Introduction
When Provision 1/2026 of the Undersecretariat of Foreign Trade came into force in Argentina on May 1, 2026, a cycle that had been developing since the negotiation of the Agreement between the European Union and MERCOSUR, back in 2019, came to a close.
At that time, our country, along with its MERCOSUR partners, made several commitments; one of them was to move towards a self-certification of origin model, thus incorporating advancements in this area into the bloc. None of the members were certain about the timeframe in which each would achieve the necessary internal adjustments for its implementation. However, there was consensus that it was a necessary step to facilitate regional foreign trade..
Since 2019, several factors have contributed — such as changes in the environment and the development of technologies, among others — to accelerating the processes that today allow this to be a reality for almost all members of the bloc: the scheme of self-declaration of origin by the exporter himself.
Indeed, since May 1st, Argentina has joined Brazil and Uruguay in adopting regulatory frameworks that allow the issuance of a declaration directly by the exporter, gradually replacing - as will be seen later - the traditional Certificate of Origin managed before an authorized entity.
This change teaches us—in parallel—another way of understanding the elements that impact operational processes: clearly, the availability of accurate information is the key to success. Like any new management system, this will involve fine-tuning the mechanisms to avoid beginner mistakes.
Thus, it's important to remember that the previous system has the advantage of years of application and use. This experience and evolution, inherent to the passage of time, facilitate the detection and prevention of errors in the preparation process. This situation will be quite a challenge during the initial stages of the new self-management mechanism. However, this should in no way be seen as an obstacle; on the contrary, this change allows for the validation of the original proof of origin, assuming the risk with the responsibility it deserves.
Towards a change of model: coexistence and transience
As we anticipated, for a period, both systems will coexist: self-certification and the current system of Certificates of Origin. Indeed, we must emphasize that the latter It is still in effect and is not affected by any of these innovative changes. While they are not the focus of analysis on this occasion, the other agreements signed by Argentina and Mercosur maintain the duality of emission models. However, what is essential to bear in mind is that, particularly in the case of the Interim Trade Agreement between Mercosur and the European Union (ITA), this duality will only last during a transition period. 3 yearswhich could be extended - or not depending on how it works - by 2 moreThis is because the ITA Rules of Origin are clear in referring to its system of origin certification based on the Declaration of Origin as the main test and maintaining this permissive "waiver" during the first few years so that MERCOSUR exporters can adapt to the new modality.
Validation vs. Presumption
This change is significant for the current issuance schemes in the region. It's important to remember that the standard system relies on prior validation by the issuing entity, supported by a sworn statement from the exporter or producer, and complies with the requirements of current regulations, given that this issuance system is delegated by the relevant government agency.
The new Declaration of Origin system relies on a presumption of truthfulness that transfers all legal responsibility to the exporter (identified by their CUIT), who uploads their data and issues the document via the platform. TAD (Remote procedures), -free of charge- and with a validity of 12 monthsThis document itself has the character of a Sworn Statement as established by the provision.
Responsibility and Control
With the disappearance of the management of the Chambers, the acuity The exporter's role in the new model is vital. An error in determining origin can lead to controls and audits. ex post, following the logic of the procedures foreseen in the section on verification and control of origin which in their development may take up to 10 months.
Therefore, to operate under this new scheme, it is essential that the exporter knows the "fine print" of the agreement.
Technical accuracy in identifying products at the six-digit level of the nomenclature is now the primary support for verifying origin. Incorrect tariff classification is grounds for denying preferential treatment if it affects the product's "originating" status. While typographical errors can be corrected, an incorrect tax identification number (CUIT) or a description—for example—that affects the origin status are grounds for denying preferential treatment, among other reasons.
Likewise, the regulation is strict regarding document preservation: both exporters and importers must keep backups of information for at least 3 years.
Accumulation and value chains
A frequently underestimated concept is the accumulation of origin. The Agreement establishes this concept bilaterally (Art. 3.6 of the ITA 2026): materials originating in one Party and used in the production of another are considered to originate in the latter. This opens opportunities for integrated value chains within the bloc, but requires that the processing carried out goes beyond so-called insufficient operations (simple assembly, changes in packaging, labeling, simple mixing of products, etc.), which by themselves do not confer origin—an aspect that deserves further exploration in future analyses.
What happens in the rest of the block
In the case of BrazilThe self-certification mechanism is regulated by Ordinance SECEX 373/2024—in force since March 2025. This regulation provides for an extended document retention period of five years, with a more robust archiving system, especially for companies with operations in both countries. Regarding sanctions, disqualifications of one to five years are foreseen.
UruguayFor its part, it recently incorporated Resolution 3.003/026—April 2026—adopting the Declaration under the terms of CMC Decision No. 05/23, aligning the bloc with international standards. Regarding sanctions, the regulation establishes the application of the sanctions regime of Law No. 20.446.
Unlike the Argentine standard, these do not incorporate loading platforms such as TAD, which allows the exporter's own declaration to be given the status of a sworn statement.
Learning as a strategic asset
Trade facilitation should not be interpreted as an absence of controls, but rather as their optimization. This new scenario requires Argentine exporters to transform their administrative structure into a true preventive audit unit. acuity mentioned at the beginning of this analysis is not optional: it is the ability to convert the availability of technical data in legal security.
El learning This will be the curve that separates resilient companies from those exposed to tariff risks. Leveraging available digital tools, understanding the depth of bilateral accumulation, and professionalizing origin determination are the necessary steps to transform the autonomy we have gained into a sustainable competitive advantage in the global market.
Pages of interest:
Argentina
- Single Window for Foreign Trade (VUCE): https://www.vuce.gob.ar/acuerdoMercosur
European Union
- Information on customs relations and agreements: https://taxation-customs.ec.europa.eu/customs/international-affairs/third-countries/latin-america-0
Regulation
- Official Gazette of the Argentine Republic:
https://www.boletinoficial.gob.ar/detalleAviso/primera/341406/20260430 - Ministry of Economy and Finance (Uruguay):
https://www.gub.uy/ministerio-economia-finanzas/institucional/normativa/resolucion-n-3029026-acuerdo-interino-comercial-entre-mercosur-union - Secretariat of Foreign Trade (Brazil):
https://www.gov.br/siscomex/pt-br/acordos-comerciais/PORTARIASECEXN373DE18DEDEZEMBRODE2024PORTARIASECEXN373DE18DEDEZEMBRODE2.pdf
She holds a degree in International Trade (Universidad Nacional de Luján) with postgraduate studies in the Master's Degree in International Economic Relations (Universidad Nacional de Tres de Febrero). She has been a professional development fellow of the Organization of American States (OAS) at the George Washington University School of Law (USA). In the academic field, she is a professor at the Universidad Nacional de Luján. In the professional field, she has been an official of the Secretariat of Commerce dependent on the Ministry of Economy of the Nation, since 2005. Currently, she is the National Coordinator of the Technical Committee No. 3 "Trade Standards and Disciplines" in charge of the negotiations of rules of origin of MERCOSUR; in addition, she is the Alternate National Coordinator of the Technical Committee No. 8 "Transposition of nomenclature of trade agreements with third countries and groups of countries" also of MERCOSUR.
