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• A number of electronic platforms have been built to provide various government services, led by the Egyptian Government Portal, which currently has 75 services and aims to increase them to 100.
• An electronic application was launched to provide services via mobile phone and includes 30 services so far.

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• Increasing the speed of the time period for deciding disputes, setting a maximum for it, and presenting the results of disputes to the Ministerial Committee at least twice a month without committing to a number of disputes presented or what the recommendations reached in principle.

• The Investor Problems Solution Unit was established under the Prime Ministry on May 11, 2022, headed by Ms. Engineer Randa El Minshawy - First Assistant to the Prime Minister.

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• The Prime Minister’s Decision No. 104 of 2022 was issued specifying the activities and sectors where investment projects established after the implementation of this law in accordance with the investment map will be granted an investment incentive and a deduction from the net taxable profits, according to Tables A and B.
• Law No. 160 of 2023 was issued amending some provisions of Investment Law No. 72 of 2017, including the activation of incentives and extending their duration.

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• Forming an advisory committee for the Council that includes representatives from the private sector and the civil society sector so that there is representation from the various parties influencing or benefiting from financial services.

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• Adding the head of the National Postal Authority to the membership of the National Payments Council so that more can be achieved
• Integration between the postal accounts system and the banking system.

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• The National Payments Council undertakes initiatives and projects that promote cashless dealing.

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• Shifting towards electronic budgets.

• Applying the GFMIS system to economic bodies on an experimental basis during the period from March 2022 until the end of next June, in preparation for its implementation in the budget of the next fiscal year to connect all government agencies electronically. This contributes to creating a strong public financial management system by integrating, controlling and computerizing all government financial operations, starting with budget preparation, implementation and oversight. This helps achieve financial discipline and use state resources efficiently and effectively.

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• Failure to adhere to the necessity of developing an annual plan for opening branches and submitting it at a specific date during the year.

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• Adding provisions in each of the laws regulating these activities prohibits making any payments, whether for dealing in securities, paying insurance premiums, financial leasing, real estate financing, or others, except through banking and electronic means if the amount paid exceeds a certain minimum.
• Establishing national programs with the support of international institutions to develop non-banking financial intermediaries, financial markets, financial leasing companies, insurance companies, and others to expand the use of electronic means of payment.

• Law No. (5) of 2022 was issued to regulate and develop the use of financial technology in non-banking financial activities:
• The law allows the use of modern and innovative technological technologies in the non-banking financial sector to support and facilitate financial, financing and insurance activities and services through applications, programs, digital platforms, artificial intelligence, or electronic records.
• The law sets conditions for obtaining a license to practice non-banking financial activities using financial technology, which are included in Article No. (4), which limits the company’s work to practicing licensed activities, specifying the direct and indirect ownership structure and related parties in a specific way, and that the company must have the equipment, technological structure, information systems, and means of protection and insurance necessary to carry out the activity.
• The draft law in Article (18) shall punish anyone who practices, establishes, or manages one of the activities stipulated in this law without obtaining a license or approval, as stipulated in this law, with imprisonment for a period of not less than six months and a fine of not less than 200,000 pounds and not more than one million pounds, or with one of these two penalties. In the event of recidivism, a sentence of imprisonment and a fine shall be imposed together.
• The law aims to use technological applications to ensure compliance with established laws and rules, which works to facilitate the Authority’s performance of its supervisory role over the entities subject to it regarding compliance with transparency and governance standards. It also works to protect traders in non-banking financial markets.
• The law adopts modern and innovative technological tools to facilitate dealing with the non-banking financial sector in the field of using financial technology. It also includes the use of technological applications to collect data digitally, verify it, and analyze its indicators through programs designed for this purpose.

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• General recommendations:
• ♦ The National Payments Council did not announce its strategy to enable community dialogue regarding it
• ♦ From follow-up, we recommend making explanatory notes available for the Central Bank’s decisions, which leads to extreme disparity between banks and sometimes ambiguity and contradiction in implementing the decisions. For example, despite the Central Bank’s decision to facilitate the process of opening accounts for citizens, some banks still adhere to complex procedures, or some see them as arbitrary, that prevent the smoothness and ease of opening accounts in banks. This also applies to financial wallets, as many banks do not open wallets for citizens if they create wallets in other banks or through mobile networks.
• ♦ The Egyptian Post is still outside the banking sector system, which hinders the process of financial inclusion and the transition towards a cashless economy.
• ♦ There are many government agencies that still require payment of some expenses, such as fees and forms, through cash payment. For example, the Traffic Department requires citizens to purchase a first aid kit by paying cash and other expenses such as the Tahya Misr form or compulsory insurance. The Passport Authority, as another example but not exclusively, also receives compulsory travel insurance amounts through direct cash payment.
• ♦ The e-commerce law has not yet been issued, which would enhance the system of transition towards a cashless economy.
• ♦ In a positive step, the Law Regulating the Practice of Private Work No. 149 of 2019 stipulates the following maximum: “In all cases, cash funds exceeding five hundred Egyptian pounds or its equivalent in any other foreign currency may not be accepted except by a bank check or any banking procedure through one of the banks subject to the supervision of the Central Bank, without prejudice to the limits set forth in the executive regulations of the Law Regulating the Use of Non-Cash Means of Payment.”

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• Surveying is considered a requirement for land registration, but the current capacity of the Survey Authority is not sufficient to cover the entire republic and meet urgent registration needs.

• Allowing the establishment of special accreditation offices for conducting surveying to facilitate registration procedures (similar to the Licensing Law and the Investment Law), as well as the use of modern geographical imaging techniques by any entity that has security approval to carry out this task.

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• Geographic problem in the lands:
• The owners of industrial units in the Amriya and Agami neighborhoods in Alexandria Governorate are facing a crisis represented by the failure to settle and reconcile the legal status of the industrial lands on which they have established their factories for a long period of time, extending to about thirty since 1989. The pricing committees formed by the governorate in coordination with the State Property Protection Agency have issued successive illogical pricing decisions at very high prices compared to the average price of industrial lands in Egypt, ranging from 2,500 pounds per meter to 6000 pounds per meter.
• As a result, the current legal conditions for industrial units in the areas related to this problem were divided into the following:
• Units for which enforceable legal rulings have been issued regarding the pricing value.
• Units paid their dues in full, and did not obtain ownership contracts as a result of slowdowns on the part of the governorate.
• Units partially paid their dues as a result of a lack of response from the governorate, or failure to pay.
• Units purchased reconciliation brochures from the neighborhood before the revolution, but the neighborhood refuses to deal with them.
• Investors want to legalize lands and pay the full value, but there is no mechanism for that.
• Investors have received the decision to allocate the land since 2021, but no pricing decision has been issued for it.
• Egyptian investors returned from abroad to invest in Egypt and were not successful in finalizing the land to start investing. Some of them want to expand, but there is no mechanism for that.
• Units did not follow the official direction to legalize the situation and continued in a state of squat.
• Problem areas:
• First: Areas affiliated with the Amriya Department:
• Margham Industrial Zone, Bahri and Qibli, Alexandria, total area 6,201 acres, the party that owns the land - the State Property Protection Agency.
• Seven Up Industrial Factory Zone - Kilo 31 - Al Amriya District - West of Alexandria Road, total area 814 acres, land owner - recovered property - unplanned area.
• Nasiriyah Industrial Zone, the total area of ​​the area is 198 acres, the party that owns the land - Mariout Agricultural Company - the unplanned area.
• Second: Lands belonging to the Al-Ajami neighborhood:
• Umm Zaghbo Industrial City - Al-Ajami District, the total area of the area is 2851 acres, the party that owns the land - the State Property Protection Agency - the unplanned area.

• Adding a legislative article pertaining to the pricing of lands located within the boundaries of industrial zones in the governorate, assigning the pricing decision to the Industrial Development Authority - Adding an article to Resolution No. 18 of 2017 regarding the provisions implementing Law No. 144 of 2017
• Reviewing land pricing decisions, as pricing decisions in the problem areas contradict a number of decisions of the Prime Minister, the Industrial Development Authority, and the Small and Medium Enterprises Development Law, and even clearly contradict the state’s directions to support local industry, and there is ambiguity in the economic foundations of pricing.
• The necessity of coordination with the competent authorities, specifically the Ministry of Industry and the General Authority for Industrial Development, and their participation in pricing committees.
• The necessity of coordination with the responsible employees of the State Property Authority and the governorate.
• Land pricing must be in accordance with the decisions regulating that, or based on the cost of the utilities, taking into account the deduction of the value of the utilities that the investor may have obtained at his own expense, and land settlement work is also taken into account.
• Based on a letter addressed by the Industrial Development Authority to the governorate, the inspection is carried out by the governorate and the applicant receives the inspection report within a specified period of 30 days from the date the governorate receives the inspection request letter. The Industrial Development Authority is committed within 30 days to adjusting the conditions of the land after paying the specified value of the land to the state authority.
• All entities of the state are committed to the pricing decision issued by the Industrial Development Authority and granting the investor a letter to register the land in the real estate registry.
• Land installments are based on the same system used in offering industrial lands to investors, taking into account that payment periods are commensurate with the current economic conditions.

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• The prices of industrial lands rose successively over a short period of time on the pretext of high utility costs. Three Cabinet decisions were issued to raise land prices within a period of only 15 months, as Prime Minister’s Resolution No. 1670 of 2024 issued on May 21, 2024, Cabinet Resolution No. 36 of 2025 issued on June 12, 2025, and Cabinet Resolution No. 50 of 2025 Issued on August 18, 2025, which makes industrial investment expensive and non-competitive to meet the government’s ambitions to increase industrial investment compared to competing neighboring countries that offer packages of various incentives to encourage industrial investment.
• The industrial land that is contracted by the investor with the state authority is not considered a justification for obtaining integrated benefits as an incentive package under the signing of the land contract, similar to what exists in some countries such as Saudi Arabia, Jordan, Morocco, and Turkey, where in the current situation prices are not compared with the advantages and disadvantages related to each similar industrial area, the structure of the infrastructure, and the methods of support and incentives provided by the governments in each of them.

• The state must adopt an industrial policy through which priority is given to projects related to land allocation, financing, labor training, export incentives, etc., and the policies must be fixed regardless of whether those in charge of them change or not. Accordingly, unified institutional coordination takes place between all state agencies within one framework, instead of multiplicity and overlap in paths and procedures, which achieves the desired policy goals.
• The importance of providing incentive packages to encourage industrial investment in a manner similar to what neighboring competing countries offer.

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• The final contracts of the Urban Communities Authority for ownership of industrial lands do not entitle the landowner to obtain bank financing guaranteed by the industrial lands after paying their full price and registering them. There are articles in the contracts that give the Urban Communities Authority the right to withdraw this land and cancel the final contract without notification, warning, or taking any legal action.

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• Raising the prices of industrial lands as a result of the increase in the value of basic facilities provided by the Urban Communities Authority.

• The importance of providing industrial lands and their development becoming a strategic national project, which requires studying the tools for financing the development of industrial lands, whether connecting electricity, water, gas, or otherwise, through long-term financing tools in agreement with the Ministry of Finance in a way that guarantees this financing, whether from the state or from other parties, including studying the repayment of bonds allocated for this purpose through the proceeds of using existing facilities for long-term periods of up to 25 years.

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• Difficulty in identifying industrial licensing procedures and their complexity due to paper and bureaucratic procedures

• Activating the portal to facilitate government procedures for economic activities, which aims to simplify all procedures related to the industrial licensing system, which aims to:
• Providing information to the industrial investor about all required procedures.
• Providing a central platform for consultation between the competent administrative authority and the industrial investor.
• Providing reports and analysis related to industrial development in Egypt.

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• The fees imposed by the Authority for its services are high and drain the investor’s capital.

• Reconsidering the fees imposed by the Industrial Development Authority on its services to take into account reducing the financial burdens on investors.

• The Industrial Development Authority Resolution No. 239 of 2019 was issued to reduce some service fees collected by the Authority. Most fees were also reduced, especially for small industries
• However, the decision to reduce fees was not affected by the amounts of fines.

• Problems related to the regulations of the Industrial Development Authority law:
• The procedures by which ownership of the factory is transferred after payment of the full agreed-upon value have not been clarified, and the factories are still suffering from the inability to obtain a title deed from the Authority.
• There is no clarification in the articles on how to choose the Authority’s Board of Directors.
• Article 31 stipulated payment of 25% down payment in the event of allocating the land and only four years for the repayment period.
• Article 38 specifies the basis for comparison using the points system when there is a competition between industrial investors’ requests to deal in the real estate needed to establish industrial activity. In the event that it is not possible to differentiate between competitors using the points system, it is permissible to compare between them according to the highest price offered by them.
• Article 44 specifies the rules for changing the purpose for which the property was disposed of, and stipulated that it is not permissible to change the activity except after the approval of the Authority and all concerned parties on this change, and stipulated that the investor pay no less than 50% of the difference between the value at which he obtains the property and the market value on the date of submitting the application.
• Article 34 allows entities with jurisdiction over lands to participate in industrial projects with real estate as an in-kind share within the capital of the project company, in accordance with the conditions and controls specified by the same article.

• This must be clarified in order to preserve the factory’s rights with the Authority.
• The private industrial sector shall be represented on the Board of Directors through the Federation of Industries with two or three representatives, which is in line with other laws issued in the Authority’s jurisdiction, so that the Federation has a say in all the committees to be formed.
• The repayment period should be 15 years, and the price should include the cost of introducing utilities (electricity, gas, and water), so that it is paid in installments on the price of the land, including installment interest.
• The Central Bank should allocate special funding to finance the installments of industrial lands and their facilities for each factory, similar to a previous initiative, with the aim of helping to drive growth in the industrial sector.
• Amending the conditions for registering and transferring ownership upon achieving a construction rate of 20% of the licensed buildings instead of the existing 40% to enable the investor to obtain credit guaranteed by the land after transferring its ownership and registration.
• Abolishing the principle of bidding on the pricing of industrial lands while guaranteeing the right of the owner of an existing factory to obtain a neighboring plot of land according to the pre-emption system.
• The role of the government and its affiliated agencies should be limited to being a regulator, facilitator, and monitor, and not an investor, especially in light of the structural reforms the state is undertaking and the listing of some state-affiliated companies on the stock exchange to exit their activities.

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• One of the most common problems with the Urban Communities Authority that investors suffer from is the request to prove any amendment or change in the activity or the shares of partners or the addition of an activity, regardless of the type of amendment or the type of facility to the original contract in the industrial zone. This is a procedure that takes large periods of time, in addition to the complaint of some manufacturers about the lack of approval from the industrial zone (the Urban Communities Authority) to make this amendment.
• The Urban Communities Authority collects 2% of the value of the land, which applies to factories and developers, even though the decision concerns agricultural lands.
• Collecting 1.5% of the land value (0.5% for the Board of Trustees and 1% for administrative services)
• The Urban Communities Authority collects road cleaning fees at 10 pounds per meter instead of 50 piasters.

• Study a legal formulation to achieve the solutions required in implementing any new procedure on the original contract in order to facilitate the procedures for investors through the following legal solutions:-
• A - Amending Law No. 95 of 2018 regarding the Public Authority for Industrial Development so that it has the right to change the activity from one industrial to another industrial or take any procedure required to amend the original contract previously concluded with the Urban Communities Authority or localities and notify the state authority of this amendment.
• B - Adding a section in the Urban Communities Authority law or its executive regulations that is specific to industrial activity in order to make it easier for the industry to make the amendment related to any required procedure.
• The Industrial Development Authority should participate in the databases of existing industrial facilities in the Urban Communities Authority or in the localities so that it has data on existing industrial facilities and land vacancies until the Industrial Development Authority has the ability to fully manage these files.
• Reducing the amounts collected by the Urban Communities Authority by a percentage of the price of the land.
• Reducing the amounts collected by the Urban Communities Authority for road cleaning, which was raised from 50 piasters to ten pounds per meter, to be only 3 pounds, and that a percentage increase be made every five years.
• The Urban Communities Authority did not collect 2% of the land value from factories and industrial developers, as the decision concerns agricultural lands.

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• Connecting utilities (electricity, gas, and water) and the amounts charged to the investor in addition to the length of time.

• Forming a joint committee to follow up on government agencies to connect the facilities so that the timetable for implementation can be adhered to with the General Authority for Industrial Development. It consists of the Authority and the competent authorities to connect gas, electricity and water facilities to factories to solve the problems related to connecting these facilities, their duration and cost. A decision will be issued by the Prime Minister to form this committee.

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• There is no branch of the General Authority for Industrial Development in Suez Governorate, despite the presence of a large number of factories in the governorate. There are also large factories in New Suez that are closed and not working.

• Establishing a branch of the General Authority for Industrial Development in New Suez Authority.

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• Taxes constitute a huge burden on the industrial product, as they lead to a rise in the price, which in most cases becomes uncompetitive.
• The ambiguity of the law and the executive regulations, which led to diligence and differences in interpretation within the authority in all transactions. The most important differences in standards and application concerned specialized industries related to the food industry, the detergent industry, the pharmaceutical industry, the cosmetics industry, and paper pulp (wood pulp or cellulosic fibrous materials).

• The importance of clarifying and simplifying tax laws, regulations and instructions in order to reduce the discretionary power of tax administration employees.
• Forming a small committee with the membership of the head of the Tax Authority, the head of the Customs Authority, a deputy for the Minister of Finance, the membership of the President of the Federation of Industries or his representative, and representatives of the industrial chambers. Its mission will be to discuss the procedural and legal obstacles facing industrial investors in taxes and customs and to reach practical solutions and decisions that have a rapid impact on the ground.
• Signing a protocol between the Ministry of Finance and the Organization for Economic Cooperation and Development to develop tax dealing systems in line with international developments and enhance investors’ confidence in tax reforms.

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• Arbitrary assessment: The continuation of the system of arbitrary tax assessment, and the budgets and submitted returns are not taken into account.
• The tax examination is delayed for several years, which may reach 10 or 15 years, which results in companies being burdened with additional financial burdens, represented by delay fees and an additional tax that exceeds the original tax.
• Tax offices issue estimation forms to cut off the statute of limitations without paying any attention to the returns submitted by companies. Taxes may exceed the volume of sales themselves, and complex procedures are required to re-examine taxes that are more than five years old.
• During the examination, the inspector wastes books and documents. In this matter, the examining officer who claims a violation must prove this violation himself and differentiate between tax evasion and a human violation.
• The lack of connection between all the tax office’s divisions, “Commercial Inspection Division - Employment Procurement - Stamping - Source Deduction”, which leads to wasting the time of the taxpayer and the tax office alike, as more than one file is prepared for examination with more than one official with almost the same documents and sometimes at the same time. What is required is to unify the examination so as not to waste the time of the office and the taxpayer.
• The tax office’s intransigence in examining files that do not produce tax revenues, without regard to the taxpayer’s obligation to submit all tax documents supporting his approval, and the tax office’s intransigence in delaying the file because it is not useful from its point of view.
• Administrative seizure of all the company’s funds instead of just what is equal to the value of the tax, which affects the daily transactions of factories and companies until the seizure is lifted without exhausting friendly methods.

• Abolition of the so-called (arbitrary) tax assessment. The law must be applied regarding the reliability of the tax return. A random examination of the submitted documents is carried out, and if it is proven otherwise than what is in the return, the assessment is re-evaluated.
• The commitment of the tax authorities to finalize approved submitted budgets that are five years old to resolve tax disputes and collect the tax faster.

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• Double taxation prevention agreements: The Tax Authority does not take into account double taxation prevention agreements in some cases, which negatively affects the continued flow of foreign investments into Egypt.

• Double taxation prevention agreements must be adhered to to encourage foreign companies to pump more investments into Egypt.

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• Value-added tax: Imposing a value-added tax on capital goods leads to a rise in the cost of production in a way that weakens the ability to compete externally.

• Eliminate value added tax on capital goods.

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• Registration limit for companies: Raising the registration limit for companies to 500,000 Egyptian pounds in light of the value-added tax law will lead to the exit of many producers from the circle of official production, and thus the state will lose opportunities to collect financial resources.

• The importance of reducing the registration limit for companies to ensure the expansion of the tax community

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• Recovering value-added tax: Exporting companies are unable to recover value-added tax on production inputs of raw materials and supplies used in exported products for a long period that may take years.

• Facilitating the procedures for recovering value-added tax for exporting companies and quickly paying the amounts owed to companies within two weeks from the date of export because they are funds frozen with the Tax Authority that companies need for capital turnover.

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• Fines for late payment of tax: According to Minister of Finance Resolution No. 484 of 2019, fines for late payment of tax are imposed without distinguishing between delay resulting from evasion and delay resulting from tax dispute.

• When imposing fines for late payment of taxes, differentiate between clear cases of evasion and cases of disagreement and conflict with the Tax Authority over the tax amounts owed. Fines should not be imposed in cases of a dispute because the delay here results from the existence of a dispute and not from evasion of payment.

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• Real estate tax on industrial and health facilities
• The overestimation of the price per meter of land and buildings in industrial facilities, and the resulting overestimation of the rental value, is what all industrial sectors have suffered from, which has led to ongoing conflict and public discontent over the tax in its current form.
• Some tax authorities refuse to pay the tax in installments and insist on collecting it in one go, or seize companies’ funds with banks to force financiers to pay and intimidate them from following any legal means of litigation without taking into account the economic situation of the establishments and their reputation, which may be affected by the banks by this seizure, which has led to countless disputes and disagreements.

• A proposal to issue new legislation to abolish the real estate tax on establishments (factories, hospitals, and free zones).

• Real estate tax collection has been postponed for 3 years.

• Fines for late payment of tax: According to Minister of Finance Resolution No. 484 of 2019
• Fines are imposed
• Delay in paying tax without distinguishing between delay resulting from evasion and delay resulting from tax dispute.

• When imposing fines for late payment of taxes, differentiate between clear cases of evasion and cases of disagreement and dispute with the Tax Authority over the tax amounts owed. Fines should not be imposed in cases of a dispute because the delay here results from the existence of a dispute and not from evasion of payment.

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• The presence of more than one file and number for the same facility on multiple devices

• Creating a national number for the facility to deal with the various types of taxes specified by law to which the facility is subject, whether they are income taxes, value added, customs, insurance, or other government agencies.
• Unifying the value-added tax with the income tax in one tax file to facilitate the clearing of obligations and receivables with the Tax Authority.

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• Applied problems in electronic invoice:
• Inability to use the same date and number to issue the new invoice for invoices that were rejected

• The same invoice number can be used while changing the issuance date.

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• Applied problems in electronic invoice:
• Lack of knowledge of the registration process and the procedures required to be followed to complete registration successfully.
• The lack of a single platform for taxes, which creates a kind of confusion among participants: The need to use more than one platform to complete the registration process, which led to a state of confusion among participants.

• Organizing a comprehensive training program to spread awareness among registered companies to familiarize them with the tax system, recent developments, and how to use different tax platforms.

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• Applied problems in electronic invoice:
• Lack of complete digitization in the registration process and application to the system: Some participants indicated the necessity of submitting some paper documents to the Egyptian Tax Authority to complete the registration process, which indicates a lack of complete digitization in the system.

• It is necessary to provide options for submitting electronic documents completely, and if the client himself desires to submit documents in paper form, he can do so, that is, working with both mechanisms at the same time.

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• Applied problems in electronic invoice:
• Variation in information provided by some department workers in different missions or even a single mission.

• Implementing a comprehensive technical training program for the department’s employees to ensure the standardization of information and assistance provided to customers.

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• Applied problems in electronic invoice:
• The lack of a clear mechanism for collecting and analyzing fully issued electronic invoice data, which makes it difficult for the company to issue comprehensive reports and analyzes for all its various transactions.

• Providing the service of obtaining detailed, simplified or comprehensive reports from the system.

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• Applied problems in electronic invoice:
• The difficulty in the process of recovering the user name in the event of a system hack, as recovering that data requires going to the authority and going through long and complex operations.
• The difficulty of procedures for replacing a company official in the system if he leaves his job duties or is replaced by another person.

• Simplifying the process of recovering the user name in the event of hacks, as well as the process of replacing administrators who have the right to sign if they leave their current job. For example implementing a digital method such as using one-time passwords (OTP) or other reliable methods to recover the account and replace administrators efficiently and easily for the user.

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• Applied problems in electronic invoice:
• The difficulty of searching for the company’s previous invoices, as the search is done by entering a lot of different data about the invoice.

• Simplify the process of searching for previously issued invoices by allowing searching using the invoice number only.

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• Applied problems in electronic invoice:
• Delay in settling invoices issued with government agencies, causing companies to have to pay value-added tax on behalf of government agencies until settlement is completed.

• Postponing the imposition of fines resulting from delays in settling invoices between suppliers and government agencies.

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• Applied problems in electronic invoice:
• Lack of guidance on how to code products across different platforms, the difference between all platforms, and the cost required to do so.
• The need to issue different codes for each product/service, even in the case of minor differences such as color, size, shape, etc.

• Download a comprehensive guide that includes guidance on how to set up codes for various services and goods on the system, as well as short educational videos to provide the necessary instructions on how to issue codes for products/services.

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• Applied problems in electronic invoice:
• The inability of all small and medium enterprises to have their own ERP system in order to integrate into the electronic invoicing system.

• Providing a simplified version of the Enterprise Resource Planning (ERP) system that can be introduced and used by small and medium-sized enterprises through cooperation with relevant authorities and international organizations.
• Developing a simplified registration system designed specifically for small business owners, freelancers, and small projects, such as developing a mobile phone application.

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• Applied problems in electronic invoice:
• Difficulty in accurately calculating the total amount of taxes imposed on companies.

• Inserting the possibility of calculating taxes within the electronic tax system to facilitate the calculation of the total tax amount.

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• Applied problems in electronic invoice:
• Lack of clear instructions regarding issuing electronic invoices: Participants expressed the need to provide clearer instructions for issuing electronic invoices on the system, while ensuring consistency and accuracy in the issuance process.
• There are no directives regarding including the costs of renting headquarters, water, electricity, and gas and reflecting them in the tax calculation and the electronic billing system.

• The need to issue clear instructions that must be followed by the user to register and use the electronic invoice system.

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• Applied problems in electronic invoice:
• Difficulty in communicating with customer service to obtain information about the electronic tax system due to intense pressure from all companies on this service.

• It is suggested to rely on a number of other various means, including automated chat, and include it within the electronic tax system, as it can provide immediate assistance and answer common questions in an easy way for the user.

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• Applied problems in electronic invoice:
• Dealing with late invoices by companies, especially when the current month’s invoice is not issued until the following month, as this delay can cause difficulties for companies in settling their invoices and maintaining accurate financial records.

• Providing a detailed guide in the form of questions and answers that includes clear instructions and procedures for dealing with late invoices and ensuring compliance with tax regulations.

