The Food, Beverage and Cosmetics Law Review: Argentina

Overview

The Argentine Food Code (Law No. 18,284) is the main statutory law regulating the manufacture, sale and marketing of food and beverages (the Food Code). The Food Code follows the standards, guidelines and codes of practice established by the Food and Agriculture Organization of the United Nations, the World Health Organization and MERCOSUR. It contains all current regulations related to the development, packaging, equipment, transformation, labelling, transport, distribution and commercialisation of foods and beverages for human consumption. In addition, the Ministry of Health and the Ministry of Agriculture, Livestock and Fisheries, and particularly the National Administration of Medicines, Food and Medical Technology (ANMAT) and the National Service of Agri-Food Health and Quality (SENASA), within the scope of said ministries, respectively, issue regulations applicable to food and beverages.

With respect to cosmetics, ANMAT is the main regulatory body issuing the applicable regulations that are aligned with the European Union and MERCOSUR standards. ANMAT regulates all matters related to elaboration, good manufacturing practices, cosmetovigilance and other technical matters.

As regards the Argentine market, the covid-19 pandemic and particularly the mandatory social isolation (quarantine) adopted by the Argentine government, impacted on people's lifestyle and eating habits. For instance, during the period of confinement there was a significant decrease in the consumption of immunomodulatory potential food such as fruits and vegetables, and an increased intake of bakery products, sweets, sugary drinks and alcoholic beverages.2 More than half of the daily diet of Argentines is centred on wheat-based foods (bread, pasta, crackers, cookies, baked goods, pizza), sugar (soft drinks, juices, candies, snacks) and meat (100kg per capita consumption). According to several statistics, during the pandemic alcohol consumption increased by 255 per cent, fish increased by 221 per cent, rice snacks increased by 182 per cent, baby/child food increased by 100 per cent and candy increased by 98 per cent.3

Year in review

The most notable development in the legal framework over the past year is the Food Labelling Bill (the Bill), which was already approved by the Senate Chamber and by the competent committees of the Deputies Chamber. The last step for the Bill to be enacted is its discussion and approval in the Chamber of Deputies and publication in the Official Gazette.

In summary, the Bill's purpose is to:

  1. promote healthy eating, providing simple and understandable nutritional information on packaged foods and soft drinks and non-alcoholic beverages, to promote active decisions and safeguarding the rights of consumers;
  2. warn consumers about the excesses of certain components such as sugars, saturated fats, total fats and calories, based on clear, timely and truthful information; and
  3. promote the prevention of malnutrition in the population and the reduction of chronic non-communicable diseases.

It is worth highlighting that packaged food with critical nutrients and energy values exceeding the values established by the Bill will have to include on the packaging front face an indelible warning label for each critical nutrient in excess, setting forth, as appropriate: 'EXCESS SUGARS'; 'EXCESS SODIUM'; 'EXCESS FAT'; 'EXCESS SATURATED FAT'; 'EXCESS TOTAL FAT'; and 'EXCESS CALORIES'. In the case of food containing sweeteners or caffeine, the package must include a cautionary legend immediately below the warning seals with the wording: 'CONTAINS SWEETENERS/CAFFEINE, NOT RECOMMENDED FOR CHILDREN'.

The warning label must comply with the following provisions:

  1. a form of black octagon with a border and white letters, in capital letters;
  2. its size shall never be less than 5 per cent of the surface of the front face of the package; and
  3. it may not be partially or totally covered by any other element.

The Bill sets forth that the maximum values for sugars, saturated fats, total fats and sodium must comply with the limits of the Nutrient Profile of the Pan American Health Organization. As for the energy value, the enforcement authority must establish specific parameters for its determination.

In other cases of advertising of food and non-alcoholic beverages that contain at least one warning label:

  1. they are not allowed to highlight positive supplemental nutritional qualities of the products referred, so as not to promote confusion about the nutritional contributions;
  2. the warning labels that apply to the product must be visible and fully displayed on the product;
  3. they are not allowed to include children's characters, animations, cartoons, celebrities, athletes or mascots; delivery or the promise of delivery of gifts, prizes, or any other element; as well as the participation or promise to participate in contests, games, musical, theatrical or cultural events, that incite, promote or encourage the consumption, purchase or choice thereof; and
  4. they are prohibited from promotion or delivery free of charge. 

Another matter to highlight is that all forms of advertising, promotion and sponsorship of packaged non-alcoholic food and beverages containing at least one warning label, which is especially directed to children and teenagers, is prohibited.

