0 · Verdict
Amber · depends on the compositionThe product can be exported with the agreement's preference. The duty today is 7.8% + 87.5% of EA, with a maximum of 21.1% + 87.5% of AD S/Z instead of (9 + EA) MAX (24.2 + AD S/Z), and it reaches zero on 1 January 2033. EA is the agricultural component, an amount in euros per 100 kg that depends on the milk, starch and sugar in the product. The AD S/Z in the maximum is an additional duty on sugar.
Recommended action: calculate the agricultural component with the composition of the product (block 2), declare the additional code it gives and make sure origin can be proven.
Bread › Sandwich biscuits (CN 1905 31 91) has a reduction under the EU-Mercosur Agreement, but the duty depends on the composition of the product (the agricultural component of the Meursing table). It reaches zero on 1 January 2033. There is no quota. Data as of 31 October 2026, from the EU-Mercosur Interim Trade Agreement and the Combined Nomenclature 2026.
1 · Classification
The product in the three nomenclatures
This sheet is built on the EU tariff line 1905 31 91, which is the code the importer declares in the European Union. In Argentina it corresponds to NCM 1905.31.00. The classification should be confirmed by a customs broker.
| Nomenclature | Code | Version | Official description |
|---|---|---|---|
| NCM (Argentina) | 1905.31.00 | NCM in force 2026 | Galletas dulces (con adición de edulcorante) |
| CN (European Union) | 1905 31 91 | CN 2026 (annex in CN 2013: 1905 31 91) | Sweet biscuits; waffles and wafers: sweet biscuits: other: other: sandwich biscuits |
| HS (worldwide) | 1905.31 | Harmonized System | Bread, pastry, cakes, biscuits and other bakers' wares, whether or not containing cocoa; communion wafers, empty cachets of a kind suitable for pharmaceutical use, sealing wafers, rice paper and similar products |
2 · Duty and schedule
The duty today and when it reaches zero
The duty on this line depends on the composition of the product. Besides a percentage it carries an agricultural component (EA) taken from the Meursing table according to milk fat, milk proteins, starch and sugar, with a maximum that adds an additional duty on sugar (AD S/Z). With the agreement, the duty today is 7.8% + 87.5% of EA, with a maximum of 21.1% + 87.5% of AD S/Z. Without the agreement it would be (9 + EA) MAX (24.2 + AD S/Z). With the composition, the calculator below gives the additional code and the amount. It reaches zero on 1 January 2033. On the Argentine side, the export duty today is 0% (Decree 38/2025).
Importing this product from Europe into Argentina
The agreement also lowers what Argentina charges on European goods. Appendix 2-A-2 mirrors the one used in the rest of this sheet. It sets the duty Argentina charges on EU goods entering the country, and lowers it on the same timetable. For an EU supplier selling this product to Argentina, this is the duty that applies.
Import sheet, laid out for buyers sourcing from Europe
| Annex line (NCM 2012) | Base rate | Category | Reaches zero |
|---|---|---|---|
| 1905.31.00 Galletas dulces, con adición de edulcorante Declared today as 1905.31.00 · Same code, unchanged | 18% | 10 | 1 January 2036 |
How this line was reached. The annex writes its list in NCM 2012, while imports are declared in the edition in force. This line did not change between the two editions (the official correlation tables do not list it). All of this covers only the duty. If the purchase falls within a quota, an import licence is also needed (it is below, in the authorisations block). What other Argentine agencies require for entry is below, as the VUCE publishes it. Which ones apply depends on the SIM subdivision declared, set by the customs broker.
Argentine agencies involved in the import
The duty comes from the agreement, the rest is required by each agency. The VUCE assigns 5 interventions of other agencies to the import of this position. Each one is shown with the agency’s own text, in Spanish and unabridged, and with the conditions under which it applies. Several only apply in certain cases (wooden packaging, used goods, goods for consumption), and each one says so. Where the origin changes something, each one also states what applies to goods from the EU.