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• The inability of companies to recover the withholding tax and deduct it from the taxes owed by companies:
• Minister of Finance Resolution No. 310 of 2013 specified the percentages, goods, and rents to which the tax addition system will be applied, which includes foodstuffs at a rate of 0.05%, and electronic devices at a rate of 1%. The decision classified most industrial products at a rate of 1%, and the taxpayer must be given a receipt for the tax amount to be added to the account of the tax due on him, and the total amounts collected at the end of each quarter are submitted to the Tax Authority on “Form 41 Deduction.” “And adding and collecting.” However, the addition tax is no longer in effect in accordance with Law No. 91 of 2005, as the law introduced the system of advance payments and maintained the withholding tax. Thus, it is difficult for many companies to recover from the Ministry of Finance the values that are deducted, so they are not deducted from the taxes of these companies and no clearing is done with them.

• Making a legislative amendment or issuing a ministerial decision solves this applied problem in the tax law.

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• The Prime Minister’s decision issued a draft law amending some provisions of the Stamp Tax Law promulgated by Law No. 111 of 1980, Law No. 147 of 1984 imposing a fee for developing the state’s financial resources, and Law No. 24 of 1999 imposing a tax on entry to theaters and other entertainment venues and amusement parks:
• Article Three, Clause 29, indicated the addition of 10% of the value of the invoice for customs purposes, in addition to the customs tax, noting that the item proposed to be added is under the Resource Development Duty Law and not the Customs Law or the Customs Tariff, and therefore it is a fee that is not matched by a service. The various laws stipulate not to impose fees that are not matched by an actual service, otherwise they will be considered trade-distorting fees (a non-customs impediment). In addition, it is considered a fee on the total value of the incoming invoice without regard to the value of the invoice. Their customs categories, in addition to the impact of this and its reflection on the increase in the value of the value-added tax that will be collected, and this is considered a procedure that violates the law.
• What is stated in the text of Article Three is to determine the value of the duty value attributable to the value of the invoice and not to the category of customs duties imposed on it, which means collecting duties on goods exempt from customs duties or with a low category in the customs tariff, such as items 0303, 0304, 030360, which are items exempt from customs duties, and items 0302, 0305, which are items with duties. Customs duties are only 5%, and items 850940, 851010, 851631, 851679, and 851830 are items currently in the category of customs duties at a rate of 60%, which is the ceiling of our obligations in the World Trade Organization. This is considered a fraud on the customs tariff, and countries will be met with similar measures against our exports, as these duties were only imposed on the import invoice. For imported goods.

• Not to violate the provisions of the last paragraph of Article No. (4) of Investment Law No. 72 of 2017, which states: “No administrative body may issue general regulatory decisions that add financial or procedural burdens related to the establishment or operation of projects subject to the provisions of this law, or impose fees or charges for services on them, or amend them, except after taking the opinion of the Authority’s Board of Directors and the approval of both the Council of Ministers and the Supreme Council.”

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• Failure to implement Law No. 16 of 2020 regarding ending tax disputes and amending some provisions of the Income Tax Law promulgated by Law No. 91 of 2005, which stipulated that the third and fourth paragraphs be added to Article (110) of the law. The second article included “If the Authority amends the taxpayer’s tax return after the first three years have passed from the date of the end of the period specified for its submission, it may not calculate the delay fee for the period following the end of the three-year period.” referred to until the date of notifying the taxpayer of this amendment, and the calculation of the delay fee shall be determined after this notification. In the event of an appeal against the Authority’s decision to amend the declaration, the delay compensation due must be recalculated in accordance with what is agreed upon between the taxpayer and the Authority or according to what is revealed by the decision of the appeal committee or the court ruling regarding the determination of the tax payable.
• The taxpayer is exempted from paying (30%) of the delay fee for the unpaid tax that is due based on the agreement concluded with the authority before the appeals committee’s decision is issued, on the condition that the taxpayer pays the tax due from him.”

• The necessity of activating the application of the law and issuing the executive regulations for Law No. 16 of 2020, as it has not been issued yet, and only executive instructions and a circular letter have been issued regarding it.
• The police departments do not properly implement the provisions of the law, and fines are imposed for the entire period.

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• Applying value-added tax on software and consulting services in the fields of information technology.

• Exempting software and consulting services in the fields of information technology from value-added tax, as they are an intellectual property product.

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• The lending rate for working capital, according to the rate announced by the Central Bank for industrial activities, does not encourage any expansion or establishment of new projects in industrial activities to meet the government’s ambitions to increase industrial investment.

• The importance of providing financing for working capital at a lending rate commensurate with industrial activities.

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• Temporary permission and the Draw Back system still suffer from problems in the application that prevent them from performing their assigned role.
• In addition, there are problems related to the complementary mechanisms of these two mechanisms, such as: determining depreciation factors and rates and determining the parameters of the use of inputs in production that determine the value of customs that are recovered.

• Facilitating and facilitating the procedures for refunding deposit fees and other fees collected for pending shipments or released under the reservation system, so that the Customs and Tax Authority does not lose its credibility with importers and exporters.

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• The most important problems with the temporary permission mechanism:
• The length and complexity of the procedures necessary to release the letter of guarantee.
• Imposing customs duties on imports that constitute the export product, especially imported equipment and machinery.
• The length of time from the start of issuing the letter of guarantee until the completion of the export process and its release, which sometimes reached a period of one year in addition to the period during which exports are allowed from the date of importing raw materials.

• Implementing the green track release system for factories and companies that maintain a good reputation as an importer, as well as the supplier and customs broker as a single entity, taking into account all due and sufficient precautions and strict legal and punitive measures in the event that it is proven otherwise and then transferring them to the red track.
• Conducting a contractual arrangement between the companies on the white list and the Customs Authority by signing strict penal terms in the event that these companies violate the terms and procedures.
• Amending Article No. 98 of Customs Law No. 66 of 1963, amended by Law No. 172 of 2018 regarding the temporary permit system.
• Extending the period of release permission to four years.
• Cancel the letter of guarantee and suffice with an insurance policy.
• Canceling fines on remaining material balances and simply paying customs on them
• Facilitating the study of rates through industrial control and stabilization.

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• The most important problems with the Draw Back system:
• The large number of documents and the number of parties dealt with.
• Differences in views between exporting industrial companies and customs regarding waste mechanisms.
• Slow customs recovery, which sometimes takes up to two years.

• Notifying the factories and companies from the computer department in sufficient time by sending a message upon entering the customs systems containing the importer’s customer number for taking the initial stage (book 46) and notifying him of the date when it is necessary to renew the document that will expire and submit it after the renewal, taking into account giving sufficient time to the factories.
• Notifying the factory or company by registered mail of the existence of a cash claim as a result of a discrepancy from the Review Department regarding a discrepancy in one of the letters released earlier.
• Giving a notified photocopy to the broker who cleared the letter and signs with an acknowledgment that the importer will be informed of it after reviewing the contradiction and reviewing it with the Reviews Department in order to shorten the time to settle it because the factory is very surprised that the Administrative Seizure Department is present to implement an administrative seizure on the factory regarding contradictions that it does not know anything about.

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• Customs Authority website: The applicable customs duties are available on the Customs Authority website in Arabic only. Companies always rely on a third party to obtain information, especially the documents that are prepared and sent with the containers, which in most cases differ from the requirements received online.

• The electronic content of the Customs Authority’s website must be developed to clarify the procedures in English to prevent any confusion or contradiction in the procedures of foreign companies dealing with Egypt.
• The requirements received online must be updated to comply with the documents required to be sent with the containers.

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• The Customs Authority issued Circular No. 5 of 2020 regarding instructions that must be adhered to in the field of importing production supplies by submitting certain documents:
• A document proving the activity (or operating license) from the issuing authority
• Gas and electricity bills to prove activity.
• The problem lies in the Authority’s issuance of sudden decisions, which represents an obstacle for manufacturers and importers, and such a decision is unjustified in light of the fact that industrial establishments that import their production inputs are subject to the control of other bodies such as the Industrial Control Authority and the Industrial Development Authority. It also wastes what the state previously created through the white list.

• Cancellation of Resolution No. 5 of 2020.
• Stop issuing sudden decisions and consult with concerned parties before issuing decisions.

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• Problems and complications in the customs evaluation system, which leads to obstacles in the import process, which is considered an essential cornerstone of investment and the provision of inputs and production equipment in factories.

• Commitment to the value agreement for customs purposes (improving invoice prices) as it is one of the biggest obstacles facing importing companies, especially companies that are members of the white list.
• Adopting a risk assessment system for countries supplying messages to the Arab Republic of Egypt
• Establishing a clear mechanism for the role of the committee formed by the five different parties to ensure that the release is not disrupted in the event of the absence of a committee member.
• Unifying customs transactions and electronic connectivity in all ports in the Arab Republic of Egypt due to the necessity of electronic connectivity between all customs ports and that the transaction be electronic, not paper.
• Determine a period of time to activate the subsequent review of the goods that are released, let it be two weeks from the date of release, as the importing company may have sold the goods during that period.
• Misr Technology Services has established an electronic link to reduce the release period at Port Said Customs and Cairo Airport Customs.
• Using programs that use artificial intelligence mechanisms to create a mechanism for selecting companies on the white list based on the companies’ credibility and dealing history - the country of origin - the goods they import - finished goods or production inputs - the company’s reputation - the importing party.

• A white list has been issued that includes 75 companies, which is a good and positive measure, but the white list must include all companies and the exception should be the black list and not the generality, with the importance of reviewing the standards for the two lists due to the difficulty of achieving some of these standards.

• The new Customs Law No. 207 of 2020 was issued, and the most important features of the new Customs Law are the following:
• The law added to the places that judicial officers have the right to enter the headquarters of exporters and natural and legal persons who are related to customs operations, including those located in economic zones of a special nature and free zones.
• Increasing the period of obligation to retain papers and documents to five years instead of the previous three years, and in the subsequent review, it is permissible (in addition to reviewing the documents) to review the goods themselves, if they exist.
• Taxes and fees due may be recalculated.
• A fee has been charged for services for the single window, advance inquiries, work outside official working hours or outside the customs office, and any other actual services provided by the authority.
• Customs exemptions have become part of the articles of the Customs Law and are not a separate law.
• The previous letter of guarantee was canceled before the recent amendments to the value of the customs tax, and it became a condition for exemption that the importer deposit with the authority a guarantee for other taxes and various fees, and that the re-export be done within a year and a half from the date of release, and it may be extended for periods exceeding one year.
• Shipping Lists - The text obliges the captain or shipping agent to register in the manifest all goods transported by sea and to sign this list. If the goods are of the prohibited types, they must be recorded in the list with their real names. The carrier or his agent must verify the identity and name of the recipient of the goods before shipping, and that the recipient accepts their shipment. The carrier or his agent is obligated to reship the prohibited goods in the event that the data provided by him is incorrect and the concerned party does not come forward to complete the procedures. Customs duties. If the carrier or his agent does not return the shipment, it will be destroyed at his expense under the supervision of the customs authority.
• Pre-clearance - The law allows the importer or his agent to take advance customs clearance procedures and pay the initially estimated taxes and fees before the goods arrive at republican customs tariff territories, and for the final settlement to be made after the arrival of the goods according to the period in force at the time of release.
• The Authority may inspect the goods to conform them to the clarifications contained in the statement, and it may inspect all or some of the goods or not.
• In the event of a dispute between the Authority and the interested party, the text did not specify the mechanism for selecting the head of the arbitration committee, and we previously suggested that this be by agreement between the arbitrators of the interested party and the Interest.
• Regarding the penalty for smuggling, there is a duality in the fine and punishment and a conflict in the terms of imprisonment and restrictions on freedoms.
• The fines and compensations that are collected are for the benefit of the Authority, and the goods - the subject of the crime - and the means of transport, tools and materials used in smuggling guarantee the collection of fines and compensation if the crime occurs from their owner or representative. It would have been more appropriate for the fines to be collected for the benefit of the public treasury of the state so that they are not deliberately done with those dealing with the Authority to increase the proceeds of the Authority’s income to be spent as rewards for the Authority’s employees.

• Recommendations related to the new law:
• The law must clearly define what is meant by container
• It is not permissible to enter the headquarters of shipping companies without prior judicial permission, because this article gives customs officials unlimited powers.
• Reducing the period of commitment to papers and documents.
• Do not recalculate the taxes and fees due
• Abolishing special fees for single window services, as this fee conflicts with the Investment Law, which stipulates that no administrative body may issue general regulatory decisions that add financial or procedural burdens related to the establishment or operation of projects subject to the provisions of this law, or impose fees or charges for services on them, or amend them, except after taking the opinion of the Authority’s Board of Directors and the approval of the Council of Ministers.
• The legal text must specify the mechanism for selecting the arbitration panel in the event of a dispute.
• Eliminate duplication of fine and penalty

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• The Egyptian Customs Authority has requested a number of multinational industrial and commercial companies operating and investing in Egypt to pay differences from customs and other fees paid on raw materials and production inputs imported to manufacture their products in Egypt and finished products imported for the purpose of selling in the local market on the basis that those royalties and royalties paid are included in the value base for customs purposes and are therefore entitled to pay customs and other fees, despite the fact that the vast majority of contracts concluded in this regard are with the parent companies, which explicitly stipulate that: The royalties and returns paid to it are payments for the right to produce goods or exploit trademarks for units sold in Egypt and have no relation to any raw materials or production requirements imported from abroad by foreign companies operating in Egypt, for which no royalties are paid to the parent company, and therefore these payments are not included in the value base for customs purposes.
• The value base for customs purposes for commercial companies includes royalties for finished products imported from trade agreement countries that are exempt from customs, and claims include amounts for products manufactured in company factories in Egypt (not a list of free zones).
• Assuming that companies accept the application on raw materials, the foundations of application followed by the Egyptian Customs Authority were flawed as they included local cost elements (such as: workers’ wages, local raw materials).
• These claims are issued to companies retroactively for a period of five years after the companies announce the results of their operations, distribute profits, and pay the taxes due for those years, which causes the companies to bear additional burdens that were not taken into consideration in advance. All of this leads to an increase in the cost of production in Egypt compared to other countries, which affects the competitiveness of the Egyptian product, taking into account the ease of the business climate in those countries. In that context, a number of foreign companies operating in the Arab Republic of Egypt were subjected to administrative seizure and the freezing of their balances in banks, which led to those companies resorting to the judiciary to lift the seizure, which It led to exporting a bad image of the business climate in Egypt abroad.

• Not adding those amounts paid from royalties and licenses to use the technological right to the cost elements on which the customs value of raw materials and imported production inputs is calculated, in accordance with the Egyptian Customs Law and its executive regulations, as well as the International Agreement on Value for Customs Purposes.

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• Review tourism exemptions
• Hotel and tourism establishments enjoy customs discounts amounting to (5%) only on the machinery, equipment and appliances they import. Tourism companies also enjoy the same discount on imported passenger cars and cars transporting ten or more people.
• This reduction is still in effect despite the development of the Egyptian industry in the production of many devices and equipment and the manufacture of cars and buses in Egypt and producing them in a way that competes with the importer and exporting them abroad.
• - Law No. 8 of 2022 regarding the Hotel and Tourist Establishments Law, Article 4, repealed Law No. 1 of 1973 referred to in Clause No. 3 of Article No. 22 of the Customs Law.
• Law No. 8 of 2022 regarding hotel and tourism establishments did not include any articles related to granting these incentives to hotel and tourism establishments, as they enjoy all the incentives contained in Investment Law No. 72 of 2017.
• Law No. 38 of 1973 regulating tourism companies did not stipulate any articles related to granting exemptions to tourism companies.
• - Failure to specify the machines, equipment and devices necessary to establish and expand hotel projects and facilities that are imported, and the Egyptian industry produces many of these products with high quality.

• - Reconsidering the customs discounts granted at a rate of (5%) to hotel and tourist establishments, and tourism companies, to reduce the import bill and encourage the Egyptian industry producing these products to work at its full production capacity and create new job opportunities.
• - An inventory of machinery, equipment and appliances that are not produced in Egypt to be subject to the aforementioned customs reductions, and to be reviewed annually by the General Authority for Industrial Development to determine whether or not there is a local product.

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• Delay in customs clearance leads to:
• The disruption of production lines, the inability to adhere to supply deadlines, and the decrease in the efficiency of working capital, which exposes companies to huge losses from delay fines.
• Increasing the burden of flooring and storage expenses, which imposes a high cost on companies due to cars parking and sleeping at the port.
• Delay in customs clearance results from the following reasons:
• The length of procedures for inspection, evaluation, reviews and presentation committees.
• Opening export containers at customs, performing a full inspection of the container, and not activating the white list idea for reputable customers.
• The length of the clearance period at the air port after implementing the one-stop system may reach 3 months, noting that fees are paid for the one-stop service that may reach 1,300 EGP per consignment.
• Laboratory expenses for analyzing import shipments are not fixed and vary despite the constant sample quantity.
• Sometimes dealing with inspection companies is stopped without notifying the importing companies.
• The presence of many supply destinations outside the customs office, which increases the period for examining samples.
• The severe shortage of ultrasound detection devices and the constant reliance on opening containers for manual detection and examination.
• Insufficient laboratories in the ports to conduct all types of analyzes and examinations.
• Relying on traditional paper procedures and not implementing the electronic data exchange system between customs and customers or between customs and other parties.
• Failure to circulate electronic connectivity between different customs ports, especially remote land ports, which leads to a long release period.
• The law does not stipulate a maximum period for health examination of samples on shipments that require a permit from health, and sometimes it reaches 25 days due to strikes by employees of the central laboratories affiliated with the Ministry of Health in Alexandria Port. Accordingly, the samples are sent to the central laboratories in Cairo, which leads to an accumulation of samples and a delay in the health care release of letters.
• Arbitrary decisions as a result of the lack of coordination in decisions between different parties to stop clearing trucks from the customs officer, which leads to disruption of work.
• Examples:
• The release of shipments of production inputs for cosmetics in the border departments was halted based on a decision from the Ministry of Health until the medical stamp tax was paid retroactively from 2015. This decision does not pertain to the cosmetics industry and pertains to medicines and has no legal basis.
• Export shipments of loose tea were halted based on an internal tobacco circular unrelated to the tea from customs officials for weeks.
• The examination of shipments of frozen corn for human consumption was stopped based on a letter from the commercial representation in Spain, the country of origin, based on the presence of field injuries in the corn crop and without any scientific support.

• Developing customs ports by increasing detection devices, electronic gates, scales, flashlights, lighting, and cameras, as well as increasing laboratory equipment and developing the laboratories of the General Authority for Exports and Imports and the Chemistry Department.
• Accreditation of independent international laboratories in testing and scientific body laboratories.
• Electronic linking between all customs ports, overcoming the problem of frequent malfunctions in the customs system, and linking customs with the Central Bank and other banks.
• All offers are made within customs departments under the supervision of the General Authority for Exports and Imports, in implementation of Republican Decree No. 106 of 2000.
• Unifying the entities that address customs into one entity, whether it is the foreign trade sector or the General Authority for Exports and Imports, provided that all entities concerned with import and export are represented.
• Providing a sufficient number of employees to complete all clearance procedures in a period not exceeding 24 hours, and returning to work on the decision of the former Prime Minister to increase the number of customs shifts to facilitate the possibility of releasing incoming shipments.
• Any decision to stop any shipment must be issued through an integrated system, headed by the foreign trade sector, in which all parties must be represented, and the decision must not be in the hands of the customs official.

• Prime Minister’s Decision No. 20 of 2019 was issued regarding the formation of the ministerial committee responsible for following up on the implementation of the single window system, and the Ministry of Finance assumed responsibility for implementing the single window system with the aim of facilitating trade movement and improving the investment climate.
• The Minister of Finance’s Resolution No. 74 of 2019 was issued to include the Egyptian Company for Electronic Commerce Technology assuming the implementation, management and operation of the national single window system in accordance with the contract concluded with the Customs Authority.
• The executive framework document for the single window system was issued.
• A plan for developing and implementing customs applications within the national single window system for foreign trade and a timetable for implementation were issued.
• A recommendation was contained in a study prepared by the Ministry of Planning and Administrative Reform on ways to rationalize imports and develop Egyptian exports, which included completing efforts to block customs smuggling outlets and increasing penalties on anyone proven to have carried out total or partial smuggling operations.
• Another recommendation was also received, which included accelerating the implementation of the electronic link between the Customs Authority, the Export and Import Control Authority, and the Industrial Development Authority, to reduce the time and cost of transactions.

• Duplication of inspection of imported goods
• The inspection is carried out twice, once in the country of origin before shipment, and again upon arrival, which is an unnecessary repetition and causes wasted time and additional costs.
• According to regulations, companies can avoid issuing a pre-inspection certificate under the condition of registering on the whitelist of the General Authority for Export and Import Control, but the procedures for registering on the whitelist are complex and lengthy.
• Customs objects to the invoice prices submitted despite their approval by the chambers of commerce in the country of origin. All required proofs are submitted to the Customs Authority (a contract with the supplier, documented and approved, and supply orders) to no avail, and the price is adjusted upward (improving the price), especially for raw materials imported from outside the European Union.
• Minister of Finance Resolution No. 394 of 2019 stipulated the imposition of a financial fine on anyone who was late in submitting his papers to customs, and did not stipulate the imposition of a fine for customs delay in terminating service.

• “The importance of making a legislative amendment to the text contained in Law No. 53 of 1966 for agricultural affairs, to comply with the text contained in Article No. 83 in the import and export regulations issued by Ministerial Resolution No. 770 of 2005 to abolish the procedures under which double inspection of imported goods takes place, as Ministerial Resolution No. 991 of 2015 requires inspection before shipment, and then inspection is done again upon the arrival of the goods, We request that the text be amended in accordance with the commitment to apply the international agreement in pre-shipment inspection, and that the inspection at the ports be random in accordance with the recognized rules for random selection of samples.
• Issuing instructions to re-examine the indicative prices for imported raw materials and products to reduce customs evasion, and to update them periodically in coordination with the chambers of industry in the various industrial sectors, as the indicative prices work to increase the volume of business that is evaded, thus returning the market to its nature and achieving fair competition.
• Adopting the white companies system with regard to import invoices as well, so that their invoices are recognized without resorting to indicative prices, and in the event of violation, penalties and fines are imposed on them and they are removed from the white list.
• The Minister of Finance should issue binding decisions on the Customs Authority by setting a time limit for completing customs services and imposing fines on the Authority for delays resulting from bureaucracy.
• Activating the text of the executive regulations to suffice with one examination and to suffice either with the approval of examination and review certificates from foreign bodies, provided that this certificate is issued by an entity accredited by one of the bodies accredited by the International Accreditation Federation or by an Egyptian or foreign body that has accredited laboratories specialized in the tests required for each commodity approved by the competent minister, or that the examination is conducted in the laboratories of the General Authority for Export and Import Control.
• Reconsidering the executive procedures for the provisions of Ministerial Resolutions No. 992 of 2015 and 43 of 2016 and Resolution No. 44 regarding amending the rules governing the registration of factories eligible to export their products to the Arab Republic of Egypt, which was taken as a temporary measure before the decision to float the pound. There are companies that completed all the data and documents two years ago and have not obtained approval yet, and Resolution 43 of 2016 in itself is compatible with international agreements and the World Trade Organization, but its problem is In implementation mechanisms, as there are many companies that have not been registered for a while, and there are companies with a global reputation and quality that have not been registered, if any factory has an internal quality system, it must be sufficient to have an accredited company stating that the factory applies an internal quality system in it, which is what the decision stipulates first in Article Two, which states: “A certificate that the factory has a quality control system implemented, issued by a body recognized by the International Accreditation Association (LAC) or the International Accreditation Forum (IAF) or by an Egyptian or foreign government body that approves The Minister responsible for foreign trade.
• In this regard, the following is suggested:
• Correctly applying the provisions of the aforementioned ministerial decision regarding the quality system, such that it is sufficient to submit a certificate from an accredited international company stating the implementation of a quality system without requiring obtaining a quality certificate.
• Registration of companies directly by the General Authority for Export and Import Control if they meet the registration conditions and procedures without requiring a ministerial decision to be issued.
• Publish a list of companies that meet the quality systems in the Egyptian Gazette.

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• Sometimes the procedures for transferring and analyzing samples between the Export and Import Control Authority and the Authority’s central laboratories are slow.

• Unifying the efforts of the General Authority for Export and Import Control and the central laboratories regarding sample analysis procedures, and the private sector can contribute to financing any laboratories or modern equipment required.

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• Customs clearance procedures in Egypt take from two to five weeks, while they do not exceed two days in neighboring countries such as Türkiye and the Emirates.
• According to the World Bank’s Doing Business 2018 report:
• The release period for export in Egypt is 136 hours at a cost of $100 per container, compared to 37 hours in Morocco, 20 hours in Türkiye, and 33 hours in the Emirates. The duration in OECD countries is about 2. hours, at a cost of $35.4 per container.
• The release time for imported shipments to Egypt reaches 505 hours, at a cost of $1,554 per container, compared to $344 in Morocco, $126 in Türkiye, and $961 in the Emirates. The duration in OECD countries is about 3.5 hours, at a cost of $25 per container.

• Setting a target to reduce the customs clearance period from 505 hours to 24 hours for imports by the year 2021, as well as reducing the export period from 136 hours to 24 hours, similar to developed countries, as well as eliminating delay fines.
• Working with a risk management and analysis system on what is imported for each country from which it is imported or produces a commodity whose risks have been proven.
• Signing a protocol between the Ministry of Finance and the World Bank to develop customs dealing and cross-border trade systems in line with international developments and enhance the confidence of foreign investors.
• The final release is sufficient to allow the seizure of shipments to be ended, by unifying the efforts of the General Authority for Export and Import Control and the various ministries in issuing a unified final release permit approved by the authority, which allows the importer to remove the shipment from its warehouses, regardless of its geographical location.

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• Some general problems of customs release.

• General recommendations for customs release
• It is limited to a specific examination of raw materials and final samples imported from abroad, within a specific time limit.
• Unifying the efforts of the General Authority for Export and Import Control and the central laboratories regarding sample analysis procedures.
• The final release is sufficient to allow the seizure of shipments to be ended.
• Activating the white list with clear requirements and benefits for companies that are known to everyone for prior release, with a mechanism that operates in accordance with a clear and binding system and standards. Those to whom the white list applies are excluded from Clause 4 so that it applies to those outside the list.
• Adopting a risk assessment system instead of examining all shipments, with the possibility of conducting a random inspection of the shipments of white list members. If it is proven that the shipment that was subjected to the random inspection does not conform to the specifications, the producing company will be notified to be removed from the list, and it will be removed in the event of a repeat of the violation.
• Developing analysis procedures to keep pace with the current development in various industries, setting a clear time frame for the issuance of analysis results, and unifying procedures in all laboratories and ports.
• Reducing the number of supplying bodies involved in the examination and release procedures, noting that most bodies examine the same points without change, which affects the length of the release time.
• Replace the actual local inspection to complete the customs release process with certificates of conformity from accredited bodies.
• Activating the “Green Path” system with standard and recurring industrial imports, even if they rely on the visual inspection system due to the required procedures and available time constraints. (Especially when applying Article 6 of local production)
• Reducing the time frame that follows the completion of payments, by taking into account printing the release order immediately after completing the electronic payment process and reviewing it without the need to submit a printing request through customs officials at Cairo Air Port.
• Providing training programs that increase the capabilities of Customs Authority officials, which contributes to addressing many issues, including ensuring that the required information and documents are compatible with the nature of incoming shipments.
• Providing more effective communication methods to address the delays that occur in the value estimation and customs tariff processes, especially at Cairo Air Port.
• Providing alternative solutions to address malfunctions that occur in the system and network, and taking the ongoing customs release process into account.

