GSO 2600:2021, approved on 1 July 2021, is the Gulf Standard for premises where food is packed and repacked. In the UAE, Federal Law No. (10) of 2015 treats repacking as food trading, so you need your emirate food authority's prior approval before you start.
This guide is for QA and food safety managers at UAE businesses that repack dry, chilled or frozen food.
What is GSO 2600:2021, and is it mandatory in the UAE?
GSO 2600:2021, Edition 1, is titled "General Requirements for Places of Packaging and Re-packaging of Food". GSO lists it as a Gulf Standard, not a Gulf Technical Regulation. The same GSO store page lists GSO 9:2022 on labelling and GSO 150-1:2013 on mandatory expiry dates as technical regulations.
GSO's Technical Council approved the English translation only on 31 January 2024. The Arabic text is the reference and governs if the two differ.
It has four clauses: scope, complementary standards, definitions and requirements. The scope covers places where fresh, dried and processed foods are packed and refilled, and the conditions the food must meet. The free preview stops after clause 2, so buy the full text from GSO.
Clause 2 names six complementary standards, without editions. Three cover premises and hygiene: GSO 21 (food plants and staff), GSO 1694 (general principles of food hygiene) and GSO 2309 (food shops). The others are GSO 9 (labelling), GSO 150-1 (mandatory expiry dates) and GSO 149 (unbottled drinking water).
This guide could not confirm that the UAE has made GSO 2600 a mandatory national standard. Ask your emirate's food authority whether it expects you to apply it. Federal Law 10/2015, Article 12, does require traded food to meet UAE technical regulations and mandatory standards.
What approval does a UAE food repacker need?
Federal Law 10/2015, Article 1, defines trading in food to include packing, repacking and packaging. Article 7(1) bars any food-trade activity before you obtain the prior approval of the competent authority. Article 1 defines that as the local food safety authority of each emirate.
Article 9 sets the duties of the person in charge. They include applying food safety rules based on the State's risk analysis, documented registers, staff training and medical fitness, tracking food through storage and distribution, and withdrawing unsafe food with notice to the authority.
In Dubai, a separate per-consignment permit covers label or pack changes. Dubai Municipality's 2020 permit list called it a "Temporary Permit for Changes Related to Food Label/Packages", at AED 200 per application of up to five items. It required FoodWatch registration with a licensed Dubai warehouse, the item registered in FIRS and an approved label assessment.
A February 2025 Dubai Municipality announcement describes Montaji+ for food products and the Unified Permit System for food permits. Confirm the current permit, fee and platform before you apply.
Which records must you keep, and for how long?
Cabinet Resolution No. (26) of 2017, the law's Executive Regulations in force since 1 August 2017, sets the record rules in Article 18. You keep supplier records showing name, address, date received, nature and quantity, and batch number. You keep the same fields for customers, unless you sell directly to consumers.
Article 18(3) sets minimum retention periods. In AGS's reading of the English text:
- food with a shelf life over five years: 180 days after expiry
- food with a shelf life under three months, short-shelf-life food with a definite consumption date, and food distributed directly to the consumer: 180 days from supply
- everything else: five years
Most repacked dry goods with a shelf life between three months and five years fall into the five-year group. The English wording is awkward, so check the Arabic text before you fix your retention rule. You must also hand records over on request and review tracking procedures periodically (Article 18(4) and (5)).
Can a repacker change the label or the date?
Not the original date. Dubai Municipality and ADAFSA both forbid altering it, and both want Arabic labels. The table compares the federal rules with the Dubai Food Code 2013, still the code in force, and an archived December 2020 copy of ADAFSA Code of Practice No. (5) of 2019. ADAFSA's website could not be reached to confirm that edition is still current.
