UAE Introduces Phased Sodium, Sugar and Fat Limits for Selected Packaged Foods

The UAE Ministry of Health and Prevention has begun implementing a national framework establishing maximum levels of sodium, processed sugar and fat in selected packaged food products.

The requirements apply to qualifying products manufactured in the UAE as well as imported products sold within the country. Food establishments operating in free zones are also within scope where they manufacture, import, process, store, distribute, display or sell the relevant products.

The framework introduces progressive reductions rather than requiring every product to meet the final nutritional limits immediately. The final limits must be achieved by 31 December 2030.

The first group of products includes:

• leavened bread;

• flat bread;

• sweetened milk drinks, including milk alternatives;

• sweetened or flavoured yoghurt and laban;

• salted crackers;

• salted nuts and seeds;

• pretzels; and

• certain extruded snacks and chips made from potatoes, sweet potatoes, vegetables or grains.

The second group covers processed cheese, including spreadable and other processed-cheese products.

The framework therefore does not impose the same requirements across the entire UAE food market. Businesses must first determine whether an individual product falls within one of the specified categories.

For leavened bread, the first-phase maximum per 100 grams is:

• 444mg sodium;

• 6g total sugars; and

• 8.4g total fat.

The final limits will reduce these to:

• 370mg sodium;

• 5g total sugars; and

• 7g total fat.

For flat bread, the first-phase limits are 384mg sodium, 6g sugars and 8.4g fat per 100 grams, eventually reducing to 320mg sodium, 5g sugars and 7g fat.

For manufacturers and importers, these requirements may necessitate product reformulation rather than simply a change to labelling.

Sweetened milk drinks, including milk alternatives, will initially be permitted to contain up to 9.6g of total sugar per 100g, falling to 8g under the final limit.

Sweetened or flavoured yoghurt and laban will have an initial maximum of 12g, reducing to 10g in the final phase.

Businesses dealing with these products should therefore assess the actual nutritional composition of individual SKUs rather than relying on the general product category.

The framework establishes separate sodium limits for different snack categories. For example, the maximum for salted crackers will move from 696mg to 580mg per 100g, while salted nuts and seeds will move from 336mg to 280mg. Pretzels will reduce from 912mg to 760mg, while covered extruded snacks and chips will move from 564mg to 470mg.

This category-specific structure means manufacturers and importers may need to assess products individually rather than applying a single sodium standard across an entire portfolio.

Processed cheese forms a separate compliance group. Spreadable processed cheese will initially be subject to a maximum sodium level of 864mg per 100g, eventually reducing to 720mg. For other processed cheeses, the maximum will move from 1,200mg to 1,000mg per 100g.

Businesses handling the first group of products have up to nine months from the resolution's effective date to meet the first-phase limits. Businesses handling processed cheese have up to two years and three months to reach their first-phase limits. Both groups must reach the final requirements by 31 December 2030.

Products manufactured or imported before the resolution takes effect may continue to be sold for up to one year from the effective date, or until their expiry date, whichever occurs first. After that period, products that do not meet the applicable maximum limits cannot continue to be traded in the UAE.

This provision will be particularly relevant to importers and distributors holding significant inventory with long shelf lives. Businesses should therefore review existing stock alongside future product orders and production schedules.

The framework includes a limited exception mechanism where meeting the first-phase limit would require reducing a targeted ingredient by more than 20% of its established level in an existing product. Businesses seeking this exception must submit an application to the Ministry of Health and Prevention within 30 days from the resolution's effective date. The application must include supporting technical information, registered nutrition-label data and accredited laboratory test results. Even where an exception is granted, the establishment must reduce the targeted ingredient by at least 20% during the first compliance phase. The exception also does not remove the final obligation to meet the prescribed maximum limits by 31 December 2030.

Products manufactured or imported specifically for direct export or onward export outside the UAE are excluded from the requirements, provided they are not traded within the UAE market. This distinction may be particularly relevant to manufacturers operating from UAE industrial zones or free zones that produce food exclusively for foreign markets. Once a covered product is placed on the UAE market, however, the domestic requirements become relevant.

Federal and local health authorities and other competent bodies will monitor compliance in coordination with the Ministry of Health and Prevention. Available administrative measures include:

• warnings;

• fines from AED 5,000 to AED 500,000;

• temporary closure for up to six months, with the possibility of renewal; and

• cancellation of the establishment's licence or approval in coordination with the relevant licensing authority.

The seriousness, circumstances and recurrence of the violation will be relevant to the penalty imposed.

NUR Advisory Note

The new framework is particularly relevant to food manufacturers, importers, distributors and retailers dealing with the affected product categories. Businesses should not wait until the final 2030 deadline before assessing compliance. The first-phase requirements apply much earlier.

A practical review should include:

• identifying all products falling within the regulated categories;

• reviewing current sodium, sugar and fat levels;

• obtaining laboratory analysis where necessary;

• assessing whether reformulation will be required;

• reviewing nutrition labels and registered product information;

• identifying existing inventory manufactured or imported before implementation;

• reviewing supplier specifications for imported products;

• planning future purchase and production cycles around the compliance deadlines; and

• assessing immediately whether any product may qualify for the limited first-phase exception.

Importers should also coordinate with overseas manufacturers. A product that complies with the

nutritional rules of its country of manufacture may still require reformulation before it can continue to be sold in the UAE.

For businesses with large product portfolios, the new framework should therefore be treated as a product-level compliance exercise, not merely as a general food-licensing requirement.