For brands developing high-performance skincare, or a product that can be called “cosmeceuticals,” in the UAE market, there is one regulatory challenge to consider: Is the product classified as a cosmetic, or do some aspects of composition, intended purpose, presentation, or claims indicate another regulatory approach should be used? The term “cosmeceutical” is not a standalone regulatory category, and a lack of a definition is still a common issue for cosmetic markets. Under cosmeceutical regulations UAE, an early classification helps manufacturers, brand owners, importers and R&D to develop formulations, claims and registration before launch. [1]
Cosmeceuticals in the UAE: Cosmetic or Drug? A Product Claims Compliance Guide
For brands developing high-performance skincare, or a product that can be called “cosmeceuticals,” in the UAE market, there is one regulatory challenge to consider: Is the product classified as a cosmetic, or do some aspects of composition, intended purpose, presentation, or claims indicate another regulatory approach should be used? The term “cosmeceutical” is not a standalone regulatory category, and a lack of a definition is still a common issue for cosmetic markets. Under cosmeceutical regulations UAE, an early classification helps manufacturers, brand owners, importers and R&D to develop formulations, claims and registration before launch. [1]
Cosmeceutical, Cosmetic or Drug? Why Classification Matters in the UAE
Under the current Gulf regulatory framework, GSO 1943:2024 defines cosmetics and personal care products by their functions such as cleaning, perfuming, changing appearance, protection, maintaining the body in good condition and correcting body odours. The regulation also addresses safety, labelling, packaging and banned and restricted ingredients. [2]
Therefore, “cosmeceutical” does not create a separate legal status. Cosmetic vs. drug classification should be considered based on all characteristics of the product profile, including formulation, intended purpose, presentation, and claims.
For cosmeceutical product development, classification is an early consideration alongside formulation development, testing, packaging, and commercial strategy, rather than a final registration step.
How UAE Regulators Define a Cosmetic vs a Medicinal Product
The Role of Intended Use and Claims
Intended use is vital when determining if the product still falls into the cosmetic category. Claims concerning moisturizing, cleaning, protecting, or enhancing appearance are completely different from claims that state a product’s treatment of disease or significant physiological action.
GSO 2528:2024 is the latest Gulf technical regulation concerning cosmetic claims. It establishes requirements for acceptable claims and identifies circumstances in which claims can take a product outside the cosmetic scope.
Therapeutic claims become an important aspect of regulatory evaluation. For example, “moisturizes dry skin” is a cosmetic claim, whereas “treats eczema” is a medical claim that requires further classification consideration.
Therefore, claims should be evaluated prior to finalization of packaging, websites, advertisements, and other marketing material. [3]
Ingredient-Based Triggers That Push a Product Into “Drug” Territory
The presence of an active ingredient should not necessarily be considered a trigger for the medicinal-product classification. But assessment needs to be based on the active ingredient, its concentration, intended use, presentation and claims together.
On the other hand, the use of ingredients with known pharmacological or therapeutic properties needs to be subjected to regulatory assessment prior to positioning the product as a cosmetic. The formula should also be evaluated against the prohibited and restricted substances list under the current cosmetic framework. Annexes on prohibited substances and substances with specific restrictions are provided in GSO 1943:2024.
For B2B teams, this is a practical reason to integrate regulatory review into cosmetic product development from the concept stage.
FRL R&D Insight: Regulatory positioning should be established in parallel with formulation development. Ingredient selection, formulation, stability, intended use, and claims should be aligned before the claim set is developed.
Making a Compliant Claim — What You Can and Cannot Say
Requirements of GSO 2528:2024 include that cosmetic claims have to satisfy certain criteria such as legal compliance, truthfulness, clarity and consumer understanding. Claims should be relevant to the product and supported by appropriate evidence.
An effective product claim substantiation process must make a connection between:
- The exact proposed claim.
- The finished product and formulation.
- Evidence to support the claim.
- The test methodology or scientific basis, where applicable.
- The justification from a regulatory perspective of why the claim falls within cosmetics.
This issue becomes especially important when research from published sources is used for peptides, botanical extracts, antioxidants or any other active ingredients. Literature relating to an ingredient does not necessarily present as evidence that the finished formulation produces the same effect.
Claims must be consistent in all places where they are used across packaging, website, advertising and other communications. Labeling compliance is therefore a market-access requirement, not simply an artwork exercise, and should be reviewed alongside claims. [4] [5]
UAE Registration Pathways: MoIAT, Dubai Municipality and the EDE Medical-Product Route
Federal Cosmetic Conformity: MoIAT and ECAS
Standard cosmetic products have a federal conformity framework that includes the Emirates Conformity Assessment Scheme (ECAS), which is regulated by the Ministry of Industry and Advanced Technology (MoIAT). Relevant requirements include technical documents such as lab test reports and formulation documents.
