I. Introduction
In late 2024, two new regulations were issued that modified the Courier Regime (the “Regime”). On one hand, Decree 1065/2024 (the “Decree”) and, on the other, General Resolution ARCA 5608/2024 (the “GR 5608”), which was later modified by General Resolution ARCA 5631/2025 (the “GR 5631”).

The Decree and GR 5608 were published on December 2, 2024, in the Official Gazette. The first took effect the day after its publication, while the second took effect on the same day as its publication in the Official Gazette. However, the implementation of its provisions will be carried out according to the schedule available on the "Envíos Internacionales" (International Shipments) Microsite on the ARCA website (the “Microsite”) (1).

The Decree established a customs duty reduction and an exemption from the payment of the statistical fee, in both cases up to a FOB value of USD 400 per shipment, for the import for consumption of goods through the Regime. This is contingent on the shipment being for non-commercial purposes and with a maximum of 5 shipments per year and per person (the “Franchise”). Any excess in value or quota is excluded from the Franchise. This measure does not apply to other taxes that may be applicable, for example, VAT, internal taxes, etc.

It is worth noting that, according to the Microsite and based on administrative precedents, when the shipment is a “small shipment” (as specified later), the Franchise would also cover antidumping duties (2). However, the value of the shipment in excess of the Franchise would be subject to antidumping duties.

The recitals of the Decree indicate that the purpose of the Franchise is—in addition to the free movement of goods and the facilitation and simplification of trade for the consumer/user—to stabilize domestic prices at convenient levels and maintain an adequate volume of supply to meet the needs of the domestic market.

For its part, GR 5608 established a single regulatory framework for the simplified import and export of goods through companies authorized as Postal Service Providers (“PSPs”)/Courier, abrogating the various regulations that, until this moment, governed the Regime. In addition, it raised the FOB value limit from USD 1,000 to USD 3,000 for the import of goods, with or without a commercial purpose.

Both regulations aim to especially encourage the import of goods through the Regime. The first, through a franchise. The second, through the new entry limit and various operational improvements.

One of the most relevant of these improvements could be related to the use of a fraction of the fiscal warehouse premises by PSPs/Couriers to carry out their activity there. Indeed, although previous regulations, namely Resolution ANA 2436/1996 and its modifying Resolution ANA 3236/1996, already provided for the possibility of diverting cargo to authorized warehouses (3), now, under GR 5608, work is underway on the IT developments and regulatory implementations for this possibility to materialize, especially given the estimation that, with these new modifications, trade through the Regime, particularly for importers, would increase substantially. The assignment of this fraction of the premises to the PSP/Courier by the fiscal warehouse permisionary is provided for in point 15 of Annex IV of General Resolution AFIP N° 4352/2018, which established the regulations regarding the authorization of fiscal warehouses (4).

Next, GR 5608 is analyzed in detail, with the modifications introduced by GR 5631 (published in the Official Gazette on January 9, 2025), since, as mentioned, the Decree only provided for the Franchise, which has already been commented on above in the third paragraph.

GR 5608

GR 5608 is divided into 4 annexes, also providing for complementary procedural guidelines on the Microsite. The DGA was authorized to update its Annex I (General Regulatory Provisions), and the DGA and the Directorate of Programs and Customs Procedure Regulations of the ARCA's Sub-Directorate of Revenue were authorized to issue the complementary instructions to implement the provisions of its Annex IV (Registration of simplified import and export for consumption requests).

Annex I – General Regulatory Provisions

The activity of the international postal market is specified (5), indicating that it is carried out by: (i) PSPs/Couriers, (ii) individuals or legal entities that transport their own correspondence (6), and (iii) freight companies that operate these shipments (up to 50 kg.) and do not have the character of postal activity.

Of these subjects, the only ones that must be registered in the National Registry of Postal Service Providers are the PSPs/Couriers (7).

Regarding the shipments that can be carried out under the Regime, a distinction is made:

1. Shipments: Correspondence/documentation
   • Scope: General correspondence; spreadsheets; lists; magnetic media with information extracted from computer systems intended for banking and general business activities; other documentation whose shipment is usually routed this way, and books, fascicles, and similar printed materials, including illustrated or with advertising, and albums or stamp books and drawing or coloring books for children, in accordance with Art. 4 of Law 25,446 for the promotion of books and reading.
   • Limitations: The conditions related to value and weight do not apply. That is, for correspondence or documentation, an excess of USD 3,000 in value and/or 50 kg. would not imply exclusion from the Regime.
   • Consequences of exceeding the limitations: N/A
2. Shipments: Postal package/parcel (8)
   • Scope: Packages containing goods.
   • Limitations: Packages containing goods may be imported/exported under this regime as long as the weight of each package or postal item, regardless of the total weight of the shipment, is up to 50 kg (conf. GR 5631).
     • Import: The FOB value cannot exceed USD 3,000 for each Courier shipment.
     • Export: The FOB value must not exceed USD 3,000 for each Courier shipment (conf. GR 5631).
   • Consequences of exceeding the limitations: The general import or export regime applies—including declarations through the AFIP Codes—when the goods are: a) subject to the goods identification regime (GR 5581); b) subject to the application of prohibitions or interventions by other Agencies. In the latter case, provided that the fulfillment of certain conditions before the competent Agency by the importer/exporter is required to authorize the destination. For import operations, interventions by third-party Agencies, whose regulatory norms have determined control in the domestic market after the release of the goods, will not be a reason for exclusion (e.g., energy efficiency; metrology); c) subject to the presentation of the Certificate of Origin, including ALADI and MERCOSUR, unless the extra-zone treatment is chosen; d) beneficiaries of special tax regimes, unless the extra-zone treatment is chosen; e) subject to the collection of export incentives (and these are not waived); f) when the customs value to be determined exceeds the current limit, without prejudice to the application of the corresponding infraction procedure.

To formalize simplified import or export for consumption requests, PSPs/Couriers must be registered in the “Special Customs Registries,” for which they must comply with general and specific requirements (9).

Likewise, PSPs/Couriers may declare the AFIP Codes, according to the procedure established by General Resolution AFIP 3628 and its complementary regulations. The AFIP Codes currently enabled for Couriers are the following (10): N° 0000.04.10.000H “Ingreso / Egreso de correspondencia. Documentación efectuado por Prestadores de Servicios Postales/Courier (PSP/Courier) (11)”; N° 0000.04.32.000T “Ley N° 25613. Importación a consumo de insumos destinados a investigaciones científico tecnológicas, efectuadas por organismos del Estado y entidades de bien público”; N° 0000.04.36.100D “Materiales biológicos, con fines diagnósticos, investigativos, con propósitos de participación en Programas de Control de Calidad Externos y vigilancia epidemiológica realizada por instituciones con responsabilidad en políticas de prevención y control de enfermedades (excepto importación de material reproductivo humano)”; and N° 0000.04.36.200J “Importación de material reproductivo humano para fines de diagnóstico/fertilidad.”

Regarding the tax aspect, it is provided that the goods transported by the Regime are subject to the payment of all taxes of the general regime that levy import for consumption (including current collections) and export for consumption, in force at the time of registration of the respective operation.

Regarding valuation, it is provided that, in the import destination request, PSPs/Couriers must declare the CIF value of the goods in question, considering for this purpose the real value of the freight, and must provide, when appropriate and at the request of the customs service, the commercial invoice in accordance with the provisions of General Resolution AFIP 2793 and its modifications, as well as equivalent documents such as an order, receipt, and/or purchase “ticket” issued by the e-commerce platform through which the goods were acquired (12).

It is provided that the DGA may determine the customs value of the goods based on precedents, price references, and verification. It is worth mentioning that, in matters of import valuation, the Agreement on the Application of Article VII of the GATT 1994, approved by Law N° 24,425, is in force in Argentina, whose Art. 17 provides: “Nothing in this Agreement shall be construed as restricting or calling into question the right of Customs Administrations to satisfy themselves as to the truth or accuracy of any statement, document or declaration presented for customs valuation purposes.”

However, when the valuation carried out by the DGA results in a customs value higher than the declared value and within the admitted limits (that is, the maximum FOB value of USD 3,000 for each Courier shipment), the release of the goods will be allowed upon payment of the corresponding tax difference, provided that the commercial invoice was originally provided in accordance with the provisions of GR AFIP 2793 and its modifications, or equivalent documents such as those mentioned above.

In matters of export valuation, the corresponding provisions of Law 22,415 – Customs Code (the “CC”) are applicable. As in import matters, the DGA has broad powers to verify the correct determination of the value. For example, when the price paid or to be paid does not constitute a suitable basis for valuation for the purpose of correctly determining the taxable value, the DGA may deviate from it, in which case the valuation basis that best suits those provided for in Art. 748 of the CC must be used.

When an inaccurate declaration results in quantity and/or species and/or quality and/or value in the terms of Art. 954 of the CC, the corresponding procedure for customs infractions will be applied.

Annex II – Special Regulatory Provisions

This annex regulates different special regimes or sub-regimes, subject to the general provisions, but with the exceptions that are specifically indicated in each case.