Food and cosmetic safety

i Regulatory framework

In Argentina, there are two regulatory bodies governing the manufacture, growing and distribution of food, beverages and cosmetics: ANMAT and SENASA.

ANMAT, within the scope of the Ministry of Health, governs the registration, control and surveillance of medicines; cosmetics; medical products; packaged foods; dietary supplements; additives; sweeteners and ingredients; household products; and disinfectants.

SENASA, within the scope of the Ministry of Agriculture, Livestock and Fisheries, is responsible for planning, executing and controlling the development of actions in relation to the health of animals and plants, as well as the prevention, control and eradication of diseases and pests that affect national forestry and livestock production, flora and fauna; actions related to the production, safety and quality of agrifoods, specific agricultural inputs and the control of chemical residues and chemical and microbiological contaminants in food, and the national and international trade of such products.

Both regulatory bodies govern through periodical audits and inspections (that may be programmed or spontaneous) performed by authorised inspectors. Once the inspection has been completed, the inspector will proceed to issue a record of the conditions of the establishment or product, as applicable. This report will also include a record of the infractions committed, if any.

In the case of an infraction, offenders could be sanctioned with:

  1. public or private warning;
  2. fines;
  3. suspension;
  4. temporary or definitive shutdown of the establishment;
  5. confiscation of the involved products, even as a preventive measure; and
  6. loss of concessions, privileges, special tax or credit regimes.

Sanctions can be applied separately or together, depending on the seriousness of the infraction, the damage caused and the background of the offender. In addition, the Argentine Criminal Code establishes imprisonment from three to 10 years of those who poison, adulterate or falsify in a dangerous way for health, food intended for public use or human consumption.

With respect to import and commercialisation of food and beverages, the Food Code provides that both fall under the control and require prior authorisation from ANMAT and its National Food Institute (INAL), and SENASA.

In summary, the importer shall obtain an authorisation to perform commercial activities in connection with foods and beverages and be enrolled in ANMAT's National Register of Food Establishments (RNE), which enables the importer to develop activities related to food and beverages. Prior enrolment with the RNE is a requirement for registration of the importer's products with the National Register of Foodstuffs (RNPA).4 The RNPA certificate operates as a marketing authorisation of food and beverage products. The validity of the RNPA granted by INAL can be a maximum of up to five years, and it can be renewed 60 days before its expiration.

To secure these registrations, INAL requires:

  1. detailed information regarding the holder of the marketing authorisation;
  2. in the case of an importer, to be already authorised by the Customs Office to act as food importer; and
  3. detailed information regarding the product to be commercialised, including:
    • designation of sale;
    • trademark;
    • commercial or fantasy name;
    • production origin;
    • conditions for conservation;
    • food containers;
    • labels in original language with translation into Spanish;
    • information regarding the process of manufacturing;
    • marketing authorisation issued by the competent authorities of the place of origin; and
    • fitness for human consumption issued by the competent authority of the place of origin.

With respect to the import and commercialisation of cosmetics, ANMAT Dispositions No. 1109/99 and No. 346/06, which incorporates Resolution GMC No. 05/05 'MERCOSUR Technical Regulation' into the national legal system, require cosmetics companies to obtain from the local authorities an authorisation to operate, and each product must be registered with ANMAT. Such applicants must also comply with Disposition No. 339/2006, which incorporates Resolution GMC No. 19/05, 'Cosmetovigilance Program in the Area of Personal Hygiene Products, Cosmetics and Perfumes', and Disposition No. 6477/12, which incorporates Resolution Mercosur GMC No. 19/11 'MERCOSUR Technical Regulations on Good Manufacturing Practices for Personal Hygiene Products, Cosmetics and Perfumes'.

ii Food additives and contaminants

Chapter XVIII of the Food Code regulates all matters related to food additives. These regulations establish that food additives must be harmless, part of the Food Code's positive list of food additives, used exclusively in foods specifically mentioned in the Food Code, and meet the requirements established in the Food Code. Food additives that comply with these requirements may be added to foods to:

  1. maintain or improve nutritional values;
  2. increase the stability or preservation capacity;
  3. increase the acceptability of healthy and genuine foods lacking in attractiveness; and
  4. allow economic and large-scale manufacturing of quality food.