To import and sell in Argentina
- SENASAAviso de Importación de Alimentos, UPEI, Envases y Muestras - Alta Vigilancia.Customs regime: definitive · Goods: newFor goods from the European Union: This is the one that applies if the food or packaging comes with certification from an EU country. The sworn import declaration is enough, and the health authority may not impose additional requirements. The certificate of free sale, the marketing authorisation or a similar document from the competent health authority must be attached. Source: Decree 2126/71, Annex I, Art. 2, and Annex II, Art. 4(a), as worded by Decree 697/2026, and Annex III to Decree 35/2025.When it applies: Se necesitará realizar la solicitud de "Aviso de Importación de Alimentos y Envases" de aquellas mercaderías que hayan sido elaborados en los países listados en el Anexo III del Decreto 35/2025:
The agency's text (in Spanish)
Mandatory - SENASAEmbalajes de Madera de Importación*Customs regime: definitive/temporary · Goods: newFor goods from the European Union: It is the same for any origin: it covers all wooden packaging entering the country. Source: SENASA Resolution 614/2015.Todos los embalajes de madera de mercaderías que ingresen al territorio argentino debe estar descortezado, libre de insectos y/o signos de actividad biológica, tratado y certificado en concordancia con lo estipulado en la Norma Internacional para Medidas Fitosanitarias (NIMF N° 15) de la Convención Internacional de Protección Fitosanitaria.When it applies: La mercadería es acondicionada con embalajes de madera o madera de acomodación.
The agency's text (in Spanish)
Mandatory
Only for goods without certification from an EU country
- SENASAAutorización de Importación de Alimentos, UPEI, Envases y Muestras.Customs regime: definitive · Goods: newFor goods from the European Union: If the food or packaging comes with certification from an EU country, this procedure is not needed: the notice is enough. The authorisation is for products without that certification: in that case SENASA carries out an analytical check and does not release the product until the result is in. Source: Decree 2126/71, Annex I, Art. 2, and Annex II, Art. 4(a), as worded by Decree 697/2026, and Annex III to Decree 35/2025.When it applies: Se solicitará la Autorización de importación de alimentos para comercializar, alimentos para uso propio del establecimiento importador, muestras sin valor comercial, envases y utensilios en contacto con alimentos que NO hayan sido producidos en los países (Australia, Canadá, Confederación Suiza, Unión Europea, Estados Unidos, Nueva Zelanda, Estado de Israel, Japón, Reino Unido de Gran Bretaña e Irlanada del Norte, Países con los que rijan Tratados de Integración Económica o Acuerdos de Reciprocidad en materia higiénico-sanitarias) pertenecientes al anexo III del Decreto 25/2025, según lo establecido por la Disposición ANMAT 537/2025.
The agency's text (in Spanish)
Mandatory
Only for temporary imports, transit or other regimes
- SENASALibre circulación de importaciones temporales - alimentos y materiales en contactoCustoms regime: temporary, in transit · Goods: newPermite el ingreso temporal de mercadería al país con la obligación de reexportarla para consumo en un plazo determinado
The agency's text (in Spanish)
Mandatory
Optional: tools, not requirements
- Secretaría de Industria, Comercio y de la Pequeña y Mediana EmpresaSolicitud Resolución Anticipada de OrigenCustoms regime: definitive · Goods: new/usedWhen it applies: El origen de las mercaderías determina, principalmente, el tratamiento arancelario aplicable a su importación. La Resolución Anticipada de Origen (RAO) permite al importador conocer, antes de llevar adelante sus respectivas importaciones, qué origen va a considerar el Estado Argentino a los fines de aplicar el tratamiento arancelario.
The agency's text (in Spanish)
Optional
Source: VUCE, tariff position finder, checked on 6 October 2026. Agencies change their interventions often, so each one links the VUCE page it comes from, to be checked on the day of import.
