With the Consumer Protection Law of 2018 Egypt for the first time introduced a comprehensive consumer protection regime enforced by the Egyptian Consumer Protection Agency (CPA). In parallel Egypt's Competition Law enforced by the Egyptian Competition Authority (ECA), seeks to ensure free and fair competition by prohibiting monopolistic practices, collusion, and abuse of market dominance. These two legal regimes have different aims: consumer protection focused on individual rights, and competition law on market structure. Still, they share a common objective: promoting fairness, transparency, and economic efficiency. Their mutual reinforcement becomes most effective when competition law actively intercepts harmful conduct that undermines consumer welfare in ways that consumer law alone cannot address. This client brief considers the interplay between consumer protection and competition regulation under Egyptian law.
Competition law reinforces consumer protections in Egypt in several ways. The Consumer Protection law guarantees protections for individuals such as the right to safety, the right to accurate information, the right to fair treatment, and the right to redress—including entitlement to refund or exchange. It also places obligations on businesses to disclose product details, honor warranty commitments, and avoid deceptive advertising or pricing practices. Misleading advertising for instances violates the Consumer Protection Law as it infringes on consumers' right to accurate information. Yet, it also may violate the Competition Law by distorting market signals and undermines fair competition. Furthermore, companies engaged in deceptive marketing that misrepresents product features, origin, or pricing, not only manipulate consumer choices but also gain an unfair advantage over competitors. In this context, enforcement by both CPA and ECA becomes mutually reinforcing. The CPA can sanction deceptive communication toward consumers. In addition, the ECA can pursue broader market implications, particularly when such conduct is systematic or used to consolidate market power.
Other areas where competition law and consumer protection intersect are price discrimination and exclusive dealing, especially by dominant market players. Large suppliers offering preferential pricing or product access to selected distributors or platforms, may limit consumer choice and suppress smaller competitors. Consumer protection law addresses impacts on individuals of unfair treatment or unclear pricing. However, this alone may not suffice to address the issue. Consumer protection law does not address the root of the problem: the abuse of market power. Here competition law offers a complementary tool. It has the means to tackle the market practices that enables the behavior causing harm to consumers. The application of both regimes serve to better safeguard market diversity and long-term affordability for consumers.
However, certain aspects—such as the digital economy—remain under regulated by Egyptian law. Platform-based personalization, dynamic pricing algorithms, and data-driven consumer segmentation are not addressed by specific regulations in Egypt. In other jurisdictions like the EU, specific regulations empower enforcers to address exploitation of consumers or unlawful disadvantaging of competitors through algorithmic pricing and data monopolization. In Egypt, for lack of specific legislation, the ECA must continue to rely on general antitrust provisions to address these practices. Consequently, the Egyptian competition regime lacks appropriate tools to effectively regulate these practices. Furthermore, the CPA lacks authority in this area also. Consumer rights in the digital economy are so far not addressed in the Egyptian Competition.
Moreover, lack of coordination among authorities prevents them from effectively regulating market behavior. For instance, in Egypt rising prices, limited availability, and branding tactics that conceals product origins in sectors such as food and pharmaceuticals are typically treated as consumer protection issues or addressed as inefficiencies in supply chains. Still, these negative behaviors are typically enabled or exacerbated by concentration in upstream markets. Such concentrations can effectively be addressed through competition regulation. By failing to address these structural market issues, the authorities treat symptoms rather than root causes. Similarly, under addressed sectors include public utilities, where consumer disputes over billing or service quality often arise in monopolistic environments, and financial services, where tying and bundling, and switching barriers create risks that demand dual regulatory enforcement.
Certain hindrances for enforcement due to lack of specific regulation and coordination among authorities persist. Still, companies doing business in Egypt have to consider their obligations under increasingly interconnected regulatory regime. The intersections of consumer protection and competition regulation require businesses to consider their transactions under several regulatory regimes to ensure compliance and mitigate enforcement risk. This adds complexity and cost and requires dedicated specialist to be involved either from in-house staff or externally.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
