Food Contact Materials in the UAE: Which Rules Apply and How They Register

Food contact materials are a regulated category in the UAE on two layers. Federally, the MoIAT regulated products sheet lists Food contact material as row 10 of the categories that need a certificate of conformity under the ECAS service, on the legal basis of Cabinet Decision No. 20 of 2015, the UAE control system for articles in contact with food. The federal file needs a valid UAE industry or trade licence, a test report from an accredited laboratory against the Annex 1 requirements of that decision, a label meeting Annex 2, GMP compliance, an electronic declaration of conformity and payment of fees, and the test report must be less than three years old. In Dubai, the municipal consumer products import guideline states the opposite of what most importers expect on registration: Food Contact Materials currently is not subject to registration requirements, so there is no Montaji product certificate for the packaging itself, while the clearance document list still asks for a material migration test report (OML / SML) for food contact materials. The standards behind the category are GSO technical regulations such as GSO 2231:2012 and the GSO 839 and GSO 1863 food packages series.

Dubai Municipality's consumer products import guideline (DM-HSD-GU100-CPIE2, version 2, issued 2 May 2025) gives the working definition: food contact materials are materials and articles which in their finished state come into contact with food during its production, processing, storage, preparation and serving, or before its eventual consumption. The definition is deliberately wide: it covers articles intended to be brought into contact with food, articles already in contact with it, and articles that can reasonably be brought into contact with food or transfer their constituents to it under normal or foreseeable use, and it names both direct and indirect contact. The guideline's example list is practical: food packaging and containers of plastic, tableware and kitchenware of plastics, water bottles for human consumption, forks, spoons and knives of plastics, plates, dishes and cups of cellular plastic, nursing bottles of plastics, thermos flasks used for tea or coffee, and vacuum flasks and other vacuum vessels. Note what the list implies: the category is judged by the article's function, not by its material, so a ceramic bowl and a plastic lunch box land in the same lane even though the standards behind them differ.

Three desks divide this category, and mixing them up costs a filing cycle. The federal desk is MoIAT: the ministry's regulated products sheet lists Food contact material as an ECAS category under Cabinet Decision No. 20 of 2015, and its conformity service is the one customs looks at for regulated goods; our ECAS certificate guide explains that layer. The municipal desk in Dubai is the consumer products import clearance route: the guideline puts Food Contact Materials inside its scope, states that related services run at the counters of the Health and Safety Department offices at the port of entry rather than on the smart platform, and states that the category is not subject to product registration, so no Montaji product certificate exists for the packaging itself. The third desk is the food lane: packaged food and beverages run through federal food item registration and municipal food control (ZAD in Dubai), a separate file covered in our food import registration guide, and the MoIAT sheet shows where the two touch: food product rows such as juices and dairy list compliance with the food contact material regulation among their documents. Municipal surveillance is visible too: Dubai Municipality's food contact materials page under its health and safety circulars lists non-complying thermo flasks found to contain asbestos.

The standards layer can be verified directly on the GSO store, which lists these entries for the food and agriculture sector: GSO 2231:2012, general requirements for the materials intended to come into contact with food, a technical regulation; GSO 839:2021, food packages part 1, general requirements, a technical regulation; GSO 1863:2021, food packages part 2, plastic packages, general requirements, a technical regulation; GSO 2515:2016, food packages made of aluminum foil, a technical regulation; GSO 2700:2022, migration limits of food packages, a standard; and GSO 2545:2021, recycled plastic materials and articles intended to come into contact with food, a technical regulation. Store titles are quoted here with their punctuation normalized; the store uses dashes in some titles. What the store does not settle is the mapping question: which of these standards a specific material must be tested against inside the UAE file. The MoIAT sheet points to the technical requirements in Annex 1 of Cabinet Resolution No. 20 of 2015, but the annex text itself is not published on the pages checked, so any claim that a specific standard is mandatory for a specific material, including the migration limit values inside GSO 2700:2022, should be treated as unverified until it comes from the regulation text or the ministry. For packaged food labels, which are a different file from the package itself, see our food label requirements guide.

Every document in the federal list comes straight from the MoIAT sheet: a valid UAE industry or trade licence, a test report from an accredited and recognized laboratory against the Annex 1 requirements of Cabinet Resolution No. 20 of 2015, a label meeting the Annex 2 requirements, a list of components and raw materials used where the ministry deems it necessary, GMP compliance, an electronic declaration of conformity and payment of fees. Two documentary rules are worth marking. The first is the clock: the sheet states the test report validity should be less than three years, so a report from the factory's last audit can already be dead on arrival. The second is the source: the laboratory must be accredited and recognized, which pushes the testing decision to before shipment rather than after arrival. On the municipal side, Dubai's clearance document list asks for a material migration test report (OML / SML) for food contact materials. The abbreviations are not expanded in the guideline text; reading them as overall and specific migration limit reporting is an inference, and the numeric values behind them sit in the GSO migration standard whose content is behind the store's purchase wall, so no figure is quoted in this guide.

The practical sequence for an importer of plastic tableware, bottles or packaging runs in three moves. First, classify the goods: confirm the item falls in the food contact material row of the MoIAT sheet rather than another category, using the tariff line as a cross-check in our HS code classification guide. Second, build the federal file on the MoIAT digital platform under the service of issuing conformity certificates for products according to health and safety requirements: register on the platform, attach the valid trade licence, the accredited laboratory test report, the Annex 2 compliant label, the components list where required, the GMP evidence and the electronic declaration of conformity, then pay. The published fee lines are 600 dirhams for the product registration request, 620 dirhams for the technical review of documents per certificate, 500 dirhams for certificate issuance, and 2,500 dirhams per working day per technical assessor where a technical evaluation is conducted, with a stated service time of one and a half working days. Third, clear the shipment in Dubai through the consumer products route: a Montaji import request (CPIP) with the migration test report (OML / SML) among the clearance papers, remembering the guideline's note that FCM services run at the Health and Safety Department counters at the port of entry. The full ladder from product review to a registered file is in our product registration guide.

Four failures recur. The first is skipping the federal file because the packaging needs no municipal registration: the Dubai guideline's line about registration says nothing about the ECAS duty, and the MoIAT sheet keeps the category listed, so a shipment can be right on the municipal side and still be held at customs for want of the conformity certificate. The second is the inverse: filing a Montaji product registration for food contact goods, which the guideline does not provide for. The third is paperwork age: the three year test report limit and the accredited laboratory rule are both written on the sheet, and both fail files at review. The fourth is treating the package file and the food file as one: the sheet's food product rows separately require compliance with the food contact material regulation. On honest limits: this guide does not quote numeric migration limits because GSO 2700:2022's content is not public; it does not map materials to standards because Annex 1 of the cabinet resolution was not retrievable in the pages checked; it does not state certificate validity because the service page is silent on it; and fees move, so the official quote at filing governs. Where a product raises both a conformity mark question and a scheme question, our ECAS and G-mark comparison separates the two.

Start on paper before money moves. Read the food contact material row of the MoIAT regulated products sheet and the annex references in Cabinet Decision No. 20 of 2015, confirm your article's classification, then book testing with an accredited laboratory so the report is young and the standard it cites matches the annex requirement. Check the Dubai consumer products import guideline if the port of entry is Dubai, and keep the migration test report with the clearance set. The Dubai Municipality food contact materials page shows what market surveillance looks for, so a file that passes the border should also survive the shelf. If you want the classification, the testing brief, the federal filing and the Dubai clearance run by one team, start with our product registration assistance service.