The UAE has introduced a more detailed enforcement framework for combating commercial fraud, placing suppliers under strict timelines to stop the sale, withdraw and publicly announce counterfeit, adulterated and spoiled goods.

Cabinet Resolution No. 107 of 2026, concerning the Executive Regulation of Federal Decree by Law No. 42 of 2023 on Combating Commercial Fraud, was issued on 13 July 2026 and entered into force on 13 August 2026. It replaces Cabinet Resolution No. 11 of 2020, which implemented the previous commercial fraud law. More importantly, it sets out what businesses and authorities must actually do when fraudulent, spoiled or counterfeit goods are identified — from inspecting and testing the products to withdrawing them from the market, informing consumers, and ultimately returning, recycling or destroying them.

The reform is therefore not simply a change in the penalties for commercial fraud. The 2023 Federal Decree-Law already established the substantive prohibitions and criminal penalties. Resolution No. 107 of 2026 primarily sets out how those rules are to be enforced in practice, introducing defined responsibilities and short deadlines for businesses once fraudulent, spoiled or counterfeit goods are identified.

For businesses operating across the UAE, the practical consequence is a compliance framework in which product traceability, supplier records, recall procedures and rapid internal response become increasingly important.

From the 2016 Framework to the 2026 Executive Regulations

Federal Decree by Law No. 42 of 2023 replaced the earlier commercial fraud legislation and broadened the federal framework applicable to commercial fraud across the UAE, including free zones. Article 4 prohibits the import, export, production, manufacture, display, sale, storage, transportation, marketing, trading, promotion or disposal of fraudulent, spoiled or counterfeit goods, as well as possession of such goods for sale and attempts to carry out these acts.

The 2023 legislation also imposes obligations on providers to maintain commercial records and supporting invoices and documents and to provide product information in accordance with applicable UAE requirements. It further protects bona fide customers by requiring providers to refund the value of fraudulent, spoiled or counterfeit goods, or exchange them according to the customer’s preference, without prejudice to a separate right to compensation.

The new Executive Regulation adds the operational layer to this framework. It establishes the mechanism through which authorities identify suspected goods, conduct technical examination, order withdrawal, notify consumers, and determine whether goods should ultimately be returned, recycled or destroyed.

This is significant because the regulatory response is now structured around a sequence of specific deadlines rather than a general obligation to remove non-compliant products.

Federal and Local Authorities: A Coordinated Enforcement Framework

Resolution No. 107 of 2026 establishes a coordination mechanism between the Ministry of Economy and Tourism and the competent authority in each Emirate.

Ordinarily, the competent local authority exercises powers relating to the withdrawal, disposal, destruction or return of fraudulent, spoiled or counterfeit goods. However, the Ministry may intervene where the local authority does not exercise those powers within 10 working days of being notified, declines to act, or where the goods are distributed across more than one Emirate. The Ministry may also take action where the goods present serious risks to human, animal or environmental health and safety or where measures at the State level are required.

This is particularly relevant where a product moves through several parts of the UAE’s supply chain. A recall is not necessarily confined to the Emirate in which the product was first detected. The framework permits federal coordination where distribution extends across multiple Emirates, helping authorities standardise the timing and scope of the withdrawal.

For suppliers, this makes internal visibility across warehouses, distributors and points of sale particularly important. A business that cannot quickly identify where affected goods have been supplied may face difficulty complying with the recall obligations once notification is received.

Inspection and Testing: The Compliance Process Before Recall

The Resolution also formalises the procedure for investigating suspected goods.

Judicial enforcement officers may enter commercial premises, warehouses, factories, establishments and other non-residential locations to inspect suspected goods. Where necessary, they may also examine electronic devices, networks, equipment, electronic media, storage media, information systems, software and other technological means relevant to the inspection. The inspection is generally to be completed within five working days from commencement, unless the requirements of the inspection justify a longer period.

Where samples are required, they must be taken by a qualified technician using an appropriate sampling method and sent to specialised accredited laboratories designated by the Ministry or competent authority. Laboratory examination is generally to be completed within 15 working days from the date the sample was taken, subject to exceptions based on the nature of the goods, particularly perishable products.

During this process, suspected goods may remain detained at the supplier’s premises and at the supplier’s expense. Importantly, the supplier is not entitled to compensation for the value of samples taken or the costs of examination and analysis.

There is also a corresponding safeguard where the suspicion is not confirmed. If technical examination establishes that the goods are not fraudulent, spoiled or counterfeit, the enforcement officer must record the result, lift the detention and release the goods, with notification to the supplier within three working days from the issuance of the examination or analysis results.

The result is a more structured enforcement process: suspicion triggers investigation and testing, while confirmed non-compliance moves the matter into the recall and disposal framework.

The 24-Hour Recall Obligation

The most significant change for suppliers is the formalised 24-hour withdrawal requirement.

