A Guide to Product Liability in the UAE: Laws, Responsibilities, and Compliance Strategies

The UAE has strengthened its product liability regime through recent laws and executive regulations that align with international standards. Companies must ensure compliance with labelling, warranty, and recall requirements or face escalating fines, enforcement actions, and potential criminal referrals.

Product liability in the United Arab Emirates (UAE) is rapidly evolving, with laws focused on safeguarding consumers while holding businesses liable. Firms that produce, import, distribute or sell items, including online platforms, are required to follow rules on labelling, warranty, and recall guidelines.

The framework is based on the Product Safety Law of 2018, Consumer Protection Law of 2020, its 2023 revisions, and Cabinet resolution of 2023. These regulations enforce liability throughout the supply chain and bring the UAE in line with international consumer protection norms.

This article explains the legal framework, identifies who will be liable, and outlines safety, recall, and warranty requirements. It also discusses enforcement patterns, penalties, and practical compliance actions, which are crucial for foreign enterprises operating in the UAE’s rapidly expanding and growing market.

UAE’s product liability legal framework

The UAE’s product liability regime is anchored in a set of interlinked laws and regulations that define safety obligations, consumer rights, and enforcement powers. Together, these measures create a comprehensive framework that aligns with international standards while imposing clear responsibilities on businesses across the supply chain.

The table below summarises the key laws and their implications for companies operating in the UAE.

Following the ESMA merger, the Ministry of Economy oversees enforcement, with support from the Ministry of Industry and Advanced Technology, which now oversees standards and compliance assessments.

Who is liable? Roles and responsibilities

The law is applied to all parties in the supply chain: manufacturers, distributors, retailers, importers and UAE-registered e-commerce platforms. Each has obligations to ensure product safety. Suppliers cannot contract out of consumer rights, meaning liability cannot be waived through agreements.

Foreign online sellers not registered in the UAE are outside the law’s direct scope, but liability will still apply to local distributors or importers bringing their products into the UAE.

In the free zones, civil claims may be brought before ADGM or DIFC courts if agreed in contracts. These courts apply statutory law influenced by common law principles, but they do not replicate English law. This point is important for foreign companies considering jurisdiction and dispute resolution clauses.

Defects, warnings, and labelling duties

A product is considered defective if it has unsafe design, fails to conform to standards, or creates risks not adequately mitigated. The Executive Regulations impose strict requirements for labelling and consumer information, including:

• Mandatory Arabic labelling.
• Clear instructions for installation, use, and maintenance;
• Clear Disclosure of pricing, warranty terms, and after-sales service; and
• Advertising not misleading and needs to be accurate.

Hogan Lovells writes that failures in labelling or warranties are among the most common sources of enforcement action and can lead to fines or forced recalls.

Recalls, reporting, and record-keeping

Suppliers are required to act quickly when defects arise:2

• 4 hours to notify authorities if a defect causes a safety risk; and
• Seven days to report other recovery actions.

They must maintain recall records, notify affected consumers, and file closure reports once recalls are complete. Authorities have wide powers, including product withdrawal from the market, public safety notices and fines.

E-commerce and digital platforms

As reported by Lexology and CMS, The Consumer Protection Law extends obligations to online sales. UAE-registered platforms must provide:

• Arabic-language product information;
• Transparent pricing;
• Clear warranties and return procedures; and
• Claims, remedies, and limitation periods.

Cross-border platforms not registered in the UAE are not directly covered, However UAE-based importers or distributors handling their products remain responsible.

Consumers can demand repair, replacement, refund, or compensation for harm caused by defective products. But remedies do not apply if damage arises from misuse or use outside instructions.

Moreover, limitation periods are:Three years for most tort-based product claims, starting from awareness of harm caused and responsible party. Fifteen years for certain contractual claims, unless otherwise specified.

Sector-specific obligations

Some industries face stricter requirements due to public safety risks. High-risk categories include food, medical devices, automotive, electronics, and toys.

These sectors are subject to technical standards, conformity marks, and pre-market approvals. Hogan Lovells highlights that regulatory scrutiny is specifically strong in pharmaceuticals and automotive.

Penalties and enforcement

The 2023 Executive Regulations introduced detailed penalty schedules. Businesses can face administrative fines for failing to label products, disclose warranties, or report recalls. Repeat offences escalate fines significantly. Serious breaches under the Product Safety Law may trigger criminal referrals.

Checklist for foreign companies

Foreign investors and exporters to the UAE should:

• Register a local entity or partner responsible for compliance;
• Ensure all product information and warranties are available in Arabic;
• Verify conformity with UAE and GCC technical standards;
• Update contracts to include indemnities, insurance, and dispute resolution clauses; and
• Monitor updates from the Ministry of Economy.

Outlook

The 2023 executive regulations expanded consumer rights and increased enforcement mechanisms. E-commerce platforms are now explicitly liable for product safety compliance, while authorities have broader powers to impose recalls and penalties.

Recent cases highlight a growing willingness of regulators to hold both suppliers and retailers accountable for defects, particularly in sectors like electronics and pharmaceuticals.

The UAE is aligning its product liability regime with international best practices. Enforcement is expected to strengthen further in 2025–2026, with greater emphasis on digital sales and e-commerce compliance. For foreign companies, early and proactive compliance will not only reduce legal risk but also enhance trust with regulators and consumers.

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