UAE Gives Suppliers 24 Hours to Withdraw Counterfeit Goods: What Businesses Need to Know

The UAE has introduced stricter requirements for suppliers dealing with counterfeit, adulterated or spoiled goods, including a requirement to withdraw affected products from markets and warehouses within 24 hours of receiving official notification.

The Ministry of Economy and Tourism highlighted the new requirements on 3 September 2026 as part of the Executive Regulations of Federal Decree-Law No. 42 of 2023 concerning Anti-Commercial Fraud.

The regulations are designed to strengthen consumer protection, market integrity and oversight of commercial practices across the UAE. They also demonstrate the growing importance of supplier verification, product traceability and effective risk controls for organisations operating within complex supply chains.

What Do the New UAE Anti-Commercial Fraud Regulations Require?

Under the new regulations, a supplier that is notified by the Ministry or another competent authority about counterfeit, adulterated or spoiled goods must immediately stop selling or displaying those products.

The affected goods must then be withdrawn from markets and warehouses within no more than 24 hours of receiving the notification.

Suppliers are also required to notify all points of sale and other entities to which the goods were supplied so that they can be withdrawn within the same period.

In addition, a public announcement concerning the withdrawal must be issued within 48 hours, in both Arabic and English.

Where goods pose a risk to human or animal health, safety or the environment, those timeframes may be shortened.

For businesses, this creates a clear operational requirement: organisations need to know where their products are, who has received them and how quickly they can communicate across the supply chain if a problem is identified.

Counterfeit Goods Are a Supply-Chain Risk

Counterfeit products are often discussed primarily as a consumer-protection or intellectual-property issue.

For businesses, however, the risk can be much broader.

Counterfeit or misrepresented goods can enter a supply chain through:

• Unverified suppliers.
• Unauthorised distributors.
• Subcontractors.
• Parallel import channels.
• Online marketplaces.
• Intermediaries.
• Fraudulent documentation.
• Misleading product descriptions.

Once a product enters the supply chain, it can be difficult to determine how widely it has been distributed if accurate records have not been maintained.

This is one reason supplier due diligence can be important before a commercial relationship is established.

Conflict Advisory Group’s Due Diligence Services UAE support organisations requiring deeper verification of suppliers, companies and other commercial counterparties before significant relationships are entered into.

Traceability Is Now Even More Important

The 24-hour withdrawal requirement makes product traceability particularly important.

A supplier that does not know exactly where its products have been distributed may struggle to comply quickly with an official withdrawal notice.

Effective traceability can involve maintaining accurate records of:

• Suppliers.
• Manufacturers.
• Importers.
• Distributors.
• Warehouses.
• Retail locations.
• Product batches.
• Shipment dates.
• Customers or commercial buyers where appropriate.

The objective is to make it possible to identify the movement of goods quickly when a problem arises.

Without that visibility, a business may face delays in locating affected stock, informing customers or demonstrating that appropriate action has been taken.

The UAE Is Increasing Commercial-Fraud Oversight

The Ministry of Economy and Tourism has also highlighted the scale of enforcement activity already taking place.

According to the Ministry, UAE authorities carried out 10,023 commercial-fraud inspection tours during the first quarter of 2026, identifying 189 violations.

The Executive Regulations strengthen procedures relating to:

• Inspections.
• Detection of violations.
• Handling of counterfeit or adulterated goods.
• Custody of seized goods.
• Destruction or recycling.
• Data exchange between authorities.
• Administrative penalties.

The Ministry has said the objective is not simply to impose penalties, but also to encourage compliance and strengthen confidence among investors, traders and consumers.

For organisations operating in the UAE, this reinforces the importance of understanding regulatory obligations before a supply-chain problem occurs.

Supplier Verification Should Go Beyond Registration

A supplier may be legally registered without necessarily being the right commercial partner.

Businesses assessing a new supplier may therefore need to consider more than whether the company exists.

Questions can include:

• Who owns and controls the supplier?
• How long has it been operating?
• Is it authorised to distribute the relevant products?
• Where does it obtain its goods?
• Does it use subcontractors or intermediaries?
• Are there previous regulatory issues?
• Is there relevant adverse information?
• Are the supplier’s commercial claims consistent with independent records?

