Cosmetic Product Claims in the UAE: GSO 2528:2024 and the Evidence File

A claim is any message that states, suggests or implies a cosmetic product has a particular characteristic, and Dubai guideline GU116 counts pictures, graphics and symbols inside that definition, so a logo is a claim before any sentence is. The Gulf text that governs what you may say is GSO 2528:2024, the technical regulation of cosmetic and personal care product claims, edition 2, approved 1 May 2024. Its store abstract is one line long: it is concerned with allowed claims criteria for cosmetic products, and it warns that products carrying unacceptable claims may fall outside the cosmetic scope in its clause 2.1, which is the reclassification risk every marketer should read twice. Three rules carry most of the weight in practice. First, treatment language is out: GU116 bans any claim related to prevention, treatment or curing of any type of disease from labels, brochures, leaflets and advertisements. Second, every special claim needs a file: halal logos, organic or vegan wording, statistics and performance statements each map to a document Dubai reviewers can demand under clause 9.5. Third, the claim must survive translation: the Arabic panel says the same thing as the English one, with the same evidence behind both.

The GSO store listing settles the identity of the text. GSO 2528:2024 is a Gulf Technical Regulation titled Cosmetic products, Technical Regulation of Cosmetic and Personal Care Products Claims, edition 2, marked current, approved on 1 May 2024, classified under ICS 71.100.70 for cosmetics and toiletries. The store lists an Arabic version of 11 pages as the reference language and an English version of 12 pages, and that matters twice: the store designates the Arabic version as the reference language, and the full text is not posted for free download, it is purchased through the GSO store, so most public discussion of its categories works from the abstract and official summaries. That abstract says the regulation is concerned with allowed claims criteria for cosmetic products, and that products containing unacceptable claims could fall outside the cosmetic products scope described in clause 2.1. Adoption is GCC wide: the Bahrain standards store lists BH GSO 2528:2024 with an adoption approval dated 14 April 2024. Position it beside the sibling texts: GSO 1943 sets the safety requirements for the product itself, GSO 2528 sets what you may say about it, and Dubai Municipality guideline GU116 (version 2.1, issued 15 September 2025) is the local document that carries claims duties into the Montaji file, listing GSO 1943 among its references.

The full regulation is a paid document, so the picture below is the one documented in the public abstract and in industry summaries of the text, and the purchased standard remains the final word for edge cases. A ChemLinked summary of GSO 2528:2024 reports that all claims must follow six common criteria: legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making. An Intertek note on the earlier 2016 edition described the same architecture: in line with EU common criteria, plus a list of unacceptable claims the Gulf text adds on top. ChemLinked quotes the sort of wording the unacceptable list targets: claims suggesting medical treatment, such as stopping aging, killing germs, and treating acne. GU116 supplies the working definitions a Dubai reviewer applies: a claim is any message or representation, not mandatory under local regulations, including pictorial, graphic or symbolic representation, which states, suggests or implies that a product has a particular characteristic, and a medical claim is one that says the product or its ingredients can prevent, cure, diagnose or alleviate a disease or its symptoms. In practice the file has to cover five claim families: performance and efficacy statements, ingredient and free-from style wording, certification logos such as eco, vegan, organic and halal, statistics and numbers, and the pictures and symbols on the pack, because under the definition a drawing can carry a claim too.

GU116 clause 9.5 is where claims turn into paperwork. The clause says any other document may be requested during the registration process when necessary, then names four examples that map onto claim types one to one. A halal certificate, issued from a recognized Islamic society in the country of origin, and the guideline adds that this certificate is mandatory if a halal logo is present on the label and needs to be valid at the time of submission. The halal cosmetics certification guide covers when the certificate is mandatory and what certifiers assess. An organic or vegan certificate, to indicate the source ingredient, issued from recognized bodies in the country of origin, which is the document behind an organic or vegan claim and its logo. Clinical studies, to prove certain claims or statistics mentioned on the label, issued from recognized bodies in the country of origin, which is the evidence a performance percentage or a tested-on statement needs. And a safety assessment report, for a specific ingredient in the combination and/or for the overall product, which supports safety adjacent wording. The lesson for the claims list: write each claim and, next to it, the document that proves it, before artwork goes to print, because the same clause 9.5 phrase, any other document, also means a reviewer can ask for substantiation you did not anticipate. our guide to Montaji registration requirements and documents walks the full dossier.

