Ten-Year Extension for the Validity of Sanitary Registrations

The Productivity Bill proposes extending the validity of sanitary and phytosanitary registrations from 5 to 10 years.

Specifically, it provides that all merchandise registration certificates enabling commercialization in Uruguay will have a minimum validity period of 10 years, except for cases based on technical, sanitary, or environmental grounds. Upon expiration, the renewal will be processed through a sworn declaration stating that the technical conditions of the original registration have not changed.

What Does Not Change: Pre-existing Registrations Retain Their Original Term

A company with a current 5-year registration obtained under the existing framework will not automatically shift to a 10-year term on the day the law takes effect. The benefit will apply only to new registrations and future renewals, not retroactively. This has a practical implication: it may be advisable to evaluate the timing of upcoming renewals to leverage the new regime in the first renewal following the law's entry into force, rather than renewing under the current framework.

The Sworn Declaration Shifts the Verification Burden to the Declarant

Renewing via sworn declaration will be faster and more efficient, but the signatory will be certifying that the products' technical conditions have not changed. If it turns out that they have changed and the corresponding modification was not declared, the renewed registration will be subject to ex-post administrative audit. This carries potential penalty consequences—no longer under the rationale of "they didn't review it in time," but rather "something untrue was declared."

Practical Application

Considering the likely approval of the Bill, we suggest:

• Prepare an expiration schedule for your company's sanitary, phytosanitary, technical, and environmental registrations, highlighting those expiring in the next 12–18 months: these are the ones likely to benefit first from the new validity term.

• Conduct an internal technical audit to ensure conditions have not changed before signing any renewal sworn declaration, should the bill pass.

• Evaluate declaring modifications prior to renewal if the product underwent minor changes (raw material supplier, production process, packaging) during the registration's term, rather than renewing as if nothing had changed.

• Identify potential exclusions by checking whether your company's products fall into categories that regulations might exclude from the 10-year term (due to technical, sanitary, or environmental reasons), rather than assuming the benefit is automatic across all sectors.

Commentary

The benefit proposed by the Productivity Bill—long requested by the business sector—is tangible and valuable, but it does not come without trade-offs: it replaces a state verification burden with a truthfulness reporting obligation, thereby increasing user responsibility. Consequently, businesses will need to carefully evaluate when to transition into the new regime and ensure they have the necessary internal technical backing in each case.