Comex import projections
Reform to the automatic and non-automatic import licensing regime
By means of Resolution No. 1/2020, the Secretariat of Industry, Knowledge Economy and Foreign Trade Management, modified the regime established in Resolution No. 523/2017 for the processing of Automatic and Non-Automatic Import Licenses, which can be consulted in the Official Gazette of República Argentina. The main modifications to the Import Licensing regime, a political tool for the management of foreign trade policy, are:
- Allocation of new tariff positions
- Modification of the forms for import license applications
- Decrease in the tolerance on the FOB unit value
- Extension of exemptions to the regime
- Shortening of license validity periods
- Enforcement authority
- Import operations of merchandise in the Tierra del Fuego area
Obviously, the national government has tightened import requirements and controls. Broadly speaking, it provided for the incorporation of new tariff items that must be processed under Non-Automatic Licenses - LNA. This modification, together with the need to submit a greater volume of information, a detailed analysis of import and export operations carried out and projections of imports and exports expected for the current year and 2023, as well as projections of investments and job creation, the reduction in tolerance in FOB value, in quantities and the new protocols for approval of SIRA and payments abroad, clearly hinder the importers' operation.
Instructions for submitting Resolution 1/2020
The National Directorate of Foreign Trade Management determined the need for all importing companies to prepare and submit their import projections for each year, noting the need for quarterly updates, including the level of sales, investment projections and job creation, recalling that the submission of the Excel file "COMEX Projections Presentation" is essential for the approval of import requests.
Given the additional difficulty for importers, and as we have always done, we have proposed to help them to comply with the new procedures and, mainly, to prepare and manage their company's import projections in due time and form, avoiding delays, additional costs and/or loss of profits derived from total or partial non-compliance with the regulations in force.