Regimes

1. Small shipments (13) (for import). Remember the comments made above regarding the Franchise.
   • Scope/exceptions: Allows the entry of packages destined for individuals or legal entities, consisting of up to 3 units of the same kind and that do not presume a commercial purpose, as long as the weight of each package or postal item, regardless of the total weight of the shipment, is up to 50 kg. and the FOB value of the goods consigned to the same recipient does not exceed USD 3,000 for each Courier shipment. The shipments defined above can only be used 5 times per calendar year and per person.
   • Likewise, these shipments are exempt from: 1) The prior intervention of the National Food Institute (INAL) (Resolution ANA 1946/1993, its modification, and its complementary regulations); 2) The interventions of third-party Agencies, whose regulatory norms have determined control in the domestic market after the release of the goods; 3) The application of the goods identification regime (GR AFIP 5581); 4) Economic restrictions and prohibitions; 5) The prior intervention of the National Administration of Medicines, Food, and Medical Technology (ANMAT) regarding perfumery, toiletry, or cosmetic preparations. Additionally, the Microsite mentions the exception regarding the Certificate of Approval for Auto Parts and/or Safety Elements (C.H.A.S.) provided for in Resolution N° 166/2019 of the former Secretariat of Industry.
2. Samples (INUMUE) (for import)
   • Sample: Representative objects of a certain category of already produced goods, which are intended exclusively for exhibitions or demonstrations to arrange commercial operations with said goods, and objects that are models of goods whose production is projected, provided that the same is rendered unusable and that in both cases their quantity does not exceed what is usual for these purposes.
   • Scope/exceptions: Allows the entry of packages destined for legal entities as samples, as long as the weight of each package or postal item, regardless of the total weight of the shipment, is up to 50 kg. and the FOB value of the goods consigned to the same recipient does not exceed USD 3,000 for each Courier shipment.
   • The “INUMUE” advantage code must be declared in the PSP/Courier Simplified Destination.
   • These shipments are exempt from: 1) The application of the goods identification regime (GR AFIP 5581); 2) Economic restrictions and prohibitions; 3) The prior intervention of third-party Agencies as long as it is expressly excluded by regulatory norms.
3. Samples for testing carried out by laboratories (for import)
   • Scope/exceptions: Allows the entry of samples destined for laboratories dedicated to carrying out tests to obtain product certifications, as long as the weight of each package or postal item, regardless of the total weight of the shipment, is up to 50 kg. and the FOB value of the goods consigned to the same recipient does not exceed USD 3,000 for each Courier shipment.
   • When it comes to samples for obtaining product certifications for foreign markets, the FOB value limit will be extended to USD 10,000 for each Courier shipment.
   • The advantage codes determined for this purpose must be invoked in the Simplified Import Destination Request (SD-PSP) (according to the Microsite, this advantage code would be “ENSAYORENACLAB”).
   • The procedural guidelines will be on the Microsite (e.g., how to proceed regarding ANMAT, INAL, and/or SENASA interventions, which may be applicable depending on the type of goods in question).
   • These shipments are exempt from: 1) The goods identification regime (GR AFIP 5581); 2) Economic restrictions and prohibitions.
4. Shipments for scientific-technological research (Law N° 25,613) (for import)
   • Scope/exceptions: The entry of packages destined for the beneficiaries of the Scientific-Technological Research Regime of Law N° 25,613 is allowed (14), as long as the weight of each package or postal item, regardless of the total weight of the shipment, is up to 50 kg. and the FOB value of the goods consigned to the same recipient does not exceed USD 3,000 for each Courier shipment.
   • The “LEY25613” advantage code must be declared in the PSP/Courier Simplified Destination, and the number of the Certificate of Import of supplies for scientific-technological use (ROECYT), issued by the Registry of Scientific and Technological Organizations and Entities (ROECyT), must also be declared in the corresponding field.
   • If the established limits are exceeded (weight and value), the customs declaration will be made in a simplified manner, using the specific AFIP Code.
   • The procedural guidelines will be on the Microsite.
   • These shipments are exempt from the exclusions related to the application of: (i) prohibitions or interventions by other Agencies; in the latter case, provided that the fulfillment of certain conditions before the competent Agency by the importer/exporter is required to authorize the destination. For import operations, interventions by third-party Agencies, whose regulatory norms have determined control in the domestic market after the release of the goods, will not be a reason for exclusion; and (ii) the application of special tax regimes.
5. Shipments of works of art defined as such in Law N° 24,633 and its modifications (for import and export)
   • Scope/exceptions: When it is an import or export for consumption or a temporary destination, the “OBRASDEARTESBEN” advantage code must be declared in the PSP/Courier Simplified Destination, and the number of the Sworn Statement of Works of Art (Form OM-3290), registered with the ARCA, must also be declared in the corresponding field.
   • The procedural guidelines will be on the Microsite.
   • These shipments are exempt from the value condition established in the Regime (works of art can be exported or imported above the USD 3,000 limit) and from the application of the exclusions from the application of special tax regimes.
   • It is the responsibility of the importer or exporter, as appropriate, to notify the PSP/Courier of the shipment that it involves works of art and to accompany the corresponding sworn statement (OM 3290).
6. Samples of products and by-products of plant and animal origin (for export)
   • Scope/exceptions: The export of samples of products and by-products of plant and animal origin, of up to 10 kg. net and whose FOB value does not exceed USD 500 for each shipment consigned abroad through the Regime, is exempt from the application of prohibitions or interventions by other Agencies (in the latter case, under the conditions indicated above) (conf. GR 5631).
   • When registering the Simplified Courier Export Destination (DSCE), PSPs/Couriers may invoke the “MUESTRACOURIER” advantage code to process, through this modality, shipments of products and by-products of plant and/or animal origin subject exclusively to the prior intervention of SENASA.
   • The operator must have the certificate issued by said intervening Agency, which may eventually be required by the DGA based on its powers.
7. Medicines through the Simplified Regime, destined for Argentines residing abroad (for export)
   • Scope/exceptions: The PSP/Courier must register a Simplified Courier Export Destination (DSCE) by country of destination separately from the rest of the goods and other personal and commercial shipments. Likewise, it must accompany each summary destination “DSCE” with a Sworn Statement in which it undertakes that the goods to be exported are not or do not contain narcotics, psychotropics, or other substances subject to special control that require the intervention of the competent authority in the matter, in accordance with the provisions of Laws N° 17,818 and 19,303 and their respective modifications.
   • The operator must have the complementary documentation that accredits the nature of the shipment (document that accredits the patient's identity, medical prescription that identifies the type of medicine in question, active ingredient, and its content, and purchase invoice), which may eventually be required by the DGA.

