Businesses notified that they are dealing in counterfeit, adulterated or spoiled goods may now have as little as 24 hours to remove those products from UAE markets and warehouses.
The requirement forms part of the new Executive Regulations implementing the UAE’s Anti-Commercial Fraud Law.
Issued under Cabinet Decision No. 107 of 2026, the Regulations give practical effect to Federal Decree-Law No. 42 of 2023 and introduce detailed procedures governing the withdrawal, notification, handling and disposal of non-compliant goods.
The most immediate requirement is clear.
Once a supplier receives notification from the Ministry of Economy and Tourism or another competent authority, it must stop selling or displaying the affected goods immediately and withdraw them from markets and warehouses within no more than 24 hours.
That transforms anti-counterfeit compliance in the UAE from something businesses can treat primarily as a later legal dispute into an immediate operational obligation.
The 24-Hour Deadline Starts With Official Notification
The new rule should be understood precisely.
It does not mean every retailer automatically has 24 hours from the moment a counterfeit product enters its possession.
The prescribed withdrawal period is triggered by notification from the Ministry or competent authority.
Once that notification is received, however, the response must be rapid.
The supplier must:
- immediately stop selling the goods;
- immediately stop displaying the goods;
- withdraw them from markets;
- withdraw them from warehouses; and
- complete the withdrawal within the prescribed 24-hour period.
For businesses with multiple branches, distributors or storage locations, that can require significant coordination in a very short time.
The Rules Cover More Than Counterfeit Products
Although counterfeit goods are likely to attract the greatest public attention, the Regulations extend beyond traditional fake branded products.
The withdrawal requirements also cover adulterated and spoiled goods.
This distinction matters.
A counterfeit product generally involves false representation as to identity, brand or origin.
An adulterated product may involve changes to composition, characteristics or quality that render the product misleading or non-compliant.
A spoiled product may have deteriorated to the point that it is no longer suitable for its intended purpose.
The new framework therefore operates across consumer protection, market integrity and product safety, rather than dealing only with trademark infringement.
Every Point of Sale Must Be Reached Quickly
Removing stock from one shop is not necessarily enough.
The Regulations require the supplier to notify the points of sale and other entities that received the affected goods so that the products can also be withdrawn within the required timeframe.
This makes traceability a central compliance issue.
A business should be able to identify:
- which branches received the product;
- which warehouses currently hold stock;
- which retailers or distributors were supplied;
- how many units were distributed;
- when they were delivered; and
- where the remaining inventory is located.
Without reliable records, complying with a 24-hour withdrawal requirement can become extremely difficult.
The practical value of inventory and distribution records therefore extends well beyond ordinary accounting or logistics.
They can become critical evidence of legal compliance.
A Public Withdrawal Notice May Also Be Required
The withdrawal process does not necessarily end when products are removed from shelves.
The Regulations also require a public announcement concerning the withdrawal within 48 hours.
The announcement must be made in Arabic and English.
This is important where goods have already entered the consumer market.
Removing remaining stock does not address products that may already have been purchased.
Public notification can therefore help alert consumers, businesses and other participants in the distribution chain to the issue.
For suppliers, this means product-withdrawal planning should include a communications process as well as a logistics process.
Authorities Can Require Faster Action
The 24-hour and 48-hour periods should not be treated as guaranteed minimum response times in every case.
Where the affected goods create risks to:
- human health;
- animal health;
- human safety; or
- the environment,
the competent authority may require action within a shorter period.
This is especially relevant to businesses dealing with products such as:
- food;
- cosmetics;
- healthcare products;
- children’s products;
- electrical goods;
- chemicals; or
- other safety-sensitive items.
The greater the potential harm, the less realistic it is for a business to assume that it will always have the full statutory period available.
Counterfeit Compliance Is Becoming an Operational Issue
The important change for businesses is not simply that counterfeit products are prohibited.
That was already well established.
The new Regulations focus attention on what the business must do once a violation has been identified.
That requires internal coordination between potentially several departments:
- legal;
- compliance;
- procurement;
- inventory management;
- warehousing;
- retail operations;
- communications; and
- senior management.
If those departments first begin deciding who is responsible after receiving an official withdrawal notice, valuable hours may already have been lost.
