“Regulation on the provision of manuals and information on products and services in digital format”.
Consumer Protection Department Report | “Regulation on the provision of manuals and information on products and services in digital format”.
Today, the Official Gazette published Resolution No. 619/2024 from the Undersecretariat for Consumer Protection and Fair Trade, under the Ministry of Industry and Trade.
Resolution No. 619/2024 regulates Articles 4 and 6 of Consumer Protection Law No. 24.240 (“CPL”).
-Article 4 establishes a general and broad duty of information that is highly relevant to the activities of any provider of goods or services to consumers: “The provider has the obligation to supply consumers with all information related to the essential characteristics of the goods and services offered, and the conditions of their commercialization, in a certain, clear, and detailed manner.”
-Article 6 specifies that goods and services that could potentially put the health or physical safety of consumers or users at risk must be commercialized with a manual in Spanish that provides information on their safe use, installation, and maintenance.
Resolution No. 619/2024 clarifies that the obligation to provide the manual and instructions for use, installation, and maintenance established by Article 6 of the CPL, as well as the information required by Article 4, can be fulfilled by providing the documentation to the consumer in either paper or electronic formats.
In the latter case, the information must be digitally stored in an unalterable format and must explicitly indicate its location for free consultation through electronic means at all times, allowing consumers to print and/or digitally store it (for example, through a link that allows downloading, saving, and printing it in a PDF file).
Lastly, Resolution No. 619/2024 adds that, if provided in electronic format, the location of the manuals and the means of access must be printed or attached on the external part of the product or its packaging.