| Rule | Federal: Cabinet Resolution 26/2017 | Dubai Municipality: Food Code 2013 | ADAFSA: CoP 5/2019 (2020 copy) |
|---|---|---|---|
| Label language | Arabic, clear and true (Article 9(1)) | Arabic, with the content the Food Control Department requires (§8.1(a), (b)) | Arabic. An Arabic sticker is allowed under conditions, with no dates on it (§1.2) |
| Original date mark | No rule on altering dates found. Expired food may not be traded without written permission (Article 9(2)(b)) | Must not be removed, erased, altered, obscured or over-stickered (§8.1(f)) | No date stickers. No re-labelling with an altered date, or re-wrapping, except by the manufacturer or producer (§2.5.2.1) |
| New shelf life | No specific rule found | You set it, within any Department limit (§8.2(a), (b)). Establishments that prepare and distribute pre-packaged perishable or high-risk food validate it and get shelf-life approval before label approval (§8.2(d)). Raw cereals, pulses and dry foods are exempt from validation (§8.2(h)) | Set by manufacturers or producers. A packing date counts as a production-type date (§2.5) |
| Who packed it | Country of packing on imports, where it differs from the country of origin (Article 9(1)(e)) | No specific rule found | Name and address of the manufacturer, packer or other responsible business (§2.7) |
Two ADAFSA points catch repackers. If an imported product arrives without production and expiry dates, printing them in the UAE is prohibited. And §2.5.2.1 allows a changed date, or re-wrapping, only "by the manufacturers or producers". The code does not say whether a licensed repacker counts, so confirm with ADAFSA in writing before you date any repacked product in Abu Dhabi.
Does a repacking line need a HACCP plan?
You need a risk-based food safety system. Federal Law 10/2015, Article 9(1), requires you to apply food safety rules based on the risk analysis the State approves. The Dubai Food Code 2013 requires every food establishment to run a risk-based programme and refers to HACCP as adopted by Codex. The current Codex text is CXC 1-1969, revised in 2020 and 2022, which our guide to Codex HACCP explains.
Repacking has no kill step. AGS's illustrative repacking study therefore treats most hazards, such as pathogens or chemical contaminants already in the product, as controlled by supplier approval and prerequisite programmes. This is a design choice, not a rule from any authority. Likely CCPs depend on the line:
- a cold-chain break when chilled or frozen cartons are opened (Dubai Municipality's danger zone is 5 to 60 °C)
- allergen cross-contact on shared lines
- metal detection, where a detector is installed
Label and date errors are better caught by label verification than by a CCP. Authorities license and inspect the system. They do not certify a HACCP plan. For cold rooms and dispatch, see our guide to warehouse time and temperature control.
What should you have ready when the inspector visits?
Have these ready:
- the emirate food authority's approval for repacking (Federal Law 10/2015, Article 7(1))
- supplier and customer records with batch numbers, kept for the Article 18(3) periods (Cabinet Resolution 26/2017)
- tracking registers and a withdrawal and recall procedure (Federal Law 10/2015, Article 9), as our guide to recall readiness explains
- Arabic labels showing the country of packing where it differs from the country of origin (Cabinet Resolution 26/2017, Article 9(1)(e))
- in Dubai, allergens declared on re-packaged food (Food Code §3.4.3(c)), and in Dubai and Abu Dhabi, original dates left untouched
- evidence that packaging is fit for food contact (Cabinet Resolution 26/2017, Article 9(1)(b))
How AGS can help
The UAE Food Repacking & Repackaging HACCP Management System (GSO 2600:2021) has 40 documents in editable Microsoft Word and Excel. It includes a Food Safety Manual, SOP and forms packs for receiving, repacking, labelling, traceability and recall, and a HACCP study with illustrative plans for dry, chilled and frozen lines. Its workbooks include an Allergen Matrix Workbook, a Mock Recall Workbook and a Regulatory Compliance Matrix Workbook. It contains no GSO 2600 text or clause-by-clause GSO 2600 mapping.
Frequently asked questions
Why do some sites call it GSO 2600:2023?
Yemen adopted the standard nationally as YSMO GSO 2600:2023. The Gulf Standard itself is GSO 2600:2021.
Can we repack food from home under a Dubai home licence?
Not on the latest statement found. The Dubai Media Office said in August 2020 that repackaging should be done through a "licensed and accredited institution" with the food safety authority's approval. Under the Intelaq home licence, a residence is a management office only.
Does bulk food bought for repacking need an Arabic label?
In Abu Dhabi, ADAFSA's CoP 5/2019 may accept English-only labels on food intended for repacking or re-export (§1.2(d)). The consumer pack you produce still needs the Arabic label.
What are the penalties for breaking UAE food law?
Under Federal Law 10/2015, Article 14, trading food that breaches technical regulations carries a fine of AED 10,000 to 100,000. Adulterated, harmful or spoiled food carries at least three months' imprisonment and/or a fine of AED 100,000 to 2,000,000. Penalties double for a repeat offence.
AGS provides independent documentation toolkits. This guide and the referenced kit are not affiliated with, endorsed by or approved by GSO, Dubai Municipality or ADAFSA. It is general information, not legal advice. What applies depends on your emirate, your licence activity and your product, and other emirates are not covered here.
Reviewed October 2026. Facts checked against the sources current at publication.
