UAE Anti-Commercial Fraud Law 2026: 24-Hour Product Withdrawal Rules Explained

What happens when a business is notified that products it sells may be counterfeit, adulterated or spoiled? In the UAE, suppliers may have as little as 24 hours to withdraw the affected goods from the market after receiving the relevant notification.

The UAE has strengthened its approach to commercial fraud through Cabinet Resolution No. 107 of 2026, concerning the Executive Regulations of Federal Decree-Law No. 42 of 2023 on Combating Commercial Fraud.

The Ministry of Economy and Tourism outlined the requirements on 3 September 2026, highlighting the responsibilities of suppliers when goods are identified for withdrawal. These include stopping sales, recovering affected goods, informing relevant points of sale and making a public announcement within the prescribed period.

For retailers, importers, distributors, manufacturers and online sellers, these requirements make product traceability and a clear withdrawal procedure important parts of business compliance.

This article explains the relevant legislation, the key article numbers and the practical steps businesses should understand.

1. What Is Cabinet Resolution No. 107 of 2026?

Cabinet Resolution No. 107 of 2026 sets out the Executive Regulations of Federal Decree-Law No. 42 of 2023 concerning Combating Commercial Fraud.

The Federal Decree-Law provides the broader legal basis for addressing commercial fraud. The 2026 Cabinet Resolution sets out procedures for implementing the law, including the withdrawal of affected goods, public announcements, reporting obligations and the handling of goods after seizure.

The Executive Regulations address goods identified as fraudulent, corrupt or counterfeit under the legislation. Businesses should use the terminology in the legislation when assessing their obligations rather than assuming that every product complaint automatically triggers the same procedure.

The resolution is particularly relevant to businesses that import, supply, distribute, store or sell products in the UAE, as the withdrawal process can involve goods held in warehouses as well as products already distributed to points of sale.

2. Which Goods May Be Subject to Withdrawal?

The Executive Regulations address fraudulent, corrupt or counterfeit goods. Depending on the circumstances, this can involve products that are counterfeit, adulterated or spoiled.

The relevant authority may determine that goods must be withdrawn after identifying a violation under the applicable legislation.

For businesses, the practical concern is not limited to whether goods remain on shop shelves. Affected products may also be held in warehouses, supplied to other businesses or distributed across multiple locations.

A company may therefore need to identify where the goods have gone, which entities received them and what quantities remain in circulation.

Important: Whether a particular product falls within the legal categories depends on the facts and the applicable statutory definitions. A customer complaint or quality issue should not automatically be treated as a formal withdrawal order without examining the circumstances and any notification from the competent authority.

3. Article 5: The 24-Hour Product Withdrawal Requirement

Article 5 of Cabinet Resolution No. 107 of 2026 sets out the procedure for withdrawing fraudulent, corrupt or counterfeit goods.

Where the Ministry or competent authority determines that goods should be withdrawn, it must notify the supplier through an approved method.

Following receipt of that notification, the supplier must immediately stop selling or offering the affected goods for sale and, within no more than 24 hours, take the necessary steps to withdraw them from markets and warehouses.

The supplier must also notify all points of sale and other entities to which the goods were supplied. Those entities must be informed of the requirement to withdraw the goods within the applicable 24-hour period.

The supplier must take the necessary measures to recover the goods from circulation and provide evidence of completion of the notification, withdrawal and recovery procedures in accordance with the approved process.

What does this mean in practice?

A supplier may need to coordinate several actions within a short period:

• Stop selling or displaying the affected products.

• Identify the relevant stock in warehouses and distribution locations.

• Notify retailers, resellers and other recipients.

• Arrange the recovery and segregation of affected goods.

• Keep records showing what action was taken and when.

• Provide evidence of compliance to the Ministry or competent authority.

A business should not wait until every unit has physically returned before beginning the withdrawal process. The priority is to stop further sales, initiate recovery and document the steps taken.

The authority may also detain the affected goods at the offender's expense and prohibit their disposal or use, as provided under the regulations.

4. Article 6: The 48-Hour Public Announcement Requirement

Withdrawing products from warehouses and retail shelves is only one part of the process.

Article 6 of Cabinet Resolution No. 107 of 2026 requires the supplier to announce the withdrawal through the advertising media determined by the Ministry or competent authority within no more than 48 hours from receipt of the notification.

The authority may shorten this period where circumstances require it, particularly where the goods pose risks to human or animal health or safety, or to the environment.

The announcement must contain prescribed information so that consumers can identify the affected goods and understand what to do.

Depending on the applicable requirements, the announcement must include:

• The supplier's telephone number or email address.

• The trademark appearing on the affected goods.

• The product type, model and description.

• The country of origin.

• Instructions for obtaining a refund.

• The approved withdrawal period and designated return locations.

• Publication in both Arabic and English.

The regulations also prescribe requirements for the size of the announcement in printed or electronic media, including a minimum size of 15 cm × 15 cm or its digital equivalent.

The competent authority determines the number of times the announcement must be published and may extend publication requirements in specified circumstances.

Why should businesses prepare for this requirement?

A public withdrawal announcement needs to be accurate, timely and understandable. A generic message stating that a product has been recalled may not provide enough information for consumers to identify the affected product or understand how to obtain a refund.

Businesses should therefore maintain reliable product descriptions, model numbers, trademarks, country-of-origin details and customer contact information.

5. Article 7: Reporting the Withdrawal to the Authorities

Article 7 of Cabinet Resolution No. 107 of 2026 addresses the supplier's reporting obligations.