Businesses dealing with significant volumes of consumer products should therefore have a pre-agreed withdrawal procedure.
What Should Happen Immediately After a Notice Is Received?
The first hours can be critical.
A supplier receiving an official notice should promptly establish:
1. Which product is affected
The relevant product, batch, model, SKU or category should be identified precisely.
2. Where the goods are located
The business should determine which warehouses, stores, branches or third parties hold the goods.
3. Who has received them
Records should identify distributors, retailers and other recipients.
4. How sales will be stopped
Point-of-sale systems and internal instructions may need to be updated immediately.
5. How stock will be isolated
Affected inventory should be separated so that it cannot accidentally return to circulation.
6. Who will communicate with the authority
A responsible person should coordinate compliance and preserve evidence showing what steps were taken and when.
A structured response can make the difference between completing a withdrawal within hours and losing control of the process.
Online Sales Require the Same Practical Urgency
Modern retail is not limited to physical shelves.
Where affected goods are offered online, practical withdrawal should also include stopping further digital sales.
That may require businesses to:
- deactivate product listings;
- stop accepting orders;
- remove sponsored advertisements;
- notify fulfilment partners;
- block warehouse dispatch;
- stop marketplace listings; and
- ensure customer-service teams understand the issue.
A product cannot realistically be regarded as withdrawn from the market while consumers can still purchase it through an active digital channel.
For businesses operating through multiple platforms, control over listings should therefore form part of any product-withdrawal plan.
What Happens to the Goods After Withdrawal?
Withdrawal does not automatically determine the final fate of the goods.
The Executive Regulations also establish procedures governing matters such as:
- recycling;
- destruction;
- re-export; and
- other approved forms of disposal.
The applicable method will depend on the type of product and the legal circumstances surrounding it.
Businesses should not simply dispose of suspect goods independently without considering the directions of the competent authority.
The products may be relevant to enforcement proceedings, inspection or evidential requirements.
Re-Export May Be Possible in Certain Cases
The Regulations also provide a framework under which eligible goods may be re-exported to the country of origin or exporting country.
Where re-export is permitted, the applicable period can be 30 days, subject to the prescribed controls.
This should not be interpreted as meaning counterfeit products can simply be moved out of the UAE whenever a supplier wishes.
The availability of re-export depends on the nature of the goods, the legal requirements and the directions of the competent authorities.
Where destruction or another form of disposal is required, the supplier will need to comply with that process instead.
Who Bears the Cost of a Withdrawal?
Product withdrawals can be commercially expensive.
Potential costs include:
- transportation;
- warehouse handling;
- storage;
- destruction;
- recycling;
- communications;
- stock replacement;
- refunds;
- legal advice; and
- disruption to normal operations.
Businesses should therefore understand that dealing with fraudulent or non-compliant goods can create financial consequences even before any formal penalty is considered.
This makes supplier due diligence particularly important.
A retailer that purchases suspiciously cheap branded goods from an unreliable source may eventually bear operational and reputational costs that far exceed the original saving.
Counterfeit Goods Can Also Create Intellectual Property Exposure
Where the goods reproduce or misuse a protected brand, trademark or other intellectual property right, the commercial fraud framework may operate alongside separate intellectual property laws.
Brand owners may have their own rights to pursue:
- counterfeit importers;
- distributors;
- wholesalers;
- retailers; or
- other parties involved in the unlawful trade.
A single batch of counterfeit products can therefore raise several overlapping legal issues.
These may include:
- anti-commercial fraud;
- consumer protection;
- trademark infringement;
- customs enforcement;
- contractual liability; and
- regulatory penalties.
Businesses should not assume that complying with a withdrawal notice necessarily resolves all potential liability.
Retailers Cannot Rely Entirely on Their Supplier
A common commercial assumption is that responsibility for counterfeit goods lies only with the importer or upstream supplier.
That is risky.
A retailer placing goods into the market has its own responsibilities.
Retailers should therefore carry out reasonable checks concerning:
- supplier identity;
- invoices;
- product origin;
- authenticity;
- distribution rights;
- unusually low pricing; and
- supporting documentation.
