The UAE has introduced a more detailed and time-sensitive enforcement framework for combating commercial fraud through Cabinet Resolution No. (107) of 2026 (“Regulation”), concerning the Executive Regulations of Federal Decree-Law No. (42) of 2023 on Combating Commercial Fraud.
These Laws/Regulations focuses on preventing the sale and circulation of counterfeit, adulterated, defective, or unsafe products, and on prohibiting misleading practices regarding a product's nature, origin, quality, or specifications.
The Regulation was issued on 13 July 2026, published in Official Gazette No. 827 on 14 July 2026, and entered into force on 13 August 2026, repealing the previous Executive Regulations issued in 2020.
The new framework regulates the inspection, sampling, examination, recall, public notification, reporting, treatment, re-export, recycling and destruction of counterfeit, adulterated and spoiled goods. It also provides for co-ordination between Competent Authority and Ministry of Economy, particularly in Multi-Emirate matters, as well as intervention of the Ministry in particular situations.
Its practical significance lies in the specific deadlines imposed throughout the enforcement and recall process.
Within 24 hours of receiving the notification, the supplier must: withdraw the goods from markets and warehouses; and notify all sales outlets and other places such goods have been supplied to, to withdraw such goods within 24 hours, recover them and remove them from circulation.
The supplier must also provide evidence of the notification, withdrawal and recovery measures to the Ministry or competent authority.
The practical implication is clear: businesses need effective product traceability systems capable of identifying affected goods, their locations and recipients without delay.
The supplier must announce the recall through the means specified by the Ministry or competent authority, including visual, audio, electronic and printed media, within 48 hours of receiving the notification. This period may be shortened, particularly where the goods pose risks to human, animal or environmental health or safety.
The announcement must include key information such as the supplier’s contact details and relevant trademark; the type, model, description and country of origin of the goods; instructions for returning the goods and obtaining a refund; and the withdrawal period and designated collection locations.
Importantly, the announcement must be made in both Arabic and English.
Where goods are distributed across multiple Emirates or present serious risks, the Ministry may coordinate with the competent authorities to unify the announcement’s form, timing or scope.
The report must include key information, including: the type, description and quantities of the goods held, including their source and locations; quantities sold or distributed and the relevant markets or recipients; quantities withdrawn and their value; and quantities refunded to customers, including their names and addresses.
The Ministry or competent authority may also request additional documents, information or periodic reports as necessary.
Accordingly, accurate record-keeping is an essential part of recall compliance, not merely an administrative requirement.
If the supplier fails to withdraw the affected goods within the 24-hour period under Article 5, the Ministry or competent authority may undertake the withdrawal from markets and warehouses within the following 48 hours, at the supplier’s expense.
If the supplier cannot be located or notified, the authorities may also undertake the recall within 48 hours of establishing the existence of the affected goods, and the associated costs shall be recovered from the supplier.
Where the failure to carry out the recall is committed knowingly, the supplier will also face applicable administrative sanctions, in addition to the recovery of costs and expenses set out above. Accordingly, failure to act within the prescribed timeframe may result in both regulatory intervention and additional financial exposure.
Where required, inspections may also extend to electronic devices, networks, information systems, computer programs and other technological means relevant to the inspection.
As a general rule, the inspection must be completed within 5 working days from commencement, unless the circumstances justify a longer period.
Businesses should therefore ensure that relevant procurement, inventory, distribution, sales and digital records can be readily identified and produced when required.
The examination and analysis should generally be completed within 15 working days from sampling, unless the nature of the goods or examination requirements justify otherwise. For perishable goods, the period is determined by the accredited laboratory in coordination with the Ministry or competent authority.
If the results confirm that the goods are not counterfeit, adulterated or spoiled, the precautionary measures must be lifted and the goods released within 3 working days of the receiving the results.
The supplier is not entitled to compensation for the samples or for the examination and analysis costs.
Requests for use, recycling or destruction are considered by the Higher Committee before referral to the competent court.
Where re-export is permitted, the supplier must return the goods to the country of origin or export within 30 days from seizure, at its own expense, provided the goods are capable of re-export and pose no health, safety or environmental risks.
Where destruction is ordered, it must generally be completed within 15 working days from the relevant judgment or decision, unless otherwise determined. Related costs may be charged to the supplier.
A violator or its representative may submit a written settlement request within 10 working days from notification of the violation and applicable fine, or from rejection of a grievance, as applicable and the Ministry or competent authority must decide the request within 15 working days, failing which it is deemed rejected.