The supplier must submit a report on the withdrawal procedures to the Ministry or competent authority within five working days from the commencement of the withdrawal procedures.

The report must contain information about the affected goods and the steps taken to withdraw them. This includes details such as:

• The type and description of the goods.

• The quantities and locations of goods remaining with the supplier.

• Quantities sold or distributed to points of sale and other entities.

• The quantity and value of goods withdrawn from markets and warehouses.

• Information about refunds made to customers, including the relevant quantities and customer details specified in the regulation.

The Ministry or competent authority may request additional data, documents, periodic reports or further measures relating to the withdrawal.

This means that businesses should not treat product withdrawal as merely an operational task. They must also be able to demonstrate what happened to the affected goods.

What records should businesses maintain?

Businesses should consider maintaining a central record containing:

1. The authority's notification and the date and time it was received.

2. Product identification details, including models, batches and quantities where applicable.

3. Warehouse and point-of-sale inventory records.

4. Communications sent to retailers, distributors and other recipients.

5. Evidence of withdrawal, recovery and segregation.

6. Public announcements and refund records.

7. Reports submitted to the competent authority.

These records can help a business respond to regulatory requests and demonstrate the steps taken to comply.

6. Article 8: What Happens If the Supplier Fails to Withdraw the Goods?

Article 8 addresses the situation in which a supplier fails to withdraw the affected goods within the period prescribed by Article 5.

In that case, the Ministry or competent authority must take the necessary measures to withdraw the goods from markets and warehouses within the following 48 hours, at the supplier's expense.

This provision is important because a failure to act does not necessarily mean that the products will remain in circulation. The authority may intervene, and the supplier may be responsible for the resulting costs.

Businesses should therefore establish an internal escalation procedure so that an official withdrawal notification reaches the people responsible for inventory, sales, distribution, legal compliance and customer communications without delay.

7. What Happens to Withdrawn Goods?

Withdrawal does not automatically mean that products can be returned to ordinary stock or disposed of at the supplier's discretion.

The regulations provide for the handling of affected goods, including detention, destruction, recycling and, where legally permitted, return to their source.

Article 15 of Cabinet Resolution No. 107 of 2026 addresses the return of fraudulent, corrupt or counterfeit goods to their source.

Where the specified conditions are satisfied and no decision or court judgment requires destruction, the supplier must return the seized goods to the country of origin or country of export within 30 days from seizure, at the supplier's expense. This is subject to the goods being capable of re-export and the re-export not creating risks to human or animal health or safety, or the environment.

The provision should not be read as an unconditional right to re-export every withdrawn product. The nature of the goods, the applicable conditions and any relevant decision must be considered.

Businesses should obtain instructions from the competent authority before disposing of, recycling or re-exporting affected goods.

8. What Should Retailers, Importers and Online Sellers Do Now?

The withdrawal deadlines may leave little time to establish the facts after an official notification arrives. Businesses should prepare before a problem occurs.

Step 1: Establish product traceability

Maintain records that allow the business to identify product types, suppliers, quantities, warehouse locations and recipients. Where relevant, use batch or model details to distinguish affected products from other stock.

Step 2: Assign responsibility

Identify the employees responsible for receiving regulatory notifications and coordinating product withdrawals. Make sure that the relevant managers can contact warehouse teams, retailers, distributors and online sales platforms quickly.

Step 3: Prepare a notification process

Maintain current contact details for all points of sale and business recipients. Prepare an internal process for stopping sales, sending withdrawal notices and recording confirmations.

Step 4: Prepare public communication procedures

Identify who will prepare, approve and publish a withdrawal announcement. The process should allow the business to meet the applicable deadline and include the required information in Arabic and English.

Step 5: Maintain evidence of compliance

Keep copies of notices, communications, stock records, recovery documents, refund information and reports submitted to the authority.

Step 6: Escalate legal questions promptly

If the business disputes the notification, is unsure whether particular goods are covered or needs clarification about their handling, it should seek appropriate advice promptly. It should not assume that raising a concern automatically suspends a withdrawal deadline.

9. How Do These Rules Protect Consumers?

The withdrawal procedure is intended to help prevent affected products from remaining available for purchase or use.

The 24-hour withdrawal requirement addresses the removal of goods from markets and warehouses. The 48-hour announcement requirement helps consumers identify affected products and understand the steps available to them. The reporting procedure also allows authorities to monitor the withdrawal and request further information.

For consumers, the practical message is straightforward: if a business or authority announces a product withdrawal, check the product description and follow the stated instructions. Depending on the announcement, consumers may need to stop using the product, return it to a designated location or contact the supplier to arrange a refund.

For businesses, the same requirements underline the importance of accurate product information, reliable distribution records and a documented response process.

Conclusion

Cabinet Resolution No. 107 of 2026 sets out detailed procedures under the UAE's anti-commercial fraud legislation. Articles 5, 6 and 7 establish distinct requirements for withdrawing affected goods, announcing the withdrawal and reporting the action taken. Article 8 addresses the authority's intervention if a supplier fails to withdraw the goods within the prescribed period.

For suppliers, retailers, importers and online sellers, compliance requires more than removing products from shelves. Businesses need to identify affected stock, contact recipients, communicate clearly with consumers and maintain evidence of the withdrawal process.

Preparing these procedures in advance can help businesses respond more effectively when an official notification is received.

Malhotra Legal Consultancy can assist businesses in understanding UAE regulatory requirements, reviewing compliance procedures and identifying areas that may require legal attention.