Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

Minimum Age Convention, 1973 (No. 138) - Egypt (Ratification: 1999)

Article 1 of the Convention. National policy on the effective abolition of child labour and application of the Convention in practice. Following its previous comments, the Committee notes the Government’s information, in its report, that it continues to implement the National Action Plan to Combat the Worst Forms of Child Labour and Supporting Family 2018–25 (NAP-WFCL). The Committee notes, from a November 2024 Egypt Factsheet on the implementation of the programme to accelerate the action of the elimination of child labour in global supply chains (ACCEL Africa), that ACCEL Egypt has supported the Ministry of Labour in establishing the NAP National Steering Committee (NSC) to serve as the main national coordinating mechanism to eliminate child labour in Egypt. The Government provides information about a number of measures taken in the framework of the NAP-WFCL, including:

• enhancing knowledge on child labour through awareness-raising programmes, including for the beneficiaries of the “Takaful” and “Karama” social protection programmes;
• strengthening and coordinating the legislative and institutional frameworks to combat child labour, including through the adoption of Ministerial Decision No. 78 of 2021, which establishes an executive Child Protection Unit to oversee the NAP implementation progress and serves as the permanent institutional mechanism to support child labour elimination in Egypt, and the promulgation of Ministerial Decision No. 767 of 2022 issuing bylaws regulating the Child Labour Centres at the national level;
• strengthening the monitoring, protection and prevention of children from child labour through technical capacity-building, including through training workshops for the relevant bodies, such as labour inspectors, employees at the child labour combat centres, and others;
• promoting the practice of prevention and protection in combating child labour, through such initiatives as reviewing the National Council for Childhood and Motherhood (NCCM)’s Standard Operating Procedures (SOPs), which handle the identification, referral and management procedures and mechanisms for different groups of children involved in child labour, setting up child labour focal points in employers’ and workers’ organizations, and coordinating with the ACCEL Africa Programme and Better Work Project to develop a code of conduct on child labour for employers;
• promoting training, apprenticeships and dual education to combat child labour, through which 20,653 apprenticeship contracts were concluded between 2020-24 for children between 15 and 18 years and 50,000 trainees aged 15 to 18 were enrolled in dual education;
• promoting awareness and social mobilization to combat child labour, through initiatives such as a publication by the Directory of Public Services for Child Protection and Family Support aiming to sensitize families of working children as to the services provided by the State in all sectors.

The Committee notes, from a 2024 UNICEF Egypt Data Snapshot, that a 2021 Egypt Family Health Survey (EFHS) showed that 1.3 million children (4.9 per cent) were engaged in child labour activities, with 900,000 exposed to hazardous work environments. The survey showed that children in rural areas, especially in rural Upper Egypt, were twice as likely to be engaged in child labour compared to those in urban areas, and 10 per cent of children not attending school were in child labour. The Committee observes, from the 2024 ACCEL Africa Egypt factsheet, that the Central Agency for Public Mobilization and Statistics (CAPMAS) conducted the National Survey for Child Labour 2023 to update the outdated national statistics of 2010. The Committee notes with deepconcern that, according to the survey results, 4.2 million children are working in Egypt, out of which 3.7 million are engaged in hazardous forms of work, and that this represents a significant increase when compared to the 1.59 million children who were estimated to be in child labour according to the previous National Child Labour Survey of 2010, and the 1.3 million children found in child labour through the 2021 EHFS. The Committee therefore urges the Government to continue strengthening its efforts to ensure the progressive elimination of child labour. It requests that the Government continue providing information on the measures taken in the framework of the NAP-WFCL, and to provide information on the results achieved in terms of the number of children who are effectively removed from child labour. It also requests the Government to take measures to identify the factors leading to the significant increase in the incidence of child labour since 2021.

Article 7. Determination of types of light work. The Committee notes with regret that the Government’s report provides no new information on any progress made in reviewing section 64 of the Child Law. As previously noted, since the general minimum age for admission to work or employment is 15 years in Egypt, the minimum age for light work should be set at 13 years. Currently, section 64 of the Child Law permits children between the ages of 12 and 14 years to perform light seasonal work. The Government reiterates that a new child law – which will be named Child Rights Law – is currently being reviewed by the concerned authorities and that this new draft will prohibit the employment of children under 15 years generally, with the only exception being apprenticeships or trainings from the age of 14. The new draft law will therefore not permit the employment of children under 15 in any work, including any light work, seasonal or otherwise. The Committee therefore urges the Government to take the necessary measures to ensure that the review of the Child Law is completed as soon as possible and that, as a result, section 64 is amended to remove the possibility for children performing light seasonal work from the age of 12.

Labour inspection. The Committee notes the Government’s information that the Ministry of Labour, through the labour directorates at the level of the governorates, continues to prepare annual plans for field visits aimed at inspecting child labour in accordance with the Labour Code of 2003, the Child Law of 2008 and, more recently, Ministerial Decree No. 215 of 2021. In this regard, the Committee notes that, in the framework of the NAP-WFCL and the provision of technical support by the ACCEL Africa Project to the Ministry of Labour, measures have been taken to strengthen the capacity of labour inspectors on using a new digitalized inspection system.

The Committee notes the statistics provided by the Government for the period 2014 to 2023, notably: 174,103 undertakings inspected with children specifically targeted; 8,418 surprise inspection campaigns undertaken; 28,618 warnings addressed to employers found in violation; 3,295 minutes drafted against employers found in violation; and 81,370 children who were reached and protected. Furthermore, the Government indicates that 162 inspection campaigns were launched between 2023 and the first half of 2024 in several governorates to activate Ministerial Decree No. 215 of 2021 focusing on bakeries, the glass and aluminium industries and brick making, and that 35 minutes were immediately drafted against violating employers as a result. In addition, the Government indicates that it has been intensifying inspection campaigns in labour-intensive undertakings, especially those that employ children or women or where employees work at night, and that 11,017 such undertakings were inspected in 2023. The Committee observes with regret, however, that the Government again does not provide specific information on the number of cases of child labour that were discovered, or on the number of penalties applied. The Committee requests the Government to continue taking measures to strengthen the capacity of the Labour Inspectorate to adequately detect cases of child labour and ensure the effective implementation of the relevant provisions of the national legislation, in particular Ministerial Decree No. 215 of 2021. It once again requests the Government to provide information related specifically to the number and nature of violations relating to the employment of children and young persons detected by the Labour Inspectorate and on the penalties imposed.

The Committee is raising other matters in a request addressed directly to the Government.