Regarding contaminants, the 'General Standards for Contaminants and Toxins in Food', established by the Food Code's Commission, contain the principles and procedures applied and recommended in relation to contaminants and toxins in food, and the indication of maximum levels of contaminants and naturally occurring toxicants in food. It defines 'contaminant' as any substance not intentionally added to food, which is present in food because of the production (including operations carried out in agriculture, animal husbandry and veterinary medicine), manufacture, processing, preparation, treatment, packaging, transport, or storage of such food or because of environmental contamination. This term does not include insect fragments, rodent hair and other foreign matter. This standard establishes that contaminant levels in food should be as low as reasonably achievable, and provides the following proposed measures to reduce contamination of food:

  1. avoid contamination of food at the source, for example, by reducing contamination of the environment;
  2. apply appropriate technologies in food production, handling, storage, processing and packaging; and
  3. implement measures to decontaminate contaminated food or feed and measures to prevent contaminated food or feed from being placed on the market for consumption.

Also, the Food Code sets forth that Law No. 18,073 on Pesticides and Decree No. 2678/69 are applicable to all agricultural products. The enforcement agencies of Law No. 18,073 will keep permanently updated the permits for the use of new pesticides, as well as the fixing and revision of residual levels of pesticides in agricultural raw materials and processed food.

Due to the high level of chicken consumption in Argentina, SENASA Resolution No. 86/2016, issued within the scope of the National Poultry Health Plan, establishes a mandatory surveillance and control programme aimed at reducing the prevalence of certain serotypes of salmonella at chicken farms, as a fundamental measure to mitigate the risk of contamination of the final poultry product.

iii Recalls

There are different recall regulations in Argentina.

First, Law No. 24,240 on Consumer Defence, its regulatory Decree No. 1798/94 and the regulations issued by the National Direction of Consumer Defence, establish that the supplier of goods or services who, after the introduction of such goods or services in the consumer market, becomes aware of any risk, must immediately inform the competent authorities and consumers of this circumstance by means of sufficient publicity announcements.

Second, both ANMAT and the Food Code provide 'Guides of Procedures for Food Recalls'. These guides provide step-by-step actions to be taken by the food company and the health authority in the event of a recall. Both guides establish that a recall can be the measure to manage a risk detected from:

  1. complaints from different sectors of the community (e.g., consumers, non-governmental organisations, etc.);
  2. actions initiated by health authorities, following an adverse result of an official sample collected in a routine inspection; and
  3. a company suspected of manufacturing or distributing a product that does not comply with the regulations in force and presents a potential risk to the health of the population. For each case, the level within the distribution chain to which the recall action will be extended shall be determined according to the distribution channels that have been used and the extent of the distribution of the product.

In summary, the first step of the procedure is the initiation of the recall, which includes incident detection, risk assessment, recall decision-making and notification to the enforcement authority, food company or consumers. If the recall is initiated by the company, the first step is notifying the enforcement authority and proposing the recall strategy. If the incident is detected by the enforcement authority, it shall notify the company detailing the violation of the regulation, identifying the product to be recalled, and requesting the company to communicate the recall to the consumer. The notification to the public shall detail methods to stop the distribution and marketing of the product and directions on how to store and isolate the product. This communication may be from the company or the enforcement authority, or both, depending on the case. The enforcement authority will control the whole process until the recalled products have been properly identified and withdrawn.

Finally, there is another set of rules that conform to the 'Procedure on alert and recall of products and services considered potentially harmful or dangerous in MERCOSUR', incorporated in the national legal system by Resolution No. 808/2017 of the Secretary of Commerce. This Resolution sets forth a process similar to the one described herein.

It is important to clarify that in the event of a possible complaint from a consumer or the enforcement authority about a risky or failed product, the company would be in a better position if it has made a voluntary recall of the product.

Supply chains

i Labour and immigration

The employer must comply with the provisions of Labour Contract Law No. 20,744, as amended and complemented, and the applicable collective bargaining agreement. These regulations seek to protect the worker, regulating the working conditions, limits to the working day, the applicable regime in case of illness, the payment of overtime work, the vacation regime, the employer's obligation to contract the corresponding insurance for each worker and the payment of an indemnity in the case of unjustified dismissal. The employer is also obliged to observe the relevant occupational health and safety provisions.

With respect to immigration, there are no labour categories in the private sector that are restricted to foreigners; however, there are different types of visas that allow a person to work in Argentina. In accordance with the immigration regulations (Law No. 25,871), all individuals and entities domiciled in Argentina who invite foreigners to work in the country must be registered before the National Registry of Foreign Applicants. This registration allows the company to request transitory work visas and temporary residencies for non-MERCOSUR employees. As stipulated by MERCOSUR regulations, nationals of member countries do not require sponsorship from an employer to apply for a temporary residence in Argentina.

ii Processing and certifications

SENASA is the authority controlling compliance with regulations regarding processing, certifications and quality control mechanisms.

