Tariffs, regulations and customs
Egyptian customs regulations are complicated and rigid in areas such as duty rates and are designed to eliminate trading loopholes. Authorities don’t have to explain or justify their decisions and there’s no formal appeal process. Customs procedures are subjective when it comes to identifying which tariff category a commodity fits into.
Although tariff levels have fallen in recent times, as a result of Egypt adhering to World Trade Organization rules, the government now levies an ad valorem service fee on imported shipments in return for inspection, listing, classification and re-examination of shipments. In addition to the customs tariff, a sales tax ranging between five per cent and 25 per cent is added to the final customs value of the imported item. However, most food and agricultural (livestock, dairy) products are exempt from this tax.
Pesticide residues and other contaminate regulations
Regulations governing pesticides, pesticide registration and use, are the responsibility of the Ministry of Agriculture. The Division of Pesticide Residues and Environmental Pollution (DREP), an office of the Central Agricultural Pesticides Laboratory (CAPL), is charged with analysing pesticides and chemical contaminants in foods. CAPL is a laboratory within the Agricultural Research Centre (ARC). The Centre also makes recommendations to the Ministry of Agriculture on matters pertaining to pesticide legislation and regulations.
All pesticides must be registered before they can be used. The registration process includes the following:
- An application submitted to the Pesticides Committee (PC) of the Ministry of Agriculture showing the following information:
- Registration certificate valid for the country of origin
- Toxicological data prepared by the FAO/WHO Joint Meeting on pesticide residues
- Copies of all environmental impact studies
- Field and laboratory evaluation results and recommendations
- Label
- Upon review, the PC refers the application to the Recommendation Committee, which sets the recommended usage rates.
- The Recommendation Committee then forwards the application to the Research Station for field evaluations and monitoring.
Egyptian standards for pesticide residues in food are derived from FAO and WHO standards.
Import procedures
It often takes at least two weeks for the product to complete all customs formalities. The rejection of a product for any reason quickly throws the consignment off track. Getting the product back on track is both time-consuming (occasionally in excess of three months or more) and expensive. There are no guarantees or assurances in appealing a rejection and in the end, authorities may still refuse to clear the product.
The initial import procedure includes the following:
- The assignment of a shipping agent (a GOE entity and separate from the vessel shipping agent)
- Arrival of the consignment at port and a comparison of the invoice and bill of lading with the ship’s manifest
- Issuance of a title transfer document to the importer
- The unloading of the consignment
- The purchase and completion of the importation form and registration of the consignment with customs
- Initial tariff classification of the product
Egyptian companies often rely on customs brokers, or their own staff to check on shipments and to clear products through customs.
The following documents must be presented to the customs office in order for a shipment to be released:
- Bill of Lading or Letter of Guarantee
- Commercial invoice
- Packing lists
- Weight list
- Insurance policy
- Certificate of origin countersigned by the Chamber of Commerce and notarised by the Egyptian Embassy or Consulate in the country of origin
- Import/export permit of the importer
- If the importer is an agent of a foreign manufacturer, the latter has to present an Agency
- Authorization Certificate for the products being imported
- Form 11 from a local bank advising that payment has been transferred to the supplier. This form guarantees payment to the supplier
- Food certificates
(Source: US Global Agriculture Information Network)
Industry standards
There is a complex array of standards and specifications for many food products. Exporters should always check that their products meet these requirements prior to finalising a deal.
Domestic food and agriculture industries must comply with the specifications of Egyptian standard definitions. The Egyptian Organization for Standardization and Quality Control (EOS) in the Ministry of Industry has sole responsibility for establishing, adopting and publishing food standards and codes of practice.
The Ministry of Health and the Ministry of Foreign Trade apply all standards. Anyone who wants to have a new specification established and included on the list of approved Egyptian specifications must present proof that the desired specification standard already exists and is approved for use in some other 'acceptable' country.
In cases where no mandatory Egyptian standard exists, the following standards are acceptable:
- International Standards
- European Standards (EN) - in the absence of EN standards, British, German, and French standards may be applied
- American Standards
- Japanese Standards
- Codex Standards
In the absence of an Egyptian or international standard, authorities often refer to the Analysis Certificate accompanying the product. If no suitable standard exists for a product, a committee may be formed to develop a new standard. However, it may take up to two years or more for the new standard to be implemented after it is approved.
The Food Institute of the Ministry of Health is responsible for registering and approving all speciality and dietary foods. Importers are required to submit a form in order to obtain a license for dietary products. The validity period of the license varies from one to five years depending on the product. After the expiration date of the license, the importer has to submit a new request for license renewal. It takes four to six months to register a product and the renewal of the license costs about $500. However, if a similar local dietary product is available in the market, registration for an imported product is not approved.
The General Authority for Veterinary Services, an affiliate of the Egyptian Ministry of Agriculture is the main inspection body for livestock production. The law stipulates that animals must be slaughtered in government slaughterhouses, where attempts are made at regulation and quality control. Each carcass must have a government stamp in order for it to be transported or sold in butcher shops.
The Ministry of Health and Ministry of Home Trade and Supplies apply shelf life standards and product specifications to food and agricultural products. Any product that exceeds its established shelf life is considered no longer fit for human consumption and is subject to confiscation.
Labelling and packaging requirements
Egypt maintains restrictive labelling requirements for imports of food products:
- There are no specific size or placement requirements for labels. However, labels with all required information must be placed on every package weighing 50 grams or more.
- Labels can be printed on the package or be of a permanent adhesive type.
- Labels and must be inserted inside the package as well as on the outside carton.
- Information on the label cannot be erased, scratched, or altered in any way.
- With the exception of the production and expiration dates, information printed in English (or other foreign language) is not allowed. Dates are accepted in English, but the word 'production' and 'expiry' must be written in Arabic. Arabic labelling is mandatory.
