The United Arab Emirates (UAE) has announced its intention to implement a new list of approved halal certifiers on June 1, 2017, which at present includes only one U.S. certifier - Halal Transaction, Inc. - for all of the Americas. The UAE has been working to update its approved certifier list to include those certifiers meeting the UAE's domestic halal requirements, and the revised list had been expected to be published late in 2017, following some regulatory initiatives in the UAE to approve more certifiers in multiple countries. However, this week the UAE announced the transition of halal responsibilities from the Ministry of Climate Change & Environment to the Emirates Authority for Standardization & Metrology (ESMA) effective June 1, and therefore the new list of certifiers will be effective the same day. ESMA has indicated there will be no grace period for shipments that have already departed for the UAE, and are set to arrive on or after June 1^st, with a halal certificate from non-ESMA approved certifiers.

The timing of the halal agency change is expected to coincide with the implementation of the UAE's halal mark. As noted in the Member Alert of April 19, the UAE announced the implementation of the UAE national halal mark scheme on June 1, as well. The use of the UAE halal mark is optional, but when this regulation enters into force, the national UAE halal mark will be the only reference to halal allowed on the labels of all foods. USDEC has already received member feedback on the impact of the halal mark's implementation on USDEC members and is working closely with FAS to address these concerns. At this time, however, the implementation of the halal mark is also expected on June 1, so exporters are encouraged to check with importers before proceeding with any shipments if there is a halal reference on the product packaging.  

USDEC is asking all concerned exporters to reach out to their importers to ask them to contact UAE officials (contact details below) with the following messages:

• All new regulations should be notified to trading partners and implemented within a reasonable period of time according to the WTO TBT agreement. A reasonable period of time is generally considered to be a minimum of 6 months. The announcement of the implementation of a new halal certifiers list should be delayed for a minimum of 6 months, with additional time following afterwards for businesses to adjust. Thus, the Ministry of Climate Change & Environment's list of approved halal certification bodies should continue to be used in the interim.
• The transit time to the UAE from the United States is approximately one month. The short time period between the announcement and implementation of the new halal certifier's list means that there is already product on the water that is certified by companies not on the newly issued approver list, and will be unnecessarily held upon arrival in the UAE.
• The implementation of the new halal certifier list with so few approved certifiers will effectively act as a barrier to trade. These halal certifiers cannot possibly have time to approve all interested manufacturers by June 1. The UAE should continue its efforts to approve additional certifiers and accredit formerly approved certifiers (including IFANCA and the Islamic Society of the Washington Area) as soon as possible.  

Contact information for UAE officials are as follows:

• ESMA Contact: ESMA's Director General Abdulla Al Maeeni, Tel: +971 4208 4319
• Ministry of Economy: Juma Mohammed Al Kait, Assistant Undersecretary for Foreign Trade Affairs; Tel: +971 2613 1284; Email: juma.alkait@economy.ae
• Embassy of the United Arab Emirates to the United States:  Ambassador Yousef Al Otaiba; Tel: (202) 243-2425; Email: http://www.uae-embassy.org/contact-embassy

We are hoping that pressure from importers, the U.S. government, and the governments of other countries that share our concerns will lead to a reconsideration of the implementation date.

USDEC also requests that members provide feedback to Sandra Benson (sbenson@usdec.org) and Jonathan Gardner (jgardner@usdec.org) ASAP on the impact of the new Halal certifier list on your company. We will aggregate all member responses to provide FAS with information on the financial implications of these measures and the amount of product now on the water certified by any of the companies that is no longer approved.