Particularly with respect to organic products, SENASA authorises certified entities to control the operators who produce, process and market these products.5 SENASA controls the certified entities through audits and inspections, providing transparency, ensuring quality and complying with international requirements.

Organic production for final consumption has grown in the past few years. Organic products destined for the domestic market remain at low levels. Today, only 2.8 per cent of certified products are destined for local consumers.6 Currently, there is a Strategic Plan for the Organic Production Sector in Argentina to 2030, to strengthen and develop the Argentine organic sector.

iii Sustainability

In Argentina, the environmental and sustainability legislation consists of national minimum standards that are internalised by each province and municipality. At the national level, with respect to supply chain management in the food, beverage and cosmetics industry, the following laws are relevant:

  1. General Environment Law No. 25,675, which establishes the minimum requirements for the achievement of a sustainable and adequate management of the environment, the preservation and protection of biological diversity and the implementation of sustainable development in Argentina, and provides a general framework on information and participation on environmental matters, liability for environmental damage and environmental education;
  2. Hazardous Waste Law No. 24,051, which defines hazardous waste as any waste that may cause harm to living beings or pollute the soil, water, atmosphere or environment in general; and
  3. Household Waste Management Law No. 25,916, which establishes the minimum environmental protection requirements for the integrated management of household waste.

iv Anti-corruption rules

Argentina has ratified the Inter-American Convention against Corruption, the United Nations Convention against Corruption and the OECD Anti-bribery Convention, and therefore has incorporated in the national legislation certain duties of transparency applicable to the private sector.

At a local level, the most relevant legislation is the Criminal Code (Articles 256 to 259) and Law No. 27,401, and its regulatory decree and complementary regulations (particularly Resolution No. 36/19 of the Argentine Anti-Corruption Office).

The Criminal Code prohibits the active and passive bribery of public officials as well as active bribery of foreign public officials. Under the Code, only individuals can be held liable. In 2017 the Argentine Congress passed Law No. 27,401, which provides criminal liability for legal entities regarding crimes of corruption against public administration and foreign bribery. The most relevant aspects of this law are the following:

  1. legal entities shall be held criminally liable;
  2. in the case of M&A, the successor is liable for the corrupt acts committed by the acquired legal entity;
  3. the statute of limitations is six years;
  4. the sanctions are fines, suspension, inability to participate in public bids, cancellation, loss or suspension of state benefits;
  5. the legal entity and the public prosecutor are entitled to execute a cooperation agreement; and
  6. legal entities must have an adequate compliance programme in place.

v Due diligence and monitoring

When conducting due diligence and monitoring of suppliers and distributors across the supply chain, it is worth mentioning their challenge to keep proper records of compliance with all regulatory requirements of the industry. For that purpose, they must collect all the documentation, forms and health requirements requested by the Food Code and ANMAT Resolution No. 1307/2017 that includes the 'Federal Program of Food Control'. Particularly, companies must have a valid RNE, RNPA and authorisation to perform commercial activities in connection with foods granted by the enforcement authority.

Another common challenge is the lack of compliance with the surveillance programmes aimed at reducing the prevalence of certain serotypes of salmonella at chicken farms, as described in Section III.ii.

Sales and marketing

i Regulatory framework

See Section III.i.

ii Consumer protection and false advertising

The Consumer Protection Law provisions ensure proper disclosure of information and health protection of consumers. It also regulates the terms and conditions of contracts, advertisement, condition of goods and services, warranties, abusive practices and technical services, among other provisions.

With respect to advertising, the National Civil and Commercial Code prohibits misleading, comparative, abusive and discriminatory advertising. Decree 274/2019 on Commercial Loyalty prohibits making any kind of advertising that through inaccuracies may mislead, deceive or confuse, regarding the characteristics or properties, nature, origin, quality, purity, mixture, quantity, use, price, marketing conditions or production techniques of goods, real estate or services.

