Amendments to the Argentine Food Code (CAA) | Decree 35/2025
Administrative Law Department Report | Amendments to the Argentine Food Code (CAA) – Decree 35/2025
On January 20, 2025, Decree 35/2025 (the “Decree”) was published in the Official Gazette, through which the National Executive Branch introduced significant amendments to the Argentine Food Code (CAA), particularly to Chapter I.
1-Key Amendments to the CAA
1.1. Changes to Requirements for Imported Products
Annex III of the Decree lists countries whose health and food safety systems are considered equivalent to those of Argentina and are therefore deemed compliant with the CAA without additional evaluations. These countries include Australia, Canada, Switzerland, the United States of America, New Zealand, Israel, Japan, and the United Kingdom of Great Britain and Northern Ireland, as well as the European Union.
Previously, the CAA stipulated that equivalence was solely at the discretion of the National Health Authority, which assessed whether the country of origin had food control levels comparable to those of Argentina on a case-by-case basis.
Another significant amendment introduced by the Decree is that imported products previously certified by the health authorities of these countries are exempt from the obligation to be incorporated into the CAA. Additionally, these products are exempt from registering with the National Establishments Registry (from its initials in Spanish “RNE”), the National Food Products Registry (from its initials in Spanish “RNPA”), the National Packaging Establishments Registry (from its initials in Spanish “RNEE”), and the National Registry of Food Products and Packaging in Contact with Food (from its initials in Spanish “RNPE”), as well as from filing the Declaration of Seals and Nutritional Warnings. Instead, importers of these products must submit, for each operation, a sworn statement including detailed information on:
-Importing company details (corporate name, tax ID, address, authorization, among others).
-Details of the goods warehouse.
-Product information (name, brand, batch, expiration date, quantity, presentation, country of origin, manufacturer name).
-Labeling in accordance with current legislation, in the national language, including the importer’s name and address and batch number.
-Product destination (commercialization, importer’s personal use, or sample without commercial value).
Additionally, a certificate of free sale or marketing authorization issued by the health authority of the country of origin must be submitted.
Products from countries not listed in Annex III will remain subject to compliance with traditional registrations and verifications by the National Health Authority, including the RNE, RNPA, RNEE, RNPE, and the Declaration of Seals and Nutritional Warnings. Lastly, the Decree stipulates that for these cases, the National Health Authority will conduct an analytical verification of the hygienic-sanitary conditions of the food, and such products may not be circulated, marketed, or sold until the results of this verification are available.
1.2. Requirements for Exports
The Decree mandates the issuance of specific certificates attesting that exported products comply with the destination country’s standards, without the National Health Authority imposing additional requirements. Furthermore, exporters may request the necessary certificates from the National Health Authority when required by the destination country.
1.3. Introduction of Updated Principles for Additives Use
The Decree incorporates a more rigorous approach to evaluating additives, requiring consideration of their cumulative, synergistic, or protective effects. Additionally, requirements are aligned with international standards from the FAO and WHO, thereby enhancing food safety and confidence in regulated products.
2- Implications for the Sector
The amendments introduced by the Decree aim to modernize the regulatory framework of the CAA, facilitate international trade, and align local regulations with international standards. Specifically, they seek to:
-Simplify imports from countries with recognized health systems.
-Increase transparency and confidence in exported products through mandatory certificate issuance.
-Achieve greater rigor in the evaluation and use of additives.
We remain available to provide specific advice on how these changes may impact your business operations and to answer any related inquiries.
Kind regards,