Under Federal Law No. (10) of 2015, the person in charge of a UAE food business must withdraw and recover unsafe food and notify the Ministry and the emirate's food authority. Cabinet Resolution 26/2017 makes you keep batch records of suppliers and customers, for five years in most cases.
This guide is for QA and food safety managers at UAE manufacturers, importers and distributors, and their recall teams.
What does UAE food law require in a recall?
Article 9 of Federal Law No. (10) of 2015 on food safety lists your duties. Notify the Ministry and the competent authority of food that risks consumer health (item 7). Trace where it was distributed and stored, and hand over the records (item 8). Withdraw and recover food that is unfit or breaks the law, and notify both bodies (item 10).
The competent authority is the local food safety authority in each emirate. The law names the Ministry of Environment and Water, and the Ministry of Climate Change and Environment (MOCCAE) now acts as the Ministry. The law covers the whole State, free zones included (Art. 3 and 19).
In Dubai, the Dubai Municipality Food Code 2013 adds duties in §8.8. Manufacturers, importers and distributors must promptly withdraw or recall food that is unsafe, adulterated or not conforming to Islamic law or UAE norms. They must also recall when the Food Control Department or another authority orders it (§8.8(g) and (h)). They should notify the Food Control Department, and consumers if the product reached them (§8.8(i)).
Is a withdrawal the same as a recall?
Not in UAE law. Federal Law 10/2015, Article 1, defines withdrawal as recovering non-compliant food before it reaches the end user, while recovery also includes communicating with the consumer. The Dubai Food Code defines only recall: removing from distribution, sale and consumption food that may pose a health risk. Its §8.8 says "withdraw or recall" but does not define withdrawal.
The IFS Food v8 glossary splits them another way. A recall returns a dangerous product already supplied to consumers. A withdrawal stops distribution and display of an out-of-specification or possibly dangerous product.
The US FDA's recall rules (21 CFR Part 7) grade recalls Class I to III, and much recall training follows them. The AGS package below does, and uses withdrawal for quality-only removals. UAE law and the Dubai Food Code have no recall classes. The FAO/WHO guide to national food recall systems (2012) avoids the word withdrawal because it means different things in different countries.
So write your procedure in your regulator's terms, and add a line mapping each scheme's terms to them.
Can the commercial fraud rules also apply to food?
They can. Federal Decree-Law No. (42) of 2023 on combating commercial fraud sits with the Ministry of Economy, now the Ministry of Economy and Tourism. It defines goods to include animal and agricultural products, and nothing in it excludes food. Article 5 makes a provider recall spoilt, fraudulent or counterfeit goods, inform the authority and announce it.
Its executive regulation, Cabinet Resolution No. (107) of 2026, has been in force since 13 August 2026. After a notice from the Ministry or the emirate's competent authority, sale must stop at once. Within 24 hours the supplier must withdraw the goods, tell every point of sale it supplied, start recovery and give the authority evidence (Art. 5).
A public announcement is due within 48 hours, sooner if the authority decides health or safety is at risk (Art. 6). If the supplier misses the 24 hours, the authority withdraws the goods at the supplier's cost (Art. 8).
Neither text says how this sits beside the food safety law's own duty. Treat the 24-hour and 48-hour steps as a possible second route, and confirm with your competent authority which rules it applies to your products.
Which deadlines apply, from UAE law to FSSC, IFS and SQF?
ISO 22000:2018, with Amendment 1:2024, has a clause for this, 8.9.5 Withdrawal/recall. The table puts the UAE clocks first. Scheme deadlines apply on top of them.
| Clock | What must happen | Set by |
|---|---|---|
| 5 years (default) | Keep supplier and customer records with batch numbers | Cabinet Resolution 26/2017, Art. 18 |
| 24 hours | Withdraw goods and tell all points of sale, after an authority's notice | Cabinet Resolution 107/2026, Art. 5 (commercial fraud, can also apply) |
| 48 hours | Announce the withdrawal in media the authority sets | Cabinet Resolution 107/2026, Art. 6 (commercial fraud, can also apply) |
| 3 working days | Tell the certification body of a public recall or withdrawal | FSSC 22000 Version 7, Part 2 §2.5.17 |
| 3 working days | Tell the certification body of any recall, or an authority's recall or withdrawal | IFS Food v8, 1.2.6 |
| 24 hours | Notify SQFI and the certification body in writing | SQF Food Manufacturing Edition 9, 2.6.3.4 |
| 4 hours | Trace finished product to raw materials and to customers | IFS Food v8, 4.18.3 |
| 12 months, never over 15 | Run an end-to-end recall test | IFS Food v8, 5.9.2 |
| At least yearly | Test recall one step back and one forward, across shifts | SQF Edition 9, 2.6.3.2 |
In IFS Food v8 the recall procedure is knock-out requirement 9 (5.9.1). It needs an authorised person who is permanently available, a current alert contact list and a communication plan.
