Factory Registration With GOEIC Egypt | Import Compliance Guide

Registration Controls on the Register of Factories at the General Authority for Export and Import Control

Imported goods trading in the Egyptian market is no longer just a commercial activity governed by import regulations and competition considerations. It's now subject to a comprehensive legal and regulatory system that aims to protect consumers, ensure product quality, and tighten control over cross-border supply chains. This system highlights the importance of registering with the General Authority for Export and Import Control (GOEIC) as a prerequisite for the entry of imported goods into the market, rather than a mere administrative procedure or formal requirement that can be ignored.

The Egyptian lawmakers established, through ministerial resolutions regulating inspection and control rules, foremost among which are Resolutions 991 of 2015, 43 of 2016, 44 of 2019, and 195 of 2022, to regulate the legality of trading certain imported goods, especially consumer goods, by requiring the manufacturing plant or brand to be registered with the competent authority. This allows the product's source to be traced and its compliance with approved technical standards and specifications to be verified.

Under these Resolutions, the Register of Factories is no longer merely a regulatory tool, but has become a legal mechanism that separates legal trade from prohibited trade. Violations of the Register have direct legal consequences, including suspension of customs clearance and legal liability for the importer, even though the importer is not the producer of the goods.

This Paper, therefore, addresses the legislative framework governing the registration of factories, including its regulations and legal implications on the circulation of imported goods within the Egyptian market.

v. Factories and corporations with trademarks that are eligible to export products to Egypt are registered in the Register of Factories at the GOEIC. Registration in the Register of Factories is a prerequisite for the release of products for trade purposes. The Minister of Foreign Trade issues a resolution on registration in the Register and has the right to waive any or all of the registration requirements as he deems appropriate.

v. The Factory Register is an official database managed by the GOEIC, which aims to document all factories producing goods imported or exported to the Egyptian market, whether local or foreign. This register is a fundamental regulatory and legal tool that enables the Authority to verify the product's source and ensure its compliance with technical and health standards and approved specifications before allowing it to be marketed.

v. Basic requirements for registering factories and companies that own trademarks in the Register of Factories with the GOEIC:

1. The application for registration shall be submitted by the legal representative of the factory or company that owns the trademark, or by his authorised representative or agent, accompanied by:

Certificate of legal entity of the factory and the issued licence. - Statement of the types of products and trademarks.

2. The factory or company that owns the trademark shall have a quality control system in place, issued by a body recognised by the International Laboratory Accreditation Cooperation (ILAC) or the International Accreditation Forum (IAF).

3. The following documents shall be valid so that the factory or company owning the trademark does not lose any of the registration conditions:

Industrial register, quality certificate, trademark title certificate.

4. The trademark ownership document shall be issued by the trademark administration of the country where the trademark was issued and registered with one of the following organisations: WIPO, EUIPO, or American

5. In the case of registration of factories and companies as trademark owners.

The products under the trademark to be registered shall correspond to the products to be registered and listed in the product statement and industrial register.

v. Documents Required for Factory Registration with the GOEIC:

1. A letter to the GOEIC, printed on company letterhead, with the following:

Factory details (name/address/nationality).

The factory's products are to be exported to Egypt, in compliance with the quality certificate and industrial register.

Brand names (if any); if none exist, add the following statement to the product description: 'The manufacturer does not own a brand name and manufactures under the name of the factory.'

Authorisation by the factory, for the company or authorised persons, to carry out the registration process with the GOEIC, in accordance with Resolution 43 of 2016 and Resolution 44 of 2019.

1. An industrial record of the factory, stating that it manufactures the products to be registered.

2. If the factory has a trademark, the following shall be submitted:

A copy of the trademark title document shall be issued by the trademark administration of the country where the trademark originated. It shall state that the products to be registered are consistent with the product description and the industrial register.

3. If the trademark to be registered is not owned by the manufacturer, the following shall be submitted:

Authorisation from the trademark owner to use the trademark for manufacturing and exporting for the factory to be registered.

Trademark title document issued by the official trademark registration authority.

4. A quality certificate stating the following:

That the factory to be registered implements a quality system related to product quality.

Issued by a body recognised by the International Laboratory Accreditation Cooperation (ILAC) or the International Accreditation Forum (IAF).

It includes the items to be registered in English.

It shall state that the factory manufactures such products.

All documents shall be translated into Arabic and certified by the Ministry of Foreign Affairs of the foreign country and the Egyptian embassy abroad, except for the quality certificate.

v. Documents required for registering companies owning trademarks with the Register of Factories at the GOEIC:

1. A letter to the GOEIC, printed on company letterhead, with the following:

Details of the company that owns the trademark (name/address/nationality).

The brand trademark's products, in compliance with the quality certificate.

Trademark names (name or logo).

List of factories (name/address/nationality).

List of distribution centres (name/address/nationality).

Authorisation by the company to be registered, for the company or persons authorised to carry out the registration process with the GOEIC, in accordance with Resolution 43 of 2016 and Resolution 44 of 2019.

2. A copy of the trademark title document from the trademark administration of the country where the trademark was issued. Trademarks shall be registered with one of the following organisations: WIPO, EUIPO, or American.