Specifically, the advertising of food products must aim at the adequate consumption of the product, presenting its properties objectively without deception or misleading, providing truthful, accurate and clear information; must be in Spanish; and must include characteristics and warnings of the product. It must not:

  1. advertise products not authorised by the health authority;
  2. include phrases that involve public authorities;
  3. modify labels regarding the uses and specific properties of the product;
  4. promote that the consumption of it constitutes a health guarantee;
  5. attribute therapeutic actions or properties, or suggest that the food is medicinal or mention that a food diagnoses, cures, calms, mitigates, alleviates, prevents or protects from a certain disease;
  6. advise its consumption for reasons of stimulating action or health improvement or preventive or curative action of a disease or disorder;
  7. provoke fear or anguish, suggesting that the health of a subject will be affected if the product is not used;
  8. be directed exclusively or mainly to children under 12 years of age, without the advice of an adult; or
  9. state that a food can be used as a replacement for a conventional meal or as the only food in a diet.

Product liability

The Consumer Protection Law provides a summary procedure that should be initiated with the Mandatory Mediation Service called COPREC, which works as a compulsory and previous stage for small-amount consumer claims. If the mediation fails, the consumer will be entitled to file the claim before a higher administrative body called the Audit for Consumer Relations (depending on the purpose of the claim) or before the National Consumer Relationships' Courts. Additionally, if the parties reach an agreement, after its approval by COPREC, this will be enforceable at court in case of breach by the condemned party.

Argentina sanctioned several resolutions and national safety programmes with the aim of mitigating the risk of food contamination and safety (see Section III.i. and III.ii).

Intellectual property

Trademarks are regulated under the Trademarks and Designations Law No. 22,362, as amended by Law No. 27,444, Regulatory Decree No. 242/19 and INPI (National Institute of Industrial Property) Resolution No. 123/19, which establishes what can be registered as trademarks. Pursuant to this law, the ownership of a trademark and the exclusivity of use are obtained with its registration, which must be processed before INPI. The term of duration of the registered trademark is 10 years, renewable indefinitely.

The Trademarks and Designations Law, together with Decree No. 556/2009 that regulates Law No. 25,380 and its amendment Law No. 25,966 (legal regime of Geographical Indications and Appellations of Origin for Agricultural and Food Products), expressly forbid the registration of geographical indications and designations of origin as trademarks.

Decree No. 206/2001, regulatory of Law No. 25,127, prohibits the registration as trademark or as part of a trademark of the expression biologic, ecologic, organic, eco and bio with respect to agricultural products such as food.

Patents and utility models are regulated by the Law on Invention Patents and Utility Models No. 24,481 as amended by Law No. 27,444 and Regulatory Decree No. 403/19. This law establishes that product or process inventions are patentable, if they are new, involve an inventive step and are susceptible of industrial application. The term of validity of the invention patent is 20 years from the date of its application, after which it becomes part of the public domain. The application and registration procedures must be carried out before INPI.

Industrial designs and models are regulated under Decree Law No. 6673/63, amended by Law No. 27,444. Said decree law provides protection to industrial and artisanal products (such as packaging, containers, products themselves) of which the shape or outside appearance has an ornamental character. The term of validity of the industrial designs and models is five years as of the date of registration. They can be renewed for two consecutive five-year terms, after which they become part of the public domain. The application and registration procedure must be carried out before INPI.

Trade organisations

In Argentina, there are different chambers and trade associations that bring together and represent the sectors that make up the food, beverage and cosmetics industry, such as the Argentine Association of Cosmetic Chemists, the Argentine Chamber of the Cosmetics and Perfumery Industry, the Chamber of Food Products Industrialists, and the Food Products Industries Coordinating Committee (COPAL).

Argentinean Antitrust Law No. 27,442 (the Antitrust Law) provides that acts and behaviours related to the production or trade of goods and services limiting, restricting or distorting competition or constituting an abuse of a dominant position in a market, in a manner that may result in damage to the general economic interest, are prohibited and shall be sanctioned. Section 2 of the Antitrust Law sets forth a list of types of anticompetitive agreements between competitors, including price-fixing, output-fixing, bid rigging and market and customer allocation, that are considered 'practices absolutely restrictive of competition' and 'presumed to affect the general economic interest'. Section 3 sets forth a non-exhaustive list of practices that are considered unlawful if they fall under the general prohibition of Section 1, and to which a rule of reason or effects-based approach applies.

Conducts provided in Section 3 of the Antitrust Law (such as exchanges of confidential information that are not ancillary to a cartel) must be analysed under the rule of reason or effects-based approach, thus, taking into consideration the nature of the action, the market share of the company under investigation, and each market-specific structure and characteristics.