Once the Ministry or competent authority establishes that fraudulent, spoiled or counterfeit goods exist and decides that they must be withdrawn, the supplier must immediately stop selling or offering those goods for sale. Within no more than 24 hours of receiving the notification, the supplier must:

• withdraw the affected goods from markets and warehouses;
• notify every point of sale and entity to which the goods were supplied;
• require those entities to withdraw the goods within 24 hours of receiving the notification; and
• provide evidence to the authority that the notification, withdrawal and recovery procedures have been completed.

The detained goods cannot then be disposed of freely and are to be held in designated premises at the offender’s expense. Authorities may also issue public warnings identifying the affected goods and associated trademarks.

The practical importance of the 24-hour period is that a supplier cannot treat recall as a conventional administrative exercise that can be handled over several days. Internal escalation procedures, inventory systems and communication channels need to be capable of responding once an official notification is received.

Public Recall Notices Must Be Published Within 48 Hours

The new framework also moves beyond private notification between regulators and businesses.

Under Article 6, the supplier must publicly announce the withdrawal of the relevant goods through the advertising media determined by the Ministry or competent authority within 48 hours of receiving the notification. The authority may shorten this period where the goods present risks to human, animal or environmental health and safety.

The notice must contain sufficient information for consumers to identify the affected product and understand what they should do. Among other requirements, it must specify the supplier’s contact information, the trademark, the type, model and description of the goods, the country of origin and the procedures for obtaining a refund.

The announcement must be published in both Arabic and English. Printed or electronic notices must generally meet a minimum size of 15 cm by 15 cm, or the equivalent digital format, subject to the requirements applicable to the particular advertising medium.

This makes the recall process not only a product-removal exercise but also a consumer-information obligation. Businesses need to be able to communicate rapidly and accurately once a recall is ordered.

Five Working Days to Account for the Recall

The obligations do not end once goods are removed from circulation.

Within five working days from the commencement of withdrawal procedures, the supplier must submit a report to the Ministry or competent authority detailing the steps taken. The report must include information concerning the type and description of the goods, remaining quantities, goods already sold or distributed, quantities withdrawn and the quantities and value for which refunds have been issued. The authority may also request additional documents, data or periodic reports.

This reporting requirement has an important compliance consequence. Businesses must be able to reconstruct the movement of affected goods through their supply chain, not merely identify the stock remaining in their own warehouses.

Invoices, distribution records, inventory data, customer records and supplier information may therefore become relevant to demonstrating that the recall was actually completed.

What Happens When a Supplier Does Not Act?

The Resolution provides a mechanism for authorities to step in where the supplier fails to comply.

If a supplier does not withdraw the goods within the prescribed 24-hour period, the Ministry or competent authority must take the necessary measures to withdraw them from markets and warehouses within the following 48 hours. The costs are borne by the supplier.

Failure to withdraw the goods does not prevent the imposition of administrative penalties where the supplier knowingly refused or failed to act. The Resolution therefore creates two separate consequences: the authority can undertake the physical withdrawal itself, while the supplier may still face the applicable administrative sanctions.

The underlying 2023 Decree-Law separately provides for criminal penalties. Violations of Articles 4, 5, 8 and 11 may attract imprisonment of up to two years and/or a fine between AED 5,000 and AED 1 million. Where specified aggravating circumstances apply, including where the goods or materials are harmful to human or animal health and safety or involve medical drugs, agricultural crops or organic food products, the fine can rise to between AED 100,000 and AED 2 million.

Accordingly, the 24-hour recall obligation should not be viewed in isolation from the wider enforcement consequences of the parent legislation.

Return, Recycling and Destruction of Non-Compliant Goods

The Executive Regulation also establishes what happens after fraudulent, spoiled or counterfeit goods have been withdrawn.

Where the relevant conditions are satisfied and no destruction order has been issued, the supplier may be required to return the seized goods to the country of origin or country of export within 30 days from seizure, at the supplier’s expense. Re-export is permitted only where the nature of the goods allows it and the return does not create health, safety or environmental risks.

The framework also recognises recycling and other forms of controlled disposal. Where goods are to be destroyed following a decision of the Supreme Committee for Combating Commercial Fraud or a competent court judgment, the destruction must generally be carried out within 15 working days from the relevant decision or judgment, unless the competent authority specifies otherwise. The process must ensure that the goods cannot be reused or circulated and must not create direct or indirect environmental or health harm.

Where counterfeit goods are being considered for an alternative use or recycling, the framework also requires safeguards against infringement of intellectual property rights and requires counterfeit trademarks to be removed before the goods are disposed of again.

The result is a controlled lifecycle for non-compliant goods: they may be withdrawn, detained, returned, recycled or destroyed, but each route is subject to regulatory controls rather than leaving disposal to the supplier’s discretion.

Liability Can Extend Beyond the Original Supplier

The 2026 framework also addresses situations in which a customer or other market participant knowingly deals with fraudulent, spoiled or counterfeit goods.

Article 20 permits an administrative fine to be imposed on a customer where it is established that the customer knew, or ought to have known by virtue of their profession, trade or expertise, that the goods or materials used in their fraudulent alteration were harmful to human or animal health and safety.