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• Obstacles to working with the MTS system on a system in force in various ports that lead to a gap in implementation and the complexity of the customs release system are summarized as follows:
• ♦ The system does not have the ability to add, copy, or merge lines.
• ♦ Not providing the ability to delete a supply order or delete an invoice if it was uploaded to the system by mistake.
• ♦ Several reports were not available, including (the laboratory rejected messages report - the expired messages report, but no
• Payment is made after)
• ♦ Delay in updating the authority’s fees on the window system, which forces the fees to be calculated manually from
• Financial references.
• ♦ In the event that there is an expired certificate for customs, there is no possibility to work on the food safety request, as for technical support, and vice versa, in the event that there is a request that has expired food safety procedures and there is an error in the customs classification, the request will be canceled from the beginning.
• ♦ Execution record document and partial re-export issued in full number and weight by mistake.
• ♦ Sometimes the transmission of an identical message that is apparently acceptable and laboratory acceptable is delayed, which leads to
• Delay of the concerned party
• ♦ In the event of a laboratory rejection and a response to the grievances is sufficient, a conformity is not issued, which leads to a delay.
• The concerned person.
• ♦ There is no warning or notice on the window in the event that the inspection report is returned to the review department.
• ♦ Lack of guidance from MTS officials regarding the possibility of identifying advance inspection certificates (ELAC) on
• The window.
• ♦ Some reports that were available on the system with the matches that were issued have disappeared and been closed, for example
• Example but not limited to:
• • Samples for which results have not been received for more than 3 days (not available)
• • Food inspection requests for an approved virtual inspection report for which no approved regulatory results have been issued (ineffective)
• •Inspection requests to be received (inactive)
• • Follow-up of food imports (inaccurate)
• ♦ Follow up on collected invoices (ineffective) When reviewing some reports, the phrase “Cannot be displayed” appears
• Required documents”
• ♦ There are some reports that need to be added in the first place, which are:
• • A list of identical messages issued
• •Total number of conformity certificates
• •Follow up on requests to inspect food imports
• • A list of messages that have received a rejection notice
• •Request a grievance procedure
• •A statement of the letters for which a decision was issued “under reservation”
• ♦ The risk system for certificates was discontinued a long time ago, as the risk system determines the degree of risk for items and determines withdrawal rates.
• ♦ It is not possible to modify the terms of the consignments except after the customs inspection.
• ♦ Failure to automatically include drawings of containers in contact with food on the system.
• ♦ In some food messages, the inclusion of fees differs each time, such that they are included once on the basis of the new list, sometimes on the basis of the old list, and sometimes not included at all, which forces the fees to be modified and included manually.
• ♦ When some messages are sent to the virtual inspection, it becomes clear that the offer has been canceled by customs, which forces you to return to customs and MTS to re-offer.
• ♦ Some messages that do not belong to the National Food Safety Authority are displayed and their display is not canceled until they are sent for virtual inspection so that customs and MTS can cancel the display.
• ♦ When the result of the laboratory rejection grievance is received, there is no option in the grievance result box to be satisfied with the laboratory results according to the decision of the Grievances Committee, which forces one to choose to be satisfied with what is recorded (which is the response to the virtual rejection, not the laboratory one). Also, when the result is matched by the Grievances Committee, the match is not included automatically, which forces the results to be edited and re-registered identically.
• ♦ There is a problem with displaying the files listed on the window from the outside, which causes a significant loss of time during review (slow downloading of files)

• It is necessary to work on addressing the problems related to the MTS system on an effective system.

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• Various problems related to the MTS system on the Window system:
• A lot of time and effort is spent on creating the structural invoices required by suppliers, and many suppliers have already refused to raise these invoices, especially in the presence of some abbreviations and codes that are unknown to them.

• Postponing the work of these invoices or canceling them and replacing them with some basic data such as type, number, weight and value in order to automatically modify the message inputs on the system as an alternative to those structural invoices and making exceptions to what was previously submitted, and allowing the procedures to be carried out for the release of goods at the ports on the condition of obtaining an ACID number. Taking into account that the delay resulting from not submitting these invoices will not appear at the time of release, as that delay results before the customs registration in Book 46, and therefore the delay before calculating the release time does not appear, so those shipments present in the ports must be counted before registration in Book 46 so that this statistic shows the extent of the delay.

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• Various problems related to the MTS system on the Window system:
• There are many removals and bans on the system that appear before registration in Book 46, and most of them are unknown to customers.

• Activating a committee to review and inventory the clearances and announce them to those dealing with customs.
• Print a guide for customs clearances and announce it clearly via one of the media to those dealing with customs.

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• Various problems related to the MTS system on the Window system:
• Problems in applying international trade agreements, as the original certificate of origin is required and is not sufficient
• By uploading it to an effective platform, and when inserting the agreement application code, the exemption may not appear, and it is even possible
• Canceling the agreement for the possibility of registering 46, as it is not possible to register in the 46 book except after canceling the agreement.

• Issuing instructions to implement the agreements in the event of prior clearance in the form of the exemption document, provided that it is completed
• Submit it later in the second stage.
• MTS Company reviews the agreement codes, their application and appearance.

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• Various problems related to the MTS system on the Window system:
• Many suppliers were forced to re-upload documents more than once on the CargoXola platform
• The document appears more than 3 or 4 times in a row.

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• Various problems related to the MTS system on the Window system:
• Problems in linking with regulatory authorities, as this results in the following problems:
• •Failure to implement Prime Minister’s Decision 3053 regarding joint committees.
• •Delaying the presentation to these parties, which may reach 4 days or more.
• •The documents required for each party separately and not only the documents that have been submitted with knowledge
• Suppliers.
• •Delaying the issuance of message matches.
• •Abolishing the grievances committees that were previously in place under Republican Decree 106.

• Implementing Prime Minister’s Resolution 3053 regarding joint committees.
• Abolishing the requirement to specify the standard specification in the food industries upon inclusion of the ACI, because the food industries operate according to the technical requirements and the responsibility for the technical requirements falls on the Food Safety Authority.

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• Problems related to the Window platform lead to a gap in the application and complicate the customs release system.

• Simplifying the data required on the “Nafza” platform and allowing one-time registration with suppliers abroad.
• Introducing automated technology to download part specifications, numbers and HS codes. For example, consider uploading Excel pages accompanied by all shipment data to the electronic platform.
• Finding solutions for system delays and malfunctions and ensuring the “Nafza” system’s commitment to issuing “Advanced Cargo Information” (ACI) numbers in a period not exceeding two days.
• Connecting the global “CargoX” platform to the “Nafza” platform to ensure the accuracy of the system.
• Effective linking of main accounts and sub-accounts of service providers, with the need to allow sub-accounts to issue Advance Cargo Information (ACI) numbers.
• Allowing modifications to be made to goods information before their arrival.
• Addressing cost challenges related to the issuance of Advance Cargo Information (ACI) numbers.

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• Problems in implementing the ACI system
• Prohibiting the entry of any shipped goods into Egyptian ports except through the ACI pre-registration system for shipments, despite the complexity of the implementation mechanisms.
• Implementing this system takes time, as the number of registered companies is currently only 400, representing less than 1% of customers.
• The program requires 20 days to activate each facility, in addition to the user himself needing at least a week to face the challenges and complexities of the program.
• Obtaining the advance number for any shipment takes two days, according to a statement from the MTS company responsible for the program.
• Many do not yet know how to implement the new system.
• It is not yet known whether the Customs Authority will ignore the necessity of submitting the bill of lading to the shipping agency before giving permission to exchange the goods.
• The grievance mechanism is not yet known.

• Postponing the implementation of the system for a specified period.
• Forming a permanent committee of concerned parties to discuss all the problems that have been monitored and that arise during implementation and to determine the necessary treatments to produce the new system in the best possible and implementable way and to avoid requesting postponement for an additional period.

• Issuance of Minister of Finance Resolution No. 328 of 2021, which included extending the trial implementation period for the pre-registration system for shipments arriving at Egyptian ports until 9/30/2021, provided that the actual binding implementation of this system begins from 10/1/2021.
• A coordination committee was formed to discuss all the challenges and problems of implementing the pre-registration system for incoming shipments, commissioned by the Prime Minister and at the request of the Federation of Egyptian Industries, and the committee began to carry out its tasks.

• Problems specific to the Authorized Economic Operator (AEO) Egypt program:
• General Form 2 - AEO includes the criteria for accreditation, temporary suspension, and cancellation of the Egyptian Customs Authorized Economic Operator Program, which includes many criteria for accreditation to obtain the Authorized Economic Operator status, many of which are difficult for medium and small enterprises to meet, which include such as the following:
• The applicant must have a history of commitment with customs and other parties for at least 3 years, without specifying the names of these other parties.
• The company has a charter of professional conduct and adherence to it (a code of honor).
• Evidence of compliance with all relevant government regulations.
• The applicant must have a satisfactory internal control system to maintain timely, accurate, complete and verifiable records relating to customs transactions, accounting, records and related logistical activities.
• Establish standardized and integrated accounting and logistics systems where the company must implement an accounting system compatible with Generally Accepted Accounting Principles (GAAPS) or the latest equivalent accounting standards, allowing for audit-based customs control and maintaining a historical record of data that provides an audit trail from the moment the data enters the file.
• An appropriate level of automation of the company's operations, allowing the Customs Authority to have physical access to the company's accounting system and, when necessary, to the necessary commercial and transportation records.
• The company must agree to undergo subsequent auditing, and fulfill the requirements of such auditing by granting customs officials access to data and documents at the company's headquarters.
• Documents must be maintained and submitted to prove the financial solvency of the company which may include profit and loss statements, balance sheets, declaration of insolvency proceedings, if any, and statements from banks, financial institutions or the tax authority.
• Compliance with the conditions for security and safety standards has been achieved, including:
• Documented procedures and a written system to ensure that a company's supply chain has security controls.
• Conduct regular assessments of security risks in the company's operations and take appropriate measures to mitigate these risks.
• Conduct a self-evaluation of the security management system regularly, provided that the evaluation includes the results and feedback from concerned parties, and recommendations for potential enhancements that should be included in a plan for the coming period, to ensure the continued efficiency of the security management system.
• The existence of a complete document for self-evaluation procedures and those of responsible parties.
• This is in addition to the other requirements that must be submitted by the applicant to join the Authorized Economic Operator system, related to security and insurance for facilities (buildings), appropriate and correct cargo security, logistical security and transportation security, information technology security, appropriate measures for crisis management and returning to normal after the occurrence of emergency situations (fire - robbery - radioactive contamination - explosions - terrorism), employee security, education, training and awareness of security workers, appropriate security and safety requirements regarding commercial partners. Satisfactory practice of follow-up, monitoring, measurement, analysis, improvement and development.

• It is necessary to simplify these rules and procedures so that small and medium enterprises can join these systems and expand the number of those joining them and not be limited to a very limited number representing less than one percent of those dealing with customs, as there are two systems for joining the white list, one of which is in accordance with the rules of the General Authority for Export and Import Control, and the other belongs to the Customs Authority, known as the Authorized Economic Operator system, as there is a cooperation protocol between the two parties for those who join these systems to benefit from the benefits they have.

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• Problems of customs release for pharmaceutical industries:
• The periods specified for release from ports range between 4-6 days on average or more depending on customs capacity or in the event of any problems in the system or following official holidays.

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• Problems of food industry release:
• Durations specified for release from ports:
• - East Port Said Port, 20 days
• - Damietta Port 15 days
• The large number of agencies involved in customs release, such as the General Authority for Export and Import Control, the National Food Safety Authority, the Customs Authority, the Ministry of Health and Quarantine, the Atomic Energy Agency (for goods imported from Eastern Europe/Asia), the Ministry of Agriculture, the Veterinary Services Authority, the Egyptian Customs Authority, and the General Authority for Investment and Free Zones.
• Customs duties are collected on the highest current purchase price and not on the price mentioned in the purchase invoice.

• Reducing the average number of days of customs clearance on food industry goods
• Reducing the number of agencies supervising customs release and ensuring the speed of their response, especially the Ministry of Health
• Collecting customs duties on the purchase invoice.
• Activate the white list for importers.
• Ignoring the ILAC certificate.

• The Food Safety Authority prepared a list to inspect only 25% of the total imported consignments.
• The Food Safety Authority prepared the first list of chemical inputs and biological inputs, with one standard examination procedure that did not exist before.

• Problems of customs release for cosmetic industries:
• Durations specified for release from ports:
• Air ports: 25 days on average (5-10 before the Egyptian Company for E-commerce Technology services are available).
• Alexandria Port: 25 days on average for finished goods and 7 days for raw materials.
• Port Said Port: 28 days on average (20 days before the Egyptian Company for E-Commerce Technology services are available).
• Sokhna Port: 5-7 days on average for finished goods

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• Problems of release of industrial goods:
• The average release time for chemical raw materials and packaging materials is 7-15 days, for non-chemical raw materials and packaging materials it is 5-10 days, and for the finished product it is 10-15 days. The total release time is 22-40 days, and it is also possible to reserve industrial products for 10-15 days after their release.
• There are not enough laboratories to accommodate the samples, which increases the average from 10 days to a year and a half.
• The large number of entities involved in customs clearance, such as the Ministry of Health, the General Authority for Export and Import Control, the Department of Chemistry, Quarantine, and Public Security.
• There is no grievance mechanism.

• Reducing the number of days for customs release on industrial products
• Increasing the number of laboratories to analyze samples and relying on external parties
• Reducing the number of parties involved in the customs release process
• Establish a clear mechanism for grievances and complaints

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• Problems of customs release for the textile industry:
• Durations specified for release from ports:
• - Sokhna Port: 4-12 days
• - Port Said Port: 4-12 days
• - Alexandria Port: 4-7 days
• - Cairo Air Port: 3-5 days

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• Release problems of electric power industry:
• Durations specified for release from ports:
• - Industrial shipments: 7 days on average
• - Commercial shipments: 11 days on average
• The concerned authorities and the period it takes for each of them to complete the customs release:
• - Egyptian Customs Authority: 2-3 days
• - General Authority for Export and Import Control: 4-7 days
• - National Telecommunications Regulatory Authority: 1 day
• - Public Security: 3-5 days
• - Chemistry: 15 days

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• Problems of customs release for the automobile industry:
• Durations specified for release from ports:
• - Cairo Air Port: more than 4 days
• - Alexandria Port: more than 3 days
• - Port Said Port: more than 2 days
• - Sokhna Port: 7 days

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• The length of time it takes to reprice incoming messages at the airport

• The importance of the Customs Authority’s commitment to the Customs Valuation Agreement (Article 7 of the GATT Agreement) signed by the Arab Republic of Egypt, which specified the methods for repricing consignments, and that one should not move from one method to the next method except in the event that it is not possible to apply the previous method according to the data and documents required in each method, and that the customer be notified of the reasons and within the specified time periods, and despite the fact that Article No. 30 of Customs Law No. 207 of 2020 and Articles 30 to 55 of The executive regulations of the Customs Law have regulated this, but the business community suffers greatly from the customs’ non-compliance with what is included in the international agreement. Repricing takes a long period of time and the customer is not notified of the method used and the reasons for that. It is worth noting that both the Kingdom of Saudi Arabia and the UAE implement the customs valuation and repricing agreement well.

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• Authentication and authentication of documents by the Ministry of Foreign Affairs: Article 2 stipulated in Resolution No. 43 of 2016 and subsequent resolutions No. 44, and the same condition continued in the application of Resolution No. 195 of 2022, the requirement to authenticate and approve documents submitted by companies and have them authenticated by the Ministry of Foreign Affairs. This requires a long period of time, which hinders the movement of trade and puts Egypt in a weak position on the lists of “trade across borders and facilitation of international trade.” It is known that the authentication and authentication of the Ministry of Foreign Affairs is a formal certification and that the responsibility The technical accuracy of the submitted papers is the responsibility of the companies.

• This step should be replaced by using a special system or email to send the necessary attachments and letters directly from the company without the need for documentation. This is in line with the state’s policies of mechanization and the use of technology to facilitate the speed of trade movement, such as the ACI system that the Ministry of Finance is currently following to dispense with the submission of original documents.

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• - Increasing tariff rates at shipping agencies in Port Tawfiq Port in Suez Governorate.
• - The value of unloading expenses for cars increased significantly within eight months (it was 5,400 pounds at the beginning of 2024, then it increased to 5,900 pounds, then 6,300 pounds, then it increased to 7,850 pounds).
• - Receipts for this are not included on the electronic invoice.
• - The value of the freight freight is paid in advance abroad at the shipping port according to the CIF contract system.
• - Unloading costs at the Red Sea ports (Safaga) are less than at Port Tawfiq port by more than 400%.
• - Shipping agencies collect 5,265 pounds under the fines for breakdowns on cars, even though the car models are new and there are no actual breakdowns in the cars during shipping and no breakdowns are recorded on the competition.

• - Reviewing the tariffs of shipping agencies at various ports, especially Port Tawfiq, and the fines they collect for car breakdowns that did not occur.
• - Reviewing the electronic invoice system to allow these receipts to be uploaded to it.
• - Reviewing the decision for loading and unloading fees at all Egyptian ports compared to what is actually collected.
• - Reviewing the Sea Ports Authority’s fees and codifying the recurring increases collected over a short period of time.

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• - Sokhna Port delays the disembarkation of containers for exports required for inspection at the yards from customs and supply destinations and makes them a lower rank in the disembarkation priorities after the unloading of the ships and the disembarkation of the containers at the import yards and then the disembarkation of the export containers, which results in a delay in the disembarkation of the inspection and inspection committees until the time the employees of these committees leave under the pretext of the lack of sufficient equipment for all the yards, which results in postponement to the next day and the non-disembarkation of the containers required for the next day because there are no spaces.
• This leads to a delay in completing customs procedures, which leads to a delay in handing over the documents for the shipment to the agency. Accordingly, the containers are processed for the next trip, and the customer is charged dollar fines for the agency, and port floors in the case of dry containers, and the customer is charged the cost of electricity used in the case of refrigerated containers.
• Customs collects fees for the X-ray device, but the Port of Sokhna assesses additional fees, which increases the costs for the exporter.
• - In the event that containers are presented to the regulatory authorities, all containers are selected to go to the yard and not selected as happens in customs, while the port of Sokhna does not have the capabilities or yards that can accommodate all the containers required to be detected.

• - Forming committees from the movement to check the containers required to be checked at the port’s door before the X-ray display, in order to speed up the procedures, especially for working marble.
• - Selecting containers and not downloading all containers.
• - Separating the completion of the economic zone procedures from the customs issued at the port of Sokhna, due to the presence of full customs committees in the economic zone.
• - Not to repeat the inspection in Sokhna Port, as was disclosed in Badr Dry Port by customs and regulatory authorities.
• - Increasing the equipment for export customs, including computers and printers, to speed up the completion of procedures.
• - Obligating the Port of Sokhna to provide sufficient equipment for container disembarkation and to open hours during working hours.

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• Window specific problem:
• - Stopping amendments to customs items before registering 46.
• - The currency price changes on the window system for customs certificates (advance) while attaching the delivery permit.
• - Repeat the cycle on the system window for customs certificates for which an attachment was requested after uploading the attachment.
• - Dual evaluation stage.
• - Not knowing why certificates are returned from one stage to another.
• - It is not possible to open supply visas (Resolution 106) with the statement submitter.
• - Numerous amendments and decisions related to Nafez in short periods on an almost weekly basis, as it has become a burden that leads to the price of the Egyptian product becoming uncompetitive in the countries it exports to.

• - Opening amendments to customs items before registration 46 due to lack of knowledge of all customs items before registration.
• - Adopting the currency price at which 46 was registered, as the point is in applying the currency price at 46, not the arrival of the boat and attaching the permit.
• - The importance of not repeating the cycle on the system after uploading the attachment, as it had previously performed the cycle before requesting the attachment.
• - Cancel the documentary appraiser and suffice with the inspecting appraiser, as he is responsible for the actual inspection that removes ignorance, determines the value, item, supply destinations, and fulfills the import rules.
• - Reducing the amounts collected in the window, especially exports

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• Window problem:
• From the point of view of the business community, no benefit was achieved from implementing the single window system. On the contrary, the system led to an increase in the cost and effort to complete customs work.
• The absence of a full estimate of the total fees for customs-related procedures with various authorities, and therefore the system does not operate as a single window as applied in other countries, especially Southeast Asia.
• The length of time it takes to issue export completion certificates (two months).
• Request to complete data that is not related to the released goods
• Papers are still submitted manually to banks, and the bill of lading is still available electronically/manually, and in all countries electronically. In this regard, it is suggested that the E Bill of Loading be the basis, and the documents are sent from the window directly to the bank, and then Form 4 is sent to the beneficiary.
• Paper documents are still handled in some ports
• Some foreign exporters refuse to register with Cargoex, which forces the importer to search for a new supplier who accepts payment of registration fees, provided that the importer pays them to him at a later time.
• A problem in dealing with the Nafezh system in obtaining an ACID number, as the number is not obtained except after many attempts, which may reach thirty attempts, and a message appears, the request is being studied.
• Any difference in the customs identification number requires a decision from the Prime Minister.

• Reconsidering the window system, as the complexity of procedures increased and the time period required to complete customs release increased, which realistically reduced the effectiveness of the digital transformation process.
• Full estimation of the total fees for customs-related procedures with various entities, and thus the system operates as a Single Window as applied in other countries.
• It is suggested that the original Bill of Loading be recognized as an alternative to the Export Completion Certificate
• Consider canceling the requirement for suppliers to register on the Cargoax platform and pay fees in foreign currencies, or allowing foreign companies to register on the Egyptian platform while allowing the Egyptian importer to pay platform fees in Egyptian pounds.
• Review Cargoax fees, as it is unusual in international practices for foreign exporters to be charged fees for the local market.
• Eliminating the obligation for local suppliers to register in the window system in the case of selling to free zones, and the existence of severe difficulties for companies when issuing an electronic invoice while going through customs declaration procedures.
• The importance of solving the problem of the need to correct the customs identification number for the shipment in advance release and the issuance of the decision by the head of the customs authority instead of the prime minister, especially in items related to production inputs.
• The importance of solving problems related to Window.

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• Problems with the risk system within customs:
• Before the window, about 96% of customs shipments were released through the red line. Currently, 86% are released, which means that there are still complications. Therefore, the General Authority for Export and Import Control cannot carry out the rest of its procedures unless the goods are on a green track.
• The Customs Authority manually changes the shipment release path from green to red and not according to the rules set in the electronic program.
• There are multiple risk management entities, as there is no integrated, unified risk system for all entities.

• Unifying risk management between different entities and bodies.
• It is necessary not to convert the path from green to red manually, but rather it must be in accordance with the previous rules set in the electronic program, and the goal should not be to increase the customs proceeds and re-price the letters.

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• Miscellaneous problems:
• Model 4 should be eliminated as it is a procedure that has lost its effectiveness.
• Coordination problems between customs and the Investment Authority in applying the investment incentives law: 2% incentives for importing machinery and equipment, while customs applies 5%
• Differences in release procedures from one port to another (pricing - treatment - fines)
• The ineffectiveness of the Authorized Economic Operator Program, especially in light of the failure to realistically activate the green path
• There is a need to review the list of goods subject to public security presentation. For example, chemicals and glue are currently being presented to public security in Cairo, which prolongs customs clearance procedures and incurs more costs on the importer.
• Lack of transparency, as many circulars are issued by the Customs Authority without notifying producers
• Customs duties are overestimated as a result of the difference between the gross and net weight, and the importer is charged with fines and accused of smuggling.
• There are items subject to fees, such as agricultural quarantine on imported goods and production inputs related to industry, and the application of quarantine inspection fees on them.
• Some items are registered under inaccurate names, such as fees for the Textile Support Fund, which are registered under the name of fees for the Chamber of Textile Industries, which leads to problems with the chamber.

• It is necessary to end work on Model 4, as it is a procedure that has lost its effectiveness.
• The importance of coordination between customs and the Investment Authority in implementing the Investment Incentives Law 2% incentives for importing machinery and equipment
• Unifying release procedures in different ports in terms of (pricing - treatment - fines)
• It is necessary to review the list of goods subject to Public Security display and to release them under reservation until the result of the Public Security analysis is issued in order to reduce the costs and fines incurred by these goods until they are released.
• The importance of announcing publications issued by the Customs Authority so that the business community knows them
• It is necessary to solve the problem of estimating customs duties resulting from the difference between gross weight and net weight.
• The importance of reviewing the items that receive fees, such as agricultural quarantine, and upon which quarry inspection fees are applied, which are inputs to the production of industrial goods.
• Review and correct items that are recorded under inaccurate names in the window.

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• Conflicting legislation and administrative decisions within the various ministries and agencies of the government

• It is necessary to begin restructuring the legislation, decisions and regulations in the government apparatus in a way that reduces the administrative burden on the one hand and contributes to speedy completion. We see the necessity of quickly forming the Supreme Council for Administrative Reform with clear powers to address these legislations and regulations and include them in a way that reduces the scope of the currently existing problems, in cooperation with the Central Agency for Organization, Administration and Administrative Oversight.

• The Prime Minister announced the state's administrative and structural reform program, and a committee was formed to follow up on the state's administrative and structural reform program.

• Lack of flexibility in the speed of implementation of new projects, in addition to the weak organizational capabilities of the state’s administrative apparatus.

• We agree with the Administrative Control Authority’s proposal on the need to expand linking new projects to different regulatory and administrative systems that have greater flexibility and higher regulatory capabilities, such as those stipulated in the Special Economic Zones Law No. 83 of 2002 and Investment Law No. 8 of 1997.

• The Federation of Egyptian Industries was the rapporteur of the committee concerned with reforming the business climate.

• Jobs within the state’s administrative apparatus have not yet been fully restructured, despite the issuance of the new Civil Service Law and its executive regulations

• We recommend that the Ministry of Administrative Development quickly complete the job restructuring plan.

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• Officials hesitate to make decisions for fear of bearing responsibility, which increases the obstruction and slowness of procedures and has a negative impact on the investment climate in Egypt.

