Exporting to the Emirates. The label is registered before selling.

In the Emirates compliance isn't a check at the border. It is a registration that happens beforehand, and without it the goods don't move.

This guide applies to food in general. For two products the path changes before the country does: wine travels with excise and its accompanying document, and olive oil has marketing and labelling standards all of its own. Whoever exports one of the two to the Emirates reads this guide and the product one.

This piece is part of the guide to export operations for the small food producer and it is deliberately short. In the Emirates responsibility is split between the federal level and the individual emirates, and operational details change from one local authority to another.

Who is in charge: two levels, not one

The Ministry of Climate Change and Environment has the main responsibility at federal level, and its approval is the gate for the first import. On the ground, however, the authorities of the individual emirates supervise: in Dubai the Municipality, in Abu Dhabi the agriculture and food safety authority, in Sharjah the municipal authorities.

The practical consequence is that «exporting to the Emirates» isn't a single procedure. The federal level decides whether the product can enter the country, the authority of the emirate where it is sold governs local checks and procedures. Asking the buyer which emirate they operate in isn't geographical curiosity.

Registering the label

The ZAD system is a federal platform that collects the data of food products. The written rule is that food, imported or locally produced, or modified in its label, ingredients or composition, must be registered in the system before being traded on the Emirati markets.

The surprising part is in the word «modified». Changing an ingredient, redoing the artwork, updating the nutritional values reopens the obligation: registration isn't a procedure closed once, it is a status to be kept aligned with the real product.

In the Emirates a label change doesn't end with marketing. It reopens an obligation, and with it the lead times.

Mandatory information and language

Obligation	Level	What it means for you
First import approvalfederal ministry	Federal. No food enters for the first time without the ministry's approval.	It should be put in the calendar before negotiating volumes: it is the step that can't be compressed.
Registration in the ZAD systemproduct data	Federal, managed together with the local authorities. It concerns every product and every change to it.	You need a complete and stable technical sheet. Every change of recipe or artwork reopens the file.
Compliant labelEmirati standard	Federal, with local checks. Mandatory information follows the Emirati standard on labelling of prepackaged food.	The European label isn't enough as it is. The check should be done before printing the batch, not after.
Checks on the groundemirate authority	Local: Dubai Municipality, the Abu Dhabi authority, Sharjah's municipal authorities.	Ask the buyer which emirate they operate in, because procedures and contacts change.

On the content of the label, the government portal states that packs must have clear, non-removable labels, and that mandatory information follows the Emirati standard on labelling of prepackaged food. The field-by-field detail, and the language required, should be checked with the importer against the version of the standard in force.

The penalties, stated with their number

The government portal states that misleading consumers by publishing a false description of a food, or by using incorrect labels, carries a fine of between 10,000 and 100,000 dirhams. It is a useful number because it shows how much the market cares about the label.

For a small producer the practical reading isn't the risk of a penalty, which falls on whoever places the product on the market: it is that an importer aware of that figure will be very strict about your data, and will ask for a precise, up-to-date technical sheet before ordering.

Origin and duties

There is no free trade agreement being applied between the European Union and the Emirates, so there is no preferential origin and no EUR.1 to produce. The document that may be requested is the Chamber of Commerce certificate of origin, often legalised, which attests the «made in» without reducing the duty.

The version with legalisation stamp has a stated Chamber cost: the Lecce Chamber of Commerce gives €8. The difference between origin documents, and when each is needed, is in EUR.1 or certificate of origin.

When every change reopens a file

A market where changing an ingredient reopens a registration punishes exactly the companies that don't keep track of their own versions. If you don't know which sheet was used to register, you don't know when the registration went out of alignment either.

That is the point where product data should be taken out of scattered files and put in a single place from which the versions are generated, with language versions generated from the same base. With a constraint that matters more than the technology, written in Ethics: the system prepares and flags, but no document reaches a buyer without a person having read and approved it.

Questions and answers