UAE food contact materials: CR 20/2015, current editions, Dubai rules

UAE food contact materials fall under Cabinet Resolution No. (20) of 2015, which makes 31 listed standards mandatory and bars sale without ECAS registration. Since 2022, Cabinet resolutions have made newer editions of GSO 839, 1863 and 1791 mandatory, and Dubai Municipality adds its own labelling and traceability guideline.

This guide is for QA and regulatory managers who make, import or sell food packaging and kitchenware in the UAE, and for the inspectors who check them.

What does Cabinet Resolution 20 of 2015 cover?

The Cabinet's resolution, CR 20/2015 (Arabic text), was issued on 25 June 2015. Article 2 covers every food contact material imported, placed on the market, made or distributed in the UAE whose standard sits in Annex (1). Article 1 defines these as materials designed to touch food in normal use, whether plastic, rubber, wood, glass, ceramic or metal.

Six exclusions apply: antiques, coatings that form part of the food, fixed water supply equipment, secondary packaging that does not touch food directly, production-line and sterilisation materials, and goods prepared for re-export.

Under Article 3, every supplier, from manufacturer to storer, must meet the Annex (1) standards. It must also work to good manufacturing practice (GMP) or an accepted food safety or quality system. The resolution named the Emirates Authority for Standardization and Metrology (ESMA) as regulator. MoIAT's Ministerial Resolution 105 of 2022 (MR 105/2022) refers to CR 20/2015 certificates issued by the Ministry, so MoIAT now administers it.

Annex (1) lists 31 standards, led by UAE.S GSO 2231 on general requirements. The rest cover items such as melamine tableware, plastic cups, cans and glass cookware, lead and cadmium limits for ceramic and glass ware, and labelling and hygiene. Only GSO ISO 4531-2:2013 carries an edition year.

Which editions and newer rules apply now?

Annex (1) gives no other edition years, so current editions come from later instruments.

The Cabinet's CR 22/2022 made 153 Gulf Technical Regulations mandatory, with 180 days for authorities to adjust. Its schedule also lists UAE.S GSO 21:2021 on food plant hygiene and UAE.S GSO 193:2021 on contaminants and toxins, which match Annex (1) items 30 and 19. For the other Annex (1) standards, confirm the current edition with MoIAT or the GSO store.

MoIAT's MR 105/2022 covers rPET water bottles sold in the UAE, free zones included, wherever they were filled. MOCCAE announced the 2026 phase through WAM, the state news agency, with exemptions for labelled export goods not sold locally and products made from UAE-recycled materials.

Do you need a MoIAT conformity certificate?

Usually, yes. Article 5 of CR 20/2015 places the products a supplier makes, packs or imports under Model (B) of the Emirates Conformity Assessment System (ECAS). This applies provided the Authority issues a list of the products it considers must be registered for health and safety reasons. Whether that list is still published is unconfirmed, so check with MoIAT.

The supplier provides the documents that prove conformity, and a product with the Emirates Quality Mark is deemed to conform. Article 7(b) is the hard line: no outlet may display or sell covered products unless they are registered under ECAS. MoIAT gives one and a half working days as its ECAS certificate service time. Its fee table does not pair amounts clearly to steps, so confirm the fee with MoIAT.

What must a food contact label show?

Article 4 of CR 20/2015 sets five conditions. The label must conform with UAE.S GSO 2231 and Annex (1), and carry "suitable for food contact", the glass-and-fork symbol in Annex (2) or another accepted mark. Pictures and words must respect public order, public morals and Islamic values. Instructions and warnings must be clear and hard to remove, and all information backed by scientific and laboratory evidence.

Dubai Municipality's GU132 (section 7) asks for "for food contact" or the same symbol. It adds the name and contact details of the business placing the item on the market, traceability marking, safe-use instructions where needed, and, for active materials, the substances they release. Section 5 adds that a gift or absorber inside a food pack must be declared on the label and marked "do not eat" in Arabic and English.