• Amending Article 8 bis of the Code of Criminal Procedure as follows:
• “A criminal lawsuit may not be filed for crimes stipulated in Article 116 bis (a) of the Penal Code except by the Public Prosecutor or the Attorney General. If the employee is an employee of the entities specified in Paragraphs (A, B) of Article 119 of the Penal Code, a criminal lawsuit may not be filed except based on the approval of the competent minister to whom the employee reports or from the Prime Minister if the perpetrator of the crime is the minister or his deputy.” This is to allow the state body to be the one with the inherent right to approve the filing of criminal proceedings in crimes of unintentional harm against workers in the state’s administrative apparatus.
• Introducing an article in Part Five of Book Two of the Penal Code as follows:
• “Any employee who intentionally and without justification abstains from performing any of his job duties shall be punished by imprisonment for a period of no less than a month and not more than a year or a fine of no less than 1,000 pounds and no more than 50,000 pounds after it has been proven that it falls within his job jurisdiction and within the limits of his discretionary authority and that it is in accordance with and correct with the law. This results in obstructing any decisions, granting licenses, concluding contracts or agreements, or any other procedures that would hinder any investments. The penalty shall be if the abstention is With the intention of harming the interest of a natural or legal person or a public interest.”
• Amending the text of Article No. 115 of the Penal Code as follows: “Every public employee who obtains or attempts to obtain for himself or obtains or attempts to obtain for others, without the right, a profit or benefit from an act of his position, if this is based on a previous agreement between them, shall be punished with aggravated imprisonment and shall be punished with imprisonment or a fine in other cases.” This is done by adding an amendment to the text of the article such that the public employee shall be punished with imprisonment or a fine in other cases so that the article does not turn into a legal loophole through which the punishment can be evaded as a result of the lack of possibility of proof. The precedent of an agreement between the parties.

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• Subject of municipal waste fees
• - Issuance of Prime Minister’s Decision No. 1114 of 2024 setting fees for integrated waste management services.
• - The value of the fees specified for industrial facilities only has been determined according to the contractual capacity to use electricity, which is a standard that does not express the volume of municipal waste of the facility, and there is no link between electricity consumption and the amount of municipal waste leaving the factory.
• - The Municipal Waste Law and the Prime Minister’s decision made an unjustified distinction between the fees imposed on public sector companies and the public business sector in Paragraph 3 of Article 34 of Law No. 202 of 2020, which includes industrial facilities, and the other industrial facilities mentioned in the law in Paragraph 4 and the standard for which was set by the Prime Minister’s decision regarding the contractual capacity of electricity.
• A distinction was also made within Paragraph 4 between commercial establishments, shopping centres, commercial malls and complexes (which may also include industrial establishments) and similar governmental or private establishments or activities for which the standard was set for the number of units and between the other industrial establishments mentioned in Paragraph 4 and for which the standard was set for the contractual capacity of electricity.
• - The difference in the decision between industrial facilities according to their classification (1) public sector companies and the public business sector, (2) complexes (which may also include industrial facilities), (3) industrial facilities for which the standard was set have the contractual capacity to use electricity, which leads to unfair competition between facilities and a difference in bearing burdens between different industrial facilities.

• - The importance of amending the fees contained in the Prime Minister’s Decision No. 1114 of 2024 to enable industrial facilities to absorb them within their costs, especially since they represent a large increase from the value that was in effect before the decision was issued. The electricity bill includes added financial burdens of 70% of the value of actual electricity consumption.
• The fees mentioned in the table included in the decision will increase every two years by 10%, and these fees will be collected by the administrative body issuing the license.
• - Proposed values for industrial facilities: 200 pounds monthly service fee for a building area up to 1000 m2, 350 pounds monthly service fee for a building area from 1001 to 2000 m2, 750 pounds monthly service fee for a building area from 2001 m2 to 4000 m2, 1000 pounds monthly service fee for a building area more than 4001. M2, similar to the fees imposed on government establishments, public bodies, public sector companies, and public business sector companies.

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• The difficulty and length of procedures and high prices for introducing facilities into industrial facilities.
• Absence of services in industrial areas, such as transportation lines, health units, shops, and restaurants.
• Pricing of various energy products for industrial facilities does not follow a unified standard or reference, but rather varies according to the nature of the industrial sector.
• Gas pricing for steel factories in particular affects their competitive capabilities in light of the lack of flexibility between the local price, which currently reaches $7 per unit, while the global price currently ranges around $3 per million thermal units.

• Studying the possibility of paying utilities in installments for a period commensurate with the size of the project, and facilitating payment for industrial projects.
• Providing stable and economical transportation lines to transport workers to and from industrial areas.
• Offering commercial units in industrial areas to provide food and beverage services and provide rest hours.
• Providing treatment units to deal with medical emergencies in industrial areas.
• Implementing a unified mechanism for pricing energy products for factories, linking them to international prices according to a specific equation up and down, as is the case in most industrialized countries, in a way that achieves greater transparency and justice.
• Achieving flexibility in gas pricing for consumption-intensive factories so that they keep pace with international prices and ensure that Egyptian factories compete with the global product.

• The Prime Minister issued a package of decisions to support the industry, published on 3/17/2020, which included reducing the price of natural gas for industry to $4.5 per million British thermal units.
• He also decided to reduce electricity prices for industry for ultra-high, medium and high voltage by 10 piasters, while announcing the stabilization and non-increase of electricity prices for the rest of the industrial uses for a period of the next 3-5 years.

• Adding excessive financial burdens to business owners:
• The new draft labor law overreported the funds and the burdens they pose on establishments, such as the Fines Fund and the Vocational Training Fund, as well as the Irregular Employment Fund, and these funds represent a burden on industry costs.
• An increase in the number and types of vacations to reach more than 190 days a year if we add the weekly rest day.
• Insisting on the bankrupt employer to pay compensation to workers in the event of a total or partial cessation, and obligating the employer to grant the worker a bonus in the event that the fixed-term employment contract is not renewed after its expiration.

• The philosophy of labor law should be based on achieving a balance between the worker’s interest and not harming the facility owner, as the facility’s success in achieving efficiency and profitability maintains the continuation of workers in their positions, and even increases their incomes on the basis of real productivity.
• That the law is consistent with the state’s development plan on the basis of increasing the productivity of the Egyptian worker to be more competitive, including rights and duties.
• Not granting the worker a bonus if the contract is not renewed

• The new labor bill was approved by the House of Representatives Workforce Committee.

• The Vocational Training Fund suffers from a lack of economic feasibility and does not achieve the purpose for which it was established.

• Reconsidering the management mechanism of the Vocational Training Finance Fund so that the private sector (the main financier) has the largest number of seats on the Fund’s Board of Directors and so that decisions are taken by vote, provided that sectoral councils emerge from the Board of Directors and the Fund’s accounts are divided into a main account with sub-sectoral accounts under it to ensure that each sector benefits from what is collected from this sector.

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• The draft law does not take into account the balance between the worker and the employer, as it brings back the idea of ​​open contracts with indefinite duration, which leads to the employer being forced to resort to the judiciary to dismiss the worker who commits a serious mistake. This idea must be abandoned and the text currently applied in the labor law must be adhered to.

• Abandoning the concept of an open-term contract, and adhering to the provisions of the contract between the worker and the employer.

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• The lack of a fair mechanism to regulate the right to strike.

• The strike must be organized in a way that does not prejudice the interests of the establishment and is consistent with international labor standards, and the limits of the labor commissioner’s authority to organize the strike must be determined.

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• The draft labor law conflicts with the provisions of the Industrial Licensing Law and the Industrial Development Authority Law, in addition to its conflict with the goals and foundations approved by the government, the business community, and the House of Representatives in the Industrial Licensing Law and the Industrial Development Authority Law, as the motive behind the government and the House of Representatives’ keenness to issue the two aforementioned laws, and as the explanatory memorandums for preparing these two laws made clear, is what the business community and international institutions have monitored, that the obstacles present in the industrial licensing system are among the most important negative elements in the investment climate in Egypt.

• It is necessary to review the draft labor law with regard to the risks mentioned in the section on occupational safety and health in the draft law, in a way that eliminates any duplication in defining risks between what is included in the draft law and the standards applied by other bodies such as “Civil Defense and the Environmental Affairs Agency,” and the importance of ensuring coordination between those bodies and not multiple inspection bodies for the same standards, which creates confusion for industrial facilities and doubles the chances of issuing violations against the facility from more than one party, which affects the investment climate and the industrial sector.

• Article Five of the issuance law stipulates, “The provisions of this law and the accompanying law do not prejudice the provisions of the law facilitating procedures for granting licenses to industrial establishments issued by Law No. 15 of 2017.”

• Shipping:
• Reduced performance of port cranes; The number of moves made by cranes in Alexandria Port ranges between 10-12 moves/hour, compared to a global average of 20-25 moves/hour.
• The modesty of many services, such as transporting bulk goods or ship services transporting vehicles, and the inadequacy of shipping lines, which represents an obstacle to many industries.
• Collection of floor fees during convoy waiting times in some ports even though there are no warehouses in the port.
• Imposing loading and unloading fees by the Land Ports Authority, even though transport contractors bear the burden of loading and unloading.
• The increase in freight freight is a result of several factors, including the increase in transportation and marine fuel prices.
• Increasing the cost of shipping lines and obligatory payment in dollars, even though the service is provided on Egyptian territory (not a free zone), and therefore payment must be made in Egyptian pounds.

• إصدار تعريفة شاملة وموحدة لرسوم الخدمات التي تقدم بالموانئ المصرية للسفن بهدف تنمية أنشطة وخدمات النقل البحري وتحديثها مع منع تقاضي أي رسوم إضافية أو مقابل خدمات تحت أي مسمى فيما عدا الضرائب والرسوم المقررة بناء على قانون أو قرارات وزارية.
• Giving priority in carrying out maritime transport activities and services to companies that own ships flying the Egyptian flag to increase the volume of trade exchange and stimulate export movement.
• Taking measures to haul the waste out of the ports and preparing warehouses and spaces outside the port to receive it.
• Developing Alexandria Port with the aim of eliminating slums within it and modernizing the infrastructure of the road network, sewage, water and electricity, in addition to removing dilapidated buildings and waste - establishing a new passenger station.
• Ensuring that priority is given to ships of the national commercial fleet to transport Egyptian goods, and this is not a matter that conflicts with the rules of the GATT agreement regarding the maritime transport sector or with market mechanisms.
• Developing the performance of loading and unloading companies in ports and determining appropriate facilities for private sector companies that are licensed to perform this service so that they have the technical competence and modern equipment to allow for providing distinguished and rapid service to ships while maintaining the level and reputation of Egyptian ports in this field.
• Developing Egyptian naval arsenals and ship repair companies, whether owned by the private sector or the public business sector, in order to attract owners of frequent and transiting ships to carry out overhauls and repairs in Egyptian ports, leading to increased income, with the need to develop a policy to benefit from the capacity of the Egyptian arsenal in construction and repair work to develop the Egyptian naval fleet.
• Studying the reasons for the low prices of ship supplies in neighboring ports compared to their prices in Egypt, which leads to ships resorting to fueling in other ports, which results in wasting resources that could be collected through fueling operations.

• In July 2019, the Council of Ministers approved the Ministry of Transport’s proposal to amend some provisions of the two Minister of Transport decisions:
• The first No. 488 of 2015, regarding a regulation of fees for services provided to ships in Egyptian seaports, fees for the use of fixed and floating missions and facilities affiliated with seaports authorities and the Egyptian Authority for the Safety of Maritime Navigation, and fees for electronic services provided by seaports authorities to their clients.
• The second is No. 800 of 2016 regarding the issuance of regulations regulating the practice of activities and businesses related to maritime transport and the fees for benefiting from them.
• The proposal also included the cancellation of Minister of Transport Resolution No. 468 of 2018.
• Among the incentives provided under the new Ministerial Resolution No. 416 of 2019 are:
• Reducing insurance fees from 10,000 to 5,000 pounds, and licensing fees from 3,000 to 1,000 pounds only, in addition to reducing fees for ship catering services by 50%.
• It includes reducing the lighthouse fee by 10% if the ship crossing the Suez Canal enters one Egyptian port, and by 20% if it enters two or more ports.
• Increasing the license period for loading and unloading activity to between 10 and 15 years, instead of 5 years previously, with the possibility of renewal for other similar periods. Raising the license period for storage and warehouse activity to 10 years, renewable for other similar periods, compared to only 5 years previously. Reducing the insurance that the licensee is obligated to provide to 5,000 pounds (paid in cash or under a bank letter of guarantee), compared to 10,000 pounds previously. Reducing licensing fees to carry out marine works/supply activities. Navy to 1,000 pounds for each activity separately, instead of 3,000 pounds.
• It also includes reducing the fees for obtaining ship catering services by half, reducing the fees paid by companies operating in the activity of purchasing ship waste to only one thousand pounds annually, from 10 thousand pounds, and canceling the condition that the Egyptian partner’s share in the capital of shipping agency companies with joint capital should not be less than 51%.

• Air transportation problems
• Lack of cargo storage space and outdated cold storage facilities belonging to the private sector at Cairo Airport.
• Lack of experience among those responsible for loading and unloading work.

• Allowing foreign airlines operating in the Arab Republic of Egypt that operate regular international routes to ship all types of Egyptian exports abroad at all Egyptian international airports without any restrictions imposed on them and with the same treatment that the national company bears, with the suspension of the “royalty” fee.
• Allowing all foreign airlines crossing Egyptian airspace and technical landing aircraft to land at Egyptian international airports to ship Egyptian products with the same treatment and costs borne by the national company.
• Allowing the exploitation of transport capabilities by charter flights (goods or passengers) to ship all Egyptian exports from all Egyptian airports abroad without restrictions imposed on the operation of these flights with the same treatment as the national company in Egyptian airports and airspace.
• Launching freedom of competition in air freight to and from Egypt to serve air transport movement under the open skies system, allowing the shipment of goods from all Egyptian airports on any aircraft without restrictions imposed on the operation of these flights, provided that these aircraft are treated as national companies, without imposing any fees or new additions.
• Agreeing on a specific maximum price for ground services that EgyptAir and other companies adhere to.
• Opening the way for foreign companies and their agents to carry out ground services operations at all Egyptian airports without paying administrative expenses to national companies and allowing them to service their aircraft, and providing this service to others.
• Approval for transit or charter aircraft to ship Egyptian exports without the condition of obtaining the approval of EgyptAir.
• Rapid completion of cargo inspection equipment to meet security procedures at all airports and allow all shipping companies and their agents to provide these devices.
• Providing soft loans to finance the purchase of transport aircraft.
• Granting tax exemptions to investors who purchase transport aircraft, even for a limited period.
• Allowing airlines and transportation services to establish warehouses and offices inside airports.
• Expanding the storage spaces equipped to receive exported goods until export procedures are completed or until spaces are available on aircraft.

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• Land transportation problems:
• Land transport activity in Egypt is shared by 5 companies, with holding companies contributing about 5% of their shares, and 95% owned by their working shareholders and a number of transport cooperative societies. The two represent 85% of land transport capacity in Egypt, then 15% for the private sector.
• According to the latest available data, the total number of trucks owned by business sector companies is about 1,588 trucks.
• The capacity of Egypt's cargo transport fleet is estimated at approximately 5,480 million tons
• It suffers from many problems that limit its efficiency and at the same time raise the cost of marketing. These problems are: -
• Most of the transportation fleet in Egypt, especially refrigerated cars, provided the price of new units required to replace dilapidated units, as the unit price has now reached approximately one million pounds due to the rise in customs duties and other taxes on them.
• The Egyptian carriers do not have a fleet of refrigerators equipped to transport vegetables and fruits, which led to a monopoly on the transport of these items by Jordanian and Syrian carriers.
• Minister of Transport Resolution No. 28 of 2000 stipulates the imposition of a fee of 10 pounds on each ton of the licensed load, up to 40% of it, and then 50 pounds on each ton in excess of that, which leads to an increase in the cost of land transportation.

• Issuing legislation for the land transport sector, in addition to setting rules regulating companies operating in land transport, dividing them in terms of fleet size and investment volume, and setting safety and health standards.
• The General Authority for Roads and Bridges needs to strengthen its capabilities to monitor land transport activity and develop appropriate mechanisms and directives to manage the sector efficiently and effectively.
• Regulating the tariffs imposed on roads (cards) and making them public.
• That Egypt adopt the multimodal transport system in all its aspects. This requires establishing a seamless customs system and adopting the concept of “door-to-door” transportation without a real bill of lading. In this regard, choke points associated with inland water transport and railways should be removed, in order to take advantage of these important surface transport resources. This will significantly increase the efficiency of supply chains.
• Renewing the Egyptian land fleet while working to reduce customs duties and sales tax imposed on trucks so that the reduction is to the minimum possible.
• Cars should be charged based on their design loads, not to exceed 40-50 tons on internal highways, and then 50 pounds for each ton in excess of that, in a way that does not lead to an increase in the cost of land transportation.

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• Railway problems:
• The long period of time for sorting goods wagons is one of the biggest reasons for the decrease in the efficiency of freight transport operations by rail, as the goods wagons stay for a long time in the sorting docks, in addition to the time wasted in the freight yard and the sorting yard.
• Long crossing times between trains, especially on the main lines and suburban lines around Cairo and Alexandria.
• A decrease in the speed of goods trains in general and a decrease in the speed of passenger trains on some lines, such as branch lines and some main lines, such as the Banha - Port Said and Tanta - Damietta lines.
• The load factor for goods transport vehicles decreases and the vehicle cycle increases, or the time it takes the train to load and return empty to load again, as the vehicle cycle currently amounts to 14 days on average.
• Poor efficiency of the container transportation system and the lack of an integrated transportation system or door-to-door transportation of goods.
• The difficulty of contracting procedures with the Authority to ship goods due to the presence of many grades of goods and each grade of goods has its own tariff, which increases the difficulty of determining the transportation tariff accurately.
• The decrease in the percentage of mobile units available for operation as a result of the lack of attention to regular maintenance of locomotives and wagons and the lack of financial resources necessary to implement maintenance programs.
• There are no ticket reservation agents, and computerized ticket reservation systems are not covered except on the Cairo - Alexandria and Cairo - High Dam lines.
• Low loading and unloading efficiency at the Authority, which led to higher handling costs and increased damaged goods during loading, stowage and unloading operations.
• Increased storage period during trips, which usually leads to goods being damaged or stolen.

• Expanding the scope of work of the Railway Authority and entering into new areas to improve its profitability, such as, for example, investing in the vast land it owns.
• Reducing the storage period out of concern for goods, especially those that are highly perishable. Therefore, it is necessary to emphasize the necessity of increasing refrigerated vehicles and vehicles designated for transporting containers.

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• River transport problems:
• The waterway and navigational obstacles: The nature of the navigational course and its characteristics, whether related to the course itself or the facilities built on it, affect the efficiency and performance of the river transport sector, and this is represented in the following: -
• The water level in the navigation channel falls below 150 cm for long periods of time, which causes difficulty in the movement of river units. This also results in determining the size, load, and quality of navigation units, which negatively affects the economics of river transport. This is in addition to exposing river units to accidents as a result of the low level.
• The presence of locks and bridges causes an increase in river travel times due to the decrease in speeds at these points, in addition to an increase in waiting times, especially at locks, which are considered choke points that affect the flow of traffic in the navigational channel.

• Connecting the sea ports (Damietta - Dekheila - Port Said - Suez) to the river transport network.
• Equipping river ports along the river course.
• Payloads should be taken into account when designing bridges so that they do not represent an obstacle to the passage of ships.
• Modernizing the navigational channel as well as the river fleet with a network of wireless communication devices linked to stations distributed along the navigational channel.
• The application of multimodal transport in the river transport sector requires compatibility with other means such as railways and road transport while providing the necessary equipment and units.
• Equipping the ports with the latest methods of handling goods, whether high-capacity floating cranes, moving belts in the case of solid goods, or pipelines in the case of liquid goods, with the possibility of connecting these ports to other means of transportation.
• Providing the shipping lane with various and advanced navigational aids along the navigational course.

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• Mechanisms for implementing Ministerial Resolution No. 43 of 2016 amending the rules governing the registration of factories eligible to export their products to the Arab Republic of Egypt. The decision itself is compatible with international agreements and the World Trade Organization, but its implementation mechanisms need review.
• The decision stipulates first in Article Two: “A certificate that the factory has a quality control system in place, issued by a body recognized by the International Federation for Accreditation, the International Accreditation Forum, or by an Egyptian or foreign government body approved by the Minister responsible for foreign trade.” There are many eligible companies that have not been registered for some time, and there are companies with a global reputation and quality that have not been registered despite the high internal quality system of those companies.

• Reconsidering the executive procedures for the provisions of Ministerial Resolutions No. 992 of 2015 and 43 of 2016 and Resolution No. 44 regarding amending the rules governing the registration of factories eligible to export their products to the Arab Republic of Egypt, which was taken as a temporary measure before the decision to float the pound. There are companies that completed all the data and documents two years ago and have not obtained approval yet, and Resolution No. 43 of 2016 in itself is compatible with international agreements and the World Trade Organization, but its problem is In the implementation mechanisms, as there are many companies that have not been registered for a while, and there are companies with a global reputation and quality that have not been registered, if any factory has an internal quality system, it must be sufficient to have an accredited company stating that the factory applies an internal quality system in it, which is what the decision stipulates first in Article Two, which states: “A certificate that the factory has a quality control system implemented, issued by a body recognized by the International Accreditation Association (LAC) or the International Accreditation Forum (IAF) or by an Egyptian or foreign government body that approves The Minister responsible for foreign trade.
• In this regard, the following is suggested:
• Correctly applying the provisions of the aforementioned ministerial decision regarding the quality system, such that it is sufficient to submit a certificate from an accredited international company stating the implementation of a quality system without requiring a quality certificate.
• Registration of companies directly by the General Authority for Export and Import Control if they meet the registration conditions and procedures without requiring a ministerial decision to be issued.
• Publish a list of companies that comply with quality systems in the Egyptian Gazette.

• Issuance of Minister of Trade and Industry Resolution No. 195 of 2022 amending the rules governing the registration of factories eligible to export their products to the Arab Republic of Egypt. The decision included.
• Registration takes place in the registry once completed documents are submitted within a period of 15 days from the date of completing the required documents.
• Registration in the register is only made after verifying its validity.
• Upon the request of the registration applicant, the company or factory may be inspected to ensure the authenticity of the documents, after the approval of the Minister responsible for foreign trade
• Documents for registration may be submitted through the embassies, consulates and governments of the concerned countries.
• Documents with an expiration date shall be renewed within a period not exceeding thirty days from the expiration date.
• Publish what is registered or deleted monthly in the Egyptian Gazette and on the website of the General Authority for Export and Import Control.

• Authentication and authentication of documents by the Ministry of Foreign Affairs: Article 2 stipulated in Resolution No. 43 of 2016 and subsequent resolutions No. 44, and the same condition continued in the application of Resolution No. 195 of 2022, the requirement to authenticate and approve documents submitted by companies and have them authenticated by the Ministry of Foreign Affairs. This requires a long period of time, which hinders the movement of trade and puts Egypt in a weak position on the lists of “cross-border trade and international trade facilitation.” It is known that the authentication and authentication of the Ministry of Foreign Affairs is a formal certification and that The technical responsibility for the accuracy of the submitted documents shall be the responsibility of the companies.

• This step should be replaced by using a special system or email to send the necessary attachments and letters directly from the company without the need for documentation. This is in line with the state’s policies of mechanization and the use of technology to facilitate the speed of trade movement, such as the ACI system that the Ministry of Finance is currently following to dispense with the submission of original documents.

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• Subject of stamps and scales:
• Law No. 203 of 2020 was issued regulating measurement and calibration work (metrology).
• - The executive regulations of Law No. 203 of 2020 that specify many of the requirements and explain how to implement these requirements contained in this law have not yet been issued.
• The Ministry of Supply and Trade issues a ministerial decision whenever necessary, such as Resolution No. 120 of 2025 regarding water meters.
• - Obliging producers to present any devices or production lines, whether local or imported, complete or parts, because they have a unit of measurement, to the Department of Weights and Stamping, which refers some of them for examination to the Institute of Measurement and Calibration.
• - The Jewelry and Scales Hallmark Authority does not have the equipment for calibrating meters, nor does it have the human resources and expertise necessary for that.
• The limited number of employees in the department specialized in stamping products before they are traded in the markets leads to the disruption of the work of these factories in their work cycle, whether selling to the local market or exporting.

• 1- The importance of canceling the decision of the Minister of Supply and Internal Trade No. 120 of 2025, as it represents financial burdens, loss of time, and disruption of the work cycle for companies producing these meters.
• 2- The importance of issuing the executive regulations of Law 203 of 2020 to set specific controls for many requirements and explain how to implement these requirements, especially those contained in Articles Nos. 4 and 5.
• 3- The Customs Authority refers equipment or production lines, whether complete or disassembled, that have a measurement unit for display directly to the National Institute for Metrology and Calibration in order to reduce costs, procedures, and time.
• 4- The importance of increasing the number of employees present at the Authority to stamp the products that must be stamped before they are traded in the markets, in what is required for stamping by the Authority in accordance with the regulating legislation, with the necessity of creating a permanent mechanism to solve this recurring problem on a weekly basis with these factories.
• 5- With regard to other finished products that represent an offer to the Authority before putting them on the market, disrupting the delivery of the products to the contracting authorities (such as digital, smart, and prepaid meters), the Authority joins the seven-member committee responsible for inspecting factories, and the Authority has the right to take a sample of the product to test it, and in the event of any violations regarding them, it takes the necessary measures in accordance with the laws in force.

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• Subject of quality control on industrial imports coming from Port Said
• - The importance of tightening control over industrial goods imported through the ports in the Free City of Port Said to address all forms of loopholes that can be exploited to introduce products into the Egyptian market that harm both national industries and consumer health.
• - Entry into the market of industrial products that do not conform to specifications.
• - Food and pharmaceutical goods imported through the Free City in Port Said are subject to the supervision of the competent authorities (Food Safety Authority - Medicine Authority).

• - Treating industrial goods imported through the ports in the Free City in Port Said with the same standard for food commodities and pharmaceutical goods by submitting them to the General Authority for Export and Import Control for examination according to the approved standard, regardless of whether these imports are exempt from customs duties in the Free City.

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• Law No. 5 of 2015 regarding preference for local products in government contracts has no tangible impact due to the lack of commitment by many governmental, economic, and public sector agencies to it.

• Issuing directives to all ministries and agencies to commit to implementing the law and establishing a mechanism to follow up on compliance with it from all parts of the state, and for it to be linked to the needs of future national projects and their needs from Egyptian industry as a substitute for imports.
• Referral of violations to the prosecution and a mandate from the Minister of Trade and Industry to be issued to the technical secretariat of the Local Product Preference Committee formed in accordance with the text of the law and by a decision of the Minister of Trade and Industry, based in the Federation of Egyptian Industries.
• There is no objection to reconsidering the percentage stipulated in the law regarding preference for Egyptian industrial products in government contracts (15%), provided that the law is binding on all ministries, agencies, national projects, and all beneficiaries from the private sector.

