Argentina's New SIMI System Replaces DJAI Import Process

For those of you exporting to Argentina, you know all too well how challenging customs clearance has been with the required prior approval by the Administración Federal de Ingresos Públicos (AFIP- Argentine Tax and Customs Authority) and the submission of a Sworn Affidavit of Intent to Import, commonly known as the “DJAI.”

As announced at the end of December 2015, the newly ushered in “Sistema Integral de Monitore de Importaciones,” (“SIMI” - Integral System of Import Monitoring), has taken the DJAI’s place as Argentina’s new import verification mechanism. 

Unfortunately, despite the termination of the “DJAI,” a registration for an import license remains required for all imports, under 1 of 2 categories - either an “automatic import license,” or a “non-automatic import license.”  Once obtained, these licenses remains valid for 90 days.

The processing and management of these licenses must now be done via SIMI, whose purpose is to also provide the Argentine government with a simple and transparent way to gather statistical information on imports.

Non-Automatic Import License

A non-automatic import license must be applied for where a shipment requires a prior approval.  What determines whether or not a prior approval is needed turns on whether or not the article is included in the tariff of the Mercosur Common Nomenclature (“MCN”) which includes some, but not all, tariff numbers under the following chapters:

Chapters 28, 29

Chapters 34, 36, 39

Chapter 40, 42, 44, 48, 49

Chapters 51, 52, 54, 55, 56, 57, 58, 59

Chapters 60, 61, 62, 63, 64, 65, 68, 69

Chapters 70, 73, 74, 76

Chapters 82, 83, 84, 85, 86, 87, 89

Chapter 90, 94, 95, 96

Depending on the product’s tariff number, 1 of 15 different protocols for procuring the license must be undertaken, each of which requires the submission of data related to the goods itself and the exporter.

Automatic Import License

An automatic import license may be applied for where goods do not require a prior approval.  Such application requires providing no less than 14 data points such as country of origin, FOB values, and product information.

What does this change mean?

The new SIMI system should streamline customs clearance into Argentina given the application of the non-automatic import license and the reduction in goods subject to prior approval.

If you export goods to Argentina, be prepared for the possibility that customs may come back asking questions in relation to the values you have provided as Argentina maintains a database of what it considers to be the import value of certain articles based on the history of values recorded by other prior imports of the same kind.  Moreover, in the case of warranty or replacement parts, Argentina does not recognize that these articles have no value but will accept a lower value than that under a traditional sale.

It is therefore important that valuations remain consistent both for customs entry purposes as well as in the event a customs challenge related to the value, and hence the duties and taxes paid to the government, needs to be resolved.

It should be noted that Argentina customs has been known to look to historic import data and customer price lists of third party companies when making a challenge in an effort to collect higher tax and duty revenues. 

Next Steps

Exporting to Argentina and experiencing shorter customs clearance times may be possible with some advance preparation.  If this is something you would like to explore, post your questions and/or comments below.