Golden Licenses and Customs Reform: Egypt's 2025 Legal Push to Localize Manufacturing

Egypt's legal framework for manufacturing moved decisively in 2025 toward a model that rewards strategic, export-oriented and import-substituting projects with streamlined approvals, while modernizing the customs rules that govern how producers bring inputs across the border. For manufacturers and their advisers, the two developments are best read together. The state is offering a faster route into the market for projects it considers nationally important, and at the same time tightening the procedural discipline that every importer must observe.

The centerpiece of the licensing reform is the golden license, the single approval issued by the General Authority for Investment and Free Zones under Article 20 of Investment Law No. 72 of 2017 and Articles 42 and 43 of its executive regulations. A golden license consolidates into one instrument the approvals normally required to establish, operate and manage a project, including building permits and the allocation of the real estate the project needs. The intended effect is to replace a fragmented sequence of separate permits, often spread across multiple authorities, with a single decision that covers the full project lifecycle.

Through 2025 the government leaned heavily on this mechanism for the manufacturing sector. The cabinet approved golden licenses for industrial projects including an integrated facility for the production and assembly of cars, passenger vehicles, buses and transport vehicles near the Sixth of October Dry Port, and a factory producing office, school and sports supplies on a large plot in the Tenth of Ramadan City industrial zone, with both projects committing to export-oriented output and local sourcing. The Authority issued an updated Golden License Guidebook in September 2025, reflecting the continued expansion of the program and building on earlier amendments to the executive regulations of the Investment Law. The cumulative number of golden licenses granted had climbed into the mid-forties by early 2025, signaling that the instrument has moved from a pilot to a routine tool of industrial policy.

The eligibility criteria reveal the policy intent and should frame any manufacturer's assessment of whether to pursue this route. To be treated as national or strategic, a project must satisfy two or more qualifying conditions. These include exporting at least half of annual production within three years of starting activity, and reducing imports by localizing the industry so that local components, including local raw materials, represent at least half of production. The license is therefore not a general convenience available to any factory. It is a targeted instrument for projects that advance export capacity and local content, and applicants must be prepared to evidence these commitments rather than merely assert them. Counsel should treat the qualifying thresholds as binding undertakings whose later breach could expose the project to challenge.

Running alongside the licensing reform, Egypt amended the executive regulations of Customs Law No. 207 of 2020 through Ministerial Decision No. 548 of 2025. The amendments modernize customs procedure in several respects that bear directly on manufacturers. They broaden eligibility for Authorized Economic Operator status, the trusted-trader designation that brings faster clearance and reduced inspection, by recasting the relevant provisions around the applicant rather than the company. They introduce a mechanism for non-binding advance inquiries that lets importers seek guidance on treatment before committing to a transaction. The regulations also revise warehousing periods and establish stricter handling rules for hazardous and perishable goods, with shorter permitted storage for sensitive cargo. For manufacturers importing machinery and inputs, these procedural changes reward firms that invest in compliance maturity and accurate classification.

The other procedural change manufacturers cannot ignore is the Advance Cargo Information system. Importers must obtain an ACID, the advance cargo information document, through the Nafeza portal before goods are shipped, and that number must appear on all shipping documents. Shipments arriving without a valid ACID risk denial of entry or significant delay. The system already applies to sea freight, and its extension to air freight, after a test phase that began in September 2025, became mandatory from January 2026. ACID validity now runs six months from issuance, and once a number is issued, core data such as the importer, the foreign exporter and the tariff classification cannot simply be amended; if those details change, the importer must cancel and obtain a fresh ACID. Manufacturers reliant on imported components must build ACID procurement into their procurement timelines, because a missing or incorrect document can strand an entire shipment.

For producers operating across the Gulf, the UAE provides a useful comparison. Under Ministerial Decision No. 229 of 2025, which clarifies the activities qualifying for the zero percent corporate tax rate in free zones, manufacturing and processing of goods remain squarely within scope, subject to audited accounts and the de minimis limit on non-qualifying income. The direction of travel in both jurisdictions is consistent: clearer rules, defined qualifying criteria and a premium on documented compliance. Manufacturers should treat licensing, customs and tax positioning as a single coordinated legal exercise rather than a series of disconnected filings.