FSSC 22000 Version 7 was published in May 2026, and its audits start on 1 May 2027. SQF Edition 9 also requires a crisis plan, tested at least yearly (2.6.4). SQF Edition 10 audits start no earlier than 2 January 2027.
What will an inspector or auditor ask to see?
Cabinet Resolution 26/2017, Article 18, requires supplier records with name, address, receipt date, nature, quantity and batch number. Customer records need the same, unless you sell directly to consumers.
Five years is the default. Keep records 180 days after expiry if shelf life exceeds five years. Keep them 180 days from supply for food with under three months' shelf life or sold directly to consumers.
In Dubai, the Food Code lists a recall form among its Annex A records (item 18). Recalled food must be marked, segregated, never used for human consumption and disposed of quickly (§3.6.5).
For readiness, CR 26/2017 requires tracking procedures to be efficient and reviewed periodically (Art. 18(5)). UAE law does not name a mock recall. The yearly test comes from the schemes and the FAO/WHO guide, which recommends regular recall simulations to keep contacts current and staff trained.
Have a written procedure naming who decides and who notifies, and a contact list that includes your certification body. Your annual mock recall record should show times, quantities reconciled, root cause and corrective actions.
What does a UAE recall look like in practice?
On 27 January 2026, WAM reported that MOCCAE and the Emirates Drug Establishment (EDE) confirmed major UAE retail outlets no longer stocked one batch of Aptamil Advance 1 infant formula. Bacillus cereus had been found in a production input. The action followed Danone's recall in the UK and EU.
Warehouse stock was put on hold and the batch withdrawn from all points of sale, online stores included. EDE issued a precautionary circular to retailers and healthcare facilities, and consumers were told to dispose of the product.
On 11 January 2025, MOCCAE said it was investigating possible Listeria monocytogenes in a beef pepperoni product with the Saudi Food and Drug Authority. The product was withdrawn as a precaution while samples were tested. MOCCAE noted that the Gulf Rapid Alert System for Food (GRASF) shares such alerts among GCC countries.
Neither case was an enforcement finding against a business. Both show that online stores count, withdrawal can start before results, and a recall abroad can start action here.
How AGS can help
The Food Recall & Crisis Management Training Package is training material for a one-day, instructor-led session. It has 4 editable documents (3 Word, 1 PowerPoint): a 33-slide deck with speaker notes, a workbook with three recall templates and a tabletop exercise, an exam pack and a certificate template. It follows US FDA recall terminology and classes, not the UAE terms above, and does not cover UAE law.
Frequently asked questions
What are the penalties for selling harmful food?
Under Federal Law 10/2015, Article 14, trading adulterated, harmful or spoiled food carries at least 3 months' imprisonment and/or a fine of AED 100,000 to AED 2,000,000. Repeat offences double the penalty.
Can we destroy recalled stock ourselves?
Not freely. Under Cabinet Resolution 26/2017, disposal must be safe and follow notification and approval from the competent authority (Art. 11). If the authority has seized the stock, you need its written permission first (Art. 10).
Do we have to refund our customers for recalled food?
Under the commercial fraud law, which can also apply to food, the provider must refund spoilt, fraudulent or counterfeit goods, or exchange them, as a customer who bought in good faith chooses (Decree-Law 42/2023, Art. 7).
What happens if recalled food was exported?
The FAO/WHO guide says the competent authority should contact INFOSAN, the network run by FAO and WHO, early. Your part is fast, accurate export records.
AGS provides independent documentation toolkits. This guide and the referenced package are not affiliated with or endorsed by MOCCAE, EDE, the Ministry of Economy and Tourism, Dubai Municipality or ADAFSA. The same applies to the Saudi Food and Drug Authority, FAO, WHO, the US FDA, FSSC 22000, IFS and SQFI.
It is general information, not legal advice. Which rules apply depends on your products, your emirate (Abu Dhabi has its own regulator, ADAFSA) and your scheme.
Reviewed October 2026. Facts checked against the sources current at publication.
