Registering a cosmetic product in the UAE

The guideline defines a cosmetic or personal care product as any substance or preparation intended to be placed in contact with the external parts of the human body, or with the teeth and the lining of the mouth, with a view exclusively or mainly to cleaning, perfuming, changing appearance, correcting body odours, or protecting or keeping them in good condition.

Its examples include creams, lotions, gels and oils for the skin, face masks, hair care products, sun products, skin whitening products and anti-wrinkle products.

Two consequences for a peptide skincare product:

• It is a cosmetic only if it is applied to the outside of the body. Anything injected is outside this definition altogether.
• It may not make a medical claim. The guideline defines one as a claim that a product or its ingredients can prevent, cure, diagnose or alleviate a disease or its symptoms.

The guideline states that all consumer products must be registered by Dubai Municipality before being placed on the Dubai market, under Local Order No. 11 of 2003. Imported products for the local market are registered in Montaji by the importing company or its local agent.

To use Montaji a company needs:

1. a valid licence from a competent authority in the UAE, with an activity related to consumer products;
2. an account on the Dubai Municipality portal;
3. a valid importer code from Dubai Trade.

Products brought in only for re-export, exhibitions, market tests or samples are listed in Montaji, not registered.

The guideline lists, for registration:

• a free sale certificate, authenticated in the country of origin;
• the product artwork;
• a product composition and ingredient concentrations report issued by the manufacturer.

It may also ask for others where it sees a need, among them a laboratory test report, a chemical and physical analysis report, a product safety assessment, stability data, and scientific support for claims.

• The INCI name and CAS number of each peptide, for your composition report: Copper Tripeptide-1 for GHK-Cu, Acetyl Octapeptide-3 for the ingredient known as SNAP-8.
• The certificate of analysis for the batch you bought.
• The specification sheet and safety data sheet, on file.

Your manufacturer writes the composition report for the finished product, and your claims need your own support. If the Municipality asks for something about an ingredient that is not in this list, tell us and we will ask the peptide's manufacturer.

Whoever places the product on the market is responsible, in the guideline's words, for making sure that its presentation, labelling, claims and instructions for use comply with the current rules. Describe what the product does for the look and feel of the skin. Leave out anything about treating a condition.

• Cosmetic peptide ingredients: what we supply
• For skincare brands and formulators
• Request a quote, and say which documents your file needs