• Presidency of the Council of Ministers Decision No. 3-29453 dated 10/25/2020 regarding its session held on 10/7/2020 regarding pushing government institutions and bodies towards relying on local production and emphasizing that all ministers - each in his capacity - immediately personally review the bidding brochures for supplies, contracting, projects...etc. to ensure that the established specifications and terms of reference are neutral and allow the entry of the local product alongside the foreign product. There is no incapacitating specification that prevents the local product from competing.
• The decision of the Council of Ministers in its 236th session, held on 4/12/2023, to affirm that all units of the state’s administrative apparatus, local administration units, public bodies, public sector companies, the public business sector, companies wholly owned by the state or one of the public legal persons, or companies in which the state or any of the public legal persons has a ruling stake, adhere to the provisions of Law No. 5 of 2015 regarding the preference for Egyptian products in government contracts.

• It was agreed with the previous leaders of the Industrial Development Authority to establish a complete electronic system through which a certificate of preference for the local product is issued for companies wishing to apply in government tenders to enjoy the privilege granted by this certificate as a percentage of reducing the 15% of the total bid value from the lowest price of the foreign product, and also issuing a certificate of the percentage of the local component on the basis of which the percentage of export subsidies for companies that the government disburses as an incentive to them is approved in light of the agreed upon controls and requirements. But what was agreed upon has not been implemented yet.

• The Industrial Development Authority should sign the tripartite protocol with the Federation of Industries and Fawry so that the part related to the cost of obtaining the service is completed directly, with the customer paying the cost of the service through the website or through the collection outlets that are present in the thousands across the Republic. Accordingly, each party obtains the full value of its rights once the customer pays, and this is within the framework of implementing the directives of the Ministry of Finance to pay through electronic payment procedures to facilitate citizens and stimulate the private sector to activate the cashless society.
• Regarding hosting the database that will be on the site and having a backup copy inside the Union’s servers to ensure data preservation and support the electronic update system while providing the necessary full protection for the data.

• The Industrial Development Authority has completed its procedures in the electronic program and contracted with the party that will have the hosting server for the server due to the inability to host it in the authority’s current technological system due to the technical capabilities for that. Electronic collection will be done through the collection outlets that e-Finance deals with at the level of the Republic, so that the part related to the cost of obtaining the service is completed directly, with the customer paying the cost of the service through the website or through the collection outlets that are present in the thousands throughout the Republic. Accordingly, each party gets the full value of its rights. Once the customer pays, this is within the framework of implementing the Ministry of Finance’s directives to pay through electronic payment procedures to facilitate citizens and stimulate the private sector to activate the cashless society.

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• The Export Development Fund does not cover many important services related to increasing exports

• Emphasizing the close connection between export development and the importance of supporting the development of testing laboratories for exported goods and seeking to attract private and internationally accredited laboratories to work in Egypt, as well as developing research laboratories and centers in universities so that Egyptian exporters can obtain conformity certificates at a lower cost.
• The importance of the export support program adopting a contribution to obtaining certificates of conformity from these international laboratories.
• Issuing a decision to include the cost of the consultant for the trade missions for the specific items of support from the Export Development Fund, as the consultant is the important point in bringing quality foreign buyers to Egyptian companies due to the various communication channels it has in the target countries.

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• General notes:
• The presence of state-owned companies such as MTS and Halal Company that monopolize these services, determine fees, and are not subject to a regulatory body, in violation of the provisions of the last paragraph of Article No. 4 of Investment Law No. 72 of 2017, which states, “No administrative body may issue general regulatory decisions that add financial or procedural burdens related to the establishment or operation of projects subject to the provisions of this law, or impose fees or fees for services on them, or amend them, except after taking the opinion of the Authority’s Board of Directors and the approval of both the Council of Ministers and the Supreme Council.”
• Customs does not take any action to stop shipments without prior consultation with the Foreign Trade Sector of the Ministry of Commerce and Industry and the committee concerned with inspection, and no party in the country is addressed with instructions to customs except through the Foreign Trade Sector of the Ministry of Commerce and Industry.
• Notification of the shipment of goods, their clearance, and payment of their customs duties are made completely before the arrival of the goods. The application of pre-inspection, pre-release, and dissemination of confidence are activated in engineering inspection offices and internationally accredited inspection companies, similar to what is done in accreditation offices in the Investment Law and the Law to Facilitate Procedures for Obtaining Industrial Licenses.
• Generalizing the application of the white list to all companies in Egypt to be the basis for dealing with all companies and products, with comprehensive examination being the exception, while using all the systems developed in various developed countries, such as risk assessment and the white list, and trade reform will not be achieved except through them.
• The problem of improving the price at customs leads to delaying the customs release of production inputs and charging them with delay fines that benefit from the container companies that receive these fines in dollars. The importance of the Customs Authority’s commitment to the customs valuation agreement (Article 7 of the GATT Agreement) signed by the Arab Republic of Egypt, which specified the methods for repricing messages, and that one should not move from one method to the next method except in the event that it is not possible to apply the previous method in accordance with the data and documents required in each method, and that the customer be notified of the reasons and within the specified time periods. Although Article No. 30 of Customs Law No. 207 of 2020 and Articles 30 to 55 of the Executive Regulations of the Customs Law have regulated this, the business community suffers greatly from the customs’ non-compliance with what is included in the international agreement, and re-pricing takes a long period of time, and the customer is not notified of the method used and the reasons for that.
• The importance of canceling Resolution No. 43 of 2016 and subsequent decisions No. 44 and Resolution No. 195 of 2022 because the amendment gives a reformist approach, but it is misused in the aspect of authenticating documents, as Article Two of these decisions stipulated the condition of documenting and approving documents submitted by companies and certifying them from the Ministry of Foreign Affairs. This requires a long period of time, which hinders the movement of trade and places Egypt in a weak position in the lists of “cross-border trade and facilitation of international trade.” It is common knowledge that the Ministry of Foreign Affairs should authenticate and authenticate documents. External approval is a formal certification, and the technical responsibility for the authenticity of the submitted papers is the responsibility of the companies. It is suggested that this step be replaced by using a special system or email to send the necessary attachments and letters directly from the company without the need for documentation. This is in line with the state’s policies of mechanization and the use of technology to facilitate the speed of trade movement, such as the ACI system that the Ministry of Finance currently follows to dispense with the submission of original documents.

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• The length of time required to obtain export support.

• Eliminate the Ministry of Finance's direct intervention in the Export Development Fund.
• Digitizing all procedures in the Export Development Fund so that all documents are uploaded and sent electronically, and exporter’s receivables are calculated electronically

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• The complexity of the procedures for obtaining a letter from the Industrial Control Authority (waste rates):
• The length of time it takes to conduct studies to calculate the percentage of perishing and loss and the method of its work.
• Carrying out these studies in the central administration for the benefit of industrial control only.

• The exporter undertakes to calculate the waste itself according to a number of pre-determined and internationally recognized equations according to each industry, or to cancel the book of the Industrial Control Authority completely, and the Authority reviews the accounts later.
• Designing a unified form for the Industrial Control Authority’s book so that the exporter can fill it out easily and with the least possible errors.
• Activating and empowering the branches of the Industrial Control Authority in the governorates, by providing technical cadres as an alternative to the severe centralization of the main center in Cairo performing the tasks of the governorate offices.
• Use the electronic signature of the head of the department to avoid traveling to the main headquarters in Cairo.
• Design a program to support small and medium enterprises to purchase the software needed to estimate waste and train them to use it.

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• The absence of a unified risk system applied in all regulatory authorities.
• The length of time it takes to examine samples.
• The length of time it takes to resolve product HS disputes

• Export inspection: International practices are adopted, where the physical inspection rate is estimated at only 5% of the shipment, and if the containers are successfully inspected at the factory, the inspection is not repeated at the port again.
• Inspection of imports: Linking a window to all entities responsible for inspection, developing a window to ensure delivery of inspection requests to the relevant authorities, setting a time frame for examining samples by supplying bodies, setting a time frame for resolving disputes over the Harmonized System code for the product.

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• The lack of clear inspection standards for all inspection bodies, and the inefficiency of the human element to complete the inspection process accurately.

• Generalizing the application of the white list to all companies in Egypt to be the basis for dealing with all companies and products, with comprehensive examination being the exception, while using all the systems developed in various developed countries, such as risk assessment and the white list, and trade reform will not be achieved except through them.
• Customs does not take any action to stop shipments without prior referral to the Foreign Trade Sector of the Ministry of Trade and Industry and the committee concerned with inspection, and no party in the country is addressed with instructions to Customs except through the Foreign Trade Sector of the Ministry of Investment and Foreign Trade.
• Reducing human intervention to a minimum.
• Establishing clear inspection standards for all concerned parties, the most important of which is customs, and announcing them transparently.

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• Problems related to the doorpack:
• Shortening the time period for recovering customs duties in the drawback system
• Limiting duty refunds to a response from the main customs center.
• There is no special system for small exporters to benefit from the dropback system.
• The absence of a single tax base for obligations and dues to establish clearing between all entities affiliated with the Ministry of Finance.

• Extending the time in which customs duties can be recovered from the drawback system to 3 years.
• Providing the import of customs duties from subsidiary customs offices.
• Reviewing the system to include a special path for small exporters to benefit from the dropback system similar to the Korean experience.
• Proposing that payments to the exporter, including amounts owed to exporters of VAT and customs, be deposited in a trust account that will be used to deduct payments due from it to the government in a timely manner (clearing).
• Digitizing all export procedures so that the letter of guarantee is automatically closed once the export is completed.
• Approving controls for valuation and not varying them according to different ports.

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• Many parties have encroached on the jurisdiction of the Ministry of Trade and Industry
• Not publishing information related to export and import operations.
• Not providing a transitional period between the imposition of fees and their entry into force.
• Failure to engage in dialogue with the foreign trade community before imposing these fees.
• Fees exceed the cost of services provided.
• There is no mechanism for periodic review of the fee item with the aim of reducing its value or number.
• Imposing fees on transit goods.

• Mandatory publishing of all fees and expenses that are imposed or updated on the websites of the government agencies that impose them and starting to establish a national portal for foreign trade information that includes this item.
• Establish a notification system to announce any developments in imposing or amending relevant fees.
• Publish a database of fees and expenses on the Nafez portal.
• Requiring relevant bodies to provide a grace period between imposing, publishing, and implementing new or amended fees and expenses.
• Emphasizing the role of the National Trade Facilitation Committee (NTFC) and expanding its powers to ensure facilitating communication between all stakeholders (government and private sector) and establishing an appropriate mechanism to review fees and expenses.
• Amending Nafez fees to reflect an increase in Egypt’s competitiveness in its foreign trade.
• Developing an actuarial model for pricing decisions for services provided.
• Implementing a risk management system in cargo inspection.
• Eliminate fees and charges on transit goods.

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• Infrastructure

• Expanding access to Internet services and cloud computing at affordable prices and at the speed with which the fourth generation system spreads in other countries, which can be implemented through competition between service providers and implementation over announced time frames.

• The Egyptian IT infrastructure has proven its capabilities in light of the Corona crisis, which raises the possibility of moving towards the fifth generation system.

• Skills

• Taking advantage of Internet services and smart devices in schools, and enhancing digital literacy at the level of teachers and students, especially in the uses of cloud computing.

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• Balanced regulatory agenda

• A balance must be struck between the free flow of data and information, computer security and privacy policies, frameworks for the free flow of information across borders should be created, and processes for intellectual property protection such as trademark acquisition should be simplified.

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• The role of the government as an example or model in the transition to the knowledge economy

• By embracing technology to provide services to citizens and improve the productivity of public services, partnering with the private sector in the field of online safety (internet risks) – and community awareness of the rights and responsibilities of users regarding usage and security.

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• The resources of a number of these accounts are used to finance the deficit of traditional budgetary bodies instead of being used for designated purposes, whether service or production.
• The legal, institutional and financial basis for private accounts and funds in Egypt is insufficient.
• These funds do not meet the requirements of modern financial management, financial reporting system, and consistency of financial and administrative subordination.
• This includes the responsibilities and independence of the Board of Directors and its accountability aspects, and the transparency of the decision-making process.
• A number of funds and private accounts have accumulated many financial and non-financial obligations and have entered into institutional interactions with government agencies, including hiring workers and implementing services outside the scope of their purposes.

• Some proposed policies for reforming private funds:
• Establishing political and technical mechanisms to reduce the possibility of unjustifiably establishing new private accounts and funds outside the budget, which would harm the integrity of the budgetary system.
• Making legal amendments, including the legal text on adopting the financial regulations as a requirement for the continuity of the private account’s operation, preparing standard financial regulations for standard private accounts, and stipulating Parliament’s approval to exclude private accounts from the unified account.
• Modernizing the financial management of special accounts and funds, such that common requirements are established for classification of expenditures and revenues, accounting, internal control, external and internal auditing, and reporting.
• Including data related to private accounts and funds in the budget data appendices, for the purposes of financial analysis, and displaying information in financial reports, which gives Parliament the ability to play its role in monitoring priorities for the use of public resources, controlling public debt, following up on public spending, and tracking its impact at the central and local levels.
• Transparency in the fees collected through these funds to improve the investment climate, so that all fees and taxes that the investor will pay are clearly and specifically known in advance.
• Canceling exceptions for some private funds from establishing accounts outside the unified treasury account so that the law is not emptied of its content.
• Reforming the general budget and making it more flexible in spending so that there is no need to create special funds.
• Creating an integrated database on workers in private funds in cooperation between the Ministry of Finance and the Central Organization for Organization and Administration, in terms of their social and economic conditions, poverty level, age, and the disparity in their wages. This is a defect that must be addressed and fixed so that every person obtains his right by creating a system based on transparency.
• Setting standards and controls for appointments to private funds, either by stopping appointments completely or by setting a percentage between 20-25% of the expenses of Chapter One of the fund’s budget, “wage expenses,” or reducing it gradually until it reaches a specific percentage.

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• Issuance of Ministry of Finance General Circular No. 24 of 2021 regarding collecting revenues and exercising treasury rights
• The circular included “the failure of the administrative authorities to disburse the financial amounts owed.”
• For suppliers and contractors only after submitting a statement from the Insurance Fund regarding payment of insurance dues
• And a certificate of tax status (last tax return for general taxes and value-added tax).
• This circular resulted in the disbursement of any financial statements due to suppliers or contractors until after
• Submit a receipt for the 5% social insurance payment.

• In the extracts of supply contracts, it is sufficient to provide evidence that the industrial facility has paid a value
• Social insurance is due from the facility’s employees, and no special additional amounts are collected
• With social insurance.

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• Lack of previous work with a government entity, many companies, whether large or small
• Micro enterprises are unable to contract with government agencies in any government contracts due to...
• Most government agencies require a previous government work history, and despite having a previous work history with...
• The private sector but not recognized by the government.

• Finding the legal mechanism that allows the documentation and proof of assignment orders and supply orders for the private sector in
• Transactions that arise between them, and once documented, that instrument acquires the same legal status as that granted
• Because of the precedent of government sector work, and therefore government agencies are prohibited from engaging in government contracts
• A company's bid was rejected due to its previous work with the private sector.

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• Delaying the financial dues of private sector companies to government agencies, delaying their dues
• Financial despite the completion of the inspection, addition, installation, operation, or initial receipt work
• For the project, for unclear and unknown reasons, which negatively affects them in fulfilling their obligations towards
• Other parties, in addition to their financial difficulty and the lack of sufficient financial liquidity to continue their activity.

• Requiring government agencies to write the date of receipt of financial dues in the award or supply order
• issued by it, explaining that in the event that the company’s work is carried out, the financial dues will be paid within
• Fifteen working days. In the event of delay beyond this period, delay fines will be imposed on the entity
• The government is estimated at 5% of the total support order or supply order for each month of delay and transfer of employees
• To investigate to hold the wrongdoer and the person responsible for the delay accountable.

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• The prices of services provided by the state change suddenly, such as an increase in customs tariffs or a price change
• Exchange or increase in tax obligations, causing financial losses to the company due to the obligations incurred
• Before this increase, it was previously associated with government sector entities, and some even limited companies
• Al-Saghr is reluctant to participate in government contracting because of this problem.

• The state's commitment to establish a transitional period of at least six months in the event of a desire to change the prices of services provided
• provided or the obligations it imposes on the private sector.
• Establishing an insurance fund to protect small and micro-enterprises from sudden price changes.
• In the event that the prices of services or government obligations change suddenly, the state is obligated to hold them accountable
• Private sector contractors with the state must be held accountable for their prices before implementing these obligations
• old until the completion of their contractual obligations.

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• Do not accept bids that are significantly low in value

• Amending Article 35 of Law 182 by setting the minimum low bid by setting a value percentage
• A maximum decrease of 20% from the estimated value of the transaction.

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• Monopolizing contracts over specific parties and contracting by direct agreement in Article 78 of Law 182

• Activating the accounting and complaints system for concerned parties
• Reducing reliance on the human factor and mechanizing tenders
• Activating the points evaluation system (sound evaluation foundations) by amending Law 182 and setting percentages
• Specific to administrative authorities.

• A circular letter was issued on 8/10/2023 from the Presidency of the Council of Ministers to all ministers, governors, and heads of public bodies and agencies stating that the Prime Minister directed not to sign any protocols (contracts concluded in accordance with the provisions of Article 78 of the Law Regulating Contracts Concluded by Public Entities promulgated by Law No. 182 of 2018) except after prior coordination with the Ministry of Planning and Economic Development and presentation to the Council of Ministers.

• In the event that the dues of the supplier companies awarded the bid are paid, the items will be supplied within
• Ten days from receipt of the supply order, except that the disbursement of the extracts is stopped by the finance representative
• Until the contract is issued.

• In the case of supplying items that do not have a warranty after supply, such as (office tools - carpentry - tools).
• Plumbing) It is not necessary to make a contract for it, or to make ready-made contracts with specific values ​​for a specific amount from 1,000 pounds to 50,000 pounds.
• Its use does not disrupt the dispensing of extracts, except for maintenance or any devices it may have
• Ensuring that contracts are issued according to the concluded agreement.

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• Government agencies face the problem of issuing contracts for all operations, even for small amounts such as 1,000 pounds
• And above, which represents a burden on the supplier himself due to the delay in his payments until the contract is completed despite
• Supplying it and receiving it from it due to the entity’s urgency to obtain its needs - which led to some people’s reluctance
• Suppliers conclude any contracts and refuse to deal.

• There is no obligation to write a contract up to a certain financial limit, which is suggested to be 50,000 pounds, and the entity is allowed to spend
• directly from its budget.

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• Excluding companies due to the lack of some documents that must be attached to the technical offer during opening
• Technical envelopes, noting that companies have documents such as (a document proving participation in the public contracting portal - evidence of the existence of a maintenance center - another tax return document - previous work history - etc.)

• Giving a period of three days from the date of opening the envelopes. If the entity does not provide these documents within the period, the company will be excluded before the process is referred to the decision committee.

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• In the event of awarding a single bid, some members of the accounting unit do not comply with Article 39 of Law No. 182 of 2018 by notifying the winning bidder to pay the insurance, and after 7 days the supply order is issued to the company, which subsequently results in a delay fine.

• Commitment to implementation in accordance with the text of Article 39 of the Tenders Law No. 182 of 2018, by notifying the sole company that it has been awarded and issuing the assignment order within only two days after the end of 7 days without the supply order being executed.

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• In mechanical works, upon contracting, the company is asked to pay insurance for irregular workers at the insurance office to which the operation is affiliated, and the payment order is delayed until payment is made, and upon delay, interest is paid.

• Irregular employment insurance is deducted from the government entity that issued the offer and it is paid by that authority for insurance directly without delaying the dues, or providing a place where the insurance share is paid directly and thus saving time and effort for business owners, especially in the case of carrying out work nationwide, which requires traveling to the governorates to insurance offices for payment, which causes a delay in the process of paying contractors’ dues and an increase in costs and implementation time.

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• The length of the documentary cycle and returning the document more than once to complete payment of company dues (15 days to review accounts and disburse dues within 60 days) and partially reviewing the document, which results in a long period and returning the document more than once to complete it.

• Reducing the time period as companies wait to pay their dues for at least six months, which is a very long period of time in the capital cycle, which leads to the reluctance of many companies, especially small ones, from participating in government contracts.

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• The establishment of real estate registration at the required level of importance has been delayed for many decades, as the real estate registry is considered a revolution in the registration system. Its implementation results in a radical change in the existing registration systems. Despite this, we find the state’s insistence over the decades on implementing the real estate registration system and not providing the necessary resources and political support to implement the real estate registry system.
• For example, the application of the in-kind registry system was not imposed on desert lands privately owned by the state and which are allocated or transferred to any of the administrative bodies such as the New Urban Communities Authority and the lands allocated to it for the establishment of new urban communities, despite the ease of applying it in pristine places. Rather, a law was issued to simplify real estate registration procedures in new urban communities. Merely seeking to expand the scope of enforcement of the Property Registry Law in its current form is not a practical alternative to real estate registration procedures in its current form due to the long time it takes to implement the initial registration stage. The Real Estate Registry Law came into effect nearly sixty years ago and has not produced tangible results yet.
• Relying on the same law issued in 1964 no longer provides the appropriate legal framework for the nature of the times, the number of properties required to be registered, the modern technologies available, and the goal of registering the entire Egyptian real estate wealth.

• Implementing the in-kind registry system - which is the best solution - requires not only resources and political will, but also the development of this old system.

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• The state has withdrawn from obliging government agencies to deposit the documents of their transactions in the lands belonging to them in the competent real estate registration offices, provided that the deposit results in the same effects as the registration. Thus, the sequence of registered properties has begun, which allows the transferee to transfer his ownership to other persons and obtain financing with the guarantee of the registered property and other transactions that enable the transferee to enjoy his ownership in a calm and stable manner, which is what is desired by the Egyptian Civil Code and the real estate registration laws.

• Making a legislative amendment with a text requiring administrative authorities to register their actions, and not leaving the entire matter to individuals to record their actions if they succeed in convincing the competent authority to register its actions for them in the first place.

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• Loading real estate registration with the responsibility of protecting the state’s rights - despite the weak public demand to register their properties - contrary to logic and despite reducing registration fees - the registration process itself has been burdened with the burden of protecting the state’s rights despite the presence of other ways to protect these rights that already exist in the various laws, which led to the reluctance of the administrative authorities to register the lands that had been disposed of to investors even if the full price was paid for fear of accountability and out of concern for the state’s rights, so the goal of protecting the state’s rights became the real obstacle to starting the chain of ownership required to enable individuals to register their ownership later.
• The decisions issued by the Prime Minister and the competent administrative authorities adopted the same texts in the various laws regulating this, and one of the most dangerous things that was adopted through these decisions - based on the spirit of the laws and considering the protection of the rights of the state as the most important priority - is to consider compliance with all the provisions of the contract as a condition for the administrative authorities to register. Consequently, every condition added to the contract became a barrier to registration, which greatly harmed the issue of real estate registration due to the difficulty of obtaining evidence of the recipient’s commitment to all the terms of the contract from the administrative authorities.

• The importance of relying on the laws governing the disposal of state-owned lands, which include many texts that guarantee the state the protection of its rights in other legal and effective ways that do not conflict with property registration.

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• Details of the registration process:
• Although the legislator took the decision to adopt the real estate registry system since 1964 due to its preference over the real estate registration system, all the reforms that affected the real estate registration process focused on the real estate registration law instead of reforming the real estate registry law to apply it to all parts of the republic. The process of transformation of the real estate registry system has been continuing since 1964.
• One of the most important reforms that the real estate registration process underwent - from which the real estate registry law also benefited - was in 2006 when relative fees were abolished and specific fees for registration were set at a maximum of 2,000 pounds. Despite the utmost importance of these reforms, they were not sufficient to solve the problem of real estate registration in Egypt or create a boom in registration.
• Bar Association certification fees, as these fees now exceed the registration fees that the legislator worked to reduce to encourage citizens to register.
• A re-cadastral survey is required even if the area of ​​the same property has been raised previously. Cadastral maps are required when carrying out every registration or registration of a property right, and the property must be inspected even if the area of ​​the property has been raised before.
• The lack of a clear system for separating the discrepancies in cadastral surveying that arise as a result of the use of different types of maps in different cadastral bodies, and the discrepancies that appear between these maps and the cadastral surveying in reality, as these discrepancies cause a prolongation of the time required to complete this procedure or
• Proving some inaccurate data to speed up the completion of the procedure.
• It is often difficult to obtain some documents, such as a building license and a revenue certificate, especially if these certificates were damaged as a result of the places where they were kept being exposed to riots or because these papers were outdated. It is also sometimes difficult to obtain national numbers for deceased persons before the time period covered by the national number system, or to obtain an identical building license in the event of building violations, which also leads to stopping registration procedures.
• Applications are piling up at real estate registration offices, even in light of the increased efficiency of the offices and their tasks, in addition to the inactivation of the website and the lack of clarity about the extent to which it is possible to replace the procedures carried out by employees by registering through the website.

• The 2022 reforms - despite their importance - are not sufficient to bring about the boom that the Egyptian economy needs in registering real estate wealth because they focus mainly on the real estate registration system, despite the necessity of moving to the real estate registry system.
• These reforms depend mainly on individuals taking registration procedures, which will necessarily lead to the process of registering Egyptian real estate wealth taking decades without clarity in the time frame, which will necessarily hinder efforts for the national economy to benefit from Egyptian real estate wealth.
• The importance of reviewing the real estate registry law comprehensively in all cases.
• The real estate registry law did not receive the same degree of attention as the real estate registration law. The initial registration procedures in the real estate registry were not reviewed and the procedural problems that hinder its implementation were not identified, whether at the level of inventorying and registering real estate, at the level of examining and proving ownership, or at the level of adjudicating cases and requests submitted to change the data recorded in the registry.
• The importance of amending the law after ruling two important articles of it unconstitutional, especially the article related to the Judicial Committee to which requests and lawsuits are submitted to change the data recorded in the register.