Year-by-year table and how it is calculated
| From | Stage | Ad valorem | Specific (€) | Applies |
|---|---|---|---|---|
| 1 May 2026 | 1 of 8 (year 0) | 7.8% | 87.5% of EA | Preferential |
| 1 January 2027 | 2 of 8 | 6.7% | 75% of EA | Preferential |
| 1 January 2028 | 3 of 8 | 5.6% | 62.5% of EA | Preferential |
| 1 January 2029 | 4 of 8 | 4.5% | 50% of EA | Preferential |
| 1 January 2030 | 5 of 8 | 3.3% | 37.5% of EA | Preferential |
| 1 January 2031 | 6 of 8 | 2.2% | 25% of EA | Preferential |
| 1 January 2032 | 7 of 8 | 1.1% | 12.5% of EA | Preferential |
| 1 January 2033 | 8 of 8 | 0% | 0 | Duty-free |
How it is calculated. The line's category reduces the whole duty, agricultural component included. Article 1.3 and its footnote 1 count agricultural components and the additional duties on sugar and flour as «customs duty», and Article 2.4(4) requires the reduction to start from the base rate of the annex. The specific column shows which share of the agricultural component (and of the additional duty in the maximum) is paid each year; the amount comes from the Meursing table with the composition, in the calculator below.
Note. The MFN duty and the agreement duty are expressed differently, so they cannot be compared automatically. The calculation uses the annex base rate and should be confirmed in TARIC.
Additional refund. Certified organic products, products bearing the Alimentos Argentinos una elección natural seal and products with a registered designation of origin or geographical indication get an additional 0.5% (Decree 1341/2016, Arts. 3 to 5, maintained by Art. 11 of Decree 557/2023). They do not add up: a product that meets more than one condition still gets 0.5% (Resolution 90-E/2017, Art. 9), and each condition is proven with a certificate per shipment (Arts. 1 and 2).
On the Argentine side. Today's export duty is set by Decree 38/2025, Art. 1 and Annex I (IF-2025-08161099-APN-SAGYP#MEC), and it is the rate the VUCE applies (checked on 17 October 2026).
Agricultural component calculator
The duty on this line depends on what the product contains. Enter the content of each component as a percentage of weight and the calculator finds the additional code of the Meursing table and calculates the duty.
Fill in the four contents; if the product has none of one, enter 0.
How it is measured and where it comes from
How each content is measured. Everything as a percentage of the weight of the goods as presented. Notes (132) to (134) of Table 1 specify it: starch/glucose includes its degradation products and the glucose present, expressed as starch (glucose is converted with the factor 0.9); sucrose adds the mixture of glucose and fructose expressed as sucrose (multiplied by 0.95); and caseins or caseinates do not count as milk proteins if the goods contain no other milk component.
Where the amounts come from. The additional code comes from Table 1 and the amounts, in euros per 100 kg net weight, from Table 2 of the same annex. AD S/Z only counts towards the maximum, as the annex says. The additional code is declared at EU customs together with the CN code.
With the agreement. The line's category reduces the whole duty, agricultural component included (Article 1.3, footnote 1, and Article 2.4(4)). TARIC publishes the reduced agricultural component as «EAR» and does not print the amount in the measure: the one here is the table amount multiplied by the share still payable, truncated to the cent like the rest of the schedule. It should be confirmed with the customs broker.
Source: Regulation (CEE) No 2658/87, Annex I, tercera parte, Section I, Annex 1, cuadros 1 y 2 · Agreement: iTA · Annex 2-A, Section A
3 · Tariff-rate quota and access
This line has no tariff-rate quota
The agreement opens no tariff-rate quota (TRQ) for this line. The preference therefore applies to every shipment, with no volume limit and no quota procedure.
Where to check it
- Section B of Annex 2-A lists the 23 quotas the European Union opens for Mercosur. None covers this line.
| Period | Volume | Status |
|---|
If the product may fall under one of them, write to us and we will review it.
4 · Rules of origin
Whether the product qualifies as originating
To benefit from the preference the product has to be originating. The applicable rule is the one for 19.04 – 19.05, which requires that all the conditions it lists be met at the same time, not just one. Answer the questions to see whether the product qualifies.
Materials questionnaire
Only the questions the case needs are shown. The result applies the Annex 3-B rule for this line.
Check the materials one by one with the origin assistant, with their tariff code and their share of the price.
The rule as published, the tolerance and the proof of origin
The rule, as published in the agreement: «CC, provided that: all the materials of Chapter 4 used are wholly obtained; the total weight of non-originating materials of headings 10.06 and 11.01 to 11.08 used does not exceed 20 % of the weight of the product; and the total weight of non-originating materials of headings 17.01 and 17.02 used does not exceed 20 % of the weight of the product.»
Tolerance. Article 3.5 tolerates materials that do not meet the rule up to 10% of the ex-works price.
