ANMAT medical device registration checklist (Argentina, 2026)

Quick answer. In Argentina, medical devices are registered with ANMAT (Administración Nacional de Medicamentos, Alimentos y Tecnología Médica); devices are classed I–IV by risk; imported Class I and II devices register by sworn-declaration prior notice (Disp. ANMAT 236/2026, art. 2); locally made Class II devices use a declaration of conformity reviewed in 15 business days (ANMAT Disp. 9688/2019, art. 5) (Disp. 9688/2019, art. 5); Classes III and IV require full technical review with a 110-business-day review period (art. 6); the registration must be held by a locally authorized representative/importer with a designated Technical Director — which bioaccess® provides, holding the registration in the manufacturer's name.

Classification (Disposición ANMAT N° 64/2025)

The current framework (Disposición ANMAT N° 64/2025, which replaced 2318/2002) keeps four risk classes — Class I low risk, Class II low-moderate, Class III moderate-high, Class IV high; the definitive class comes from a short review of the technical file before filing and sets the pathway and dossier depth.

The two pathways

• Sworn declaration or declaration of conformity (Class I/II) — imported Class I/II: sworn-declaration prior notice (Disp. 236/2026, art. 2), Class II backed by reference-country authorization or accredited test reports (arts. 3–4); locally made Class I: sworn declaration if listed, non-sterile, non-measuring, non-active (Disp. 9688/2019, art. 4), else declaration of conformity (art. 5); locally made Class II: declaration of conformity, reviewed in 15 business days (ANMAT Disp. 9688/2019, art. 5) (art. 5).
• Full technical evaluation (Class III/IV) — full technical review by ANMAT, with a 110-business-day review period and approval by formal disposition (Disp. 9688/2019, art. 6).

Submission checklist

• Local Authorized Representative (AAR)/importer established and licensed in Argentina
• Designated Technical Director
• Manufacturer quality evidence (ISO 13485, and MDSAP where relevant)
• Reference-country approval (CE, or FDA/home-country) where applicable plus Certificate of Free Sale (FSC) as the baseline
• Technical documentation (device description and intended use, essential-principles/safety and performance, risk management ISO 14971, and clinical evaluation for higher classes)
• Labeling and IFU in Spanish
• Certified (sworn) Spanish translations where required
• Legalizations/apostille of foreign public documents (power of attorney, FSC) done in the country of origin
• Electronic filing through HELENA, digitally signed by the legal representative and Technical Director

Indicative timeline

Locally made Class II declarations of conformity are reviewed in 15 business days (ANMAT Disp. 9688/2019, art. 5) (Disp. 9688/2019, art. 5); Class III/IV technical review has a 110-business-day review period (art. 6); Argentine government fees are modest relative to the region.

Importation note (Disposición 4446/2025)

Since Disposición ANMAT 4446/2025 (effective August 2025), imports of Class I and II registered devices are handled by a 48-hour post-nationalization import notice (a sworn statement, free of charge) rather than a prior per-shipment authorization — a meaningful simplification for commercial supply.

Answers to common questions

Can a foreign manufacturer hold the ANMAT registration directly?

No — it must be held by a locally authorized establishment. bioaccess® serves as your Registration Holder (Titular), Legal Representative, and Importer of Record, holding it for your benefit so you can appoint and rotate distributors freely.

Does CE marking guarantee ANMAT approval?

No. For imported Class II devices, reference-country authorization or accredited test reports back the sworn-declaration prior notice (Disp. 236/2026, arts. 3–4); Class III/IV still go through full technical review.

What triggers a Class III determination?

ANMAT treating the device as higher-risk by its invasiveness, energy delivered, or intended use; we confirm the class in the review that opens the engagement.

Book a 30-min Argentina market-access call · Medical device registration in Latin America: 2026 country-by-country guide

General information as of 2026; ANMAT requirements change and the definitive pathway is confirmed at scoping. bioaccess® provides regulatory representation, not legal advice.