| Sanitary registration — renewal (all sanitary products)(Renovación del Registro Sanitario, filed within the three months before expiry; automatic on payment of the fee while the registration is in force) The renewal service page publishes the same 90 dÃas laborables as the registration page. CONTRADICTION BETWEEN THE PUBLISHED FIGURE AND THE GOVERNING INSTRUMENT, disclosed rather than resolved: Decreto 117-18 as amended by Decreto 45-23 Art. 2 provides that 'La renovación de los registros sanitarios de los alimentos, medicamentos, productos sanitarios, cosméticos, higiene personal y del hogar será automática' once the renewal fee is paid and the registration to be renewed is in force, and Art. 3 provides that the automatic renewal 'se realizará a partir del depósito de la solicitud'. On the automatic-renewal reading there is no substantive review of a renewal dossier, so a 90-working-day decision clock cannot describe the ordinary case — the published 90 days describes the service counter's handling time, not a review. The 90 dÃas laborables stays correct for the residual case in which DIGEMAPS finds a discrepancy against an automatically renewed registration and the holder must submit a modification, which is why the row keeps its officialTimeline. Renewal is automatic provided the renewal fee has been paid and the registration to be renewed is in force; the holder must file within the three months before expiry, and a registration that reaches expiry without an application is cancelled with no right to an extension (Decreto 117-18 as amended by Decreto 45-23, ArtÃculos 2-4). Where the registration has changed in any way, the modification application must be filed together with the renewal and both fees paid; if DIGEMAPS finds a discrepancy against an automatically renewed registration the holder must submit the modification procedure within 15 calendar days (Art. 2 Párrafo II), and a modification filed within the six months before expiry causes the certificate to issue with automatic renewal (Art. 5). |