Cumulation. The agreement allows bilateral cumulation: originating materials of the other Party count as originating (Chapter 3 of the iTA).
How it is proven. Origin is proven with the exporter's statement on origin (Annex 3-C). At the start, the transitional certificate of origin of Annex 3-D also applies (notice 2026/875).
Edition. Annex 3-B is written in the 2017 Harmonized System and this sheet uses the edition in force. At four and six digits they almost always match. If the product changed heading between editions, the rule should be confirmed with the customs broker.
For now the certificate of origin is still accepted. Until 1 May 2029 the European Union also accepts the traditional certificate of origin, besides the exporter's own statement on origin. In the Spanish text: «Durante un período no superior a 3 (tres) años a partir de la fecha de entrada en vigor del presente Acuerdo, la Unión Europea aceptará también como declaración de origen un «certificado de origen» que indique que los productos importados en la Unión Europea cumplen los requisitos de origen establecidos en el presente Acuerdo.» (iTA, Annex 3-D, paragraph 1). The period may be extended by 2 more years at Mercosur's request.
5 · Health, technical and labelling requirements
What the product must meet to enter the EU
The product is on the list of goods the European Union controls at the border, so it enters through a border control post and with an official certificate. It is a procedure to complete, not a prohibition, but without it the consignment is not cleared, even at zero duty. The Commission's portal (Access2Markets) assigns 5 EU product requirements to this line (technical, labelling or marketing rules). It assigns them to the whole line, and the table lists each one with its act and the link to check whether it applies to the product.
- SPSOfficial control at an EU border control postConfirmedmust be met before shipmentThe consignment must enter through an approved border control post, be pre-notified in TRACES with a common health entry document (CHED) and travel with the official certificate that applies. The annex narrows it as follows: «Solo si contienen productos de origen animal.»
- Where it is handledTRACES NT · EU consignment control systemConfirmedprocedureThe consignment is notified here before it arrives, and the certificate is issued by SENASA on the Argentine side.
EU requirements for this line (6)check which ones apply to the product
The European Commission assigns them to the whole line, so each one should be checked against the actual product.
- EU · healthControl of contaminants in foodstuffsRegulation 2017/625, Regulation 315/1993, Regulation 2023/915 and 3 more acts
- EU · healthHealth control of Genetically Modified (GM) food and novel food
- EU · healthHealth control of foodstuffs of non-animal originRegulation 2017/625, Regulation 852/2004, Regulation 2073/2005 and 7 more acts
- EU · labellingLabelling of foodstuffsRegulation 1169/2011, Regulation 2018/848, Regulation 834/2007 and 9 more acts
- EU · healthTraceability, compliance and responsibility in food and feedRegulation 178/2002
- Only if applicableVoluntary - Products from organic productionRegulation 2018/848, Regulation 834/2007, Regulation 2021/2325 and 4 more acts
Source: Access2Markets (European Commission) · checked on 1 September 2026
6 · Authorisations and registrations
What must be approved before exporting
There are two gates, in this order. First the country, since the European Union only admits products of animal origin from countries whose control plan it has approved, and Argentina is approved for 12 of 13 categories. Then the plant, which must be approved in Argentina and, for most products of animal origin, appear on the list the Commission publishes.
- Third-country listArgentina is on the list of authorised countriesConfirmedthe country is authorisedThe Commission has approved Argentina's control plan for Bovine, Ovine/caprine, Equine, Poultry, Aquaculture (16), Milk, Eggs, Rabbit, Wild game, Farmed game, Honey, Casings. The category of the product should be confirmed with the customs broker, because the annex does not express them by tariff code.
- No approved planCategories for which Argentina is NOT on the listConfirmedcheck whether it is the category of the productPorcine. A product in any of these cannot enter the European Union today, even at zero duty and with an establishment approved in Argentina.
- Establishment approvalThe plant, approved in Argentina and listed by the European UnionNo dataNo data. It is in SENASA's register and the European Commission's list of establishments.
- Exporter registrationRegistration as an exporter with Argentine customsNo dataNo data. It is in ARCA's register of importers and exporters.
