The government of the United Arab Emirates (UAE) will be mandating a new requirement for all food products that are marketed in the UAE as Halal, and shipments of products that contain any reference to Halal on the packaging may be impacted. All food products are impacted, including bulk ingredients for further processing, food service, and retail dairy products. When the UAE's Halal mark regulation is implemented, a UAE government-owned Halal mark from the Emirates Authority for Standardization & Metrology (ESMA) will be the only recognized reference to Halal that will be allowed on food product packaging. ESMA has established a June 2017 implementation date for the Halal mark requirement. 

The use of the EMSA Halal mark is voluntary and the alternative is for a manufacturer to not include any reference to halal on the package. Any U.S. company that chooses to market their products as Halal in the UAE will only be allowed to apply the ESMA Halal mark once the regulation is enforced. Companies will need to apply directly to ESMA to use the ESMA Halal mark and undergo an audit, which is separate from the inspection to obtain a Halal certificate and any Halal requirements that may be enforced under the GCC Import Guide. The cost of the Halal Mark is the licensing fee, which is 15,000AED (approximately $4,000 USD) per manufacturer per UAE/GSO product standard for a 3 year period.

Once the Halal mark is implemented, any reference to halal on the package other than the ESMA halal mark will be grounds for the rejection of the shipment. Therefore, any companies now shipping to the UAE that include the Halal mark of their U.S.-based Halal certifying agency on the package or contain any other reference to Halal will need to remove this Halal reference in order to ship to the UAE, or alternatively, obtain the ESMA halal mark and list this ESMA Halal mark in lieu of the current halal reference. ESMA has established June 2017 as the implementation date of the Halal mark requirement, although it is unclear at this point whether the implementation date may be extended. FAS is seeking clarification from ESMA on the implementation date.

USDEC has conveyed our concerns to FAS surrounding the potential impact of this new regulation on U.S. exports because so many companies already include a Halal reference on the packages shipped to the UAE. In order to convey the true cost of this measure to FAS, and to request their assistance in pushing for an extension of the implementation date, USDEC is asking for member input on the following questions:

1. Which products does your company export to the UAE?
2. Does your product packaging now contain any reference to halal, including the mark of your U.S.-based Halal certifier?
3. If you need to create a new package without a halal reference to serve the UAE market, what is the estimated cost?
4. How long would it take to create a new package that does not contain any references to Halal?
5. What timeframe would you need to work through existing packaging stocks?
6. If you are now marketing your product as halal in the UAE, what is your estimated business loss for any time needed to obtain the ESMA Halal mark?

Please send responses to Jonathan Gardner at jgardner@usdec.org and Sandra Benson at sbenson@usdec.org by April 26, 2017. All member responses will be aggregated so no individual company's confidential information will be shared.