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Lack of Stakeholder Consultation

- Institutionalize stakeholder consultation mechanisms.

- Conduct pilot testing phases with private sector participation.

- Establish permanent feedback channels.

- Increase transparency regarding policy/ measure/ regulation objectives, implementation timelines, and technical requirements.

- Differentiation between compliant and high-risk firms.

- Simplify documentation requirements and reduce redundant inspections.

- Strengthen public–private dialogue mechanisms.

Distrust of the Private Sector
Inconsistency Between Ports

- Unified operating guidelines.

- Digitize and integrate port systems.

- Establish transparent benchmarks for processing times and service standards.

- Enhance coordination among customs authorities, port operators, and regulatory agencies.

- A fundamental policy shift — from an orientation of 'import prohibition' toward ‘export promotion’.

Government Orientation: Import Restriction vs. Export Promotion
Ministry of Finance vs. Trade Development Misalignment

- Institutional coordination mechanism

- Align customs, taxation, and trade policies with Egypt’s broader industrial and export promotion strategy.

- Joint policy committees to evaluate the trade and industrial impact of fiscal measures before implementation.

- Introduce KPIs linked to export growth and trade facilitation alongside revenue targets.

- A Green Industrial Investment Code (tax incentives for EU backed clean energy and water efficiency projects, or any investments in the highly potential sectors).

Incentives for green and sustainable industrial investment
Judicial processes and contract enforcement mechanisms

- Fast track commercial and investment dispute resolution.

- A real “one stop shop”.

- Convert the one stop shop procedures into a fully digital, legally binding single system.

Investment procedures and licensing processes
Problem
Recommended Reform Measure

- Enhance supply chain resilience.

Incomplete post-COVID recovery and persistent supply chain disruptions
GOEIC foreign supplier registration requirements

- Simplify registration procedures,

- Adopt internationally recognized compliance and certification mechanisms.

- A unified risk-based inspection system,

- Reduce duplicate inspections for compliant importers.

Multiple uncoordinated inspection authorities (38 inspection bodies)
Radiation inspection bottlenecks and manual approval procedures

- Digitize radiation clearance procedures,

- Mandatory presence of EAEA representative at ports,

- Decentralize approval authority (not only Cairo)

- Transparent customs valuation guidelines,

- Appeal mechanisms,

- Consistent application of valuation rules across customs offices.

Arbitrary customs valuation practices
Risk of goods being auctioned due to customs and banking delays

- Temporary storage periods for strategic industrial imports

- Automatic extensions when delays arise from government or banking procedures.

- Fast-track channels for industrial inputs, Review storage policies.

Escalating port detention and storage costs
Excessive import processing time (103 days on average)

- Greater inter-agency coordination, process automation,

- Clear service-level timelines.

- Ensure stable access to foreign currency for productive sectors 

- Alternative trade finance instruments.

Mandatory use of Letters of Credit (LCs) and foreign currency shortages
Problem
Recommended Reform Measure
Heavy congestion at certain ports (particularly Ain Sokhna) resulting in inspection and clearance delays.

- Expand inspection capacity

- Invest in infrastructure upgrades.

- Decentralize classification decisions

- Introduce time-bound dispute-resolution procedures.

Delays and bottlenecks in customs classification disputes (15–20 days or longer to resolve due to centralized decision-making by the Chemistry Administration.
Redundant approvals from multiple authorities, including separate approvals from the General Security Authority and the Civil Defense Authority.

- Consolidate overlapping approvals into a single integrated clearance process.

Requiring physical movement of samples and documents between ports and Cairo.

- Implement fully electronic approval mechanisms.

Mandatory sample testing and security approvals for chemical products (10 days on average).

- Establish accredited laboratories at major ports

- Digitize the transmission of test results.

- Publish updated procedural guidelines, fees, and service standards on official digital platforms.

Lack of transparency regarding procedures, fees, required documents, and processing timelines.
Industrial licensing delays at IDA.

- Accelerate the implementation of Law 15/2017,

- Establish expedited approval mechanisms for industrial projects.

- A unified registration system.

Multiple and uncoordinated pre-import registration requirements across GOEIC, IDA, GAFI, and Customs, requiring repeated submission of the same documents.
Problem
Recommended Reform Measure

Recommended Policy Reforms

Difficulty in compliance with some EU technical regulations and standards:

  • Modernization and upgrade of the EU–Egypt Association Agreement to include other areas such as services sector and updated technical regulations.

