Egyptian authorities require halal certification for imports of meat, poultry and dairy. The text of this requirement was recently changed from ‘certification from a recognized certifier at the export country’ to ‘certification under supervision of IS EG Halal Egypt’ which is a state company based in Egypt, not in export countries. Upon inquiry, Egypt advised to adhere strictly to the instructions of the named company in Egypt. This caused confusion as in some cases (not yet in Europe) IS EG Halal Egypt instructs exporters to contact halal certifiers in export countries not recognized by Egypt, resulting in a halal certification that may not be accepted upon arrival of shipment.
Furthermore, a recent Egyptian Customs circular (no. 17/2024) required halal certification for all imports of goods of animal origin without excluding dairy, in conflict with Egypt’s notification to the WTO excluding dairy until the end of 2024.
The European Union would like to express concerns with regard to the requirements on Halal certification as of 1 October 2021 based on the Egyptian Halal standard 4249/2014 and also would like to receive information on the latest development as regards the Halal certification in Egypt.
As regards dairy products, the corresponding waiver was extended several times, most recently until 31 December 2024, by the Addendum 7 to the relevant notification. We would like to appreciate Egypt’s considerable level of flexibility, which is very helpful to economic operators. At the same time, we would be grateful for information about future plans of Egypt as regards this waiver for dairy.
a. Could Egypt provide information regarding the Customs Circular no. 17/2024 which requires halal certification for all imports of goods of animal origin? As this Circular did not, confusingly, exclude dairy, the EU would appreciate information on the relation between this Customs Circular and the corresponding waiver for dairy products.
As regards the Decision No. 1 of 2023 of the General Organization for Veterinary Services (GOVS) on the Regulating Procedures for Registration of companies granting international conformity certificates for Halal food, the EU appreciates its notification to the WTO in March 2024.
Nevertheless, some of criteria this Decision imposes on conformity assessment bodies seem to be excessive or even discriminatory, such as the requirement to be registered at least in seven different countries, mandatory address in Egypt, or monthly reporting on certified food facilities.
b. Could Egypt provide information on fees for registration with GOVS and what the timetable is for the launch of the registration? In this respect, could Egypt indicate how many foreign conformity assessment bodies have already applied and/or been registered in line with the Decision No.1 /2023?
In respect to the latest developments of the matter, it seems that the GOVS Decision No.1/2023 has recently been adjusted to provide more powers to the company IS EG Halal Egypt. This company is now supposed to become the entity to supervise certifications by foreign Halal conformity assessment bodies.
c. Can Egypt confirm these changes of the said Decision No.1/2023 and explain what this means in practice? Is the IS EG Halal Egypt to become the single certification or accreditation body for foreign exporters?
The EU would like to remind that the Decision No.1/2023 previously did not attribute any role to this company. It is important to highlight that such a step would inevitably lead to less transparency in Halal certification, and most probably also to serious trade disruptions, not mentioning effects on the legal certainty for economic operators.
d. Could Egypt provide comprehensive and publicly available guidance to stakeholders, including the list of products to be Halal certified, detailed description of the certification procedure, its duration, costs, and required documents, as well as the process for registration of suppliers?