Annex III – Operational Provisions

1. GeneralA. Registration GR AFIP 2570: As indicated above, PSPs/Couriers must comply with General Resolution AFIP 2570, Registry System. Special Customs Registries. See Footnote N° 9 in this regard.B. Declaration in the cargo manifest – SIM Cargo Manifest
   • Goods imported by PSPs/Couriers: Customs Transport Agents will proceed to register the Import Cargo Manifest (MANI) in the SIM, through which transport documents with cargo covered by the Regime will be registered.
   • If it is necessary to document a declaration of “Ignoring Content,” the value “N” must be entered in the consolidated indicator of the transport document. Subsequently, if it is intended to deconsolidate such a document, the “Update of a transport title” transaction must be used to change the value of the consolidated indicator of the transport document to “S.”
   • The cargo corresponding to the mentioned transport document will be transferred to the Courier cargo warehouse or another authorized for this purpose, where the permisionary of said warehouse will proceed, with the necessary precautions, to carry out the transaction corresponding to the “Closure of entry to warehouse.”
   • If necessary, the PSP/Courier will register the deconsolidation of all the packages transported in the SIM, using the “Re-packaging” transaction.
   • If applicable, the MANI will be registered, by virtue of the applicable regulation according to each arrival route, with the necessary number of child documents—which will have the prefix of the acting PSP/Courier—according to the specific destination needs, using the “Registration of a summary declaration” transaction.
   • Goods imported by passengers: The service provider company will proceed to register the MANI in the SIM, through which transport documents with cargo covered by the Regime will be registered.
   • If it is necessary to document a declaration of “Ignoring Content,” the value “N” must be entered in the consolidated indicator of the transport document. Subsequently, if it is intended to deconsolidate such a document, the “Update of a transport title” transaction must be used to change the value of the consolidated indicator of the transport document to “S.”
   • The cargo corresponding to the mentioned transport document will be transferred to the Courier cargo warehouse or another authorized for this purpose, where the permisionary of said warehouse will proceed, with the necessary precautions, to carry out the transaction corresponding to the “Closure of entry to warehouse.”
   • This transfer must be carried out with customs custody, which will be designated by the corresponding area.
   • If necessary, the PSP/Courier will register the deconsolidation of all the packages transported in the SIM, using the “Re-packaging” transaction.
   • If applicable, the MANI will be registered by virtue of the applicable regulation according to each arrival route, with the necessary number of child documents—which will have the prefix of the acting PSP/Courier—according to the specific destination needs, using the “Registration of a summary declaration” transaction.
   • Special situations: remediation: When: (i) the CUIT/CUIL data of the recipient is not available, or (ii) the recipient does not have a declared Electronic Tax Domicile, or (iii) the intervention of a third-party Agency permitted in this regulation is required, or (iv) partial shipments that are pending arrival, to remedy this situation, without the shipment losing its “express” condition, it may exceptionally remain for a period not exceeding 5 business days in a space designated by the PSP/Courier for this purpose, remaining under its care and at the disposal of the DGA if required.
   • For these purposes, the PSP/Courier must inform the DGA at the end of the day of the shipments that are under its custody, and must send the data inherent to them, as well as the expiration date of the 5 days established and the reason for their permanence, through the SITA (Customs Procedures IT System), by presenting an electronic customs multinote (MUELA), addressed to the Courier Section or its equivalent in the corresponding jurisdiction, selecting the sub-procedure – “10184 Shipments in custody- Shipments in the process of remediation.”
   • Import destination for consumption
     • Packages: Must be documented according to the procedure in Annex IV of GR 5608 (see below).
     • The payment of taxes must be satisfied by the PSP/Courier, and the proper records must be established in the respective document. To register the payment of summary destinations (PART) through the SIM, PSPs/Couriers must deposit the funds in accordance with the provisions of General Resolution AFIP 2883 and its modifications, selecting the option “Anticipo Pago Tributos Aduaneros” (Advance Payment of Customs Taxes) (Code N° 2555), concept “Pago Aduanero” (Customs Payment) (Code N° 800) and sub-concept “Pago Aduanero” (Customs Payment) (Code N° 800).
