Through Decree No. 196/2025, published in the Official Gazette on March 18, 2025, significant amendments have been made to the General Regulations of Law No. 24,449 on Traffic and Road Safety. These changes introduce key modifications for the automotive industry, including more flexible regulations regarding the type-approval of vehicle models already certified in certain markets—thereby simplifying their importation—as well as the deregulation of auto parts imports and, notably, the regulation of autonomous driving.
In this regard, the new regulatory framework introduces the following major changes:
– Simplified Type-Approval and Importation of Vehicles Certified in Certain Jurisdictions:
Under the current regime, in order for new vehicle models to be legally operated on public roads, manufacturers and importers must obtain a Model Configuration License (“LCM”), which certifies compliance with active and passive safety requirements under applicable regulations, as well as an Environmental Configuration License (“LCA”), which certifies compliance with all requirements concerning pollutant emissions, vehicle noise, and parasitic radiation.
To avoid, in certain cases, the need for manufacturers and importers to obtain both LCM and LCA, Decree No. 196/2025 introduces an innovative mechanism allowing total or partial validation of certifications granted by other recognized certifying bodies. In this way, existing type-approvals granted abroad may be submitted to fulfill domestic requirements.
Accordingly, in order to obtain LCM and LCA for vehicles already certified under the standards of a Certifying Body recognized by the United Nations—in accordance with TRANS/WP.29/343—it will suffice to provide evidence of such certification.
Moreover, to ensure compliance with active and passive safety requirements for M1 and N1 category vehicles manufactured under the Federal Motor Vehicle Safety Standards (FMVSS), test reports issued by internal laboratories of manufacturing plants will be recognized as valid, provided the plant is endorsed by a “Blue Ribbon Letter” issued by the National Highway Traffic Safety Administration (NHTSA). This letter must include the vehicle’s make, model, and VIN (Vehicle Identification Number), specifically the WMI (World Manufacturer Identifier) and VDS (Vehicle Description Section), to ensure traceability.
Such recognition shall be granted according to the criteria established by the competent enforcement authority.
– Liberalization of the Commercialization, Production, and Importation of Auto Parts:
Decree No. 196/2025 further establishes that all components, parts, auto parts, and other elements intended for use in vehicles, trailers, and semi-trailers—whether manufactured locally or imported—shall be freely produced, imported, and sold, without any requirement for prior authorization, with manufacturers and importers being solely responsible for ensuring compliance with applicable regulations.
In this regard, the Certificate of Homologation for Auto Parts and/or Safety Components (CHAS) is eliminated.
– Autonomous Driving:
The Traffic Law has also been amended to authorize the circulation of vehicles equipped with autonomous driving systems.
The regulation defines an “autonomous vehicle” as a vehicle equipped with:
“Complex systems such as laser sensors, radar, global positioning systems, computer vision, actuators, and communication and data processing systems, which enhance, assist, and supplement human driving, control, and navigation capabilities under predetermined conditions and environments, enabling the connection between point A and point B, as defined by the operator, with a statistically higher safety level than the best human driver average.”
This definition aligns with the various levels of driving automation. The Decree recognizes the following levels:
• Level 0 – No Driving Automation:
The driver is responsible for all driving tasks. The vehicle does not provide any automated assistance.
• Level 1 – Driver Assistance:
The vehicle may assist with specific functions, such as steering or braking, but not simultaneously. The driver remains fully responsible for monitoring the environment and performing all other driving tasks.
• Level 2 – Partial Automation:
The vehicle may perform two or more driving functions simultaneously—such as acceleration, steering, and braking—under specific conditions. However, the driver must remain ready to take full control at any time.
• Level 3 – Conditional Automation:
The vehicle can perform most driving tasks under predefined conditions. The driver may engage in other activities while the vehicle operates autonomously but must be prepared to take over when required.
• Level 4 – High Automation:
The vehicle can operate autonomously in most conditions and environments without human intervention. However, its autonomous operation may be limited to certain geographical areas or specific weather conditions.
• Level 5 – Full Automation:
The vehicle is entirely autonomous and capable of operating safely in any environment and condition without any human intervention. There are no geographical or climatic limitations on its operation.
For Level 5 vehicles, the Decree provides that initial approval will be granted on an experimental basis, subject to final authorization by the enforcement authority.
Additionally, all autonomous vehicles must be equipped with an integrated system (hardware, sensors, actuators, satellite positioning, and software) that is authorized by the National Road Safety Agency (Agencia Nacional de Seguridad Vial).
Authorization for such systems shall only be granted upon conclusive evidence that the accident rate is lower than the statistical average for human-driven vehicles. Once authorization is granted, it may only be revoked if the system no longer meets this requirement. To assess compliance, the enforcement authority may permit provisional circulation of the software or rely on data provided by its developers in other countries.
Finally, it is established that the competent authority shall determine the authorized modes of operation for each roadway in the national territory, and may issue permits with geographical, speed, or other restrictions, based on the development and testing stage of each autonomous system.
To access the full text of Decree No. 196/2025, including all annexes, please visit:
https://www.boletinoficial.gob.ar/detalleAviso/primera/322652/20250318
If you require assistance regarding the content of this article, please contact Federico Osvaldo Valiño (valino@abeledogottheil.com.ar) or your usual contact at Abeledo Gottheil.
This summary is for general informational purposes only and does not constitute legal advice.