In December 2018, Argentina's Antitrust Commission issued a Guideline for Business Associations and Chambers and Professional Associations and Colleges aimed at preventing the creation of cartels and avoiding the exchange of confidential information between the members of a trade organisation, by setting clear-cut rules as to what kind of information cannot be shared, and if sharing the information is essential, what arrangements or safeguards shall be implemented to eliminate or reduce the antitrust contingency.7

Financing and M&A

The common financing used by local food, beverage and cosmetic companies, mainly small and medium-sized companies, are credits granted by the government through the Argentine National Bank. For instance, due to the covid-19 pandemic, the Ministry of Economy issued new lines of credit to guarantee the production and supply of food and basic inputs.

The most common M&A structure is the share acquisition. Some of the most notable recent deals in the sector are:

  1. the purchase of 100 per cent of the stock issued by La Salteña SA, a well-known pasta and 'empanadas' manufacturer, by Molinos Río de la Plata of the Perez Companc Group, on 23 July 2019;
  2. the purchase of 91.89 per cent of the stock of Quickfood SA by the Brazilian Mafrig Global Foods SA, one of the leaders in the beef production market, on 28 October 2019; and
  3. the purchase of 100 per cent of the stock of Avex SA, a chicken, beef and pork supplier, by Fribel SA and Granja Tres Arroyos SACAF.

Special issues for certain products

i Alcohol

Section XIV of the Food Code regulates all matters related to alcohol, by providing technical specifications about alcohol itself and its different kinds, sweeteners, blendings, flavourings, volumetic alcoholic strength, etc.

It is relevant to mention Law No. 26,870, which declares Argentine wine as a 'national beverage'. Wine production in Argentina stands out for its quality, diversity and geographical extension. According to Article 2 of this law, the Ministry of Agriculture, Livestock and Fisheries oversees promoting the activities foreseen in the Viticulture Strategic Plan 2020 (the Plan). Its objectives are the integration of small and medium-sized producers, the promotion of Argentine wine consumption in the domestic market, the consolidation of Argentine wines in international markets and the implementation of research and development programmes for the sector. Moreover, Law No. 25,849 creates the Argentina Wine Corporation (COVIAR) to manage and coordinate the implementation of the Plan.

ii Cannabis

The Chamber of Senators recently approved the Regulatory Framework for the Development of the Medical Cannabis and Hemp Industries Bill (the Cannabis Bill), which will broaden the regulatory framework allowing production and commercialisation of cannabis-based products, including food, beverages and cosmetics. The last step for the Cannabis Bill to be enacted is its discussion and approval in the Chamber of Deputies and publication in the Official Gazette. The Cannabis Bill complements existing Medical Cannabis Law No. 27,350, enacted in 2017, under which there was a first advance in the production of medical cannabis. The Cannabis Bill does not address recreational use of cannabis, which is not allowed.

Outlook and conclusions

Argentina has a wide recognition and tradition in the production, industrialisation and commercialisation of food and beverages. This industry is the leader of the Argentine manufacturing sector, representing approximately 25 per cent.8 As we have seen in this chapter, these and the cosmetic industries are strongly regulated, and in practice such regulations are often not easy to comply with by local players.

It is expected that in the coming months there will be significant regulatory changes in terms of labelling, children's advertising, traceability and environment (food waste). As we have described, the most relevant development that is already being considered by the Argentine Congress and will have a strong impact on the industry is the Food Labelling Bill, which is supported by medical associations and consumers, but subject to several observations by the industry.

Footnotes

1 María Morena del Río and Fernando Martínez Zuviría are partners, and Carola Pignatelli and Vanesa Fernández are associates at Allende & Brea.

2 Conicet. Sudria, Maria Emilce; Andreatta, María Marta; Defagó, María Daniela; Los efectos de la cuarentena por coronavirus (Covid-19) en los hábitos alimentarios en Argentina; Asociación Argentina de Dietistas y Nutricionistas Dietistas; Diaeta; 38; 171; 9-2020; 10-19.

4 ANMAT Resolution No. 1307/2017 includes the Federal Program of Food Control, which provides guidelines for the authorisation of food products and the purposes of their commercialisation in the national territory.

5 Law No. 25,127, Decree 97/2001, Decree No. 206/2001, SENASA Resolution No. 374/16, SAGyP Resolution No. 1291/2012 and clarifying notes No. 25970605/2017, No. 26466664/2017, No. 28408075/2017, No. 14/2017, No. 54/2017, No. 62/2017, No. 108/2016 regulate organic production and its control system.

7 Commission for the Defense of Competition, Guideline for Business Associations and Chambers and Professional Associations and Colleges (2018) (Arg.).

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