Settlement is not available where, among other conditions, the violator was previously fined under the Federal Decree-Law within the preceding 12 months; committed the violation intentionally or in bad faith; failed to remove the causes of the violation; or does not satisfy the other statutory requirements.
The Regulation also sets out a review mechanism for rejections of settlement requests.
Businesses should review whether they can:
Note: This Legal Update / Newsletter is intended for general informational purposes only and should not be construed as legal advice. It is based on laws and legal interpretations in effect as of the date of publication. Laws and regulations may change over time, and their application can vary depending on individual circumstances. Readers are strongly encouraged to seek specific legal counsel before acting on any of the information provided herein.
These Laws/Regulations focuses on preventing the sale and circulation of counterfeit, adulterated, defective, or unsafe products, and on prohibiting misleading practices regarding a product's nature, origin, quality, or specifications.
The Regulation was issued on 13 July 2026, published in Official Gazette No. 827 on 14 July 2026, and entered into force on 13 August 2026, repealing the previous Executive Regulations issued in 2020.
The new framework regulates the inspection, sampling, examination, recall, public notification, reporting, treatment, re-export, recycling and destruction of counterfeit, adulterated and spoiled goods. It also provides for co-ordination between Competent Authority and Ministry of Economy, particularly in Multi-Emirate matters, as well as intervention of the Ministry in particular situations.
Its practical significance lies in the specific deadlines imposed throughout the enforcement and recall process.
A 24-hour recall obligation
Legal basis: Article 5
Where the Ministry or competent authority establishes that goods are counterfeit, adulterated or spoiled and requires their recall, the Ministry shall notify the Supplier to immediately stop selling or offering the goods for sale.Within 24 hours of receiving the notification, the supplier must: withdraw the goods from markets and warehouses; and notify all sales outlets and other places such goods have been supplied to, to withdraw such goods within 24 hours, recover them and remove them from circulation.
The supplier must also provide evidence of the notification, withdrawal and recovery measures to the Ministry or competent authority.
The practical implication is clear: businesses need effective product traceability systems capable of identifying affected goods, their locations and recipients without delay.
Public recall announcements within 48 hours
Legal basis: Article 6
The recall process is followed by a separate public notification requirement.The supplier must announce the recall through the means specified by the Ministry or competent authority, including visual, audio, electronic and printed media, within 48 hours of receiving the notification. This period may be shortened, particularly where the goods pose risks to human, animal or environmental health or safety.
The announcement must include key information such as the supplier’s contact details and relevant trademark; the type, model, description and country of origin of the goods; instructions for returning the goods and obtaining a refund; and the withdrawal period and designated collection locations.
Importantly, the announcement must be made in both Arabic and English.
Where goods are distributed across multiple Emirates or present serious risks, the Ministry may coordinate with the competent authorities to unify the announcement’s form, timing or scope.
Five working days to report on the recall
Legal basis: Article 7
The supplier must submit a recall report within 5 working days from the commencement of the recall.The report must include key information, including: the type, description and quantities of the goods held, including their source and locations; quantities sold or distributed and the relevant markets or recipients; quantities withdrawn and their value; and quantities refunded to customers, including their names and addresses.
The Ministry or competent authority may also request additional documents, information or periodic reports as necessary.
Accordingly, accurate record-keeping is an essential part of recall compliance, not merely an administrative requirement.
Failure to recall may trigger regulatory intervention and administrative sanctions
Legal basis: Articles 8, 9 and 10
The Regulations provide for regulatory intervention where a supplier fails to carry out the required recall.If the supplier fails to withdraw the affected goods within the 24-hour period under Article 5, the Ministry or competent authority may undertake the withdrawal from markets and warehouses within the following 48 hours, at the supplier’s expense.
If the supplier cannot be located or notified, the authorities may also undertake the recall within 48 hours of establishing the existence of the affected goods, and the associated costs shall be recovered from the supplier.
Where the failure to carry out the recall is committed knowingly, the supplier will also face applicable administrative sanctions, in addition to the recovery of costs and expenses set out above. Accordingly, failure to act within the prescribed timeframe may result in both regulatory intervention and additional financial exposure.
Inspections may extend to digital systems
Legal basis: Article 3
Where necessary or where there are grounds to suspect counterfeit, adulterated or spoiled goods, judicial officers may inspect commercial premises, warehouses, factories and other non-residential locations.Where required, inspections may also extend to electronic devices, networks, information systems, computer programs and other technological means relevant to the inspection.