     • For the IT registration of the presentation or cancellation of the summary destination (PART), the DGA must operate the “Presentation of a Summary Declaration” transaction.
     • Through the “Registration of a liquidation for various collections” transaction, the DGA will register in the SIM the liquidation corresponding to the summary destination (PART) in “Presented” status, with the breakdown of the concepts and amounts to be paid by the provider.
     • The DGA, through the “Payment of a manual liquidation” transaction, will allocate the previously deposited funds, canceling the payment of the summary destinations.
     • The details of the goods (shipment number, tariff position, number of units, value, and taxes to be paid) must be added to the summary destination “PART,” and must be identified with the “PART” number and correlatively numbered, in addition to being signed by the PSP/Courier and the DGA.
     • The verification area will carry out the control of the goods in the sectors reserved for this purpose. The acting verifier will manually record the result of the verification in the summary destination “PART.” If the verification of all the goods covered by the summary destination “PART” is in conformity, the departure from the Primary Customs Zone and its cancellation will be proceeded with according to current procedures.
     • If any of the shipments are not in conformity during verification, a partial departure of the summary destination “PART” will be made for the shipments that were in conformity, leaving a record of the verification result on said destination, detailing the packages and the reason for the detention.
     • Without prejudice to the application of the infraction procedure, if applicable, the departure of the pending shipment(s) will be authorized, proceeding with the cancellation of the summary destination “PART.” If the destination through form OM-1993-A is necessary, the Sub-regime “IC01” will be used, simultaneously canceling the summary destination “PART.” In the latter case, the departure from the Primary Customs Zone of the remaining packages of the summary assignment “PART” will be carried out and simultaneously with the “IC01” destination with which said packages had been declared. Both the departure from the Primary Customs Zone and the confirmation of departure from the Primary Customs Zone of the aforementioned summary assignment “PART” will be carried out solely and exclusively for the purpose of canceling said assignment, and the situations and actions that have been carried out must be recorded in said destination.
   • Correspondence/documents: Will be documented using AFIP Code N° 0000.04.10.000H (Entry of correspondence. Documentation carried out by Postal Service Providers PSP/Courier).
   • The DGA will proceed to control that the content of the sacks corresponds to the nature of correspondence and/or documents (according to the definition provided above), and may carry out such recognition externally when the characteristics of the sack allow it, authorizing the departure from the Primary Customs Zone using form OM-2144.
   • Export destination for consumption
     • Packages: Must be documented according to the procedure in Annex IV of GR 5608 (see below).
     • For the IT registration of the presentation or cancellation of the Simplified Courier Export Destination (DSCE), the DGA must operate the “Presentation of a summary declaration” transaction.
     • The verification area will carry out the control according to the corresponding selectivity.
     • The verification area will carry out the control of the goods in the sectors reserved for this purpose. The acting verifier will manually record the result of the verification in the summary destination “DSCE.” If the verification of all the goods covered by the summary destination “DSCE” is in conformity, its release will be authorized.
     • If any of the shipments are not in conformity during verification, a partial departure of the summary destination “DSCE” will be made for the shipments that were in conformity, leaving a record of the verification result on said destination, detailing the packages and the reason for the detention.
     • Without prejudice to the application of the infraction procedure, if applicable, the release of the pending shipment(s) will be authorized.
     • After the release, the records of the fulfillment will be recorded in the document of the simplified export destination, identifying the means of transport and the travel date on which the export of each shipment was fulfilled.
   • Correspondence/documents: The DGA of the authorized fiscal warehouse where the control is carried out will determine that the content of the sacks corresponds to the nature of correspondence and/or documents, and may carry out such recognition externally when the characteristic of the sack allows it, authorizing the shipment.
