Production Inputs Register Egypt | GOEIC Industrial Registration Requirements

Legal Regulation of the Production Inputs Register of Industrial Facilities in Egypt

The Production Supplies Register of Industrial Activities (Register”) is a key regulatory tool adopted by the Egyptian government to control the importation of production inputs and ensure that they are directed towards legitimate industrial use. This tool helps protect the national industry and strike a balance between industrial development requirements and the need to monitor the quality of goods. The lawmakers assigned the General Authority for Export and Import Control (GOEIC) the task of establishing and supervising the Register, as it is a prerequisite for importing the production requirements necessary for industrial activities.

Given the practical importance of the Register, this Article presents the legal framework governing the Register of Production Inputs for Industrial Activities. It explains the legal controls governing registration, the requirements for registration and renewal, and the legal consequences of violating its provisions. This Article aims to enable investors, factory owners, and importers to understand their rights and obligations and avoid legal risks that may hinder their activities or lead to the suspension or refusal of the release of imported goods.

5. The Register is an official register maintained by the GOEIC, which is responsible for registering factories and industrial establishments that import supplies necessary for the production process. The Register aims to verify the seriousness of industrial activity and that imported supplies are used in production and not in trade or resale in violation of the law.

5. Advantages of Registration

Production and service projects may import inputs for production, operation, or service performance. They may request a production inputs card based on the proof of activity documents they submit. A copy of this card shall be submitted when requesting the release of production requirements.

5. Main requirements for Industrial Facilities Registration:

1. The facility shall have a legal entity, a commercial register, and a tax card.
2. The project and the manufacturing, production, or assembly activity shall be registered in the commercial register.
3. The facility shall have a valid industrial registration, whether fixed-term, temporary or conditional, which has the same legal and procedural effects as a permanent industrial registration, regardless of the term.
4. The activity in the industrial register shall be specified in terms of duration (start and end dates), quantities, and types.
5. The activity shall be ongoing and confirmed in the operating licence.
6. The project and activity details shall be identical in the commercial register, industrial register, and operating licence.

5. Documents required for Industrial Facilities Registration in the Production Input Register:

1. A valid copy of the industrial register (fixed-term/temporary/conditional), and the original shall be submitted for review.
2. A copy of the operating licence matching the industrial register, and submission of the original for inspection.

• Upon renewal, if the new licence has not been received, a receipt for payment of the annual follow-up fees from the Industrial Development Authority (Authority) shall be submitted. The facility shall be granted a temporary production inputs card.
• Upon renewal, public sector companies with a conditional industrial registration that does not include an operating licence shall be granted a temporary production inputs card valid from the date of registration until the end of the industrial registration period.

3. Upon registration renewal, a valid statement of annual follow-up for the operating licence from the Authority shall be submitted.
4. An official extract from the main commercial register confirming the address of the business, and also the secondary commercial register if the address of the business is not listed in the main register or there are branches not listed in the main register. Both must be:

• Valid and up-to-date for three months after issue.
• The register shall include manufacturing, production, or assembly activities.
• They shall clearly state the facility's national registration number, address, and unified number.
• If the commercial register is valid and up to date but contains the word ‘outdated,’ a temporary production inputs card will be issued for a maximum period of one year or until the Authority receives the update in the commercial register, whichever comes first.

5. Tax card copy, valid and matches the commercial register, with the original presented for inspection.
6. If the address of the activity is not listed in the commercial register, the original document confirming the address of the activity listed in the industrial register and the operating licence shall be submitted.
7. If the applicant for registration is a tenant of the place of activity.

• The applicant’s name shall be mentioned alongside the name of the owner of the premises in the operating licence, industrial register, and commercial register.
• In the event of a discrepancy in the address of the activity in those documents, a copy of the lease agreement shall be submitted along with the original for review and verification of the information.

8. Application for registration in the Register, in accordance with the form prepared for this purpose.
9. The industrial register shall be signed, in accordance with the form prepared for that purpose, by the person who has the right of management and the relevant signature, or by the agent or representative before the relevant employee.
10. A copy of the national ID card or passport of the person with management and signing authority, and submission of the original for review.
11. If there are foreigners in the commercial register, the original document shall be presented for inspection, along with a copy of a valid residence permit that includes a work permit, a copy of a valid passport, and the original document for inspection.
12. If the applicant is a proxy, a notarised power of attorney, a copy of the agent's national ID card, and a declaration of the validity of the power of attorney shall be submitted.
13. If the applicant is an authorised representative, the original authorisation form shall be submitted, signed by the person with the right of management and signature, and certified by a bank.
14. If all documents are not complete, a commitment shall be made to bring the documents before receiving the card.