This is particularly important where branded goods are offered at prices or through supply channels that appear inconsistent with ordinary market practice.
A retailer may not always be able to identify sophisticated counterfeit products immediately.
But ignoring obvious warning signs can increase both legal and commercial exposure.
Brand Owners Also Benefit From Faster Withdrawal Procedures
The Regulations are significant for trademark owners as well as retailers.
One of the greatest difficulties in anti-counterfeit enforcement is speed.
Counterfeit goods can be distributed across multiple locations rapidly, particularly where sellers use digital platforms or fragmented distribution networks.
A formal requirement to withdraw identified goods within 24 hours can limit the time during which those products remain available in the market.
For brand owners, effective enforcement can protect:
- reputation;
- consumer confidence;
- product quality;
- authorised distribution networks; and
- intellectual property value.
It can also reduce the possibility that consumers unknowingly purchase unsafe or inferior products believing them to be genuine.
Objections and Conciliation Are Also Regulated
The new Executive Regulations do not deal only with withdrawal procedures.
They also establish mechanisms relating to conciliation and objections.
Where a decision rejecting conciliation is issued, the violator may object within the prescribed period.
The authority is then required to determine that objection within the applicable timeframe.
These procedural safeguards matter because anti-commercial fraud enforcement can involve significant commercial consequences.
Businesses should therefore distinguish between:
- immediate compliance obligations;
- the right to challenge particular decisions; and
- any subsequent enforcement or judicial proceedings.
An objection should not automatically be assumed to suspend obligations that are already legally effective.
What Businesses Should Put in Place Now
The practical lesson from the new Regulations is preparation.
Retailers, distributors, importers and suppliers should consider whether they could realistically remove an affected product from their entire supply chain within 24 hours.
A useful compliance review should include:
- maintaining accurate distribution records;
- ensuring inventory can be traced by product and location;
- identifying responsibility for responding to government notices;
- establishing a rapid internal escalation process;
- maintaining contact details for retailers and distributors;
- creating procedures for stopping online and offline sales;
- preparing bilingual public-notice capability;
- retaining evidence of withdrawal actions;
- reviewing supplier authenticity controls; and
- training relevant employees on the withdrawal process.
The test is simple:
If an official notice arrived this morning, would the business know where every affected unit was by tomorrow morning?
If the answer is no, the business may have a compliance gap.
A Shift From Enforcement to Prevention
The wider significance of Cabinet Decision No. 107 of 2026 is that anti-commercial fraud regulation is increasingly focused on rapid intervention.
The objective is not merely to punish misconduct after counterfeit or unsafe goods have circulated.
It is also to:
- stop continued sales;
- remove affected stock;
- notify the market;
- prevent further harm; and
- ensure goods do not remain in circulation while disputes continue.
That gives the regulatory framework a preventative dimension.
Compliance therefore becomes partly about how quickly a business can respond when a problem is identified.
Conclusion
The UAE’s new Executive Regulations on Anti-Commercial Fraud introduce a demanding operational standard for businesses dealing with counterfeit, adulterated or spoiled goods.
Following formal notification from the Ministry of Economy and Tourism or another competent authority, suppliers must immediately stop selling or displaying the affected goods and complete their withdrawal from markets and warehouses within no more than 24 hours.
Points of sale and other recipients must be brought into the withdrawal process, while public notification may also be required within 48 hours.
The Regulations additionally address disposal, re-export, objections and other enforcement procedures.
For retailers and suppliers, the central message is broader than the 24-hour deadline itself.
Anti-commercial fraud compliance now depends heavily on traceability, rapid response and the ability to control products throughout the distribution chain.
Knowing that a product must be withdrawn is only the beginning.
The real compliance question is whether the business can actually find it, stop it from being sold and remove it from the market quickly enough.
Al Kabban & Associates
For businesses seeking guidance, Al Kabban & Associates, with over 30 years of experience in UAE law and recognition by Legal 500, stands ready to help corporations build resilience against legal risks while ensuring compliance with local and international standards. For more information or to schedule a consultation, contact us at +971 4 453 9090 or visit www.alkabban.com. You can also follow us on social media for more updates on everything law related in the UAE: @Alkabban_Law
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