Amendment to the Sanitary Control Regime Applicable to Food Imports | Executive Decree No. 790/2025
Public Law Department Report | Amendment to the Sanitary Control Regime Applicable to Food Imports | Executive Decree No. 790/2025.
On November 11, 2025, the National Executive Branch published Decree No. 790/2025 (the “Decree”) in the Official Gazette, introducing amendments to Decree No. 1812/1992 regarding hygienic and sanitary controls applicable to the importation of food products, by-products, and derivatives of animal and plant origin.
Below are the main changes introduced by the new regulation:
A-Redistribution of Competences
1-Update of the Agencies Involved
The Decree assigns the National Service of Agri-Food Health and Quality (SENASA) responsibility for the pre-entry control of imported products, by-products, or derivatives of animal origin not packaged for direct sale to the public.
Post-entry controls will fall under the responsibility of the National Administration of Drugs, Food, and Medical Technology (ANMAT) or SENASA, depending on the nature of the product.
Unlike the previous regime, which covered packaging, transport, and stability controls, the new Decree limits SENASA’s intervention to those checks strictly necessary to ensure the safety and wholesomeness of products, eliminating redundant verifications and promoting more efficient coordination among sanitary authorities.
Food products certified by the countries listed in the third paragraph of Article 2 of Annex I to Decree No. 2126/1971 (“high-surveillance countries”) are exempt from post-entry controls. Such products need only comply with the procedure set out in Article 4(a) of Annex II to the same decree, and the sanitary authority may not impose additional requirements.
2-Reduction of Deadlines and Streamlining of Procedures
The Decree shortens administrative timeframes for sanitary inspections of imported food products:
-3 business days for inspections due to damage or documentation inconsistencies, extendable only once with justification.
-48 hours to resolve importers’ claims arising from the aforementioned inspections.
-5 business days for the release of products subject to pre-entry control, with a single possible extension for justified reasons.
-5 business days for controls ordered by ANMAT or SENASA on sanitary-risk grounds.
Additionally, if goods are released “without the right to use,” the importer must declare themselves the faithful custodian of the products, committing to prevent deterioration and/or contamination, while the sanitary authority has 5 business days to issue a decision.
3-Product Registration and Inter-Institutional Coordination
Registration or authorization of imported food products will fall under ANMAT’s competence, except for those of animal origin, which will continue to be registered before SENASA.
The Decree also reinforces inter-agency coordination, providing that the Ministry of Health, ANMAT, SENASA, and the Customs Revenue and Control Agency will be competent to issue supplementary and interpretative regulations.
B-Incorporation of a Risk-Based Approach and International Certifications
The Decree introduces a risk-based model for sanitary control, replacing the previous uniform inspection scheme.
Compliance with the Argentine Food Code (CAA) will be presumed when products come from, or bear free-sale certificates or equivalent documents issued by, sanitary authorities of the countries listed in Annex III of Decree No. 2126/1971 (as amended by Article 14 of Decree No. 790/2025).
The new Annex III expressly includes Canada, the United States, EU and EFTA member states, Australia, New Zealand, Israel, Japan, and the United Kingdom, as well as countries with economic integration treaties or reciprocal sanitary agreements.
National sanitary authorities may expand this list.
This amendment modernizes the sanitary control system, aligning Argentine regulations with international standards (Codex Alimentarius) and streamlining procedures for low-risk imports.
We remain available to provide advice regarding the implementation of this new regulation and its impact on your business activities. Please do not hesitate to contact us with any questions.
Kind regards,