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• The current institutional framework is not compatible with the requirements of the Egyptian real estate wealth registration program:
• First - not updating the laws adequately:
• The laws regulating the institutions concerned with the registration process date back more than seventy years and have not been sufficiently developed, especially with regard to the in-kind registry. Although a degree of modernization and facilitation has occurred during this period - especially in the past two years as a result of the recent decisions of the Ministry of Justice - the legal basis on which the entire real estate registration system in force in Egypt is based has become inappropriate for the requirements of speed, accuracy and efficiency, and is not compatible with the tremendous technological development that the world has witnessed in the processes of surveying, registering and registering, building databases and conducting transactions through them, and does not express the economic importance that the issue of registering Egyptian real estate wealth deserves.
• Second - There is no single party concerned with the issue in general:
• The adoption of the real estate registration system and the registration of real estate transactions it entails resulted in the role of real estate registration being considered essentially legal, as certain transactions are proven through it, and the role of the Survey Authority became complementary because it focuses only on describing the property and its location. It was natural to separate the Survey Authority - which performs several other roles - from the Real Estate Registry Authority, whose primary role is to complete and record legal transactions on real estate.
• When the Real Property Registry Law was adopted, the Real Estate Registry Authority also became the body with the highest jurisdiction in the registration file, and the activity of the Survey Authority continued as one of its components or as a tributary of its tributaries.
• Third - The overlap between the tasks of registration and documentation:
• The Real Estate Registry Authority is concerned not only with real estate registration, but also with another major task, which is documenting and notarizing documents and actions in general.
• If this institutional situation was previously justified when laws were issued in the middle of the last century, the current situation is different.
• There is an urgent need to unify all stages and mechanisms of real estate registration, from surveying to registration to proving transactions, in one place.
• Fourth - The inadequacy of regular dispute resolution mechanisms for implementing the real-life registry system:
• The application of the real estate registry system results in many disputes related to ownership and the transactions that take place over real estate, especially with the presence of a huge amount of real estate that is not officially registered, as well as in view of the fragmentation of ownership that occurs with the frequency of inheritance processes across generations.
• The Real Property Registry Law - in Article 21 of it - attempted to address this, by stipulating the formation of a judicial committee in each cadastral department headed by the president of a court of first instance and the membership of two department employees, one of them legal and the other engineering. The law assigned this committee - exclusively - to consider all lawsuits and requests filed during the first year after the implementation of this law to make a change in the data of the real registry. However, it allowed the Minister of Justice to extend the period during which the committee can receive lawsuits and requests. It also allowed the committee’s rulings to be appealed before the Court of Appeal, which means the continuation of litigation. Regarding initial restrictions for very long periods of time, this text was ruled unconstitutional in 2018 due to the majority of administrative members on the committee, which makes it an administrative committee and not a judicial committee, and because this deviates from the citizen’s right to resort to his natural judge.
• Fifth - Not expanding the role that the private sector can play in real estate registration:
• Despite calls to allow the private sector to participate in the various stages of real estate registration, especially in the cadastral stage, this has not been achieved in practice.

• The process of registering real estate according to the real estate registry system must be based on the integration of two paths:
• •The first involves surveying all properties, identifying their current owners or occupants, and entering all of this into a national information system.
• •The second involves registering transactions on properties that have been surveyed and registered in this national system.
• Although the second path is distinguished by the accuracy of its legal and procedural aspects and by its discussion of the origins of properties, their validity, their proof, and the registration of transactions on them - issues of a legal nature that justify the attachment of the Real Estate Registration Department to the Ministry of Justice over the past decades -, the first path, which forms the basis for building the information base necessary for registering properties, is linked to cadastral techniques, creating databases, and registering properties, and these are matters that are more related to surveying and information expertise.
• This requires restructuring the Real Estate Registry Authority to include both the Survey Authority and the Real Estate Registry Authority - or at least the functions required by the implementation of the real estate registry system from the two bodies - in one body to suit the requirements of implementing the real estate registry law.
• Adopting the internationally applicable system of independence of notary offices (or notaries) under the supervision of the Ministry of Justice, but without mixing this with real estate registration mechanisms.
• The importance of amending the law after ruling Article 21 of it related to the Judicial Committee to resolve the problem of disputes and litigation unconstitutional.
• Activating the role of private cadastral offices - whose work is approved by one of the official authorities - by assisting the real estate registration offices in determining real estate data.
• Determine the general and technical standards for accrediting private cadastral offices.

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• The absence of transparency and objectivity in allocation and pricing, and the absence of integrated information about available lands, their prices, and procedures for obtaining them.
• Land policies are developed in the absence of integrated, up-to-date information on land.
• The difference in allocation procedures between entities, the length of the allocation procedures and their complexity, as well as the change in land uses after their allocation.

• Issuing an immediate, explicit decision from the Prime Minister assigning jurisdiction over lands, infrastructure, and facilities to the Urban Communities Authority, and management and allocation to the Public Authority for Industrial Development, and defining the different roles of the Public Authority for Industrial Development and the Urban Communities Authority.
• Resolving the legislative dispute over the subordination of industrial lands under the Industrial Development Authority Law, and issuing new legislation, if necessary, that precisely defines jurisdiction over the lands, the responsibility for attachment, and the responsibility for allocation to the final beneficiary.
• Establishing an integrated, updated and available information system for industrial lands.
• Replacing the numerous land legislation with a unified and simplified law for state land management.
• The investor's dealings should be limited to the Industrial Development Authority only.
• Announcing a land bank to serve as a database with all available information about the availability of industrial lands, their prices, and the extent of their infrastructure development.

• A coordination council affiliated with the Council of Ministers was formed to study the obstacles to industrial zones.
• The Council of Ministers contracted with a consulting office (Megacom Consulting Company) to study the obstacles facing the industrial zones and determine solutions for them, and to meet with investors to discuss their opinions and the solutions proposed by them, with the Ministry of Finance bearing the cost of the office.
• After discussing the proposals between the Federation of Egyptian Industries and Megacom, the proposals concluded that the lands would be a usufruct for a ten-year lease, and if seriousness is proven, the lands will be owned by those who are serious.
• Obtaining industrial lands through the investment map on the website has become available to both the General Authority for Investment and the General Authority for Industrial Development, according to the type of projects required to be established in each region, but it is difficult for many to deal with.

• Failure to activate some provisions of Law 15 of 2017
• The Urban Communities Authority still requires a bank letter of guarantee as a condition for the investor to obtain land in industrial zones (Ministry of Housing, New Urban Communities Authority), and there is an exaggeration in it, despite its abolition in Law No. 15 of 2017, but this abolition did not take effect.

• Activating the law regarding canceling the requirement of a letter of guarantee to prove the seriousness of the investor wishing to acquire land for industrial purposes

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• Despite the importance of the Prime Minister’s Decision No. 3308 of 2022 regarding the immediate allocation of attached industrial lands to investors in application of the usufruct principle, the decision included several important points that need to be corrected:
• ♦ His Excellency the Prime Minister issued Resolution No. 3308 of 2022 regarding industrial lands, in most of the provisions contained therein, with the same rules and prices currently applied by the General Authority for Industrial Development and the Committee to Resolve the Problem by Resolution No. 2100 of 2021.
• ♦ The Federation of Egyptian Industries’ opinion was not consulted or polled regarding the land prices mentioned in the decision, which are high in value and unattractive for investment.
• ♦ The decision did not include what these required papers and documents are, as the Union had previously made reservations and objected several times to the documents that became required of industrial investors after the formation of the 2100 Committee for the year 2021, such as (submitting a detailed feasibility study that includes a technical and economic study, a financial study, buildings, infrastructure, working capital operating cycle, the proposed financing and depreciation schedule, a list of production costs, and an expected income list for five years from the beginning of the project’s life) and the reference in procedures and pricing for the committee formed according to the decision. Prime Minister No. 2100 of 2021, contrary to what was stipulated in Law No. 95 of 2018.
• ♦ The decision did not include the time period during which the installments would be made.
• ♦ The text of the decision stated that these prices are indicative.
• ♦ The decision did not include any clarification of how investors would act if they did not hand over the land attached, which is a frequent case with most manufacturers.
• ♦ It is stated in Article 1 - Paragraph No. 5: “In the event that the investor fails to pay two successive installments, the guardianship authority has the right to terminate the contract.”
• ♦ Article One - Paragraph No. 6: “The land and the facilities on it shall be transferred to the guardianship authority after the end of the usufruct period.
• ♦ In all cases, the allotted person is committed to all allocation controls, including implementing the project and starting operation within a maximum of three years from the date of receipt of the land, while adhering to the specified timetable. Otherwise, the land will be withdrawn along with the usufruct fee during the period of his occupation of the land. These rules are the same as the currently applied rules, which are marred by many defects, such as:
• •The contracts concluded with the investor are contracts of adhesion and he does not have the right to object to any clause therein, and they include what was stated in Paragraph No. (6) above contained in the Prime Minister’s decision.
• •The presence of natural obstacles on the land being delivered is not taken into account, such as the presence of a hill or other obstacles that take the investor a period of time to remove, in addition to increasing the burden of construction costs. Then, delay fines are calculated that double on a monthly basis and standard costs for the time period specified by the General Authority for Industrial Development.
• •The lands are not received attached to the land, whether at the beginning of the date of receipt of the land or during the implementation period, and the authority with jurisdiction is not committed to this, and delay fines are imposed on the investor for delaying the implementation of the time program.
• •The Industrial Development Authority sets the executive timetable for three years without taking into account any obstacles or impediments that hinder implementation.
• ♦ What was stated in the last paragraph of Article Three of the Prime Minister’s decision, which states: “Paying the price of the land after revaluing it at the full commercial price, deducting what was paid for the usufruct right.”

• The time period during which the installments will be made is 15 years
• The prevailing thought on the issue of land is still trading in land prices and not the thought of industrial development and helping manufacturers reduce construction costs for factories to expand industrial production.
• Simplifying the documents that became required of industrial investors after the formation of the 2100 Committee
• 2021, such as (submitting a detailed feasibility study).
• The importance of clarifying how investors should act if they do not deliver the land attached.
• The existence of grace periods according to the circumstances that arise outside the investor’s control and affect his circumstances, such as what happened in the case of the Corona epidemic, the Russian-Ukrainian war, or any major events that occur that affect the investor’s income and his ability to regularly pay, so there must be a grace period, and a first and second notification must be sent within a specific period of time that allows him to manage his resources to pay the late installment, especially since delay interest is calculated on the investor according to the value of the interest declared in the bank.
• Activating the text of Paragraph No. (5) of Article No. 35 of Law No. 95 regarding the Public Authority for Industrial Development on the failure of the concerned party to adhere to the time program submitted by him. "That is, the investor must set the executive time program himself."
• Activating the investor’s right, as the law does not specify the three-year period that the Authority sets for the implementation timetable without taking into account any obstacles that occurred during this period.
• Determine the value that the investor will receive at the end of the usufruct period in exchange for the buildings or production lines that have been constructed if the factory has not been liquidated and sold.
• Changing the idea of ​​revaluing the land at the commercial price upon ownership, given that the investor is the one who raised the value of this commercial price with his investments that he made and incurred in the region since the beginning of the project’s establishment, which the Union has previously objected to many times, as the organizing thought on the issue of lands is still trading at the highest price for the land and not how to strive to achieve the highest industrial development and productivity on this land.
• In the event of an agreement to purchase the land and ownership after five years, the price of the land shall be at the same price as the land that was agreed upon upon the usufruct, with a deduction for what was paid for the usufruct of the land from the purchase price of the land.

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• So far, no decision has been issued to form a new board of directors for the Industrial Development Authority based on Law No. 95 of 2018 regarding the Authority, and the executive regulations for this law have not yet been issued.

• Formation and approval of the new Board of Directors of the Public Authority for Industrial Development based on the provisions of the law.
• Speeding up the issuance of the executive regulations for the Industrial Development Authority Law.
• Issuing a law for the management of industrial zones to determine the relationship and responsibility between all concerned parties in a manner similar to free zones and operator zones.
• Taking into account the representation of the Federation of Egyptian Industries in the membership of the Authority’s Board of Directors, as the current text in the law specifies government agencies and experienced representatives without explicitly mentioning the Federation in forming the Authority’s Board of Directors.
• The formation should stipulate the presence of a representative of the Ministry of Local Development as one of the entities that grants licenses to establishments within the residential cluster.
• That the provisions of the law be applied and activated, as the Urban Communities Authority directly offers industrial lands for sale contrary to the text of the law.
• Reviewing the decisions issued regarding licenses and industrial registry during the past period to ensure their consistency with the laws regulating the issuance of licenses and industrial registry.
• Establishing a mechanism for the Federation of Egyptian Industries and member industrial chambers to be responsible for measuring the Authority’s performance with regard to licenses, the industrial registry, and lands, and monitoring all relevant executive problems, especially with regard to industrial lands.

• Issuance of the executive regulations for Law No. 95 of 2018 regarding the General Authority for Industrial Development.
• The Minister of Trade and Industry Resolution No. 325 of 2022 was issued regarding the formation of the “Requirements for Granting Licensing” committee with the aim of reviewing the requirements for granting licenses to industrial establishments and working to simplify them in a way that contributes to facilitating it for investors. The committee included in its membership two representatives from the Federation of Industries.
• The committee held two meetings and is working to simplify the procedures for granting industrial licenses and limit the essential and non-essential requirements for civil protection for industrial facilities so that the facilities obtain industrial licenses for high-risk industries in accordance with the Egyptian fire code.
• A list of essential and non-essential requirements is being prepared for high-risk industries and low-risk industries, so that civil protection inspections in industrial facilities can be carried out accordingly to solve the problems of industrial facilities with civil protection.
• It was agreed between the General Authority for Industrial Development and the National Center for Housing and Building Research to be the authority’s advisory center on the issue of the fire code and to decide on manufacturers’ problems related to industrial licenses within three days.
• A committee was formed between the Public Authority for Industrial Development and the Environmental Affairs Agency to solve the problems of industrial licenses related to the environment.

• Weak administrative capabilities of the Industrial Development Authority:
• The small number of employees in the governorates leads to the ineffectiveness of the Authority’s offices there.
• The authority’s employees in the governorates are not authorized to make decisions without referring to Cairo.
• Some of the Authority’s employees are not sufficiently qualified to implement the procedures.
• The Authority issued about 16,000 licenses by notification and does not have the manpower capable of following up and reviewing these licenses.
• The interaction and communication between the Authority and the investor public is very weak, which is why the industrial licensing facilitation law is still unknown to most of those dealing with the Authority.
• The Authority’s website needs further updating and development to become a major interaction platform for investors.

• Supporting the Authority with more financial allocations in the short term to increase human and technical capacity and enable it to spread throughout all governorates effectively and efficiently.
• Raising human capabilities through intensive training programs for the Authority’s employees to enable them to deal with the investing public professionally, professionally and with integrity.
• Restructuring the Authority to ensure implementation of the provisions of Law No. 95 of 2018.

• Partial accomplishment has been achieved in these points with regard to updating the Authority’s website and publishing most of the data needed by the investor, but the electronic transaction to complete services is still inactive, and human capabilities have not been increased or more financial allocations have been allocated to the Authority.

• Lack of full implementation of the provisions of the Law to Facilitate Industrial Licensing Procedures. We find continued interference between the Industrial Development Authority and other entities in the country in the Authority’s jurisdiction over all matters related to industrial projects, as stipulated in Licensing Law No. 15 of 2017.
• There are many different oversight and inspection bodies, and measures such as imposing fines and closures are taken by some agencies and ministries, such as finance, environment, insurance, civil defense, and municipalities.

• Implementing all provisions of Law 15 of 2017 regarding facilitating industrial licensing procedures, specifically enabling the Industrial Development Authority to perform its role effectively by stopping the interference of other parties in the procedures for granting or canceling an industrial license.
• It is necessary to simplify the guideline for possession documents and legalize what is stated therein (issuing a decision on the applications contained therein), as stated in the text of Clause No. (1) in Article No. (2) of the executive regulations of Law No. 15 of 2017, “In issuing industrial licenses, a commitment must be made to complete the procedures and take into account the timings stipulated in the law and the regulations without burdening the industrial facility with any additional burdens,” which is completely reversed.
• Refer to the Industrial Development Authority before any closure decisions issued by other parties.

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• The time to obtain the license is still long.
• The long extraction period causes banks to not accept financing for the activity until after starting operation and obtaining an operating license.
• Accreditation offices that contribute to the speed of procedures are still absent or not widespread.

• A target setting to reach seven days for licensing by notification and one month for prior licensing (as stipulated by law) by 2020.
• Authorizing governorate offices to issue licenses after completing the procedures without the need to return to the center.
• Dividing the services of accreditation offices and determining the value of the offices’ fees for each service so that it can be announced and disseminated to manufacturers to activate the role of accreditation offices.
• The presence of specialists in accreditation offices to review the documents necessary to grant industrial licenses to grant them an accreditation certificate in order to make it easier for manufacturers to obtain industrial licenses.
• The presence of offices specialized in environmental and civil protection issues whose costs for the services provided are proportional to the capabilities of small industries.

• Although about 8 offices have been approved, the issue still has not solved the problem, and we need to increase the number of offices to lift the burden on government agencies.
• The Minister of Trade and Industry Resolution No. 348 of 2022 was issued regulating the conditions, rules and procedures for licensing accreditation offices. The committee included in its formation two representatives of the Federation of Industries, and it has already held two meetings.
• The guideline issued by the Authority, which includes a detailed explanation of all provisions related to accreditation offices, is being reviewed.

• Drug pricing policies are not compatible with general economic changes such as currency rate, inflation, rising energy prices, rising operating costs and interest rates, etc.
• The current system relies on a mechanism to guide drug prices in 36 countries, so that it chooses the lowest price for the public in these countries, which does not take into account the distribution margins established in this country and their comparison with Egypt. This system needs a new review so that it adapts to new changes and drives investment in the pharmaceutical industry.

• Reviewing the pricing policy in line with the requirements of the global market and its pricing mechanisms so that export mechanisms are activated in a way that is commensurate with the size and capacity of the pharmaceutical industry in Egypt.
• All generics are priced at 65% of the price of the original product (patent owner) for new CTD registrations.
• Adopting pricing for registered products and giving priority to alternatives and deficiencies in the market.
• Speeding up the pricing of registered medicines, even if their notifications have expired, and those that have not yet been marketed and were priced before the float of the pound.
• Abolishing the value-added tax on pre-mixed and prepared pharmaceutical raw materials of two or more materials, so that they are subject to customs item 3003, with a 2% customs duty category, in addition to being exempt from value-added tax, and not subjecting them to customs item 3824, a 5% customs duty category, in addition to 14% value-added tax.

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• “Problems of customs release for pharmaceutical industries:
• The periods specified for release from ports range between 4-6 days on average or more depending on customs capacity or in the event of any problems in the system or following official holidays.

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• National Authority for Drug Safety Monitoring:
• It was proposed to establish a body to monitor drug safety, and it was established in 2019, but there are some obstacles in dealing with it, including the following:
• Requiring import approval for every shipment of raw materials that is imported, which leads to an increase in the price of the product as a result of increased duties.
• Extreme delay in issuing Free Sale and GMP certificates, which negatively affects the export process.
• The Central Administration for Pharmaceutical Affairs refused to receive trading certificates for non-sterile products issued by the Industrial Development Authority and arriving by express mail.
• Requiring new approvals for export conditions, such as pledging to provide production raw materials for a period of 6 months, visiting committees to confirm, in addition to obtaining the approval of the General Authority for Unified Purchasing.

• Eliminate the requirement to obtain import approval for each raw material consignment separately.
• Expediting the issuance of Free Sale and GMP certificates.
• Refrain from issuing new export conditions without consulting exporters.

• Law No. 151 of 2019 was issued and included the new law regulating pharmaceutical entities (Article 14):
• A public service authority shall be established to be called (the Egyptian Medicine Authority), which shall have a legal personality, report to the Prime Minister, and shall have a main headquarters determined by a decision of the Prime Minister. Other headquarters may be established by a decision of the Authority’s Board of Directors.
• The Authority aims to organize, implement, and monitor the quality, effectiveness, and safety of the medical preparations and supplies stipulated in the provisions of this law. It is based on implementing the provisions of the applicable law for practicing the pharmacy profession - in a manner that does not contravene any of the provisions of this law - and it assumes all the powers, competencies, and legal actions necessary for that.

• The box system is being abused by international companies producing patented medicines, as the collectively owned boxes are filled with fake products, which disrupts the competition of local companies and hinders the sale of medicines at an economical price.

• Abolishing the box office system and allowing Egyptian companies to produce and register communally owned medicines.
• Finishing the registration of preparations that are still in the various stages of registration within a period of two years.

• Ministerial Resolution No. 654 of 2018 was issued, stipulating:
• Accepting applications for registration of medicines in excess of the number specified in the similar fund referred to in Resolution No. 425 of 2015, in specific cases, which are preparations included in the lists of drug deficiencies that have no counterpart during the previous year from the date of the current decision, or that are determined by the Central Administration for Pharmaceutical Affairs according to market needs.

• Registration of new medicines takes a long time despite obtaining approval and licensing from developed countries and is considered a reference for drug testing.

• The immediate approval of the pharmaceutical product is sufficient if there is registration in at least two developed countries in the pharmaceutical industry.
• Converting the registration of Egyptian pharmaceutical factories to the CTD system (complete technical file) for a fee of 120 thousand pounds, not taking into account the box system and the registration period being less than six months without a maximum number of files per month.
• The factories obtain international accreditation from the FDA, WHO, GTA, EMEA, and a period of five years is given after which registration is not accepted for factories that do not have accreditation.

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• ♦ Failure to properly implement the provisions of Law No. 15 of 2017 regarding facilitating procedures for granting establishment licenses
• Industrial, as stated in Article No. (2), the last paragraph regarding the Industrial Development Authority issuing
• Licenses for industrial establishments in accordance with the provisions of this law and its executive regulations without the need to obtain
• Approval of any other party in accordance with any other law.
• ♦ Industrial facilities in the cosmetics industry are subject to the notification system for industries
• Low risk according to Law No. 15 of 2017.
• ♦ A cooperation protocol was signed between the General Authority for Industrial Development and the Egyptian Medicines Authority, which led to
• The Medicines Authority is strict and creates obstacles and difficulties that lead to industrial facilities not obtaining...
• Industrial licenses are necessary in the cosmetics industry, which leads to an increase in the third-party sector
• Official in this industry.

• The importance of returning to correctly implementing the provisions of Law No. 15 of 2017 by the Industrial Development Authority issuing
• Licenses for industrial establishments in accordance with the provisions of this law and its executive regulations without the need to obtain
• Approval of any other party in accordance with any other law.
• ♦ The importance of creating a system that is consistent with the rules of international systems, apart from drug industry licenses.
• ♦ Activating the role of accreditation offices.

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• The Value Added Tax Law singles out the cosmetics industry with two taxes within the same law (a schedule tax of 8% and a general tax rate of 14% applied to the price including the schedule tax). This is a constitutional violation, as a tax is applied to a tax.
• This measure prevents increased investments in this industry and creates a parallel informal sector. It also does not guarantee the encouragement of labor-intensive economic activities and the stimulation of their role in economic, social and cultural development, in violation of Article No. (38) of the Constitution.

• Making legislative reform by amending the value-added tax law for correction.
• The applied value-added tax becomes only 14% to allow deduction of the value-added tax paid on production inputs.

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• A double value-added tax (tax on tax) is applied to the detergents and soap industry, where a 5% schedule tax and a 14% tax are applied to production inputs.
• The table tax does not allow deduction of value-added tax on production inputs, and therefore the value-added tax applied in the detergent and soap industry becomes 5% in addition to 14%, which hinders the growth of this industry and leads to resorting to imports, as this industry does not bear more than 5% on the finished product.

• Making legislative reform by amending the value-added tax law for correction.
• The applied value-added tax will be only 14% to allow deduction of the value-added tax paid on production inputs.

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• Applying a lump sum tax on kohl, which is considered the backbone of the perfume industry, which led to the industry fleeing to other countries (such as the Jebel Ali region)

• Abolition of this tax on the production input, as the tax is paid on the finished product.

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• The importance of reviewing the value-added tax registration limit, as it does not achieve tax justice.

• It is necessary to review the registration limit, as it does not achieve fairness in the tax and helps in evasion, and to encourage companies to issue official invoices for more than 500,000 pounds, and to encourage suppliers of raw materials and service providers to issue invoices for their sales.

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• Weak role of agricultural extension entrusted with guiding farmers during the entire production process.
• Weak financial resources for agricultural research centers.
• There is a severe lack of R&D investments directed towards improving this sector.
• The Veterinary Authority not only accredits and inspects the factory that produces animal products in other countries exporting to Egypt, but also requires attendance at every operating session, even in countries known for their adherence to slaughter rules, such as Saudi Arabia.

• Developing agricultural technical education and motivating students to join it.
• Raising allocations for research in the field of agriculture to improve productivity per acre in important crops such as cotton and to develop agricultural breeds.
• The veterinary authority should be satisfied with examining and approving the factory producing animal products in other countries exporting to Egypt, and there is no need to attend every operating session.

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• Failure to implement the food safety system and adhere to international standards and specifications. Weak pesticide tracking system on farms.
• Excessive use of inorganic pesticides.

• Imposing deterrent penalties on violating companies, such as prohibiting them from exporting for a certain period, imposing a large financial fine on them, and depriving them of obtaining export support.
• Coding and approving farms for export and the local market.
• Expanding the establishment of specialized laboratories for pesticide residues.
• Reconsidering the Seed Committee to keep pace with export requirements through a more effective mechanism, as is applied in other countries.

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• The MTS system does not implement the risk analysis system for food imports specified by the National Food Safety Authority and conduct 100% analysis of incoming messages.
• Delay in the customs clearance process, as well as high costs and payment of fines in foreign currency to international shipping companies.

• Activating the Prime Minister’s directives to expedite customs release and MTS’ application of the National Food Safety Authority’s system for risk analysis of imports (raw materials in particular).

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• Poor access to appropriate financing sources and credit lines in financial institutions to ensure that food establishments comply with food safety requirements.
• The inability of companies to comply with food safety requirements and thus produce safe and sound products, as well as poor access to local and global markets.

• Adopting a special initiative to finance food establishments with the aim of complying with food safety requirements.

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• Issuance of Egyptian Medicine Authority Resolution No. 572 of 2022, which includes the following:
• In Article Two of the aforementioned decision, a definition of “complementary medical preparations” was not stipulated in Law Establishing the Authority No. 151 of 2019.
• Article Three: Complementary medical preparations are registered exclusively with the Egyptian Medicine Authority. Article Four includes limiting the authorization to trade complementary medical preparations within pharmaceutical facilities to products registered with the Egyptian Medicine Authority.
• The texts of the decision lead to contact with the aforementioned preparations and some products registered under special foods and registered with the National Food Safety Authority in accordance with Authority Resolution No. 1 of 2018, such as foods designated for medical conditions and foods prepared for people with special physiological needs.
• The economics of companies are affected by the lack of supply in pharmacies.
• Losing the opportunity to compete for export, as the term complementary medicine is not recognized in any Arab or European country.
• Exporting a product bearing the word "medicine" itself requires time and exorbitant costs far greater than what it takes to export a product bearing the word "food supplement".
• Sending a negative message to investment in Egypt in this field.

• Reconsidering the aforementioned decision of the Pharmaceutical Authority and not duplicating jurisdiction with what the National Food Safety Authority registers in accordance with international legislation for special foods, including regular nutritional supplements or for special medical purposes.
• The continued display of nutritional supplements, baby formula, etc., in pharmacies according to what is currently in place.

