UAE

UAE Cabinet Decision 107/2026: 24 hours to withdraw fake goods

On 3 September 2026, the UAE Ministry of Economy and Tourism unveiled the executive regulations to Federal Decree-Law No. 42 of 2023 on Combating Commercial Fraud, issued as Cabinet Decision No. 107 of 2026. Suppliers must immediately stop selling counterfeit, adulterated or spoiled goods and pull them from the market within 24 hours of notification. The public recall notice must be issued in Arabic and English within 48 hours. What this means for UAE retailers, importers and e-commerce operators — by the facts, from the primary sources.

Marsel ShadmanovCEO & Partner, Garant Business Consultancy · UAE banking, structuring & tax

5 September 20267 min read

On 3 September 2026, the UAE Ministry of Economy and Tourism (MoEc) held a media briefing in Dubai to unveil Cabinet Decision No. 107 of 2026 — the executive regulations to Federal Decree-Law No. 42 of 2023 on Combating Commercial Fraud. Under the new rules, a supplier must immediately stop selling and displaying adulterated, spoiled or counterfeit goods and withdraw them from markets and warehouses within 24 hours of the Ministry's notification, and publish a bilingual Arabic and English recall notice within 48 hours via channels designated by the Ministry. A detailed recall report is due within 5 business days; eligible goods may be re-exported to the country of origin within 30 days at the supplier's expense; counterfeit goods must be destroyed within 15 working days of a court or committee decision. Priority sectors include medical products, agricultural products and organic food. Primary enforcement responsibility sits with local authorities of each emirate; MoEc may intervene in multi-emirate cases or where products pose significant health, safety or environmental risks. Judicial enforcement officers have extended powers to access electronic devices, information systems, networks and digital records. A conciliation mechanism is available only for violations arising from error or negligence, once the breach is remedied and provided the offender has not been fined under the Commercial Fraud Law in the preceding 12 months; applications are determined within 15 business days. In Q1 2026, MoEc reported 10,023 inspection tours and 189 violations detected. The regulations were presented by HE Safeya Al Safi, MoEc Assistant Under-Secretary for the Commercial Control and Governance Sector.

Common questions on this topic

What exactly did UAE Cabinet Decision No. 107 of 2026 introduce?

Cabinet Decision No. 107 of 2026 sets out the executive regulations to Federal Decree-Law No. 42 of 2023 on Combating Commercial Fraud. It spells out how ministries, local authorities of each emirate and courts apply the law in practice: timelines for withdrawing goods from the market, procedures for public notification of buyers, inspection powers, re-export and destruction of counterfeit goods, conditions for administrative settlement (conciliation) and the priority categories subject to enhanced control. The UAE Ministry of Economy and Tourism unveiled the key timelines at a Dubai media briefing on 3 September 2026; the full regulations were adopted by the Cabinet and are in force. Clyde & Co's August 2026 legal note describes the mechanics: once a product is found to be counterfeit, adulterated or spoiled, a strict recall regime kicks in — measured in hours, not weeks.

What are the exact recall timelines a supplier must meet?

The regulations set out a chain of deadlines. The supplier must immediately stop selling and displaying adulterated, spoiled or counterfeit goods and withdraw them from markets and warehouses within 24 hours of the Ministry's notification (Dubai Eye 103.8 wording: 'within 24 hours'). A public recall notice must be issued within 48 hours in both Arabic and English via channels designated by the Ministry. A detailed recall report is due within 5 business days. Eligible goods may be re-exported to their country of origin within 30 days at the supplier's expense. Counterfeit goods must be destroyed within 15 working days of a court or committee decision. Where the goods pose health, safety or environmental risks, timelines can be shortened further.

Who exactly can be fined — only the manufacturer, or the whole chain?

Per Clyde & Co's legal analysis, administrative fines can be imposed on distributors, resellers and marketers who 'knew, or should reasonably have known' that the relevant products were harmful, counterfeit or spoiled. In other words: liability extends across the commercial chain, including e-commerce marketplaces and retail outlets. For sectors carrying a professional duty of care — medical products, agricultural produce and organic food — the 'should have known' bar sits higher. Primary responsibility for inspections and enforcement rests with the local authorities of each emirate; the Ministry of Economy and Tourism may intervene in multi-emirate cases, where the local authority fails to act, or when products pose significant health or safety risks.

Is conciliation (settlement) instead of a fine available?

Yes, but only under three conditions set by Cabinet Decision 107/2026 (as summarised by Clyde & Co). First, the violation must arise from error or negligence — not intent. Second, the breach must be remedied. Third, the offender must not have been fined under the Commercial Fraud Law during the preceding twelve months. Applications for conciliation are determined by the competent authority within 15 business days. If conciliation is refused, the offender has 7 working days to lodge an objection, and the Ministry or competent authority must decide on the objection within a maximum of 10 working days. This gives compliant businesses a narrow remediation window — but it does not remove the obligation to withdraw and destroy counterfeit goods under the standard timelines.