5. These documents and applications are submitted and examined by the GOEIC to verify their compliance with legal and technical requirements. If the main requirements are met, a registration decision is issued, and an official certificate is granted confirming the facility's registration in the Register.

5. Registration eligibility

Industrial facilities shall be registered in the Register for a period of five years, or until the expiry of the registration in the industrial register or commercial register in which the address of the factory or activity is registered, whichever is sooner, starting from the date of registration.

5. Deregistration

Industrial facilities are deregistered if any of the following requirements apply:

1. Administrative deregistration.

2. Deregistration based on the facility's request.

3. Deregistration based on the industrial development letter of deregistration.

5. 1. Administrative Deregistration

• The registration shall be administratively revoked in any of the following cases:

1. When 90 days have passed since the expiry date of the production inputs card, without renewal of the registration.
2. If any requirements for registration in the Register is not met.
3. If the facility is wound up, liquidated or terminated.
4. If the unified tax number has been changed.
5. Upon the termination of the natural person by the death of the person concerned (for sole proprietorships).
6. If the commercial register of the facility has been struck off.
7. If the activity is struck off from the commercial register or the document indicating the activity.
8. If the file is permanently suspended by the tax authorities.

• Documents required for deregistration of individual facilities in the event of the death of the owner:

1. Original death certificate and inheritance statement.
2. Proof of identity of the heirs.
3. Court approval of guardianship for minors.
4. If the applicant is acting on behalf of the heirs, a power of attorney from all heirs and a declaration of the validity of the power of attorney shall be submitted.

• Documents required for deregistration in the event of winding up/liquidation:

1. Liquidation agreement or minutes of the general assembly meeting on liquidation.
2. Application for striking out of the commercial register, or commercial register in liquidation and striking out.
3. Proof of identity of the liquidator, with the original for review.

• Documents required for deregistration in the event of dissolution:

1. The company's extraordinary general meeting minutes or the dissolution agreement.
2. Application for striking out of the commercial register.
3. If the applicant is a proxy, a valid power of attorney shall be submitted.
4. If the applicant is an authorised representative, a signed authorisation form shall be submitted by the person with management and signing authority, certified by a bank.

5. 2. Deregistration based on the facility's request

• The documents required for deregistration at the request of the facility are as follows:

1. A deregistration application form, in accordance with the form prepared for that purpose, signed by the person authorised to manage and sign, and certified with a bank signature.
2. A copy of the commercial register attached to the production inputs card, with the original for review.
3. Tax card copy, valid and matches the commercial register, with the original for review.
4. A copy of the document indicating the activity, with the original for review.
5. Submitting all copies of valid input registration cards issued to the establishment, or a police report confirming their loss or the loss of any of them.

5. 3. Deregistration based on the Authority

De-registration is automatically effected pursuant to a letter issued by the Industrial Development Authority, which has struck off its industrial register or operating licence issued under the Register.

In conclusion, registration in the Register for industrial activities is a fundamental legal requirement for importing production inputs into Egypt. It is based on an integrated legislative and regulatory system that aims to tighten control over imports, ensure that production requirements are directed towards legitimate industrial use, and protect national industry from illegal practices.

As the registration and renewal procedures and the multiple relevant authorities involved are highly technical and legal in nature, any procedural error or failure to complete the documentation may have serious legal and commercial consequences, most notably the suspension of customs clearance for imported consignments and the disruption of industrial activity. Therefore, it is important to seek specialised legal expertise to ensure the integrity of procedures and full compliance with the provisions of the law.

In this context, Sadany & Partners Law Firm plays a pivotal role in providing comprehensive legal support to investors and industrial facilities. This support includes examining the legal status of the activity, reviewing registration documents, and representing clients before the GOEIC, through following up on registration and renewal procedures, and ending with providing preventive legal advice that ensures the stability of the activity and avoids risks. These services are part of the institution's vision to enable its clients to conduct their industrial activities in a secure and stable legal environment, in compliance with the applicable regulations.