3. If the trademark does not belong to the company seeking registration, the following shall be submitted:

Authorisation from the trademark owner to use the trademark in the manufacturing and export activities of the company to be registered.

Trademark title document issued by the official trademark registration authority.

4. A quality certificate stating that the company owning the trademark to be registered applies a quality system related to product quality, issued by a recognised body (ILAC or IAF), listing the items to be registered in English.

All documents shall be translated into Arabic and certified by the Ministry of Foreign Affairs of the foreign country and the Egyptian embassy abroad, except for the quality certificate.

The documents shall be examined and verified for authenticity. If there is any doubt as to their authenticity, they shall not be entered in the register of factories until their authenticity has been verified. At the applicant's request for registration, the company or factory may be inspected to verify the authenticity of the documents, subject to the approval of the Minister of Trade and Industry.

v. Renewal of registration for producers and trademark owners in the Register of Factories:

Documents with an expiry date shall be renewed within a period not exceeding thirty days from the date of expiry (e.g., Industrial register – Quality certificate – Trademark title certificate).

If documents with an expiry date are not renewed within thirty days of expiry, the registered factory or trademark owner will lose one of the conditions of registration. The factory or company will be warned and banned.

If the documents are not renewed within the warning period, the registration will be revoked by a reasoned decision issued by the head of the GOEIC. An appeal against the revocation decision may be lodged with the Appeals Committee, within sixty days from the date of notification to the concerned party or the company authorised to register.

v. Documents required for renewal of registration of producers and trademark owners in the Register of Factories:

1. A copy of the authorisation submitted upon registration by the manufacturer or trademark owner registered with the GOEIC, for the company or persons authorised to carry out the registration process with the GOEIC, in accordance with Resolution 43 of 2016 and Resolution 44 of 2019.

2. A copy of the power of attorney certified by the real estate registry or a bank authorisation from the company registering the person authorised or appointed to register on behalf.

3. A copy of the national ID number of the person submitting the renewal documents, with access to the original.

4. A copy of the ministerial resolution or the GOEIC resolution of registration.

5. A copy of the document to be renewed, including:

A quality certificate stating that the factory/owner of the trademark to be registered applies a quality system related to product quality, issued by a recognised body (ILAC or IAF), listing the items to be registered in English.

An industrial record for the factory stating that it manufactures the products to be registered and certified by a foreign country.

In the case of renewal of a trademark belonging to the company that owns the trademark or the factory, the following shall be submitted:

• A copy of the trademark title document after renewal,
• issued by the trademark administration of the country where the trademark was registered.
• It shall include the products and categories to be registered according to the International Classification of Trademarks.
• Compliance with product specifications and industrial registration.

v. Appeal against the resolution to deregister from the Register of Factories:

The concerned party or their representative may appeal the resolution to deregister within sixty days of the date of notification of the concerned party or the company authorised to deregister in the Agreements and Foreign Trade Sector at the Ministry of Finance Towers in Nasr City.

The appeal shall be accompanied by documents proving the re-registration of the factory or company that owns the trademark (the same registration documents).

The appeal shall be submitted to the Appeals Committee, which shall decide on the appeal within a period not exceeding fifteen days from the date of its submission.

The complainant shall be notified of the reasons for non-registration or deregistration and the corrective measures to be taken on their part for re-registration.

v. Legal penalties of non-registration with the GOEIC:

Registration with the Register of Factories is a fundamental legal requirement for trading imported goods within the Egyptian market. Violation of this requirement results in severe penalties to ensure compliance with regulatory rules and consumer protection. The ministerial resolutions stipulate a set of direct legal penalties that apply to unregistered importers and manufacturers.

1. Suspension of customs clearance of imported shipments, as goods coming from unregistered factories are not allowed to enter the Egyptian market. Shipments imported from factories that are not registered with customs are also held until the factory's status is regularised or the shipments are rejected outright.
2. The entry of consignments into the Egyptian market will be refused if the factory registration is not maintained. The GOEIC will refuse to release the consignments permanently, which means that these goods are illegal for trade in the local market.
3. The importer bears legal responsibility: the importer is liable for the consequences of non-compliance with registration requirements, even if they are not the original producer of the goods. They bear civil and commercial liability and are subject to fines.
4. Deregistration or withdrawal of accreditation: The GOEIC has the right to revoke a factory's registration if it is proven that the factory does not comply with technical or legal standards as stipulated by law. Such revocation will prevent the factory from exporting any products to the Egyptian market until the registration requirements are met.
5. Consequences of non-compliance on product distribution: Any products imported from unregistered factories are considered illegal for distribution. This creates potential criminal or administrative liability on the importer and manufacturer. It also prohibits them from distributing their products until registration is completed.

In conclusion, registration with the Register of Factories at the GOEIC is a fundamental legal requirement for the circulation of imported goods. It ensures consumer protection and compliance with technical standards and specifications. Ministerial Resolutions 991 of 2015, 43 of 2016, 44 of 2019, and 195 of 2022 emphasise the importance of this restriction and the responsibilities of importers, along with the penalties imposed on violators.

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.