- Products cannot show more than one date of manufacture or expiration on the package.
- Colours used on the inner and outer package should not be harmful to human health and should be fixed. If the colour can be easily altered, its use is not permitted.
All labels must include the following information:
- Name and address of manufacturer
- Brand or trade mark, if appropriate
- Country of origin
- Type of product and grade
- Name and address of importer
- Production and expiration dates. Production and expiration dates may be mentioned separately on the top of the package. They can be applied by laser, imposed, or printed. In such cases, there is no need to repeat them on the label.
- Product use instructions (optional)
- Product ingredients
- Storage instructions or temperature
- Net weight
- Gross weight and total number of the packages per case or carton
- If the product contains preservatives, the percentage of each preservative should be indicated
- If the product is meat or poultry, the following statement must appear: 'Slaughtered according to the Islamic ritual' or 'Halal slaughtered'
Dairy factories are required to label their products indicating whether the product is produced from fresh or powdered milk or both. The labelling law requires processors to indicate the percentage of powdered milk in the mixture, calculated on the basis of its weight after restoration. This law applies to pasteurised milk, sterilised milk, ice cream, cheese and yoghurt.
Tests and inspections
Tests and analyses are conducted on all imported food products upon arrival at ports. Tests and analyses are conducted to assure that the product is fit for human consumption, free from contagious diseases and in compliance with Egyptian product specifications. The following tests are mandatory on all imported food products upon arrival:
- Laboratory tests and analysis by the Ministry of Health
- Ministry of Agriculture veterinary inspection of dairy, fish, meat, and poultry products
- Labelling and product compliance with Egyptian standards enforced by the General Organization for Export and Import Control (GOEIC) of the Ministry of Foreign Trade.
All tests are conducted in government laboratories. Tests and analyses by private laboratories are not permitted or acceptable.
Since inspection is now centralised in GOEIC, a committee is formed with representatives from the Ministry of Agriculture, Health, and GOEIC. Each ministry performs its analysis on the same product sample and issues its results to GOEIC. If one ministry rejects the product, GOEIC, in turn, also rejects the product.
The number of samples withdrawn have been reduced as a result of centralising the inspection process with GOEIC. Importers are supposed to be notified of all test results within seven days after samples have been drawn. However, for canned products, mineral water and frozen products, tests results must be submitted within 14 days after samples have been drawn.
A product may be rejected for the following reasons:
- Not fit for human consumption
- Incorrect labelling
- Prohibited colors, additives, or preservatives
- Incorrect or missing certificates (however, authorities usually allow importers extra time to submit corrected documents)
- Failure to comply with Egyptian product specifications
- Less than 50 per cent of the established shelf-life remains for the product
If a product is rejected, it may be re-exported from the port of entry or confiscated at the port of entry.
If the rejection is due to unsatisfactory laboratory tests, the importer has the right to have the product re-tested three times. The appeal for reconsideration should be submitted to GOEIC within seven days.
Product sampling
All product samples should be representative of the consignment and should be drawn during the unloading process. A committee is formed to withdraw random samples. One representative sample (specified in size) is drawn from each consignment and respective inspection agencies have that sample for testing. However, each agency conducts its own laboratory tests. Tests maybe conducted by three different laboratories.
Cleanliness must be assured when samples are taken to avoid contamination. Also, the committee is supposed to take the necessary steps to assure the soundness of the product samples while they are being transported to the laboratory for analysis. All sample information is indicated on the Form of Examination Results.
The following provisions are to be taken into consideration when samples are withdrawn:
- The consignment should be treated as a single shipment
- The samples should be divided according to batch size and type of product
- The samples should be distributed among the laboratories so as to avoid repetition
- All label information should be presented on the Sample Analysis Form.
If a consignment is imported from various origins or product sources, each should have a distinctive and confidential number.
Food certificates
A number of certificates are required for all imported food products:
- Certificate of origin
- Health certificate
- Veterinary certificate (for meat, poultry, fish and dairy products)
- Islamic halal certificate, if applicable (for animal products)
- Temperature certificate (for frozen, deep frozen and chilled products)
- Analysis certificate, if applicable
All the above certificates should be countersigned by the Chamber of Commerce and notarised by the Egyptian Embassy or Consulate in the country of origin, or any other Arab Consulate if there is no Egyptian Embassy or Consulate in the country of origin.
Importers must present one set of all import documents to the General Organization for Export and Import Control.
There are additional special requirements related to the importation of meat and live animals including:
- An importer must submit a request to the General Administration for Veterinary Services indicating: the number of animals or type of and meat being imported, country of origin, shipping port, expected date of shipment arrival, and means of transportation.
- The General Administration for Veterinary Services examines the request according to the epidemiological status of the country of origin. If the epidemiological status permits importation, the importer is issued a permit. The permit is valid for one month. The importer can renew the approval if importation does not occur within one month. No fees are charged for the approval permit.
- Products must be shipped directly from the country of origin to Egypt.
- Products must be packaged in appropriate bags as required by the Egyptian standards
- Release by the veterinary authorities depends heavily on the veterinary pre-approval license. If there is any discrepancy between the pre-approval license and the shipping documents, the product will be rejected. Importers should be completely familiar with all of the information required for the pre-approval license and instruct their suppliers accordingly. Importers should check with the Veterinary Authority of the Ministry of Agriculture for more information and instructions.
Batch number certificates
Batch number certificates are required for all food products in order to facilitate product sample withdrawal. Each batch will be considered as a different item for sample withdrawal purposes.
Samples will be drawn from each batch having different production and expiration dates. Products with different dates are considered to be different items and should be identified as such on the Release Certificate and Batch Number Certificate.
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