Back To E-waste in Egypt

The legal and institutional framework for e-waste management typically comprises national laws, regulations, and designated authorities responsible for overseeing the entire lifecycle of WEEE, from production to recycling and disposal. This framework aims to ensure the safe and environmentally sustainable handling of e-waste while minimizing its adverse impacts on the environment and human health.

2.1 Definition of WEEE in Egypt

The definition and scope of WEEE vary significantly by country and region due to differing regulations, infrastructure, and priorities.

In Egypt, WEEE is defined as “hazardous waste with conditions”, as described by the Waste Management Regulation (Law 202/2020) and specifically Article 1 item 21 of its Executive Regulation No. 722 of 2022.

2.2 Egyption National Policies, Laws, and Regulations on WEEE

The regulatory framework for e-waste management in Egypt is currently in the developmental phase. The primary environmental law, Law 4/1994 and its subsequent amendment 9/2009 does regulate hazardous waste but does not specifically address e-waste management. Relevant articles include:

  • Article 19,20, 21 & 23 (Environmental Impact Assessment (EIA) requirements).
  • Article 22 (Environmental Register requirements).
  • Articles 28 and 28/1 (hazardous waste storage requirements).
  • Article 28/3 (transportation of hazardous waste).
  • Articles 29, 30, 31, and articles 25,26 and 27 (Ministry of Trade and Industry regulation for hazardous waste storage and transport).
  • Article 32 (import requirements).

With the introduction of the new waste management law (Law 202/2020), and its accompanying executive regulation (No. 722 of 2022), Egypt now also has specific guidelines for e-waste collection, transportation, treatment, and recycling.

Other Egyptian legislation relevant to e-waste management includes licensing requirements for companies involved in e-waste management (such as Ministerial Decree No. 113 /2022 (Integrated Hazardous and Non-Hazardous Waste Management) and Law 15/2017 (facilitating the procedures of issuing the operational license and industrial register from Industrial Development Authority (IDA)).

Despite these advancements, certain aspects remain absent from Egyptian legislation, such as detailed guidelines for household e-waste collection. This is a crucial consideration as approximately 25% of the total e-waste generated originates from households [3]. Addressing this and other gaps in the law is essential for effective e-waste management in Egypt.

2.3 Institutional Framework

Multiple ministries and regulatory authorities have roles to play in regulating the management of e-waste in Egypt (see Table 1 below).

Table 1: Institutional Roles and Responsibilities for the Regulation of E-Waste Management in Egypt.

Ministries

Authorities and Affiliates

Roles and Responsibilities

Ministry of

Investment

Investment Authority

  • – Issuing registration documents for recycling companies such as commercial registers, tax cards and added-value certificates.

Ministry of

Environment

Egyptian Environmental Affairs Agency (EEAA)

  • – Issuing environmental approvals for e-waste management facilities.

Waste Management Regulatory Authority (WMRA)

  • – Granting specific licenses for e-waste treatment facilities, including recyclers and landfills.

  • – Monitoring the implementation of environmental management plans for all facilities involved in e-waste management.

  • – Monitoring the flow of e-waste especially through special auctions

Ministry of

Industry

Industrial Development Authority (IDA)

  • – Issuing operation licenses and industrial registration for recycling facilities.

  • – Overseeing operational procedures in collaboration with the EEAA and WMRA.

Ministry of

Interior

Civil Defense Authority

  • – Reviewing firefighting and alarm systems at recycling facilities and issuing formal certificates to ensure compliance with all firefighting code requirements.

 

2.4 Transboundary Movement of WEEE between Egypt and Other Countries

The transboundary movement of WEEE refers to its international transport across various borders. Many developed nations, including the United States, Japan, and European Union countries, often send their old second equipment or e-waste to developing countries where labor is cheaper and environmental regulations may be less stringent. Developing nations have become popular destinations for e-waste, both legally and illegally. These regions may have inadequate infrastructure for proper recycling and disposal, leading to severe environmental and health impacts.

Because of this dynamic, WEEE’s transboundary waste movement is regulated by various international agreements like the Basel Convention [4] (1989, 2019 and subsequent amendments). This primary international treaty governing the movement of hazardous waste aims to reduce the movement of hazardous waste between countries, particularly from developed to developing nations, and to ensure that such waste is disposed of in an environmentally sound manner. Under it, exports of e-waste to countries that cannot manage it properly are prohibited unless they provide explicit consent.

Egypt ratified the Basel Convention through Law No. 4/1994, highlighting the country’s recognition of the environmental and health risks posed by improper e-waste disposal and its alignment with international efforts to address the global e-waste crisis.

Through WMRA and the national Basel focal point, Egypt, follows a set of procedures aligned to Basel [1], regulating e-waste import and export to prevent illegal dumping and ensure environmentally sound operations. Before moving any WEEE, companies operating in Egypt must notify officially the competent authorities in both the exporting and importing countries. This process is designed to ensure that the receiving country has the capacity to handle the waste safely and is willing to accept it. The company, through the Egyptian authority, shall receive written and explicit consent allowing the movement. The procedure request can be fulfilled electronically, allowing for digital submission of the application form, required data, and documents.

