreign trade. [bybconsultores.pe], [perucontable.com]
• New documentation and simplified responsibilities: The rule introduces the port terminal delivery order as a supporting document and revises which parties must issue transport documents. [llbsolutions.com], [gosocket.net]
• Focus on real-time traceability and controls: New data requirements, optional fields, and event-based reporting improve monitoring of goods in transit and reduce administrative burden. [gosocket.net], [llbsolutions.com]

Article

1. Background and objective of the Resolution

On 31 May 2026, Peru’s tax and customs authority (SUNAT) issued Resolution No. 000108‑2026/SUNAT, introducing significant amendments to the framework governing electronic transport documents (“Guías de Remisión Electrónicas” – GRE). [llbsolutions.com]

The reform builds on Peru’s long-standing electronic invoicing ecosystem by strengthening the digital control of goods movements, particularly in foreign trade and logistics operations.

Its key objective is to:

• Enhance traceability of goods transportation
• Reduce operational inefficiencies at ports and logistics hubs
• Align legal obligations with electronic issuance capabilities [bybconsultores.pe], [perucontable.com]

This reflects a broader shift seen globally: extending e-invoicing regimes into end-to-end transaction monitoring, including transport and logistics data.

2. Scope and affected stakeholders

The regulation primarily impacts:

• Importers and exporters
• Customs agencies
• Transport operators and logistics providers
• Companies involved in the movement of goods (domestic and international) [mifact.net]

The changes are particularly relevant for foreign trade transactions, especially those involving:

• Movement of goods from ports or airports to customs warehouses
• Transport of non-nationalised (“foreign”) goods

3. Key reform: redefining who must issue transport documents

A central element of the reform is the revision of the obligation to issue the “Guía de Remisión – Remitente” (shipper’s electronic waybill).

1. More targeted obligation for customs agencies

• Customs agencies are no longer automatically required to issue the document
• They are only responsible when acting under a mandate and when a transport agreement exists [gosocket.net]

1. Shift of responsibility to economic operators

• In the absence of such agreement, the obligation shifts to:
  • The importer or exporter

👉 This change removes legacy obligations based on paper processes, aligning responsibilities with actual operational roles.

4. Introduction of a new supporting document

A key innovation is the recognition of the:
👉“Cita u Orden de Entrega de Mercancías del Terminal Portuario” (Port Terminal Delivery Order)

This document:

• Is now a valid supporting document for transport of foreign goods
• Applies to movements from port/airport to customs warehouse or controlled area [llbsolutions.com], [gosocket.net]

Why this matters

• Port terminals already generate this data electronically
• Integration reduces duplication of documentation
• Improves traceability and auditability of logistics flows

👉 This is a strong example of leveraging operational data for tax/control purposes—a direction increasingly seen in CTC regimes.

5. Simplification and flexibility in data requirements

The resolution introduces several important simplifications:

“Block containers” concept

• Allows grouping multiple containers under a single delivery order
• In such cases, less detailed information is required (e.g. no manifest or customs declaration) [llbsolutions.com]

Optional data fields

• For complex shipments (multiple vehicles, containers):
  • Weight
  • Container numbers
  • Seal numbers
    may become optional [gosocket.net]

👉 This reduces administrative burden while maintaining control.

6. Changes in transport documentation model (GRE remitente vs transportista)

The reform also impacts the interaction between different transport documents:

• If the shipper includes full transport data (vehicle, driver, etc.) in the GRE:
  • The carrier is no longer required to issue a separate GRE
• However, this triggers a new obligation:
  • The exact start date of transport becomes mandatory [mifact.net], [gosocket.net]

👉 This creates a data substitution mechanism: fewer documents, but more complete data per document.

7. Introduction of event-based electronic documentation

The resolution expands the use of:
👉“Guía de Remisión Electrónica por evento” (event-based transport document)

New scenarios include:

• Change of driver during transport
• Operational disruptions (e.g. inability to reach destination, contingencies) [gosocket.net]

Key requirement:

• Must be issued after the event and before resuming transport

👉 This allows dynamic real-time adjustments, aligning documentation with actual logistics events.

8. Practical impact for businesses

Operational impact

• Need to update logistics and ERP systems
• Integration with port terminal systems becomes relevant
• Review of roles and responsibilities in supply chain

Compliance impact

• Greater emphasis on:
  • Accurate real-time data
  • Consistency between transport, customs, and invoicing data

Efficiency gains

• Reduced duplication (fewer documents)
• Faster cargo release from ports
• Lower compliance costs [bybconsultores.pe]

9. Strategic perspective: beyond e-invoicing

Peru continues to be a leading CTC (continuous transaction control) jurisdiction, and this reform highlights a broader trend:

Expansion from invoice control to full supply chain visibility

Key characteristics:

• Integration of tax, customs, and logistics data
• Use of existing operational documents (port systems)
• Movement toward event-driven reporting frameworks

This is particularly relevant when compared to:

• Latin America clearance models (e.g. Mexico, Brazil)
• Emerging EU ViDA concepts (transaction + logistics data convergence)

10. Key takeaway

SUNAT Resolution 108‑2026 represents a significant step toward digitally controlled logistics ecosystems:

Transport documentation is no longer just a legal formality—it becomes a real-time data layer enabling tax control, supply chain transparency and operational efficiency.