2. Common to import and exportA. Shipments transported by travelers/carriers: Carriers must prove the representation they invoke by exhibiting a certification issued by the PSP/Courier authenticated by a public notary. The carrier or the carrier company constituted for this purpose may transport cargo from two or more PSPs/Couriers. The cargo to be imported or exported through carriers or carrier companies must be destined for consumption before the DGA by the PSP/Courier.B. Transfer of cargo to authorized warehouses: PSPs/Couriers may divert their packages and other shipments to warehouses authorized by the DGA without the need to pass through airport jurisdiction warehouses and through closed transport units sealed by the DGA (in accordance with Art. 6 of Decree 1187/1993).
   • When it is an export, the shipment to the departure airport will be made in closed trucks sealed by the DGA that carried out the control.
   • When it comes to imports, the transfer will be made to the authorized fiscal warehouse in the jurisdiction of the customs of arrival in the customs territory or the transit when it is in the jurisdiction of another customs.
   • In the latter case, the provisions of General Resolution AFIP 3278 regarding the TLEA Summary Declaration will be applied (15).C. Customs control: The control of the cargo to be exported or imported by the Regime must be carried out in suitable enclosures especially for this purpose, within the authorized fiscal warehouses.D. Selectivity: Import and export for consumption destinations are subject to the selectivity regime in accordance with current regulations, and the guidelines of General Instruction DGA N° 17 of 07.22.2011 are applicable. Currently, the green and red selectivity channels would be applicable. The competent DGA dependencies will determine the applicable selectivity based on intelligent criteria.E. Delivery and collection of cargo on non-business days or hours: The extraordinary services for the DGA's authorization that must intervene in the reception control and release of the shipments will be at the expense of the permisionary.F. Disciplinary regime applicable to PSPs/Couriers: Without prejudice to the judgment of the infractions committed in the exercise of their activity, the PSP/Courier who does not comply with the applicable customs regulations and/or with the action regime established in GR 5608 will be sanctioned, in the disciplinary field, in accordance with the provisions of Art. 109 of the CC, of Title IV “Other Subjects” of the CC.
   • In the event of an act of misconduct or fault in the exercise of their activity, or any action aimed at preventing or hindering customs control, a complaint must be filed that initiates the disciplinary summary for the application of the sanctions established in Art. 110 of the CC, which will be graduated according to the nature of the fault committed and the background of the subject reported.
   • The substantiation of the disciplinary summary will not be an obstacle to filing the complaints that may correspond if the conduct developed is also liable to be classified as a customs infraction or crime.
   • The repetition of misconduct that gives rise to the application of the sanctions provided here or those facts that allowed the commission of a crime or its attempt may give rise to the definitive revocation of the authorization to operate under the Regime.
   • Once the complaint of the detected fault has been made, it will be sent to the Department of Customs Legal Procedures dependent on the Legal Directorate of the Technical Legal Customs Sub-Directorate General, provided that the jurisdiction where the fault was committed corresponds to the scope of the Buenos Aires Customs Directorate or the Ezeiza Customs Directorate. For the rest of the cases, the complaint will be substantiated by the customs of jurisdiction.
   • A view will be given to the PSP/Courier for a period of 10 administrative business days, within which it may exercise its defense and offer the evidence that is relevant to its right.
   • The evidence must be produced within a period not exceeding 30 administrative business days, except for those rejected for not referring to the facts imputed or invoked in the defense or for being inconsequential, superfluous, or merely dilatory. Once the evidentiary stage is concluded, the interested party will be notified for 5 administrative business days to allege on its merit.
   • After the period for alleging or the period set for the defense of the interested party has elapsed, in the case of a matter of pure law, the competent authority will issue a resolution within 20 administrative business days, after a legal opinion from the Customs Legal Advisory Directorate.
   • The resolution must be notified in accordance with the provisions of Art. 1013 of the CC and must contain the appeal that the administered party has.
   • Against the sanctioning resolution, the PSP/Courier may file the appeal provided for in Art. 111 of the CC.