What does Dubai Municipality add?

Dubai Municipality's Health and Safety Department issued the Technical Guidelines for Food Contact Materials (GU132) on 24 July 2024, under Local Order No. (11) of 2003 and CR 20/2015. It covers 17 material groups, including printing inks and active and intelligent materials. Packaging must be food grade, meet the relevant GSO standards and be single use unless built for washing, sterilisation and refilling. Halal packaging makers can also read our guide to UAE.S halal assurance for packaging.

Only stainless steel with at least 16% chromium counts as food contact grade (section 6). Operators must name who they bought from and supplied to, on demand (section 8.2). Contraventions fall under Local Order 11/2003.

The food business has duties too. Dubai Municipality's Food Code 2013 (section 3.5.4) says only food grade containers should be used. High-acid foods below pH 4.6 should not be stored or cooked in lead, zinc, enamelware, copper, brass, cast iron or aluminium containers. Cast iron may still serve as a cooking surface, or for serving straight from cooking.

What does an inspector check on a food contact material?

Scope comes first: the product, by material and use, mapped to its Annex (1) standard and current edition. Then registration, meaning the ECAS certificate or the Emirates Quality Mark. Then the technical file, the laboratory evidence behind label claims and proof of GMP. Last comes the label, against Article 4 and, in Dubai, GU132 section 7.

In a food business, inspectors check that containers are food grade, single use unless built for reuse, and never reactive metal holding high-acid food. They also ask who supplied the packaging. Inspection bodies can read our ISO/IEC 17020 guide.

Article 8 of CR 20/2015 sets the consequences. The authority can order withdrawal for correction, re-export or destruction, or seize and destroy goods at the violator's cost, and MoIAT can cancel the certificate. Penalties are those of Federal Law No. (28) of 2001 or the law that replaces it. Under Article 7(c), the party where the breach is found is responsible unless it proves otherwise.

On 23 March 2026, MoIAT's Conformity Hub posted a recall of Flying Tiger drinking glasses made in China. The outer printing contained high levels of lead and cadmium. The record names no limit or standard. For decorated glassware, ask whether the test report covers the printed decoration.

How AGS can help

The UAE Food Contact Materials Regulatory Control Management System (Cabinet Resolution No. 20 of 2015) has 41 documents in editable Microsoft Word and Excel, built for teams that inspect or verify food contact materials. It holds a manual, 10 procedures, 12 forms, 14 registers including an inspection checklist, 3 matrices and a reference list. It contains no standard text, migration limit values or ECAS application forms.

Frequently asked questions

Is Cabinet Resolution 20 of 2015 still in force?

No repeal or replacement was found as of October 2026. MoIAT's MR 105/2022 and Dubai Municipality's GU132 both cite it, and MoIAT still lists it among its laws.

How do you register food contact materials in Dubai?

Dubai Municipality's GU132 sets out no registration steps. It gives montaji-fcm@dm.gov.ae as its contact, so confirm the current route and documents with Dubai Municipality.

Does the UAE accept EU or US approvals for recycled PET?

For rPET water bottles, yes. Annex (2) of MoIAT's MR 105/2022 recognises an EFSA opinion under Regulation (EC) 282/2008 or a US FDA no-objection letter. Otherwise the recycler needs MoIAT registration under CR 20/2015, or evidence such as a challenge test, migration test reports and a risk assessment.

Does the federal food safety law cover packaging too?

Yes. Under Article 9(1)(b) of the Cabinet's food safety executive regulations (CR 26/2017), food contact materials must not be a source of danger or contamination to food in their intended use.

AGS provides independent documentation toolkits. The referenced kit is written to support MoIAT requirements. Like this guide, it is not affiliated with, endorsed by or approved by the UAE Cabinet, MoIAT, MOCCAE, GSO or Dubai Municipality. It is general information, not legal advice, and what applies depends on your product, your emirate and your competent authority.

Reviewed October 2026. Facts checked against the sources current at publication.