7 · Cross-cutting EU regulations
EUDR, CBAM and safeguards
These are the rules that stop a shipment for reasons unrelated to the duty. Neither of the two covers this line, according to the list of codes in the annex of each regulation.
EUDR · deforestation
Prohibits placing on the EU market products linked to deforestation. It covers seven commodities (cattle, cocoa, coffee, oil palm, rubber, soya and wood). It does not cover this line, because it is not in the list of codes of Annex I.
Source: Regulation (EU) 2023/1115, Annex ICBAM · carbon border adjustment
Charges at the EU border for the carbon embedded in certain energy-intensive goods (cement, electricity, fertilisers, iron and steel, aluminium and some chemicals). It does not cover this line, because it is not in the list of codes of Annex I.
Source: Regulation (EU) 2023/956, Annex ISafeguards
Chapter 9 of the agreement allows either Party to suspend the preference for a product if increased imports cause injury to its industry. It is a mechanism, not a list, and nothing applies unless a specific measure has been imposed. Check in TARIC whether any measure is in force for 1905 31 91.
Measures in force · No data8 · Destination
Choose a destination country
The duty, the schedule, the quota and the rule of origin are the same in all twenty-seven Member States, so no country needs to be chosen for the above. What changes by country is the label language, VAT and local formalities.
Choose one of the destinations available
9 · EU market
How much of this product the EU imports
In 2025 the EU imported €58.3 million from outside the EU; Argentina supplied 0.4% and was the 21st supplier.
Where the EU buys from (2025)
| Rank | Country | Value | Share | €/kg |
|---|---|---|---|---|
| 1st | United Kingdom | €19.0 million | 32.6% | €3.48/kg |
| 2nd | Türkiye | €13.9 million | 23.8% | €2.83/kg |
| 3rd | Ukraine | €7.9 million | 13.5% | €2.49/kg |
| 4th | Switzerland | €1.9 million | 3.3% | €8.97/kg |
| 5th | Colombia | €1.9 million | 3.3% | €2.90/kg |
| 21st | Argentina | €243,463 | 0.4% | €2.16/kg |
Another €1,735 comes from origins Eurostat does not identify (ship stores, commercial or military reasons).
Brazil, Uruguay and Paraguay enter with the same cut (2025)
| Rank | Country | Value | Share | Quantity | €/kg |
|---|---|---|---|---|---|
| 21st | Argentina | €243,463 | 0.4% | 113 t | €2.16/kg |
| 24th | Brazil | €186,298 | 0.3% | 59 t | €3.15/kg |
| — | Uruguay | No sales | — | — | — |
| 47th | Paraguay | €16,429 | less than 0.1% | 4.7 t | €3.47/kg |
Under the agreement they pay the same duty as Argentina, so they compete on price and volume. The rank is among all suppliers from outside the EU.
Who imports within the EU (2025)
| Rank | Member State | Value | Share |
|---|---|---|---|
| 1st | Ireland | €16.2 million | 27.8% |
| 2nd | Netherlands | €9.9 million | 17.0% |
| 3rd | Romania | €8.1 million | 13.8% |
| 4th | Germany | €6.0 million | 10.4% |
| 5th | France | €3.8 million | 6.6% |
It is the Member State that declares the import, which is not always where the goods are consumed: the ports of the Netherlands and Belgium receive goods for the whole Union.
What your competitors pay
What the 13 countries on the list pay. On this line the duty is not a single figure to compare with yours, so look at each row.
