JANUARY 10, 2020

Amendment to the Import License Regime.

CIRCULARS

CIRCULAR

International Trade and Customs Department Report | Amendment to the Import License Regime

Dear Sir or Madam,

We wish to report that on January 9th, 2020 the Secretariat of Industry, Knowledge Economy and Foreign Trade Management issued Resolution No. 1/2020 by means of which it amended the import licenses regime established by Resolution No. 523/2017. In particular, Resolution No. 1/2019 made the following amendments:

a. Approximately 300 new tariff positions were added to the scope of products subject to non-automatic import licenses. As a result, it is estimated that the amount of tariff positions for which it is necessary to request for a non-automatic import license has increased from 12% to 15% of the total amount of tariff positions included in the Mercosur´s Common Nomenclator. Among all products that have been added to the list of goods affected by such restrictions, we should highlight motorcycles, home appliances and wooden products.

b. Resolution No. 1/2020 modifies the procedure that must be fulfilled in order to obtain the approval of non-automatic import licenses. Specifically, since the effective date of the new regime, importers shall only submit applications for non-automatic import licenses once they have completed all the required information (i.e., a general information form and specific information that will vary according to the tariff codes of the products to be imported). In this sense, we should recall that, in the former regime, importers could submit the non-automatic import license applications and afterwards, within 10-business days term, provide and complete the specific information about the products.

c. Resolution No. 1/2020 reduces the margin of tolerance between the FOB unit values or the quantities informed in the non-automatic import license request and the values actually imported. Please, note that in the former scheme such differences should not exceed a 7% margin of tolerance. According to the new regime the margin of tolerance is limited to 5%.

d. Resolution No. 1/2020 reduces the validity term of the non-automatic import licenses from 180 to 90 days counted as from the date of their approval. If there exist duly substantiated reasons, importers may request an extension, up to 15 days before the expiration date.

e. In case of the products listed in Annex XI, Resolution No. 1/2020 sets forth that such items will be exempted from obtaining non-automatic import licenses if, by the effective date of the provision (i) the product has an automatic import license already submitted; (ii) the goods are already loaded to the mean of transport carrying them to the country; or (iii) the items have already arrived at the country´s customs area.

Resolution No. 1/2020 and its Annexes can be consulted here.

Finally, do not hesitate to contact us for any further clarifications or comments.

Best regards,

Augusto Vechio