Annex IV – Registration of Simplified Import and Export for Consumption Requests

General provisions: The simplified import and export for consumption destination requests made by PSPs/Couriers must be formalized through electronic data transfer. The electronic document of the mentioned destination requests must be generated and sent before its presentation to the DGA. The destination requests must contain the required data, information that will have the character of a committed declaration. The mechanisms, conditions, and data structure established for the issuance, reception, and printing of the electronic documents of the destination requests, entered with Fiscal Key by the PSPs/Couriers, will be published on www.arca.gob.ar. Once the information transmitted by the electronic documents related to the simplified import for consumption destination request is validated, the IT system will automatically generate the registration of the summary destination “PART,” assigning said request the corresponding identifier number with the following format: “Year/Customs/PART/Reg. No./Control Letter.” Once the information transmitted by the electronic documents related to the simplified export for consumption destination request is validated, the IT system will generate the “Simplified Courier Export Destination” (DSCE), assigning said request the corresponding identifier, with the following format: “Year/Customs/DSCE/Reg. No./Control Letter.” The printing of the electronically transmitted data will be done on form 3003 -“Solicitud de Destinación Simplificada PSP/Courier” (SD-PSP)-, duly signed by the authorized PSP/Courier. For the release of the goods, the DGA's interventions in the fields enabled for this purpose on the aforementioned prints must be available and the transactions provided for in each case in the system must be operated. The DGA, before making the change of state of the destination requests in the SIM, from “Registered” to “Presented,” must proceed to register in the SIM the liquidation and payment of the corresponding tax obligations for such destinations.

Simplified import destination request: The general data and its description will be available on the Microsite (17).

Procedure for rectifying the simplified import declaration: To the extent that the requirements established by the CC are met, PSPs/Couriers may request the rectification, modification, or expansion of the information originally transmitted in the simplified import destinations from the customs of registration. This would currently proceed, according to the Microsite, only when it comes to the CUIT/CUIL of the consignee (18). The DGA, after analyzing that the shipment is within the extremes provided for in GR 5608, may authorize the rectification, modification, or expansion when the inaccuracy of the customs declaration is verifiable from its reading or from that of the complementary documents attached to it (19).

Simplified export destination request: The general data and its description will be available on the Microsite (20).

Conclusion

In accordance with other measures adopted by the national government, the latest regulatory modifications regarding the Regime seek to facilitate Argentine foreign trade in goods. Although different aspects of import and export are regulated, it is expected that, as a result of the franchise provided by the Decree and the new FOB value limit for the import of goods, with or without a commercial purpose, established by GR 5608, a substantial increase in import shipments through the Regime will be verified. The possibility of using fiscal warehouses should facilitate the operation of Couriers and, therefore, provide greater fluidity to international trade.

It is worth mentioning that, recently, General Resolution ARCA 5664 (Official Gazette of 03.14.2025 and effective from that date) made it possible to use authorized fiscal warehouses—that have non-intrusive control elements—to operate under the “Exporta Simple” Regime.

Therefore, the different facilitating measures must be articulated correctly so that foreign trade in goods flows, although always without affecting proper customs control.

