UAE strengthens measures in relation to fraudulent and counterfeited goods: New Executive Regulation introduces strict recall and compliance obligations

The UAE Cabinet has issued Cabinet Resolution No. 107 of 2026, introducing the Executive Regulations to Federal Decree-Law No. 42 of 2023 on Combating Commercial Fraud (the Resolution).

The Resolution replaces the previous executive regulations and establishes a comprehensive enforcement framework governing how suspected fraudulent, spoiled and counterfeit goods are investigated, recalled, re-exported, recycled or destroyed. Its primary objective is to strengthen consumer protection and provide authorities with clearer powers and businesses with stricter compliance obligations, particularly in relation to product recalls and supply chain accountability.

The Resolution applies across the UAE, including free zones, and affects a broad range of businesses, including importers, exporters, manufacturers, distributors, traders, storage providers and transporters.

Expanded Investigation and Enforcement Powers

The Resolution significantly enhances enforcement powers.

Local authorities remain responsible for dealing with fraudulent, spoiled and counterfeit goods, but the Ministry of Economy and Tourism may intervene where a local authority fails to act, declines to exercise its powers, or where products are distributed across multiple Emirates or create significant health, safety or environmental risks.

Judicial enforcement officers may inspect commercial premises, warehouses, factories and other non-residential locations. Importantly, inspection powers extend to electronic devices, information systems, networks and digital records. Inspections should generally be completed within five business days, and laboratory testing must usually be completed within fifteen business days at the supplier's expense.

A Fast Product Recall Regime

One of the most significant features of the Resolution is the introduction of strict recall timelines.

Once goods are determined to be fraudulent, spoiled or counterfeit, suppliers must immediately stop sales and begin recall procedures. Within 24 hours, suppliers must notify distributors, retailers and other recipients, who must then withdraw the products within a further 24 hours. Evidence of compliance must be provided to the authorities.

Suppliers must also publish a bilingual Arabic and English recall notice within 48 hours and submit a detailed recall report within five business days. If they fail to act, the authorities may conduct the recall themselves and recover the related costs from the supplier.

Increased Supply Chain Risk

Liability is no longer limited to suppliers.

The Resolution permits administrative fines to be imposed on distributors, resellers and marketers who knew, or should reasonably have known, that relevant products were harmful. Particular attention is given to medical products, agricultural products and organic food products, as well as misleading marketing and the resale of defective products.

This places greater emphasis on product due diligence, traceability and compliance controls throughout the supply chain.

Reconciliation Remains Available, But Subject to Strict Conditions

The Resolution allows certain violations to be settled through reconciliation. However, reconciliation is generally limited to violations arising from error or negligence, requires the breach to be remedied, and is unavailable where the offender has been fined under the Commercial Fraud Law during the preceding twelve months. Authorities must determine applications within fifteen business days.

Conclusion

The Resolution marks a significant shift towards faster and more coordinated enforcement of commercial fraud laws in the UAE. It introduces strict deadlines, broader investigative powers and substantial obligations on all parties involved that require proactive compliance planning before an issue arises.