As a general rule, the inspection must be completed within 5 working days from commencement, unless the circumstances justify a longer period.
Businesses should therefore ensure that relevant procurement, inventory, distribution, sales and digital records can be readily identified and produced when required.
Laboratory examination within 15 working days
Legal basis: Article 3
Judicial officers may take samples of suspected goods for examination and analysis. Samples must be collected by a qualified technician appointed by the Ministry or competent authority and same should be referred to specialised accredited laboratories, with all costs borne by the supplier.The examination and analysis should generally be completed within 15 working days from sampling, unless the nature of the goods or examination requirements justify otherwise. For perishable goods, the period is determined by the accredited laboratory in coordination with the Ministry or competent authority.
If the results confirm that the goods are not counterfeit, adulterated or spoiled, the precautionary measures must be lifted and the goods released within 3 working days of the receiving the results.
The supplier is not entitled to compensation for the samples or for the examination and analysis costs.
What happens to the affected goods?
Legal basis: Articles 11–19
The Regulations establish a structured framework for dealing with affected goods following seizure or recall. Depending on the circumstances and applicable approvals or judicial orders, goods may be used, recycled, re-exported or destroyed.Requests for use, recycling or destruction are considered by the Higher Committee before referral to the competent court.
Where re-export is permitted, the supplier must return the goods to the country of origin or export within 30 days from seizure, at its own expense, provided the goods are capable of re-export and pose no health, safety or environmental risks.
Where destruction is ordered, it must generally be completed within 15 working days from the relevant judgment or decision, unless otherwise determined. Related costs may be charged to the supplier.
Settlement is a regulated mechanism, not an automatic right
Legal basis: Articles 21 and 22
The Regulations also establishes a formal settlement procedure for persons violating the provisions set out therein.A violator or its representative may submit a written settlement request within 10 working days from notification of the violation and applicable fine, or from rejection of a grievance, as applicable and the Ministry or competent authority must decide the request within 15 working days, failing which it is deemed rejected.
Settlement is not available where, among other conditions, the violator was previously fined under the Federal Decree-Law within the preceding 12 months; committed the violation intentionally or in bad faith; failed to remove the causes of the violation; or does not satisfy the other statutory requirements.
The Regulation also sets out a review mechanism for rejections of settlement requests.
Key compliance timelines at a glance
| Regulatory Requirement | Timeline | Legal Basis |
| Supplier to take recall measures and notify relevant sales outlets/entities | Within 24 hours of receiving notification | Article 5 |
| Sales outlets and supplied entities to withdraw affected goods | Within 24 hours of receiving notification | Article 5 |
| Public recall announcement | Within 48 hours of receiving notification | Article 6 |
| Recall report | Within 5 working days from commencement of recall | Article 7 |
| General inspection | Up to 5 working days, unless otherwise justified | Article 3 |
| Laboratory examination and analysis | Up to 15 working days, subject to exceptions | Article 3 |
| Release following negative examination result | Within 3 working days from results | Article 3 |
| Ministry intervention following competent authority’s failure to act | After 10 working days from notification, subject to Article 2 | Article 2 |
| Government-led recall following supplier’s failure | Within the following 48 hours | Article 8 |
| Re-export, where applicable | Within 30 days from seizure | Article 15 |
| Destruction following relevant judgment/decision | Within 15 working days, unless otherwise determined | Article 18 |
| Settlement request | Within 10 working days | Article 21 |
| Consideration of settlement request | Within 15 working days | Article 21 |
| Payment following approved settlement | Within 5 working days from signing the settlement record | Article 21 |
| Grievance against settlement rejection | Within 7 working days | Article 21 |
| Decision on settlement grievance | Within 10 working days | Article 21 |
Conclusion: What businesses should review now
The Regulations establish a compliance chain extending from inspection and laboratory examination to recall, public notification, reporting, regulatory intervention and the final treatment of affected goods.Businesses should review whether they can:
- Trace affected goods quickly across the supply chain.
- Activate and document recall procedures within the prescribed timelines.
- Coordinate with distributors and retailers to ensure timely withdrawal.
- Maintain accessible records and bilingual recall communications.
- Clearly allocate recall-related responsibilities and costs under commercial agreements.
Note: This Legal Update / Newsletter is intended for general informational purposes only and should not be construed as legal advice. It is based on laws and legal interpretations in effect as of the date of publication. Laws and regulations may change over time, and their application can vary depending on individual circumstances. Readers are strongly encouraged to seek specific legal counsel before acting on any of the information provided herein.