Country by country (13)
- Argentina, todayDepends on the compositionUnder the EU-Mercosur agreement
- Argentina, at the end0%Reaches zero on 1 January 2033
- United Kingdom1st EU supplier0%EU preference for its originTARIC, measure 142 (tariff preference), Decision 2253/20, since 1 January 2021
- Türkiye2nd EU supplier0% + EA max. 24.2% + AD S/ZCustoms union with the EU«EA» is the agricultural component, worked out with the Meursing table from the composition.TARIC, measure 106 (customs union duty), Decision 0142/96, since 1 January 2006
- Ukraine3rd EU supplier0%EU preference for its originTARIC, measure 142 (tariff preference), Decision 0295/14, since 1 January 2016
- Switzerland4th EU supplier0%EU preference for its originTARIC, measure 142 (tariff preference), Decision 0045/05, since 1 September 2011
- Colombia5th EU supplier0%EU preference for its originTARIC, measure 142 (tariff preference), Decision 0735/12, since 1 August 2013
- Chile0% + EAR max. 12.1% + AD S/Z REU preference for its origin«EA» is the agricultural component, worked out with the Meursing table from the composition.Valid until 31 December 2026.It also has a quota (order 09.1933) where it pays 0%.TARIC, measure 142 (tariff preference), Decision 3016/24, since 1 January 2026
- Mexico9% + EA max. 24.2% + AD S/ZNo preference, pays the MFN duty«EA» is the agricultural component, worked out with the Meursing table from the composition.TARIC, measure 103 (MFN duty), Regulation 2031/01, since 1 January 2005
- Canada0%EU preference for its originIt also has a quota (order 09.8302) where it pays 0%.TARIC, measure 142 (tariff preference), Decision 0037/17, since 21 September 2017
- South Africa0% + EA max. 24.2% + AD S/ZEU preference for its origin«EA» is the agricultural component, worked out with the Meursing table from the composition.TARIC, measure 142 (tariff preference), Decision 1623/16, since 10 October 2016
- New Zealand0%EU preference for its originTARIC, measure 142 (tariff preference), Decision 0244/24, since 1 May 2024
- Vietnam0%EU preference for its originTARIC, measure 142 (tariff preference), Decision 0753/20, since 1 January 2023
- United States9% + EA max. 24.2% + AD S/ZNo preference, pays the MFN duty«EA» is the agricultural component, worked out with the Meursing table from the composition.It also has a quota (order 09.9015) where it pays 2.3% + €4.74/100 kg/net.TARIC, measure 103 (MFN duty), Regulation 2031/01, since 1 January 2005
- China9% + EA max. 24.2% + AD S/ZNo preference, pays the MFN duty«EA» is the agricultural component, worked out with the Meursing table from the composition.TARIC, measure 103 (MFN duty), Regulation 2031/01, since 1 January 2005
The countries are the five largest non-EU suppliers of this line (Eurostat, Comext) and a fixed reference list, with an agreement with the EU (Chile, Mexico, Canada, South Africa, New Zealand and Vietnam) and without one (United States and China). Brazil, Paraguay and Uruguay enter under the same agreement as you.
Each figure is the TARIC measure in force today for that origin, in the edition of 1 October 2026. Before clearing goods, the importer checks TARIC with the date and the ten-digit code.
TARIC, European Commission, edition of 1 October 2026 (CIRCABC)
10 · What to do, in order
The steps, in order
6 steps, in the order they are taken. Each one comes from a block of this sheet.
- 1Confirm the tariff classification with a customs brokerThis whole sheet depends on the line being 1905 31 91. If the line changes, so do the duty, the quota, the rule of origin and the requirements. It is the one step that cannot be skipped.Customs broker
- 2Register as an exporter with ARCA (Argentina)On the Argentine side, the export is lodged with customs, which requires registration in the exporters' register. That registration comes before the first shipment.
- 3Check that the product is originating, and be ready to prove itThe rule for 19.04 – 19.05 requires that all the conditions it lists be met at the same time, not just one. Without proof of origin there is no preference, and the MFN duty is paid even if the product qualifies. Origin is proven with the exporter's statement on origin (Annex 3-C). At the start, the transitional certificate of origin of Annex 3-D also applies (notice 2026/875).The exporter makes the statement. A certifying body is involved if the transitional certificate of Annex 3-D is needed.
- 4Obtain establishment approval and the health certificateThis line is on the list of goods the European Union controls at the border. The certificate is issued by SENASA, and for that the establishment must be approved and, depending on the product, appear on the EU list of approved establishments.
- 5The importer pre-notifies the consignment before arrivalThe consignment is announced in TRACES with a common health entry document (CHED) and enters through an approved border control post. If the port of destination has no post for this type of product, the consignment cannot enter there.TRACES NT · done by the EU importer
- 6Check the technical and labelling rules for the productComposition, additives, contaminants, packaging and label. The EU product requirements for this line are in block 5; the detail by destination country, in the Commission's search tool. See it in Access2MarketsEuropean Commission · Access2Markets