Where products involve recognised brands or protected intellectual property, organisations may also need to establish whether the supplier is part of an authorised distribution chain.

This can reduce the risk of unintentionally acquiring counterfeit or unauthorised goods.

Counterfeit Risk Can Affect Legitimate Businesses

A company does not need to deliberately sell counterfeit goods to experience serious consequences.

A legitimate business may unknowingly purchase products from a supplier that has misrepresented their origin or authenticity.

Potential consequences can include:

• Product withdrawals.
• Regulatory scrutiny.
• Customer complaints.
• Lost revenue.
• Contractual disputes.
• Reputational damage.
• Destruction of stock.
• Disruption to normal operations.

The new regulations therefore increase the importance of having procedures capable of responding quickly when a product problem is identified.

E-Commerce Creates Additional Challenges

The Ministry has specifically stated that the regulations are intended to keep pace with modern forms of trade, including e-commerce.

Online commerce can make counterfeit risk more difficult to manage.

Businesses may source products from suppliers they have never met physically, while platforms can connect buyers with distributors in multiple jurisdictions.

Warning signs may include:

• Prices significantly below normal market levels.
• Unclear product origin.
• Newly established suppliers.
• Inconsistent corporate information.
• Payment requests to unrelated entities.
• Limited evidence of authorised distribution.
• Unverifiable product documentation.
• Repeated changes in supplier identity or contact information.

None of these factors automatically establishes wrongdoing.

However, where concerns arise, further verification may be appropriate before substantial orders or payments are made.

Product Withdrawal Requires a Prepared Response

The new 24-hour timeframe also means businesses should consider their response procedures in advance.

Organisations may need to establish:

• Who has authority to suspend sales.
• How warehouses will be notified.
• How distributors and retailers will be contacted.
• How affected stock will be identified.
• Who will communicate with regulators.
• How public notifications will be issued.
• How evidence of withdrawal will be maintained.

The regulations also address the destruction, recycling and re-export of affected goods.

Eligible goods may, subject to the relevant controls, be re-exported to their country of origin or exporting country within 30 days.

These procedures can become difficult to coordinate if an organisation has not clearly assigned responsibilities before an incident occurs.

Counterfeit Goods Can Create Wider Commercial Risk

Counterfeit products can also expose weaknesses elsewhere in a business relationship.

If a supplier has misrepresented the authenticity of goods, organisations may need to consider whether other information supplied by that counterparty can be trusted.

That can justify a broader review of:

• Ownership.
• Trading history.
• Corporate relationships.
• Financial information.
• Licensing.
• Source of goods.
• Litigation.
• Regulatory history.
• Other adverse information.

Conflict Advisory Group’s Risk Management Services UAE support organisations assessing wider commercial and operational risks affecting business relationships in the UAE and internationally.

What Should UAE Businesses Do Now?

The new regulations provide a useful opportunity for organisations to review their current supply-chain controls.

Businesses dealing in physical goods should consider whether they can answer several important questions:

• Can we identify the origin of the products we purchase?
• Have critical suppliers been independently verified?
• Do we know whether distributors are authorised?
• Can we identify where affected goods have been sent?
• Can we stop sales quickly if required?
• Can we notify customers and points of sale within the required timeframe?
• Do we maintain sufficient records to support a withdrawal?
• Do our contracts address counterfeit or non-compliant goods?
• Do we periodically reassess higher-risk suppliers?

The stronger the visibility across the supply chain, the easier it becomes to respond when a product issue arises.

Supplier Risk Is Business Risk

The UAE’s new anti-commercial fraud regulations reinforce the importance of maintaining confidence in the origin, authenticity and distribution of goods.

The requirement to withdraw affected products within 24 hours means businesses may have very little time to investigate once a regulator has identified a problem.

Prevention and preparation therefore matter.

Organisations that understand their suppliers, maintain strong product-traceability records and have clear withdrawal procedures are likely to be better positioned to respond quickly and limit wider commercial consequences.

If your organisation requires support verifying a supplier, distributor, company or other commercial counterparty, Conflict Advisory Group can assist with due diligence and risk assessment across the UAE and internationally.

Contact Conflict Advisory Group to discuss your requirements and determine the appropriate scope of verification for your organisation.