Food Contact Material Product Registration in Dubai
Food contact materials (FCMs) are regulated in Dubai under a clear compliance system tied to UAE-wide standards. If your business manufactures or imports packaging, utensils, containers, or any material that comes into contact with food, registration is not optional, it is required.
Dubai enforces FCM compliance through a combination of federal certification and local registration. The Emirates Authority for Standardization and Metrology (ESMA) handles technical approval through the Emirates Conformity Assessment Scheme (ECAS). Dubai Municipality manages product registration, import clearance, and market surveillance. No product can be legally sold or imported unless it meets all conditions and applicable standards under both systems.
This guide outlines the specific regulatory path for FCMs in Dubai, including certification, registration, labeling, and customs approval. It is built for operators, manufacturers and importers, who need each step broken down, without assumptions, and without mistakes.
Table of Contents
What Are Food Contact Materials (FCMs)?
Food contact materials (FCMs) are products that directly or indirectly touch food during processing, packaging, storage, or consumption. These materials include plastics, metals, glass, ceramics, paper, rubber, and coatings.
FCMs must not transfer harmful substances to food in amounts that could pose a risk to health. Common examples include:
- Plastics: Packaging, containers, films
- Metals: Cans, utensils, cookware
- Paper: Food wrappers, napkins
- Glass & Ceramics: Bottles, jars, tableware
- Rubber & Silicone: Bakeware, seals
Items used in both food packaging and processing equipment are subject to FCM regulations. For instance, a non-stick coating on cookware or a plastic liner inside a can falls under this category.
Regulatory Framework in Dubai & UAE for Food Contact Materials
FCM regulation in Dubai is governed by a combination of federal and local requirements to ensure food safety. The UAE has specific standards that align with international norms, and compliance is strictly enforced.
UAE Federal Regulations
Cabinet Resolution No. 20 of 2015: This is the cornerstone of food safety regulation in the UAE, covering all food contact materials. It sets guidelines on materials, labeling, testing, and certification.
GSO Standards: The Gulf Standardization Organization (GSO) provides harmonized technical standards for FCMs across the GCC region. Key standards include GSO 2231/2012, which addresses safety and migration limits of substances from materials to food.
Dubai-Specific Regulations
Dubai Municipality (DM): DM manages the registration of FCMs through the Montaji system. All food contact products must be registered before entering the market. The municipality also monitors FCMs for safety compliance.
Emirates Authority for Standardization and Metrology (ESMA): ESMA provides technical approval through ECAS (Emirates Conformity Assessment Scheme) for certain FCM products, particularly those imported or manufactured under specific standards.
These regulations ensure that all food contact products in Dubai meet health and safety standards before they reach consumers. Non-compliance can result in penalties, product recalls, or import restrictions.
Key Government Authorities Involved
FCM registration and compliance in Dubai involve several key government authorities. These organizations play distinct roles in ensuring that food contact materials meet the required safety standards.
Dubai Municipality (DM)
Dubai Municipality oversees the registration of FCMs through the Montaji system. This system handles food safety certification, product registration, and market surveillance. DM also monitors compliance and conducts inspections to ensure that FCMs do not pose a health risk.
Emirates Authority for Standardization and Metrology (ESMA)
ESMA is responsible for the Emirates Conformity Assessment Scheme (ECAS), which certifies FCMs under UAE regulations. ESMA provides technical approval for products and materials that meet the national standards. Manufacturers and importers must obtain ESMA certification before placing products on the market.
Gulf Standardization Organization (GSO)
The GSO sets regional standards for FCMs, which are adopted by the UAE. These standards include migration limits for chemicals in materials that contact food. Compliance with GSO standards ensures that products meet the health and safety requirements for the GCC region.
Dubai Customs
Dubai Customs plays a key role in the import clearance process. All FCM products must pass through Customs Product Inspection Programs (CPIP) and the Customs Risk Profile (CRP) system. Dubai Customs ensures that imported products are compliant with FCM regulations before they enter the local market.
Ministry of Climate Change and Environment (MOCCAE)
Though not directly involved in FCM registration, MOCCAE’s broader food safety policies impact FCM regulations. The ministry supports environmental and health standards that may influence FCM regulations.
Required Documents for FCM Registration in Dubai
To successfully register your food contact materials (FCMs) in Dubai, the following documents are typically required at each stage of the registration process:
1. Business Licensing Documents
- Food Establishment License from Dubai Municipality (required for all food-related businesses)
- Trade License (business registration certificate)
2. Product Testing Documentation
- Test Reports from accredited laboratories confirming compliance with migration limits and material safety
- Material Specifications outlining the composition and properties of the FCM
- Declaration of Compliance from the manufacturer stating that the material meets safety standards and does not transfer harmful substances to food
- Food Safety Certificate (if applicable)
3. ESMA Certification Documents
- Product Information Sheet with details of the FCM (materials used, intended use, etc.)