The provision identifies circumstances including pharmaceutical products, agricultural produce and organic food products; reintroducing goods into circulation after they have been established to be unfit; purchasing fraudulent or counterfeit goods for unlawful trading gain; and promoting or marketing such goods through misleading or deceptive information.

This is important for businesses operating further down the supply chain. Commercial fraud compliance cannot be treated solely as a manufacturer’s responsibility. Traders and other professional market participants must also consider whether the products they acquire, distribute or promote raise obvious compliance concerns.

Settlement and Grievance Procedures

The Resolution does not eliminate the possibility of settlement in appropriate cases.

A person against whom a violation has been recorded may apply for settlement within 10 working days from notification of the violation and the applicable monetary fine, or from rejection of a grievance, as applicable. The Ministry or competent authority must generally decide the settlement application within 15 working days. A rejected settlement application may itself be challenged through a grievance within seven working days, with the relevant authority required to decide that grievance within 10 working days.

Settlement is not available in every situation. The Regulation requires, among other conditions, that the violation have resulted from error or negligence rather than bad faith or intent, that the causes of the violation have been remedied, and that the offender has not previously been fined under the Decree-Law during the preceding 12 months. Settlement also does not remove potential civil liability for damage suffered by an injured party.

This provides a mechanism for addressing certain compliance failures administratively while preserving the distinction between regulatory settlement and liability for consumer or third-party losses.

What Businesses Should Review

For businesses dealing with physical goods in the UAE, the new regulations make product-recall preparedness an important part of commercial compliance.

Suppliers should be able to identify the source and location of stock, establish which distributors and points of sale received affected goods, stop sales immediately following an official notification, communicate with customers and prepare the documentation necessary to demonstrate completion of the recall.

Particular attention should also be given to products with higher health and safety risks, including pharmaceutical products, agricultural produce and organic food products, which receive specific treatment under the regulatory framework.

The five-working-day reporting requirement makes accurate record keeping equally important. A business that cannot establish what quantities were sold, where they were distributed or what quantities were recovered may face practical difficulties demonstrating compliance even after it has begun withdrawing the product.

Looking Ahead

Cabinet Resolution No. 107 of 2026 represents an important development in the UAE’s commercial fraud framework because it translates the broad obligations of Federal Decree by Law No. 42 of 2023 into a detailed enforcement process with defined timelines.

The most immediate change for businesses is the 24-hour withdrawal requirement and the subsequent 48-hour public announcement obligation. But the broader reform goes further, covering inspection of physical and electronic records, accredited laboratory testing, supply-chain reporting, controlled return and disposal, and administrative settlement.

For suppliers and other market participants, the message is increasingly clear: commercial fraud compliance does not end with ensuring that goods are genuine when they enter the market. Businesses must also be capable of responding quickly when a product is found to be fraudulent, spoiled or counterfeit.

A robust compliance system should therefore include effective product traceability, documented recall procedures, clear internal responsibility for regulatory notifications, and mechanisms for preserving evidence of withdrawal and customer refunds.

As enforcement becomes more coordinated and time-sensitive, early legal and compliance review can help businesses identify weaknesses in their supply chains before a regulatory investigation turns a product issue into a wider commercial liability.

References

Federal Law by Decree No. 42 of 2023 Concerning Anti-Commercial Fraud, Ministry of Economy and Tourism https://www.moet.gov.ae/documents/20121/0/Federal%2BLaw%2Bby%2BDecree%2BNo.%2B%2842%29%2Bof%2B2023%2BConcerning%2BAnti-Commercial%2BFraud.pdf/c3d31431-e6bb-1a74-4608-719b04a073b2 accessed 7 October 2026.

Cabinet Resolution No. 107 of 2026 Regarding the Executive Regulation of Federal Decree by Law No. 42 of 2023 Regarding Combating Commercial Fraud, UAE Legislation Platform, as listed by the Ministry of Economy and Tourism https://www.moet.gov.ae/en/laws accessed 7 October 2026.

Ministry of Economy and Tourism, ‘Legislations – Consumer Protection and Commercial Control Legislations’ https://www.moet.gov.ae/en/laws accessed 7 October 2026.

Emirates News Agency (WAM), ‘Ministry of Economy and Tourism requires withdrawal of counterfeit goods within 24 hours under new regulations’ (3 September 2026) https://www.wam.ae/en/article/c227c2y-ministry-economy-tourism-requires-withdrawal accessed 7 October 2026.

Abdulla Rasheed, ‘New commercial fraud regulations come into force in the UAE today’ Gulf News (13 August 2026) https://gulfnews.com/uae/new-commercial-fraud-regulations-come-into-force-in-the-uae-today-1.500639896 accessed 7 October 2026.

‘New UAE anti-commercial fraud rules take effect’ Emirates 24|7 (13 August 2026) https://www.emirates247.com/uae/new-uae-anti-commercial-fraud-rules-take-effect-today/4505 accessed 7 October 2026.

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