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• Losses from agriculture are approximately 30%, largely due to inadequate supply chain and logistics, as well as inefficient farming methods.

• Establishing logistics hubs across Egypt to improve the supply chain for agricultural products.

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• The General Authority for Veterinary Services issues import approvals for products of animal origin before importation as a condition for importation from the authorized origin.
• Wasting effort, time and resources in issuing approvals.

• The role of the General Authority for Veterinary Services, in accordance with its establishment decision and in accordance with the Agriculture Law, is to inspect imported and exported live animals to inspect them to ensure that they are free of diseases. The following is proposed:
• Cancellation of import approvals because they are limited only to determining the epidemiological situation of different regions in accordance with notifications from the World Animal Health Organization (OIE), and it is sufficient for the Ministry of Agriculture to announce the countries and regions from which imports are prohibited.
• Amending Minister of Agriculture Resolution 47/1967 to limit the application of veterinary approvals to live animals and poultry, and not to meat, poultry and fish.

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• Delayed disbursement of dues for export support.
• The lack of the necessary resources for companies, which affects the cash flows necessary to continue production operations and export to foreign markets, which negatively affects enhancing the competitiveness of Egyptian products in global markets.

• Speeding up the disbursement of export support dues as soon as the documents are provided, without any deductions, within a period not exceeding three months, and automating the procedures to quickly return the dues.

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• Lack of regular land and shipping lines to connect Egyptian ports to African and Arab countries.
• The delayed arrival of raw materials produced in African countries to Egypt (tea, coffee, cocoa, grains, etc.) and the delayed arrival of products exported to those markets. It also leads to an increase in the cost of products as a result of the irregular flow of trade exchange between Egypt and those markets, in addition to negatively affecting the competitive advantage of Egyptian products.

• Availability of regular land and shipping lines to connect Egyptian ports with African and Arab countries

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• The legislative framework regulating the food sector includes provisions that are restrictive in nature, which imposes unjustified restrictions on investment activity and creates a regulatory climate that is repulsive to investment, which negatively affects the attractiveness of the food industry sector and limits the state’s ability to attract new local and foreign investments.

• Expediting the issuance of a draft law amending some provisions of Law No. 1 of 2017 establishing the National Food Safety Authority, which was approved by the Industry Committee of the House of Representatives, and is subject to presentation to the General Committee of the House. It includes abolishing freedom-restricting penalties for food violations, and being limited to administrative and financial fines, with the exception of serious cases that result in death or permanent disability.
• This amendment is consistent with international best practices that aim to reduce custodial penalties for non-serious economic and administrative crimes.
• The law supports the state’s move towards improving the business environment and providing an attractive and balanced investment climate, while ensuring continued effective control over food safety.

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• Imposing new tax burdens and pressures, which represent a constant source of concern for investors, due to the resulting direct increase in production costs and its impact on commodity prices, which negatively affects the competitiveness of the industrial sector and increases the burdens on the final consumer.

• Maintaining the stability of tax policies and not imposing new burdens that may affect the competitiveness of investment or the purchasing power of the consumer.

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• The food industries suffer from high transportation costs and an increase in the percentage of losses in agricultural raw materials as a result of the distance between agricultural production and manufacturing areas, and the weak efficiency of the trading and logistics system, which affects the quality of products and the cost of production.

• Expanding the establishment of industrial complexes near agricultural areas, similar to the raisin production complex, developing the efficiency of the food circulation logistics system and updating the necessary legislation.

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• Exporters face challenges in accessing new markets as a result of limited organized promotional activities and insufficient institutional coordination to open alternative and sustainable markets for food exports.

• Preparing plans to promote and open new markets for food exports in coordination with the Chamber, export councils and trade representation.

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• The customs clearance time still represents a burden on the production process, resulting in an increase in the cost and regularity of the production process and the factory bearing late fines and fees paid in foreign currency to foreign shipping companies, especially for raw materials and production requirements of an industrial nature.

• More efforts are being made to reduce the customs clearance time for raw materials and production requirements based on the principle of risk analysis, to reach 2 days from the current 3.6 days.

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• Some food industries suffer from the lack of agricultural varieties that meet manufacturing and export quality requirements, which limits the ability to meet the requirements of foreign markets.

• Expanding the cultivation of varieties suitable for manufacturing in an economical manner in accordance with quality requirements and export markets.

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• Dual controls on exports:
• 1. Exporting fish factories: subject to the supervision of the National Food Safety Authority and the Lakes and Fish Resources Protection Agency.
• 2. Table salt Source: Subject to the supervision of the National Food Safety Authority and the Mineral Resources Authority.
• 3. Gelatin: Food-grade gelatin continues to be subject to unjustified regulatory exposure within Appendix (8) of the Import and Export Regulations.
• 4. Materials in contact with food: Subject to the supervision of the National Food Safety Authority and the General Authority for Export and Import Control.
• Duplication of oversight of food establishments and markets:
• Food establishments and markets continue to be subject to the supervision of more than one entity in violation of the provisions of the Law Establishing the National Food Safety Authority No. 1 of 2017, which leads to overlapping jurisdictions and duplication of inspection procedures, and places additional burdens on establishments.

• Limiting the presentation of exports and imports of food products to the National Food Safety Authority in accordance with its establishment law No. 1 of 2017 to speed up the export and not offering it to any other party in order to avoid duplication of control and obstruction of the export process.

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• The inadequacy of the current systems for receiving investor complaints in achieving the required rapid response and transparency, with the absence of binding legal periods for adjudicating complaints, which affects the stability of investment projects.

• Further activation of the system for receiving and processing investor complaints through a unified electronic investor support unit affiliated with the Ministry of Investment, so that it relies on digital mechanisms that ensure the speed of receiving and responding to complaints and the immediate benefit of companies, with maximum legal periods for deciding on complaints and directing them towards appropriate solutions.

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• Food projects suffer from limited incentives for green transformation and sustainable production, as well as the high cost of financing for export projects, which weakens their ability to expand and keep pace with the environmental requirements of international markets.

• Providing targeted investment and financing incentives for projects that apply sustainable production practices, green transformation, and export-oriented projects

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• A unified food law has not been issued yet.

• A draft law amending the provisions of the National Food Safety Authority Law No. 1 of 2017 and the laws regulating food handling (Law No. 92 of 2018 regulating and encouraging the work of mobile food units, the Public Stores Law promulgated by Law No. 154 of 2019, and Law No. 48 of 1941 suppressing fraud and deception) is one of the most important laws that help the National Food Safety Authority after reviewing the practical application of the law they created, which resulted in some challenges that... Without the Authority fully fulfilling its duty to confront harmful practices in the field of food handling.
• The explanatory memorandum for the draft law included several important points, including, for example:
• Unifying the body responsible (which is the Authority) for issuing trading licenses instead of multiple licensing bodies, while allowing a period to reconcile the situation.
• Prohibiting the circulation of food in certain circumstances, such as if it is adulterated, of unknown origin, unfit for human consumption, or violates the technical rules issued by the Authority.
• Identifying harmful foods and not stopping them in the short term (cases of diarrhea and food-borne diseases), but rather taking into account the accumulated toxic effects and the potential effects on offspring and cases of health allergies for some groups.
• Penalties for food handling violations include micro-enterprises (street vendors), then small and then medium-sized enterprises, which represent more than 95% of food establishments already registered with the Authority.
• The benefit from the application of this law was not limited to the food field only, but also extended to the investment sector, which includes eliminating the parallel economy, providing a climate and procedures that help attract investment, and applying fair rewards and punishment in a way that suits establishments according to the available capabilities.

• The executive regulations of the Food Safety Authority Law were issued and published in the Official Gazette on February 18, 2019.

• The Food Safety Authority needs more measures to ensure its independence and effectiveness in order to effectively carry out its role in monitoring all forms of food handling in Egypt, and to end all forms of overlap in jurisdictions with other administrative bodies.

• The Authority is still facing many challenges that need conclusive solutions, the most important of which is the lack of a main headquarters for the Authority, as the Authority was established in 2017 to assume the powers of the regulatory authorities located in ministries, public bodies, government departments, and local administration units with regard to monitoring the handling of food in legislation related to food safety, and for those working in food control in those authorities to be transferred to it. The Authority’s law stipulates that its headquarters be in Cairo Governorate.

• The executive regulations of the Food Safety Authority Law were issued and published in the Official Gazette on February 18, 2019

• Obstacles in transportation and storage.

• A final moratorium on the use of all kinds of earthen crops in storing local wheat and all types of grains to preserve wheat from contamination and waste.
• Excluding private wheat and flour transport vehicles from ration mills from the decision to ban heavy transport on the ring road and in some governorates to provide strategic funds for the mills’ production units, to provide a loaf of bread to the citizen.

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• Stopping the construction of new mills in the sector by 72%.

• Stopping the construction of new mills in the 72% sector to regulate the use of idle capacities for a period of ten years, and it will be reconsidered in case of need.
• Including 72% fine flour and coarse bran (excrement mixture) in the export support system provided by the state to encourage export and investment for the purpose of increasing the state’s hard currency resources.

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• Percentage of acid insoluble ash for flour extraction: 82%

• Adjusting the percentage of acid insoluble ash for flour extraction from 82% to 0.20% instead of 0.15%, which reduces the irregularities of acid insoluble ash. It does not affect the final product, according to Standard Specification No. 1251/1 of 2015.

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• Use flour number 2 in mills.

• Expanding the addition and use of No. 2 flour in mills due to its high nutritional value (protein - vitamins - nutrients).

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• Continuing the development of the flour milling system 87.5%

• Developing the milling system producing 87.5% flour.
• Continuing to update machines and equipment to obtain a good final product of flour.

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• The absence of a regular shipping line for food commodities to Arab and African countries.

• Providing a regular shipping line for food commodities to Africa and Arab countries to facilitate transportation and trade exchange with African and Arab countries.

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• Although there is only one center in the sector for developing manufacturing technology and fashion, affiliated with the Ministry of Trade and Industry, the sector needs many technology and fashion centers that aim to raise the level of quality and develop production technology.
• The problem of shortage of qualified workers.

• Providing allocations to establish training and technology development centers that help the industry compete with global products.
• Expanding the establishment of leather industry departments in industrial secondary schools and vocational training centers, granting incentives to students attached to these departments, and studying the possibility of training them to work in factories after agreeing with the owners of major factories to contract with them to work.

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• The unjustified increase in imports of shoes and leather products that do not meet standard specifications. Import invoices are manipulated by some importers, as fictitious invoices are presented at low prices that are not commensurate with the production costs in the exporting countries. Although indicative prices are applied to some imports of shoes and leather products, some importers have placed imports of shoes and leather products on sub-customs items to which indicative prices are not applied.

• Reviewing the current indicative prices on the basis of which imports of shoes and leather products are released, and the Customs Authority taking the indicative prices prepared by the Chamber in light of the actual costs of manufacturing shoes and leather products, on the basis of which customs duties can be determined in light of importers submitting incorrect invoices.
• There is subsequent oversight of local markets to reduce this dangerous phenomenon, which could lead to the collapse of this important industry.

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• The problem of faltering and completely stopped factories and how the Ministry can support them to return to production.
• The problem of leather smuggling by circumventing ministerial decisions regulating the export of leather.

• Tightening control over customs ports, free zones and transit.
• Criminalizing smuggling and considering it a crime against honor.
• Confiscation of seized goods, applying the provisions of Article 15 of Law No. 118 of 1975.
• Stopping the export of leather prior to the full finishing stage.
• Support promotional missions.

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• Failure to provide qualitative support to the leather industry sector to develop the leather industry and its exports.

• Providing export support for the costs of bringing in foreign marketing experts to help increase the sector’s exports.
• Providing export support for the costs of bringing in foreign fashion and quality experts to help develop and modernize the products of the leather industry and raise the level of quality.
• Changing the rules for supporting exhibitions and promotional missions for leather products in particular to suit the nature of the sector.
• Cooperating with state-owned companies to provide goods available in some African countries, maximize the presence of Egyptian products, and increase their exports.

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• Irregular presence of workers due to the apartments not being delivered to the craftsmen yet.

• Speed ​​in delivering labor housing to industrialists.

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• Not starting the construction of the infrastructure for the second phase to allocate and accommodate facility owners in the Laayoune stream in the city of Roubiki.
• Irregular water service in the city of leather, Rubiki.
• Irregular drainage service in the city.

• Completing the infrastructure of the city of Rubiki and quickly equipping and rehabilitating it so that it becomes an attractive center for investment in the field of the leather industry.

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• The competent authorities have not yet issued permanent operating licenses for factories, which are considered important documents for dealing with banks

• Issuing permanent licenses to factories in the city of Roubiki, especially since it has been two years since the factories moved from Mawr El-Ayoun.

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• Moving from Mawr El-Ayoun to the city of El-Roubiki was very expensive for the factory owners, as they imported many modern machines and equipment, in addition to the expenses related to installing water, gas, and electricity.

• Alleviating the financial burden on workers in this sector by disbursing their entitlements to support exports so that factories can continue working and export abroad.

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• Lack of interest in livestock and the skins extracted from them
• Lack of interest in developing the leather tanning industry and providing the raw hides it needs
• Failure to provide qualitative support to the leather tanning industry sector to develop the leather tanning industry and its exports.

• Paying attention to livestock, paying attention to the condition of the skin, and developing laws for the trading of raw hides (distributing serums to combat lumpy skin and foot-and-mouth disease).
• Establishing special free zones for tanning factories and simplifying procedures to facilitate this and enable the tanning sector to compete with existing free zones.
• Supporting the export of crust and finish exported from the leather area in Rubiki by at least 10% in order to compensate them for the high expenses in this region.
• Opening the import of white blue in the form of a temporary permit and drawback in order to fill the gap of lack of raw materials and also operate the city’s idle capacities, and supply the sector with good hides due to the poor condition of the skin in Egypt, and to fill the deficit that occurred after gelatin factories competed with the leather tanning sector in purchasing raw hides.
• Speeding up the establishment of dry customs warehouses, similar to Italy’s, for leather and chemicals, which helps the city speed up production and export speed (making Egypt the hub of the Middle East for leather, like Italy).
• Speeding up the operation of the technology center in order to help small exporters produce well and perform the necessary analyzes according to the specifications required globally.

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• Imposing a fee for the electrical load (fixed installment) was estimated to be less than 25% of the value of consumption. However, in the case of the metal foundry industry (where smelting takes place within a day and finishing within a week) as well as factories that are forced to stop, this fee has become equivalent to many times the value of the actual consumption.

• Amending this fee by setting a maximum of 25% of consumption, which benefits the metal foundry industry and factories that stop production for any reason without prejudice to the competitiveness of other industries.

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• All factories that requested to add electrical energy above 500 kilowatts paid generation fees equivalent to 550 pounds per kilowatt for low voltage up to 3000 pounds per kilowatt for high voltage. This differs from the existing factories before that, which disrupts the competition between new and old producers. (Large factories need 100 megawatts, and the amount reaches 300 million pounds.) There is no difference between the price of purchasing kilowatts after that, between those who paid for the cost of the generating station and those who did not pay.

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• The matter was presented to the Ministry of Electricity and the Council of Ministers, and so far the matter is being studied and no decision has been taken, which disrupts the competition between new and old producers.

• Auctions for the value of licenses for heavy industries are inconsistent with the plan to increase exports, which means producing more than needs and benefiting from the comparative advantage in the availability of energy and gas (at a lower price than the countries that import them), as they represent an additional burden and lead to a competitive imbalance between new and existing ones.

• Canceling the system of license auctions for heavy industries.

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• There are errors in classifying companies as energy-intensive industries, as wire and nail drawing factories, cast foundries (iron), and aluminum forming are treated at energy prices the same as steel and aluminum smelting complexes in terms of consumption intensity.

• Previously, committees were formed in the Industrial Development Authority, and their recommendation to define intensive industries as not depending on the type of product was not taken into account.

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• Fraud in the export of scrap metals, especially copper, aluminum, and lead, and its impact on small industries that use them, and the connection of fraud and smuggling activity to the price of the currency locally and the prices of the metals exchange externally.

• Tightening control and using modern inspection devices at customs.

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• The problems of the precious crafts and jewelry sector with customs, taxes, banks, and the Stamp Authority. Setting any fees as a percentage of the value may be valid for all products except gold, where its value is very high and the profit percentage (workmanship) is low.

• It is proposed to restructure the stamp service, restore its subordination to the industry, and review its relationship with manufacturers and merchants to save the sector that has lost its markets and credibility abroad due to the widespread phenomenon of fraud and with customs procedures that limit the export of crafts and the ease of exporting raw materials. It is required to solve all bureaucratic obstacles.

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• Although more than 20% of Egypt's non-petroleum exports are from the metal industries sector, the sector (large and small) is deprived of support or refund of burdens upon export, which confirms the absence of the objectives of this support and its impact on the state, while the support represents support and strength for the exports of China, Turkey, America and many countries.

• Review the export support plan.

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• Although the selection of land for each industry was done by the Development Authority and within industrial zones, fees in the millions are required to permit heights (more than 15 metres), and approval is also required from the Civil Aviation Authority, which requests a cadastral raise (thousands of pounds for each factory) to obtain a building permit from the Authority.

• Review the conditions and fees for civil aviation approval.

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• Insurance is paid on account of the estimated gas consumption for two months (a few tens of millions). Accounting is done on the contracted quantity, not the actual consumption. If the consumption exceeds the contract, it is paid at double the price.

• Accounting is based on the actual quantity consumed and not on the contracted quantity.

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• After the discovery of many gas fields, the quantities discovered and Egypt’s share in them exceeded consumption. It is known that according to gas exploration and extraction contracts, the state has the largest share, which is estimated at about 80% of the volume of extraction without compensation, and the investor has 10% to recover the value of the investments until their completion and 10% as a return to the investor. The average cost of one million units of gas in the national grid is less than $2, which is a fixed value that is not affected by international prices.
• Selling gas to industry at cost + a small profit margin allows the state to benefit from the competitive advantage of its products from gas-based industries such as cement, iron, ceramics, glass, and fertilizers, and opens the way for those industries to fully exploit their production capacity and direct it to export after those capacities exceeded the limits of domestic consumption and doubled, which led to that industry bearing financing burdens and the consumer bearing high prices due to the high cost.

• A unified price for gas for all consumers, knowing that in all parts of the world the price decreases as consumption increases
• Gas price is the cost of gas in the network + a small profit margin
• Reducing the price of gas supplied to electricity generating companies in order to reduce electricity prices, as gas constitutes 70% of the generation cost
• After the availability of gas and the interconnection of the digital network for production and consumption, it is required that the contractual relationship between the consumer and gas companies be direct, without the need for the Industrial Development Authority, and that accounting be for the quantities actually consumed.
• All industries that use coal as an energy source are allowed to switch to using gas.

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• The conflict in imposing value-added tax on inputs, especially scrap metal and paper pulp, and requiring it to be paid by the purchasing factory, even if it was paid by the selling scrap dealer.
• Complex procedures with taxes to recover the added value paid upon export and withholding large liquidity resulting in financing burdens. At the same time, the taxes are demanding their income, business gain, real estate, or stamp tax, and they refuse to set off between their money and what they owe while awaiting the completion of the company’s tax examination to date, which is something that cannot and will not be done.
• According to the law, 1% of the value of raw materials imports is paid under the account of discount and addition to taxes, even to companies that make losses, which has led to hundreds of millions being paid to them in the finances.
• Requiring the payment of value-added tax on raw materials and investment equipment, despite judicial rulings invalidating this, still represents a burden on investors because it withholds large sums of money from taxes before starting work.
• Imposing real estate taxes on factories in a complex manner on revenue-generating assets subject to other types of taxes, including income, stamp, and value-added taxes.
• Collecting the added value in its three parts from the jewelry factories with the knowledge of the Stamping Authority at the time of stamping and before selling, and not recovering it once the jewelry is returned to the factory, which resulted in manipulation due to not resorting to the Stamping Authority.
• Bureaucratic procedures in dealing with the gold and jewelry industry, starting with the subordination of the Gold Stamping Department to the Ministry of Supply, the subordination of licenses and exhibitions to the Ministry of Industry, the subordination of export procedures to airport customs, and the imposition of valuation fees on exports, which led to the export of gold bars and bullion that are better than value-added artifacts, which lose their competitive ability because of these fees and expenses.
• Administrative complications when entering gold jewelry legally despite not banning it, and with the abundant supply of imported jewelry in the markets (Italian, Gulf, and Indian jewelry), the quantity of imports according to the data of the statistics agency or import control is limited, which disrupts competition.

• Eliminate the value-added tax on raw materials and investment equipment.
• Reducing the mentioned bureaucratic procedures

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• Financing problems with banks, starting with the high borrowing interest rates compared to their European counterparts, low credit ceilings compared to operating costs, and finally the conditions for proving credit worthiness.
• The complexity of conducting feasibility studies for small and medium industries to finance new projects and the focus of banks on financing expansions of existing projects, most of which are for non-productive or industrial sectors.
• The impact of alternative investment opportunities in the form of certificate returns is still higher than industry returns (with industry problems). Therefore, many medium and small industries preferred to convert current assets and operating expenses into deposits and temporarily stop activity, which led to conflicts in the numbers of stalled and faltering factories.
• The increase in savings during the year 2018/17 amounted to about one trillion pounds (Central Bank data), meaning
• Withdrawal of liquidity, weak purchasing power, slowdown and stagnation in sales of all non-food commodities
• Although dealing in gold is like dealing in currency, the Central Bank prohibits banks from dealing in raw gold with factories, lending and recovering, or allows foreign banks that deal with gold abroad to deal in Egypt in order to remove from the factories the risks of changing the price of raw materials during operation and pay for manufacturing instead of trading.

• Reconsidering the financing system and issuing an integrated system to avoid the problems contained therein
• Speedy correction in industry taxes while expanding the umbrella of taxes to include all economic activities.
• Providing, within the initiative to treat troubled factories, the necessary liquidity to operate with minimal burdens and simplification
• Measures where this cost doubled with the adjustment of the currency price as of 2017 and led to the cessation of many factories.

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• The nitrogen fertilizer industry faces challenges and problems as a result of the high price of energy, despite it being one of the most important Egyptian industries, as the total investments in this sector amount to about 200 billion pounds and it employs about 50 thousand workers. It is worth noting that natural gas is an essential input for production in the nitrogen fertilizer industry (about 75-80%) of the cost of fertilizer production.
• But the price supplied to nitrogen fertilizer plants was fixed between 2014 to 2020.

• Reducing the price of natural gas supplied to the nitrogen fertilizer industry to reach $3/million British thermal units.
• Working with the price equation linked to urea prices, similar to what was done with some Egyptian companies.

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• Unfair competition from imported finished products in the wood industry.

• Preventing the import of finished furniture (finished product).

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• Weak competitiveness of Egyptian exports
• Egyptian furniture exporters face strong competition from countries such as China and Turkey, which have comprehensive and integrated export support programs that include shipping support, foreign promotion, and the establishment of specialized export entities, while Egyptian exporters suffer from limited support programs and delayed payment of their dues, which has led to the loss of important market shares, especially in African markets and high-risk markets.

• The program to support shipping to Africa continues by no less than 80%.
• Speedy disbursement of export support dues.
• Studying the establishment of national companies specialized in exporting and promoting Egyptian products along the lines of successful international models.

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• Poor presence in exhibitions and international trade missions
• The sector suffers from the absence of a unified identity for Egyptian furniture in international forums, in addition to the noticeable decline in the number of companies participating in exhibitions and trade missions, especially buyers’ missions and the less expensive and more effective exploratory missions, in light of the lack of funding for the cost of consultants accompanying those missions.

• Working to build a unified identity for the Egyptian furniture sector.
• Support the cost of consultants in trade missions and buyers' missions.
• Speedy response of support to companies participating in international exhibitions.

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• The role of commercial representation offices has declined
• Decrease in the number of Egyptian commercial representation offices abroad, despite their pivotal role in promoting exports and supporting exporters.

• Study of re-expansion of commercial representation offices.
• Providing regular communication channels between these offices and relevant bodies such as chambers of industry and export councils.

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• The role of commercial representation offices has declined
• Decrease in the number of Egyptian commercial representation offices abroad, despite their pivotal role in promoting exports and supporting exporters.

• Study of re-expansion of commercial representation offices.
• Providing regular communication channels between these offices and relevant bodies such as chambers of industry and export councils.

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• Strengthening and activating the role of technological centers specialized in the furniture sector. In light of the current role played by technological centers in the areas of technical training, testing, and knowledge transfer, there is a need to activate this role in a more comprehensive and more effective way, keeping pace with industry developments and the needs of factories, and maximizing the benefit of these centers as one of the main arms for developing the furniture sector.

• Moving from a limited training role to an integrated development role, so that technological centers become major platforms for transferring and localizing modern technology within factories, and not just training bodies.
• Providing sufficient and sustainable financial support that enables the centers to modernize the infrastructure, machinery and technical equipment, to reflect the latest global technology in the furniture industry.
• Linking training programs to the actual needs of factories and industrial development plans, with a focus on applied training and the use of modern machines.
• Activating the role of the centers in approving products and granting quality certificates in accordance with local and international standard specifications, in a way that supports the competitiveness of the Egyptian product in the local and export markets.
• Launching international twinning programs between Egyptian technological centers and their international counterparts specialized in the furniture industry, with the aim of transferring expertise, exchanging trainers, and updating technical curricula in accordance with international standards.
• Strengthening institutional coordination between technological centers, the Chamber of Wood and Furniture Products Industry, and factories, to ensure integration of roles and achieving the maximum possible benefit for the sector.

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• Relying on imported production supplies
• The furniture sector depends largely on the import of many production requirements, including manufactured wood, glue, paints, accessories, leather, metal products, machinery and spare parts, which increases the cost of production and exposes factories to the risks of exchange rate fluctuations.

• Expanding the establishment of local factories for furniture production supplies.
• Attracting foreign direct investment to industries feeding the sector.

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• Tax challenges:
• The most prominent tax challenges include the difficulty and speed of refunding value-added tax on exported production inputs, imposing arbitrary assessments, retroactive tax examination in violation of the law, and failure to differentiate between delays resulting from evasion and those resulting from disputes.

• Establishing a fast and effective system for refunding value-added tax to exporters.
• Eliminate arbitrary estimates and commit to relying on tax returns.
• Commitment to legal examination periods.
• Differentiating between cases of delay when imposing fines.

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• Customs challenges:
• These include poor professional handling of exported furniture shipments, lengthy export procedures for repair, and high customs duties on spare parts imported for production.

• Training workers at customs ports on dealing with furniture shipments.
• Facilitating export procedures for repair purposes.
• Customs differentiation between spare parts for the purpose of production and trade.
• Create a whitelist of committed factories.