1. https://www.afip.gob.ar/envios-internacionales/courier/conceptos-generales/cronograma.asp
2. Indeed, on the Microsite, in the section on Courier, under the heading “Tributos” (Taxes), it is indicated: “Finally, it should be noted that the ‘Small shipment’ regime is not subject to antidumping duties.”
3. Point G of Annex III of Resolution ANA 2436/1996 and point G of Annex III “A” of Resolution ANA 2436/1996, text according to Resolution ANA 3236/1996. It is worth mentioning that Art. 6 of Decree 1187/1993 provides: “Any company that performs postal activity, within the ARGENTINE REPUBLIC and from and/or to abroad, including those that have courier activity, may divert their packages and/or shipments directly and without the need to pass through the warehouses of the airport jurisdictions, to fiscal warehouses authorized by the NATIONAL CUSTOMS ADMINISTRATION outside the jurisdiction of the airports.”
4. Which provides: “The permisionary may transfer the use of a fraction of the general fiscal warehouse premises to a courier service provider, so that it can carry out its activities in accordance with Resolution N° 2,436/96 (ANA), its modifications, and complementary regulations. The referred premises must be properly delimited with masonry separations or metallic enclosures, signposted and have Closed Circuit Television (CCTV) cameras. The permisionary of the fiscal warehouse will be responsible for compliance with customs regulations, and for the custody and conservation of the goods stored in the space transferred to the Postal Service Provider PSP/Courier in accordance with point 4, section I of Annex I of this regulation and articles 211 and concordant of the Customs Code.”
5. These are the activities that are carried out for the admission, classification, transport, distribution, and delivery of correspondence, letters, postcards, packages of up to 50 kg., from or to abroad, including the activity carried out by Couriers (conf. Art. 1 bis of Decree 1187/1993, incorporated by Decree 1005/2024).
6. In accordance with Art. 5 of Decree 1187/1993, text according to Decree 1005/2024.
7. It is necessary to refer to Art. 10 of Decree 1187/1993, text according to Decree 1005/2024.
8. It is the postal shipment in the format of a package or box or bag, of up to 50 kilograms, with identification of the sender and recipient, delivered with proof, with or without a declared value, which is subject to the principles of postal secrecy, with control from admission and throughout its distribution process until delivery. They may be subject to review and control by the police and/or judicial authority, in citizen security, national security, or counter-terrorism, smuggling, and drug trafficking procedures. This definition includes shipments from e-commerce operations and/or products purchased through a digital platform or by similar non-face-to-face means (conf. Art. 1 bis of Decree 1187/93, incorporated by Decree 1005/2024).
9. Regarding the latter, it is stipulated that they must have the importer/exporter profile registered, and be registered as a customs transport agent. Regarding the Certificate of the National Registry of Postal Service Providers, it could happen that, in accordance with the text of Art. 10 of Decree 1187/1993 according to Decree 1005/2024, the mentioned certificate is not available and that they are still authorized to provide the activity. Indeed, according to this new text, postal operators can automatically start their activities 5 days from the date of their registration, and this last authorization is sufficient to carry out the activity. Consequently, in the absence of a certificate, the registration in the National Registry of Postal Service Providers and that the mentioned period has elapsed for the postal operator to be able to automatically start its activities should be verified. Through the management of electronic authorizations, it will designate the person authorized to perform acts or procedures on its behalf before the DGA.
10. https://www.afip.gob.ar/destinacionesdeclaradasconcodigosafip/documentos/ListaDeCodigosAFIP.pdf
11. Regarding this code, the Operation Manual Version 39.8 (November 2024) indicates that the declaration “may be registered by the Customs Broker or ATA. The exporter must be registered as a ‘Postal Service Provider PSP/Courier.’ It will not require prior authorization. The operations carried out under this AFIP code will be considered ‘Free of charge,’ and will not require an Invoice. Document to be presented: – CONTENT DETAIL Allowed sub-regimes: PE01.”
12. These vouchers must contain at least data such as the full name and address of the buyer, price, quantity and description of the goods, currency and date of the transaction, payment method, shipping cost, and the corresponding information for the seller, including the surname and name/designation or company name and address.
13. For these operations, it will not be mandatory for the recipient of the shipment to have an electronic tax domicile constituted as provided for in General Resolution AFIP 4280, its modifications, and its complementary regulations (conf. GR 5631). The PSP/Courier must keep digital copies of the delivery records of the shipments for a period of 5 years after the statute of limitations for the Treasury's action has passed, which may be required by the DGA.
14. Such beneficiaries are: a) The agencies and entities of the National State, the provinces, and the Autonomous City of Buenos Aires with specific competence in the execution of scientific or technological research; and b) Public welfare entities included in article 20, subsection f) of the Income Tax Law (t.o. 1997), whose statutes attribute specific competence to them for the execution of scientific or technological research. In both cases, the referred agencies and entities must be registered, as of the date of the request, in the Registry of Scientific and Technological Organizations and Entities that the Secretariat for Technology, Science, and Productive Innovation will keep for this purpose.
15. This GR, within the framework of the Customs Transit Security Initiative (ISTA), provides that the transfer or transit of goods that arrive by air at the Customs Territory—from international airports to their reception in a Fiscal Warehouse, crossing the Secondary Customs Zone—will be mandatorily registered by presenting a Summary Declaration of the TLAT/TLMD type or a Simplified Declaration of the TRAM type, respectively, depending on whether the destination Fiscal Warehouse is within the same customs jurisdiction or not. For the sole purpose of applying the foreseen operation, the Buenos Aires Customs Directorate and the Ezeiza Customs Directorate, dependent on the General Sub-Directorate of Metropolitan Customs Operations, are considered a single customs jurisdiction.
16. The TLEA Summary Declaration allows documenting the transfer or transit of goods from the Fiscal Warehouse in the scope of the Buenos Aires Customs Directorate to Ezeiza International Airport, crossing the Secondary Customs Zone. For these purposes alone, both Directorates are considered a single customs jurisdiction [(conf. EMAIL N° 825/2020 (DE TEIM) of 08.10.2020].
17. The user manual for the Simplified Import Destination (Courier) would be the one available at https://www.afip.gob.ar/genericos/documentos/Courier-Manual-de-Usuario.pdf.
18. https://www.afip.gob.ar/envios-internacionales/courier/conceptos-generales/rectificacion-dj.asp.
19. This situation will only be admitted when the discrepancy can be detected from the simple reading of the transport document or the complementary documentation provided by the interested party, as stated at https://www.afip.gob.ar/envios-internacionales/courier/conceptos-generales/rectificacion-dj.asp.
20. The user manual for the Simplified Export Destination (Courier) would be the one available at https://www.afip.gob.ar/genericos/documentos/Courier-Exportacion-Manual-Usuario-Anexo-1.pdf.

Eduardo Mallea
Lawyer specializing in Customs Law and Foreign Trade. Former Director General of Customs.
Link to Note

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