  • Continue the negotiations on EU- Egypt Sustainable Investment Facilitation Agreement (SIFA), which will greatly enhance Egypt’s transparency and good governance standing.

Distrust of the Private Sector:

  • Differentiation between compliant and high-risk firms.

  • Simplify documentation requirements and reduce redundant inspections.

  • Strengthen public–private dialogue mechanisms.

Government Orientation: Import Restriction vs. Export Promotion:

  • A fundamental policy shift — from an orientation of 'import prohibition' toward ‘export promotion’.

Incentives for green and sustainable industrial investment:

  • A Green Industrial Investment Code (tax incentives for EU backed clean energy and water efficiency projects, or any investments in the highly potential sectors).

Investment procedures and licensing processes:

  • A real “one stop shop”.

  • Convert the one stop shop procedures into a fully digital, legally binding single system.

Problem:

  • Recommended Reform Measure

Judicial processes and contract enforcement mechanisms:

  • Fast track commercial and investment dispute resolution.

Ministry of Finance vs. Trade Development Misalignment:

  • Institutional coordination mechanism.

  • Align customs, taxation, and trade policies with Egypt’s broader industrial and export promotion strategy.

  • Joint policy committees to evaluate the trade and industrial impact of fiscal measures before implementation.

  • Introduce KPIs linked to export growth and trade facilitation alongside revenue targets.

Inconsistency Between Ports:

  • Unified operating guidelines.

  • Digitize and integrate port systems.

  • Establish transparent benchmarks for processing times and service standards.

  • Enhance coordination among customs authorities, port operators, and regulatory agencies.

Lack of Stakeholder Consultation:

  • Institutionalize stakeholder consultation mechanisms.

  • Conduct pilot testing phases with private sector participation.

  • Establish permanent feedback channels. 

  • Increase transparency regarding policy/ measure/ regulation objectives, implementation timelines, and technical requirements.

Local Testing Infrastructure:

  • Invest in certified WP29-compliant testing laboratories to enable local certification for export.

Security/NTRA Inspection:

  • Assign permanent representatives at major ports; enable electronic fee payments; set firm time-frames.

NAFEZA Platform:

  • Make system user-friendly; allow edits; accept photocopies; auto-fill from documents; fix field size limitations.

IDA Per-Shipment Approval:

  • Streamline IDA licensing; implement Law 15/2017 for low-risk activities; expand digital capabilities of IDA staff.

Problem:

  • Recommended Reform Measure

Letter of Credit / Currency:

  • Cancel CBE mandatory LC decree; prioritize hard currency for intermediate goods.

CargoX Monopoly:

  • Allow alternative digital corridor services for foreign suppliers; reduce per-transaction cost.

Risk Management:

  • Implement risk-based customs clearance (green/yellow/red tracks) from new Customs Law.

Full Digitization (4IR):

  • Deploy AI, machine learning, and big data for end-to-end automated, intelligent trade process.

Stakeholder Consultation:

  • Institutionalize regular private sector consultation in trade policy design and system updates.

Market Controls:

  • Strengthen internal market surveillance to combat counterfeit and mis-declared automotive parts.

Requiring physical movement of samples and documents between ports and Cairo:

  • Implement fully electronic approval mechanisms.

Lack of transparency regarding procedures, fees, required documents, and processing timelines:

  • Publish updated procedural guidelines, fees, and service standards on official digital platforms.

Multiple and uncoordinated pre-import registration requirements across GOEIC, IDA, GAFI, and Customs, requiring repeated submission of the same documents:

  • A unified registration system.

Problem:

  • Recommended Reform Measure

Industrial licensing delays at IDA:

  • Accelerate the implementation of Law 15/2017.

  • Establish expedited approval mechanisms for industrial projects.

Mandatory sample testing and security approvals for chemical products (10 days on average):

  • Establish accredited laboratories at major ports.

  • Digitize the transmission of test results.

Redundant approvals from multiple authorities, including separate approvals from the General Security Authority and the Civil Defense Authority:

  • Consolidate overlapping approvals into a single integrated clearance process.

Delays and bottlenecks in customs classification disputes (15–20 days or longer to resolve due to centralized decision-making by the Chemistry Administration:

  • Decentralize classification decisions.

  • Introduce time-bound dispute-resolution procedures.

Heavy congestion at certain ports (particularly Ain Sokhna) resulting in inspection and clearance delays:

  • Expand inspection capacity.

  • Invest in infrastructure upgrades.

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