Egypt’s WMRA must ensure that all shipments of hazardous waste are accompanied by appropriate documentation that complies with Basel Convention guidelines. This includes details on the type of waste, its intended destination, and the method of disposal or recycling. Required documents include:

  • A copy of the registration card in the registry of exporters/ importers
  • Filled-in notification document/form and movement document
  • A copy of the contract between the exporter and the importing company
  • Results of waste analysis from an accredited laboratory
  • Financial security/insurance
  • Importing company license
  • Description of the technology used
  • Environmental Impact Assessment (EIA) approval, in case requested due to the perceived potential risks of the export, particularly due to heavy metals found in e-waste.
  • Tracking and monitoring documentation. The exporter must track the waste until it is received and properly processed by the importing country. Documentation to this effect must also be submitted to WMRA.

Under the Basel Convention’s provisions, Egypt prohibits the illegal export of hazardous waste, including e-waste, to countries that cannot handle such waste safely or where environmental standards are inadequate. Any attempts to circumvent the regulations—such as mis-labelling e-waste as non-hazardous goods—are subject to legal penalties. WMRA may take enforcement actions also if it detects illegal shipments of waste, including imposing penalties on companies or individuals who attempt to export e-waste without the necessary permits or consent.

Egypt is also required to provide periodic reports to the Basel Convention Secretariat on the transboundary movement of hazardous waste. This includes reporting any exports of e-waste and their final disposal or recycling outcomes. The aim is to increase transparency and ensure that exported e-waste is processed in accordance with environmental standards.

Further and refined import/export requirements are included in Decree 165/2002 (amended by Decree 489/2017); Decision of the Minister of Trade and Supply No. 194 for the year 1997; Decision of the Minister of Trade and Industry No. 770 of 2005, and Decree No. 603 of 2007 of the Minister of Trade and Industry.

2.5 An EPR System for WEEE in Egypt

The legislative environment for Extended Producer Responsibility (EPR) in Egypt is still developing as part of the country’s strategy to manage WEEE. EPR, as defined by the OECD, extends a producer’s responsibility to the post-consumer phase of a product’s life cycle, including collection, recycling and disposal.

Article 17 of Egypt’s Waste Law No. 202/2020 lays the groundwork for EPR by empowering the Prime Minister to issue decrees outlining which products should be subject to EPR, the procedures for implementation, and the financial obligations of producers. However, it leaves many details to be determined later, reflecting the need for ongoing consultation and adaptation. While private sector initiatives and development cooperation programs such as the Sustainable Recycling Industries (SRI) program have made progress in shaping EPR in Egypt with a focus on ICT equipment (Category 1 according to chapter 1.1) through a comprehensive stakeholder engagement process, clarity is needed in the Prime Minister’s Decree and executive regulations to define “safe disposal” to include recycling and to specify WMRA’s role in implementing EPR. These adjustments are crucial for creating a functional and sustainable e-waste management system in Egypt.

2.6 Occupational Health and Safety Requirements for Handling WEEE in Egypt

The Egyptian Labor Law 12/2003 includes several provisions related to the health and safety of workers in the workplace, forming a legal framework to protect workers’ rights and ensure a safe working environment when managing e-waste. The most prominent provisions are as follows:

  • Article 205 – Occupational Health and Safety: “The employer must take all necessary measures to protect the health and safety of workers while performing their work,” including providing a work environment free from risks that could cause injuries or occupational diseases.
  • Article 206 – Preventive Measures: obligates the employer to provide the necessary preventive measures to protect workers from potential hazards, such as protective equipment (helmets, gloves, masks), especially in e-waste recycling.
  • Article 207 – Health Monitoring: requires the employer to conduct periodic medical examinations for workers exposed to occupational health risks. For example, workers in e-waste recycling should undergo regular health checks to detect exposure to toxic substances.
  • Article 208 – Training and Awareness: requires that the employer provides the necessary training for workers on the safe use of equipment and machinery, as well as educating them on preventive measures and how to handle potential hazards in the workplace.
  • Article 209 – Reporting and Compensation: mandates that the employer reports any accidents or injuries that occur in the workplace to the relevant authorities and provides appropriate financial compensation to workers who are injured or suffer from occupational diseases.
  • The labor law also encourages adherence to international standards related to health and safety, such as ILO conventions, to ensure the highest levels of safety in the workplace.
  • Article 43 of Law 4/1994 and 9/2009 and  its amendments and executive regulations: includes other workplace requirements.

While Egyptian labor law provides a solid legal framework for worker protection, the effective implementation of these provisions may face challenges, particularly in the informal e-waste recycling sector, where enhanced monitoring and enforcement mechanisms are needed to ensure a safe and healthy work environment for all workers.

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