- Testing Reports showing compliance with ESMA and GSO standards
- Manufacturer’s Certificate confirming compliance with relevant national standards
4. Labeling Documentation
- Product Labels featuring the required symbols (e.g., fork-and-glass symbol or “For food contact”)
- Bilingual Labels (Arabic and English)
- Ingredient/Material Information (if relevant)
5. Montaji Registration Documents
- Product Registration Form through the Montaji system (digital submission)
- ESMA Certification for FCM products
- Importation Documentation (for imported FCMs)
6. Customs Documentation
- Customs Declaration with all relevant details for product inspection (via CPIP/CRP system)
- Import Approval Certificate from Dubai Customs
- Invoice and Packing List for shipment clearance
5. Step-by-Step Guide: How to Register FCMs in Dubai
Registering food contact materials (FCMs) in Dubai requires several steps to ensure compliance with both local and federal regulations. The process involves testing, certification, product registration, and customs approval.
Step 1: Ensure Business Licensing & FIRS Registration
Before you begin, ensure your business is legally established in Dubai with a Food Establishment License from Dubai Municipality. This license is a prerequisite for registering any food-related products, including FCMs, through the Food Import and Registration System (FIRS).
Step 2: Email Request for Registration
Send an email to montaji-fcm@dm.gov.ae requesting the registration of your FCMs. Attach the necessary documents, including test reports, material specifications, and health and safety certificates.
Step 3: Product Testing & Technical Documentation
Submit your product for testing at an accredited laboratory. The lab will check for migration of harmful substances into food. Prepare a technical dossier, ensuring the documents meet the required GSO standards for the FCM.
Step 4: Receive Fees & Payment
After submitting your registration request, you will receive the applicable fees via email. Pay the fees as instructed.
Step 5: Apply for ESMA ECAS Certification
Submit the required documents to the Emirates Authority for Standardization and Metrology (ESMA) via their online platform. If your FCM meets the national standards, ESMA will approve it, allowing you to market the product in the UAE.
Step 6: Approval Response
Dubai Municipality will reply via email with the status of your registration: approved, rejected, or if amendments are needed.
Step 7: Labeling & Symbol Requirements
Once approved by ESMA, ensure your FCMs have clear labeling indicating they are for food contact. The fork-and-glass symbol or “For food contact” statement is mandatory. Labels must also be bilingual (Arabic and English) and include safety information.
Step 8: Certificate Issuance
If your FCM is approved, you will receive the registration certificate from Dubai Municipality via email.
Step 9: Import Consignment Approval
Before importing FCMs, submit your consignment for approval through the Customs Product Inspection Program (CPIP) and Customs Risk Profile (CRP) system. Dubai Customs will inspect the product to ensure compliance upon arrival.
Step 10: Maintain Compliance and Renewals
After registration, maintain compliance with Dubai’s regulatory standards. ESMA certification and product registration require periodic renewal, and your FCMs may be subject to audits or spot checks by Dubai Municipality or ESMA.
6. Common Compliance Issues & How to Avoid Them
1. Incomplete Documentation
Missing or incorrect documents delay product registration in the UAE. Ensure all required paperwork is complete and accurate, including test reports, certifications, and material specifications. Failure to submit mandatory documents can cause delays in obtaining the certificate of conformity and affect the registration process for food contact materials.
2. Non-Compliance with GSO Standards
Failure to meet GSO migration limits and material safety standards leads to rejection. To ensure compliance, conduct proper product safety verification at accredited labs that follow GSO guidelines. Test reports should reflect full compliance with UAE national standards for materials and articles intended to come into contact with food.
3. Incorrect Labeling
Improper labeling can cause delays in the product certification process. Ensure labels feature the correct conformity certificate label and are bilingual (Arabic and English), as required by Dubai Municipality. The fork-and-glass symbol or “For food contact” statement must be clearly visible on all food contact products.
4. Expired Certifications & Registrations
Expired ESMA product certification can result in the removal of products from the UAE market. Track renewal dates for the conformity certificate, product registration, and ensure certifications remain valid for one year. Renewals should be submitted two months before expiry to avoid disruptions in the sale and distribution of FCMs.
5. Customs Clearance Issues
Improper import documentation delays clearance and affects product registration. Ensure all customs declarations align with CPIP and CRP requirements. Misalignment can cause delays in obtaining the necessary certificate for food contact materials, leading to missed opportunities in the lucrative UAE market.
FAQs
1. Can a general trading license be used to register FCMs under ECAS?
Only if it includes relevant activities like packaging, kitchenware, or plastic goods. MoIAT may reject unrelated license categories.
2. Do I need separate certificates for different product sizes or colors?
If the material and intended use are the same, one certificate can cover variations. Otherwise, separate applications may be required.
3. Are recycled materials allowed in FCM products?
Yes, but only if supported by migration test results proving compliance with UAE food safety standards.
4. Can a foreign manufacturer apply for ECAS certification directly?
No. Certification must be done through a UAE-based entity holding a valid trade license.
5. What happens to FCM shipments stuck at port without a certificate?
They’re held by customs until documents are corrected—or rejected entirely. You may face demurrage charges or forced re-export.