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• Challenges in free zones:
• These include the complexity of entry procedures for production supplies, the difficulty of dealing with industrial waste, and the lengthy procedures for retrieving defective products.

• Simplifying procedures for dealing with free zones and facilitating the movement of inputs and outputs.

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• Finding financing and reducing its cost

• Urging the banking system to provide loans and short, medium and long-term financing while reducing the cost of financing.
• Study the conditions of troubled factories and find a mechanism to operate them at maximum capacity, whether by establishing a special fund for this purpose or finding another mechanism.

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• Obsolescence of machinery and equipment in the stages of textile industries

• Granting support and incentives to factories that import new machines and equipment in the stages of spinning, weaving, dyeing, printing, and processing, by deducting 50% from the tax due on them for a period of five years and 25% for ready-made clothing factories for a period of three years, in order to encourage raising quality and increasing production.
• Granting new expansions in existing factories and completely new factories a tax exemption for a period of ten years for the entire textile industries sector.

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• Weakness of the basic industry links of spinning, weaving, dyeing, printing, processing, and feeding industries.

• Attracting foreign and local investors to invest in these sectors, whether through individual projects or integrated textile cities.
• Encouraging the policy of establishing integrated textile cities, with the focus of their establishment being on the Delta and Upper Egypt governorates to increase their development rates.

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• Agricultural policy for cotton

• Expanding the cultivation of short and medium cottons instead of importing them.
• Continuing to grow long-staple cotton according to the quantities that we can export abroad and the needs of the local industry.
• Encouraging investors to invest in the field of clothing production from long-staple cotton.
• Allowing the import of cotton from all countries of the world and canceling the decision to import from specific countries.

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• Weak capabilities of the Industrial Control Authority to perform its role and calculate the percentages of loss for producers

• It is necessary to develop and modernize the Industrial Control Department using electronic and modern systems so that programs are developed that work to achieve justice and equality between exporters with regard to the proportions of perished and lost items.

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• Slow procedures for refunding export support and returning value-added tax to exporters

• Speeding up procedures to respond, whether for support or tax, and specifying a period of time not exceeding 90 days from the date of submitting all required documents, with the support being linked to the percentage of value added in the exported goods in accordance with the Egyptian rules of origin.

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• High production costs, especially gas prices, despite the fact that the textile industries are labor-intensive industries and the abuse of gas producing companies

• Reviewing gas prices and accounting for the textile industries sector with the same gas prices as brick kiln factories are accounted for.
• Reducing water prices for the textile industries sector, as it is an essential element of production in the stages of spinning, dyeing, printing and processing.

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• Labor shortage and weakness of technical institutes and schools for industrial and technical education

• Linking admission to industrial technical schools to industry-specific needs.
• Providing training centers and specialized industrial technical schools in all industrial zones, with the departments in them linked to the geographical distribution of industries in these cities and commensurate with the nature of the activity of each zone.
• Expansion through the Small and Medium Enterprises Development Agency by conducting training programs, as the agency is responsible for training centers.
• Coordination between the Chamber of Textile Industries and training centers so that the Chamber participates in the policies for preparing training programs so that factories can be prepared with skilled, trained technical workers.
• Coordination with the Chamber of Textile Industries to provide the necessary loans to support the sector. This vital role is compatible with the Small and Medium Enterprises Development Agency after amending the law relating to the agency.

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• The speedy formation of the advisory committee mentioned in the Mines and Quarries Law and its executive regulations and their amendments, and that the committee should have greater powers so that the implementing authority is committed to it in determining the rental value or royalty according to the circumstances of each case and that its opinion should not be advisory but rather binding. A decision must be issued by the Prime Minister to include those with experience and knowledge, and the need for it to meet at least 4 times annually, as stated in the law, to carry out its work of refining and developing the procedures that result from the application of the law and regulations (Ministry of Petroleum and Mining). For example: the copper royalty of 8% is considered a high percentage that will not attract any investor, which does not exceed 4% in the world, the confused and undefined position of the White Sands between mines and quarries, the royalty fees for shale petroleum.

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• The continuation of the work of the committee formed by a decision of the Prime Minister, headed by the Minister of Planning and membership of the Minister of Local Development, in order to develop a clear strategy through the accumulated chains of information in terms of the importance of the extracted raw materials and the added value, vertical integration, in accordance with the state’s priorities and needs, taking into account the factors of scarcity and abundance of these raw materials (because this is not within the jurisdiction of the Ministry of Petroleum or the Mineral Resources Authority). Rather, it is a state plan to maximize its diverse resources.

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• After the last gold auction was launched in March 2020, which is the auction that the state is counting on to put Egypt on the global mining map, and based on orders issued to the Mineral Resources Authority, 7 areas that are very distinguished in their geological formations, gold reserves, and gold mines previously produced from them were blocked due to their importance to military operations, and the request to assign these areas to the Shalatin government company, which is in the process of selling 51% (a ruling percentage) of them to a large investor, which harms Egypt’s reputation and credibility to a extent. Her commitment.

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• Stop imposing any fees or donations on the production and transportation of mines, quarries and salt ores outside the framework of Mines and Quarries Law No. 198 of 2014 and Law No. 145 of 2019 and their executive regulations (governorates, localities, roads and bridges).

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• Exempting mining, quarry and saltwater establishments from the application of real estate taxes in accordance with Article No. 18 bis of Law No. 23 of 2020.

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• Facilitating export procedures for mining, quarry, and saltwater products to prevent producers from charging ship delay fines that limit their production and competitive capabilities, and setting a time limit for issuing export approval, provided that the required documents are completed. It is imperative to reconsider the terms and conditions of export approvals in accordance with the actual reality and the obstacles that exporters suffer from.

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• Emphasis on the Environmental Affairs Agency to announce maps of sites where mining is prohibited, while alerting to the necessity of quickly issuing environmental approvals to licensed companies, while obliging operating companies to adhere to the controls and procedures established by the agency, as gold ores are exposed to theft by sleuths.

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• Facilitating the issuance of security approvals for exploration and extraction licenses, specifying the required documents in advance, and setting a time limit after the availability of documents that the responsible party adheres to in order to save the investor’s time, and extending the validity of the time approval (three years) instead of annual as long as the licensor has not issued any professional or security violation that prevents the continuation of the license. As a result of the delay in security approvals even for government companies working in the field:
• Poor reputation for attracting foreign investments, which represent the basic and most important element in the exploration system because they are high-risk investment capital.
• Ignoring the time factor often leads to missing investment opportunities.

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• Clay brick sector
• The sector suffers from licensing procedures, high costs, fines, and royalties, which led to the closure of most quarries, and the number of quarries in operation now does not exceed 15, despite the fact that the clay brick sector is an integral part of the construction sector, which represents more than 450 factories employing about one hundred thousand workers. These factories are spread throughout the republic, and its work is based on the quarry sector, as it consumes raw materials estimated at about two million cubic meters of clay per month and half a million cubic meters of sand from the quarries.
• High costs for Bahri and Delta factories in particular, which import raw materials from Giza Governorate, where the price per square meter reached 170 EGP/m3 after transportation, scales, cards, and transportation costs.
• South Giza factories suffer from daily restrictions on tractors, roads, transportation, the load imposed on them, and the inspection of quantities inside the factories. This has led to the cessation of many factories nationwide.

• Taking measures to reduce the pressure on the clay brick industry sector, in accordance with the problems mentioned.

• Issuance of Prime Minister’s Decision No. 2426 of 2021 regarding the formation of a committee from several parties headed by a representative of the Ministry of Trade and Industry. The committee is specialized in developing urgent solutions to the problems suffered by the owners of clay brick factories in the Al-Saf and Atfih centers in Giza Governorate.
• The committee shall prepare a report on the results of its work, recommendations, and implementation mechanisms within one month from its date, which the Minister of Trade and Industry will present to the Prime Minister in preparation for taking the necessary measures in this regard.

• Quarry sector/marble and granite:
• The quarry/marble and granite sector suffers from the lack of quarry materials and raw materials necessary to operate factories as a result of the reluctance of quarry investors to engage in this activity.
• The number of quarries decreased from 2000 quarries in 2020 to less than 300 quarries currently, which threatens to stop these quarries.
• Industries.
• The license renewal was delayed for more than five months despite submitting documents and renewal requests on time.
• An increase in the rental value, as the annual rental value (annual exploitation right) is calculated at 240 thousand pounds for marble and granite quarries for a period of three years in accordance with the Mineral Resources Law and its executive regulations.
• An increase in the annual rental value for new quarries (new raw materials only), as a period is set for exploration of quarry areas prior to licensing, from 3 to 6 months, to allow the licensor to ensure the presence of the raw material in economic quantities and appropriate quality, provided that after this period the licensee is billed with a rental value of 120 thousand pounds for the first year only.
• Royalties are not calculated on the actual weight of the car load, as they are based on the estimated weight based on the maximum unreasonable load (60 tons per car), meaning that it was not even in violation of the car license. The value of the royalty is also calculated at 15.20 pounds per ton of marble and 34.20 pounds per ton of granite, which is collected every three months.
• High quarry fees are paid even though the quarry is not operating due to circumstances beyond the company's control.

• Reducing the rental value, royalty value, minimum quantities and their value by a percentage commensurate with the current situation.
• Reducing quarry fees by no less than 50% of the current value.
• Reducing royalties by at least 25% of the current value.
• Royalties are calculated based on the actual weight of the car load.
• Exempting companies from quarry fees for months in which there is no operation whenever this is beyond the company’s control.
• Urging the Egyptian Mining Company to issue regulations for the company to clarify all work items in the quarry sector, such as: quarry licensing and renewal fees, violations that may be committed by the licensee and how to calculate them.
• Abolish the clause of negotiating with each quarry separately to achieve the principle of equality and implement the provisions of the law.
• Application of Article No. 85 of the executive regulations of the Mineral Resources Law to the Tshewin basins.
• Approval of the request to extend the quarry in order to facilitate the licensee’s work and to preserve the raw materials extracted from the quarry and to support the continuation of work in the quarry without interruption.
• Consider and approve requests for cessation if the reasons for cessation are technically sound and the licensee is not held accountable for the cessation period and dropped from the license period.

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• Quarry problems
• Low return on exploitation of marble and granite quarries (rental return + royalty return)
• Marble and granite exports declined due to a decrease in the quantities of raw materials extracted from quarries.
• Increasing imports of marble and granite to cover the demands of the local market and major national projects.
• High unemployment rate in this sector.
• Failure to provide investors with copies of the contracts they signed with the Egyptian Mining Company.
• In some quarries, upon starting operation, the licensee is surprised that the raw material is unsuitable or that the quarry material has many defects that cannot be used. The law and its executive regulations have permitted replacing the quarry in the event that it is unsuitable or the quarry material runs out.
• Requesting quarry owners who contracted for one year, and after the end of the contract period, did not apply to renew the contract for the quarry to increase the contract fees and the value of royalties and fines. They will be required to pay the annual contract value and be subjected to legal accountability.
• Duplicate collection of export approval fees from the Egyptian Mining Company and the Mineral Resources Authority.
• Despite the demand to reduce the rental value of marble and granite quarries, their value was raised in 1922 by 10%.

• Handing over to investors copies of the contracts they signed with the Egyptian Mining Company to serve as proof of licensing before official authorities such as banks and all concerned authorities.
• Collection of royalties every three months in accordance with the Mineral Resources Law and its executive regulations. Calculating the quantities extracted monthly by activating the system of scales to be established after 18 points.
• According to what was agreed upon in 2020 between officials of the Egyptian Mining Company and the Quarry Industry Division of the Chamber.
• The approval of the Egyptian Mining Company to contract for each Hosh Tshwain quarry whose area is four times the area of ​​the quarry, in accordance with the text of Article No. 85 of the executive regulations of the Mineral Resources Law, at an amount of 15,000 pounds to be paid annually.
• Approval of the quarry extension request to make it easier for the licensor and to preserve the raw materials extracted from the area, reduce the transportation period from the quarry, and reduce the costs of paving roads, new pistons, and transporting equipment, as the contract with the governorates allowed the quarry extension request to be accepted without stopping production and the continuation of the extraction process from the quarry.
• Considering and approving stoppage requests if the reasons for stopping are technically sound and not holding the licensee accountable for the stoppage period and dropping it from the license period, especially in the event that the material is discovered to be unusable upon start of operation.
• Failure to hold licensees whose contracts have expired accountable and offer their quarries for contracts with other investors
• Due to the difficult circumstances they are going through.
• Do not refer any violating contractors and quarry makers to the military prosecution, and only hold them accountable
• In the Egyptian Mining Company, applying the sanctions list against him, and canceling the referral clause to the prosecution
• Military from contracting with the company.
• Canceling the export approval from both the Egyptian Mining Company and the Mineral Resources Authority to ensure speedy exports and non-duplication of collecting export approval fees.
• Reaching radical solutions in renewing licenses and resolving the problems presented to the company two months before the end of the licensing period, which is 8/1/2022, as new licenses will begin on 10/1/2022.
• Scheduling the arrears of license fees and royalties for troubled licensed quarries without imposing late fines, while giving the investor the freedom to choose between continuing to work in the quarry or closing it, taking into account the estimation of fines in a clear, fair and not exaggerated manner.
• Decentralization of licensing in financial and administrative affairs to alleviate the suffering of Aswan quarry investors.
• Activating the company's headquarters in the governorates to avoid severe overcrowding at the company's main headquarters in Cairo.
• Consider signing a cooperation protocol between the chamber and the Egyptian company to serve as a framework for work between them.
• Activating the extension request submitted by the licensee without stopping work in the quarry.
• Simplifying licensing and renewal procedures, issuing an operating card to accompany the renewal application, and delivering secured books in the number requested by the licensee.
• Establishing a system that limits the licensee’s obligation to obtain financial information in all transactions with
• Company.

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• Ceramic factories do not benefit from the Central Bank’s initiatives in light of the Covid-19 crisis.

• Launching a special initiative to support the ceramic industry in Egypt, which includes energy prices in addition to financing tools that can benefit from it.

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• General problems
• Increased quarry costs and obstacles to their renewal.
• Shortage of gas supply.
• Excessive pricing and non-scheduling of installments for the Shaq Al-Tha'ban and Arab Abu Sa'id areas.
• Dumping duties on pipe factory raw materials
• The problem of documentary credits for the provision of raw materials

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• Ceramic industry problems:
• The main problems facing ceramic manufacturers are:
• The decline in exports as a result of the increase in the cost of production, due to the increase in the prices of most cost components: natural gas, transportation, quarry raw materials...
• The intense competition they face in the local market, which is filled with imported products.
• The ineffectiveness of the initiative presented to finance the ceramic industry with an interest rate of 15%, as many companies applied for the loan, but no one was approved due to the difficulty of meeting the conditions for obtaining the loan.

• Reconsidering the price of natural gas for the ceramic industry.
• Study of increasing customs tariffs on imported ceramics.
• Creating an initiative to provide the necessary financing to modernize production lines in ceramic factories and increase their viability on easy terms and a low interest rate.

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• Investment incentives are not attractive to investors (compared to the incentives granted by some countries close to us).
• High prices of lands allocated for industrial investment.

• Reconsider investment incentives to attract investors.
• Providing industrial lands at a competitive price at a price suitable for industry

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• Sanitary ware problems:
• Flooding the local market with imported sanitary ware as a result of the state allowing their import without any restrictions.
• Consultants’ reluctance to describe local products and their preference for expensive imported products.
• Decrease in sanitary ware sales in the local market as a result of decreased purchasing power.
• Some countries, such as Saudi Arabia, have transformed from an importer into a strong competitor to Egypt, attracting trained Egyptian workers to work in Saudi factories.
• High manufacturing costs: raw materials imported from abroad, energy, shipping and transportation... compared to international manufacturers.
• The price of gas is not fixed, as pricing is done at the daily price of the dollar, which is permanently variable.
• Difficulty in customs procedures for importing or exporting, which results in paying fines, fees, and guards, which raises the cost of production.

• Fixing the price of gas and not being linked to exchange rate changes.
• Establish a mechanism to reduce imported sanitary ware.
• Reducing customs release periods.

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• Problems with insulating materials:
• The main problem faced by manufacturers of insulating materials is the irregularity in obtaining their allocated quotas of the main raw material for that industry (bitumen 60-70) from the General Petroleum Authority.

• Obligating the General Petroleum Corporation to provide and disburse the prescribed quotas of the main raw material for this industry, which is (bitumen 60-70), to insulating materials factories on a regular basis.

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• Ceramics and glass problems:
• The main problem facing glass manufacturers is facing intense competition in the local market from similar imported products, which are sold at cheaper prices than the local product.

• Reconsidering the price of natural gas for the glass industry.
• Raising the customs tariff on imported glass types, the likes of which are produced in Egypt.

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• Hospitals face civil protection campaigns to comply with firefighting requirements, and in the event of any deficiencies, the Free Treatment is addressed regarding non-compliance with firefighting standards, which in turn issues decisions from the health affairs directorates to close the hospital without notifying the hospital of the deficiencies and giving it sufficient time to treat this deficiency and then re-examination.

• Giving hospitals time to address the shortcomings and then go through them again before issuing these decisions.

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• There are many requirements from the authorities responsible for the environment, which are the Ministry of Environment, the Environment Administration in the health directorates, and the Environment Administration in the governorates, and each of these bodies has different requirements from the other.

• Unifying these requirements and standards between the three parties.

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• Some value-added tax offices calculate the value of the value-added tax on the entire value of the contract without taking into account the exemption of insurance activity and health care costs from the value-added tax in the law, which has led to value-added taxes being linked to millions. These cases are before the judiciary and threaten to close these companies.

• Calculating the value added tax on the amounts specified for administration and estimated for each individual in accordance with the contracts concluded in which these amounts are recorded.

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• The General Administration does not require licenses for non-governmental medical institutions for health institutions
• With the Chamber’s membership certificate when renewing any license related to medical activity in the facility (radiology -
• Dialysis, physical therapy, blood bank, laboratory, any other activities).

• Requiring health institutions, when renewing any license related to medical activity, to submit a membership certificate from the Chamber of Health Service Providers in the Private Sector among the required documents

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• General problems:
• Overlap between the Industrial Development Authority and other entities in inspecting factories.
• Some chemical analyzes were delayed, especially in the interest of public security
• Failure to apply the reservation release system to incoming shipments of chemical raw materials.
• Delayed disbursement of export support
• Plastic industry:
• Lack of raw materials needed for production locally
• The volume of production of molds locally is limited
• Detergent industry:
• The spread of informal sector factories
• The allocated quantity of linear alkyl benzene is not sufficient for local needs.
• Glass industry:
• Lack of local production of soda ash, which is the basic raw material in the glass industry.
• Nitrogen fertilizer industry:
• Directing more than 70% of the natural gas produced in Egypt to power stations instead of directing it to the production of nitrogen fertilizers and petrochemicals.
• Paint industry:
• Unavailability of some raw materials locally, such as titanium dioxide and some dyes and colors.
• The procedures for exporting paints containing organic solvents are difficult and require the approval of the Petroleum Authority
• Paper and cardboard industry:
• Limiting the import of newsprint and magazine paper to press institutions to prevent its use in packaging.
• Waste recycling industry.
• Discouraging the production of electricity from waste.

• Emphasizing the instructions of the Prime Minister to establish an integrated, updated and available information system on attached industrial lands and to reduce their prices to attract foreign investments.
• Accelerating the system of refunding export burdens, which works to increase the competition of Egyptian products.
• Implementing the green path release system for factories and companies.
• Unifying the entity for detecting imported dual-use materials to reduce customs clearance time.
• Directing natural gas to the petrochemical and nitrogen fertilizer industry.
• Encouraging investors in the field of electricity production by amending the pricing of electricity produced from waste
• Legalizing the informal sector.
• Localizing the manufacture of equipment, machines, and molds necessary for production.
• Expanding the establishment of technical education institutes similar to Donbosco to provide trained technical workers.
• Deepening the newsprint and newspaper industry locally instead of importing them.
• Encouraging investment in local soda ash production.

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• High production costs and excessive fees for filming in tourist sites, airports, and archaeological sites

• Reducing the costs of filming films in tourist and archaeological sites, airports, etc

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• Issuing legislation and decisions related to the industry without presenting it to the industry.

• The necessity of involving the Union and the chambers in discussing legislation and decisions before they are issued by the House of Representatives

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• Filming foreign films in Egypt:
• Foreign producers suffer from many restrictions when filming their films in Egypt, which led them to flee to other countries that provide them with aid and ease of procedures without any restrictions.

• It is necessary to form a higher council composed of, for example, the following:
• Ministry of Culture - Ministry of Finance - Ministry of Interior - Chamber of Film Industry Its goal is to overcome all obstacles and issue approvals for filming in Egypt so that Egypt does not lose an important tourist and financial resource as a result of not filming in Egypt, as well as for Egyptian workers to gain foreign experience in this field.

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• Reducing the tax burdens on the cinema sector, as the cinema sector suffers from clear double taxation on the inputs of this sector, especially cinemas, as two types of indirect taxes are imposed on this sector (amusement tax - value-added tax).

• Exempting the inputs of this sector from value-added tax in accordance with Clause 47 of the list of goods and services exempted from value-added tax in Law No. 67 of 2016 (plastic arts, works of authorship, and literary and artistic publishing of all kinds), as the cinematic film is considered an artistic cultural product, and cinemas are considered a publishing house for an artistic cultural product.

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• There are no direct sea shipping lines to western Libya and North African countries, which hinders export operations.

• Opening direct lines to North African countries.

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• Setting a limit on the annual business volume as a sales value of 50 million pounds, which reduces the chances of obtaining initiatives for small companies.

• Raise this limit to 50 million pounds, taking into account inflation rates.

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• Refusal to issue industrial licenses to companies whose headquarters are outside industrial zones. y

• Exempting these companies from the requirement of location outside industrial zones.

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• Scarcity of specialized and trained technical personnel despite the availability of educational institutions.

• Raising the level of practical training in these institutions and updating the training systems to keep pace with the latest printing technologies

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• Lack of external promotion of the Egyptian product, which reduces export opportunities.

• Activating the role of commercial representation offices abroad to promote printing products.

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• Modernizing production lines to raise the quality of industrial products, provided that this is done by supporting low-interest financing initiatives.

• Supporting financing initiatives for manufacturers

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• Lack of adherence to good agricultural practices, traceability system and comprehensive quality.
• Lack of irrigation water and contamination with sewage in a number of areas.
• Problems of reclamation lands related to the allocation and pricing of those lands.
• There are no satellite images to monitor and regulate agricultural activities and illegal construction on agricultural lands.

• A complete restructuring of the Ministry of Agriculture and its various agencies.
• Amending agricultural policies and linking them to industry and export policies and the outputs of agricultural research centers.
• Accelerating the issuance of the Biological Resources Protection Law.
• Reviewing customs on raw materials and facilitating import procedures through speedy health and customs release of industry inputs.

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• Banks delay in procuring currencies and transferring them to external suppliers to pay obligations related to importing all raw materials, including raw materials for strategic commodities.
• The direct impact of banks’ delay in procuring currencies on the industry’s supply chains for its needs of raw materials, production requirements, and intermediate goods.
• A negative impact on the volume of production and the increase in prices of the final product for the consumer as well as the competitiveness of Egyptian exports.
• Loss of relationship with external suppliers as a result of non-fulfillment of contractual obligations, affecting supply and future contracts.

• Immediate provision of currency and payment of obligations to external suppliers to ensure the continuation of production operations and market stability.

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• Regarding the release of meat and poultry - Egypt has canceled the permits of 8 halal companies in America, and has relied on only one company - and this company has a geographical system and is not entitled to work in a different area and has no contact with Islamic institutions that rely on halal slaughter, and has no previous experience, unlike what is approved by Saudi Arabia and Indonesia, for example, which hinders the movement of trade. The same procedure is with South America, especially Brazil.

• Adopting a mechanism to grant or cancel permits in consultation with the private sector and the Chamber of Food Industries.

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• There is still an overlap in the powers of the National Food Safety Authority in accordance with Law 1/2017 with other bodies (agricultural quarantine - veterinary services at the Ministry of Agriculture).
• The occurrence of interference or conflict over competencies between relevant authorities (such as the Egyptian Medicines Authority - file
• Special foods and nutritional supplements).
• Overlapping jurisdictions lead to a delay in customs clearance time for imports and export procedures
• Interventions and conflicts prevent the National Food Safety Authority from carrying out its assigned role
• By law

• Prevent duplication of application and distraction of producers.
• Determine the competencies of each party in order to preserve and preserve the reforms and legislation issued
• Economic gains for a number of national industries (dietary supplements industry).

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• Civil protection measures were delayed for a number of factories for long periods.
• Factories are unable to carry out import, production and export operations.

• Expedite civil protection procedures.

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• The high debt of gas and electricity factories due to the incorrect classification that they are energy-intensive industries.

• Since the Industrial Development Authority recognized that this industry is labor-intensive and not energy-intensive, the debt should be completely cancelled, along with its interest, which represents 30% of the size of the debt.

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• The price of gas in Egypt is higher than the global level
• Egypt: $4.5
• Global price: $2.5
• Which led to:
• • Reducing Egyptian production capacity.
• • Loss of foreign currency income as a result of low export rates.
• Increasing the import of ceramics from abroad.

• Adjusting the price of gas for labor-intensive factories to become at the same level as the global price, which contributes to increasing the competitiveness of the local product.

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• The lack of qualified human resources capable of performing the tasks assigned to them and working with new mechanisms that keep pace with global development in the various areas of food control, as the responsible authorities refuse, under the pretext of overcrowding of employees in government institutions, for the Authority to contract or appoint the necessary cadres, regardless of the real and actual need of a newly established body such as the National Food Safety Authority to provide diverse expertise in various fields to complete the system. These parties also ask the Authority to reduce its previously approved organizational structure due to lack of awareness of the importance of the various activities that the Authority hopes to implement and their integration with each other in order to achieve the ultimate goal of the Authority.

• Providing the necessary funding to conduct the necessary contracts, with reservations related to the contracting procedures under Chapter Four, such as the contract period not exceeding 11 months, the inability to hand over to the recipient the covenant needed for field work, and the inability to grant these workers the status of judicial officers and the associated legal procedures necessary to monitor food establishments and their workers.
• Seeking the assistance of some university graduates in Chapter Four of the state’s general budget who are among the top graduates and those with general grades of excellence and very good, as well as holders of academic degrees (master’s and doctorate), in order to fill the deficit in the human resources necessary to carry out the work and specializations assigned to the authority.

• The approval of His Excellency the Prime Minister was issued on 4/3/2022 to employ 1,600 workers, and a number of them were used as follows according to priority: 200 individuals were hired for the 2022 wheat season and they continued to work, and 192 for the 2023 wheat season until the end of the season. The extent of their continuity will be considered based on needs.
• A number of 180 laboratory researchers were also approved to work in the newly established laboratories at the Authority’s ports (there are five laboratories).