What should a business check right now?

Five items of minimum readiness for the 107/2026 regime. One: appoint a named person to receive notifications from MoEc and local authorities, with a 24/7 contact channel — the clock runs in hours. Two: document a procedure to block and pull SKUs from retail outlets, warehouses and e-commerce listings within 24 hours. Three: prepare bilingual (Arabic + English) recall notice templates ready to publish via the channels designated by the Ministry — within 48 hours. Four: line up logistics for re-export to the country of origin at the supplier's expense, and budget lab-testing costs (also for the supplier's account). Five: tighten origin-verification and supply-chain due diligence, especially for the priority categories — medical products, agricultural produce and organic food. All of this fits inside the broader UAE 2026 compliance perimeter.

The regime is live: 24 hours to withdraw, 48 hours to go public

On 3 September 2026, the UAE Ministry of Economy and Tourism (MoEc) used a Dubai media briefing to unveil the details of Cabinet Decision No. 107 of 2026 — the executive regulations to Federal Decree-Law No. 42/2023 on Combating Commercial Fraud. The practical shift is sharp: from the moment MoEc issues an official notification, a supplier must withdraw counterfeit, adulterated or spoiled goods from markets and warehouses within 24 hours, and publish a bilingual Arabic-and-English recall notice within 48 hours via channels designated by the Ministry. This is a live regime, not a draft.

The official quoted across coverage — HE Safeya Al Safi, MoEc Assistant Under-Secretary for the Commercial Control and Governance Sector — was reported by Khaleej Times, Emirates 24|7 and Dubai Eye 103.8. According to the Ministry, Q1 2026 saw 10,023 inspection tours and 189 violations detected — a baseline of enforcement intensity that the 107/2026 regulations are set to tighten further.

The full timeline chain

The regulations impose a sequence of deadlines, each running its own clock. It helps to hold them in a single checklist.

24 hours — stop selling and displaying, and withdraw the goods from markets and warehouses from the Ministry's notification.
48 hours — issue a bilingual (Arabic + English) recall notice via the channels designated by the Ministry.
5 business days — submit a detailed recall report.
30 days — re-export eligible batches to the country of origin at the supplier's expense.
15 working days — destruction of counterfeit goods following a court or committee decision.
Acceleration — where goods pose health, safety or environmental risks, timelines can be shortened further.

Who enforces

Primary responsibility for inspections and enforcement, per Clyde & Co's legal note, sits with the local authorities of each emirate. The Ministry of Economy and Tourism steps in where the local authority fails to act, where the case spans more than one emirate, or where products carry material health, safety or environmental risk. Powers of judicial enforcement officers are meaningfully broader: they may access electronic devices, information systems, networks and digital records — an important signal for e-commerce and warehouse-management systems.

Priority categories

Per Clyde & Co, the regulations sharpen controls over medical products, agricultural produce and organic food. For these categories, the 'knew or should have known' standard sits higher, and supply-chain traceability requirements are tighter. This is the key marker for importers and retail chains: the first place to overhaul intake and origin-verification procedures.

Who can be fined

Administrative fines reach across the whole commercial chain — not only the manufacturer or first-tier importer. Clyde & Co's analysis is explicit: sanctions can be applied to distributors, resellers and marketers who knew, or should reasonably have known, that the products were harmful, counterfeit or spoiled. For e-commerce marketplaces and retail networks, this creates a real risk of platform-level liability for listing unsafe goods — with the corresponding demands on supplier KYC and complaint monitoring.

Conciliation — a narrow window

The regulations allow conciliation in place of a standard sanction, but under tight conditions. Three tests: the violation must be the result of error or negligence (not intent); the breach must be remedied; and the offender must not have incurred fines under the Commercial Fraud Law in the preceding 12 months. The competent authority determines conciliation applications within 15 business days. If refused, the offender has 7 working days to lodge an objection, and the Ministry or competent authority decides within a maximum of 10 working days. This is a narrow remediation window for good-faith businesses — but not an indulgence: the standard obligations to withdraw and destroy counterfeit goods still apply.

What this changes for business

Decision 107/2026 lives inside the broader architecture of the UAE's updated business rulebook — from corporate tax to personal data. The full context sits in our overview of 2026 business regulation changes in the UAE: what actually shifted over the past year and where the accidental-non-compliance risks are hiding. For anyone setting up a company in the Emirates and planning retail, imports or e-commerce, this is part of the baseline compliance perimeter from day one.

Q1 2026 enforcement snapshot

According to MoEc data shared at the 3 September 2026 briefing, the first quarter of 2026 saw 10,023 inspection tours and 189 violations detected across the UAE. Given the new timelines and the extended powers of enforcement officers, legal advisers expect the inspection cadence in 2026–2027 to rise, while the reaction window for businesses narrows from weeks to hours.

Topics:UAERegulationCommercial FraudComplianceRetailE-commerceImportsMinistry of Economy