The hard line in Dubai is printed in the labeling section of GU116: medical claims, any claims related to prevention, treatment or curing of any type of disease, must not be presented or referred to on the labels, brochures, leaflets or advertisements or in any other way. The same note bans pictures and illustrations inconsistent with the prevailing social customs and values. The scope logic behind the ban comes from the product definition: GU116 defines a cosmetic as a substance intended for contact with the external parts of the body or the teeth and mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, correcting body odors, protecting them or keeping them in good condition, which is the perimeter GSO 1943 polices for safety. A claim that promises treatment stops describing a cosmetic and starts describing a drug, and that is the consequence both the GSO abstract and the SFDA consultation notice attach to unacceptable claims under GSO 2528:2024: products carrying them may come out of the scope of cosmetic products. The exclusion list in GU116 itself shows how ordinary sounding wording crosses the line: products intended to improve breathing and sleep, products intended to have spiritual mental effects or claims such as calming, uplifting mood, inner peace, improving focus or meditation, products against head lice or nail biting, nasal sprays and vaginal washes. ChemLinked examples, stopping aging, killing germs, treating acne, sit in the same family.

A claim exists in every language the pack speaks, and the UAE pack speaks two. GU116 requires the mandatory label components to be declared in clear English and/or Arabic, and the GSO store marks the Arabic version of GSO 2528:2024 as the reference language of the text, so the Arabic wording of a claim is not a translation afterthought, it is the wording a regulator reads first. The practical rules follow from that. The Arabic panel must state the same claim as the English one, no softer and no stronger, because a treatment promise hidden only in Arabic is still a treatment promise. Every claim trigger needs its Arabic twin handled: a halal logo, a dermatologically tested line, a vegan mark on the back panel each carry their clause 9.5 document regardless of the language they appear in. And the bilingual check has to happen at artwork stage, not at filing, because mismatches between the two languages are a review trigger on the dossier. our Arabic labeling guide covers the language element across product labels, and the GSO 1943 labeling rules guide lists the mandatory components the claims text sits beside.

Claims are checked at three moments. At registration, the Montaji reviewer reads the dossier under clause 9 and can request any other document when necessary under clause 9.5, and the recurring rejection pattern our registration guide documents is claims specific: medical or drug style wording, or specific claims offered without the clinical studies behind them, which fails under GSO 2528:2024. At advertising, GU116 clause 11.2 requires any related advertisement or promotional activity to get pre-approval through the Montaji system, and names brochures, newspapers and magazines, promotional campaigns, social media, TV and media, and outdoor and indoor advertisements, so a claim that cleared the label still needs a clearance before it runs in a campaign; the exceptions are narrow, covering sales subject to conditions, gifts, prizes, discount coupons and free distribution of registered products or samples. In the market, clause 11.1 keeps products under an inspection program that covers the status of product registration, the physical conformity of products and sampling for laboratory testing, clause 11.3 provides for recall and withdrawal of non-compliant batches, and clause 11.4 charges violations under Local Order No. 11 of 2003, with no fine amounts published in the guideline. our UAE cosmetics registration guide covers the first moment in full, and the Montaji renewal guide keeps the second cycle clean.

Sequence the work and the claims risk shrinks to a checklist. List every claim your pack and your campaigns make, in both languages, including logos, symbols and before and after style content. Map each one to its evidence type under GU116 clause 9.5: a halal logo to a halal certificate valid at submission, organic and vegan wording to source ingredient certificates, statistics and performance lines to clinical studies from recognized bodies, safety adjacent wording to a safety assessment report. Delete anything that reads as prevention, treatment or cure, and anything on the GU116 exclusion list such as sleep, mood and focus claims, because no document fixes a claim that sits outside cosmetic scope. Reconcile the English and Arabic panels word for word, then file, and keep the advertising pre-approval step in mind for every campaign that reuses the claims. If you want the claims review, the evidence mapping and the Montaji filing handled in one pass, start with our product registration assistance service. For the dossier around the claims, read the UAE cosmetics registration guide, for the manufacturing evidence behind quality wording, the cosmetics GMP certificate guide, and for the border steps after approval, the cosmetics import guide.