Current technical requirements include GSO 1943:2024 for cosmetic safety, labeling and packaging and GSO 2528:2024 for cosmetic claims. The GSO 1943:2024 replaced GSO 1943:2021, while GSO 2528:2024 replaced GSO 2528:2016. Therefore, the relevant GSO technical regulations should be considered along with UAE conformity and market registration requirements.
Emirate-Level Registration: Dubai Municipality and Montaji
Federal conformity is independent of the local market requirements. In Dubai, Dubai Municipality operates Montaji for registering consumer products and market control. Therefore, Emirate-level requirements become an important aspect in UAE cosmetic product registration.
Businesses that distribute their products across multiple emirates need to ensure the relevant local requirements rather than considering one registration to cover all emirates.
Medical-Product Route: EDE
For products which fall under the medical product framework follow a separate pathway. The Emirates Drug Establishment (EDE) offers product classification services based on various aspects such as presentation, composition, intended use and design of the product. In case the classification indicates that marketing authorization is needed, then the product must be registered with EDE under the applicable category.
This is important for companies that still refer to the MoHAP cosmetic requirements terminology. In case a product’s classification might fall under the medical product framework, companies should confirm the current EDE pathway before proceeding with registration. [6]
Product pathway | Primary regulatory route | What to assess |
Cosmetic | MoIAT / ECAS + applicable emirate requirements | Composition, safety, labelling, claims and conformity |
Dubai market registration | Dubai Municipality / Montaji | Local consumer-product registration and market-control requirements |
Medical product | EDE | Classification, composition, presentation, intended use and applicable authorisation |
Common Claim Mistakes That Trigger Regulatory Action
Common problems include:
- Use of therapeutic language in cosmetic packaging or online marketing materials.
- Using ingredient literature as automatic evidence for finished-product efficacy.
- Giving Arabic and English claims different meanings.
- Making claims without proper evidence.
- Advertising language is more therapeutic than the product itself in terms of regulation.
- Treating “cosmeceutical” as a separate legal category.
- Finalising artwork before regulatory and claims review.
This list may have an impact on classification, compliance, registration and post-marketing regulation. Thus, a good cosmetic product developer should check the complete commercial claim package and not just claim language on the main label. [5]
UAE Cosmeceutical Compliance: What to Check Before and After Launch
UAE cosmetic compliance goes beyond registration: classification, claims, formulation, conformity, and digital marketing must stay aligned all the way through the product lifecycle.
Download the UAE Cosmeceutical Compliance Checklist to learn about critical pre-launch and post-launch controls for classification, GSO regulations, claims substantiation, labelling, MoIAT/ECAS conformity, emirate registration, and compliance monitoring.
[Download the UAE Cosmeceutical Compliance Checklist →]
This checklist has been designed as a practical tool for cosmetic product developers, R&D experts, regulatory professionals, and brand owners preparing products for the UAE market. [5]
Conclusion
The UAE cosmeceutical question should be answered before the product reaches the registration desk. When classification, formulation, claims, evidence, and conformity requirements are considered together from the R&D process, brands will have cosmeceutical products that will fit into the proper regulatory pathway.
Build the Product. Substantiate the Claim. Navigate the UAE Market.
Food Research Lab provides cosmeceutical product development through formulation development, stability tests, analytical tests, documentation, and product claim substantiation. Our R&D-based approach enables our business partners to align product performance with technical and regulatory compliance before compliance becomes a costly post-development correction.
Develop your next cosmeceutical with the regulatory pathway in mind from day one.
Frequently Asked Question
Cosmeceutical is not a standalone category. The product must be assessed under the applicable framework based on factors such as composition, intended use, presentation, and claims. Where it falls within the medical-product framework, the relevant EDE requirements apply.
Federal conformity measures relevant for regulated cosmetic products, including ECAS, are administered by MoIAT. There may be additional Emirate-level requirements, like in Dubai, where the Dubai Municipality runs Montaji to regulate registered consumer products and market control.
GSO 2528:2024 provides the list of unacceptable cosmetic claims indicating that the product can treat medical conditions, have a significant physiological effect, or impact metabolism. The exact wording and specific product features shall be considered rather than relying on isolated keywords.
No. The presence of an active ingredient does not mean the product will fall into the drug category. The complete product profile—including composition, concentration, intended use, presentation, and claims—should be assessed.
For cosmetics, businesses should monitor GSO 1943:2024 about safety, labelling and packaging, and GSO 2528:2024 about cosmetic claims. If the product falls under the medical-product framework, its EDE classification and authorisation requirements need to be confirmed before launch.
References
- Thakur, M., & Bala, R. (2026). Challenges and opportunities of cosmeceutical regulations: A global perspective. International Journal of Toxicology, 45(3), 303–313. https://doi.org/10.1177/10915818251399664
- Gulf Standardization Organization. (2024). GSO 1943:2024: Cosmetic products—Safety requirements. https://gso-sims-preview-doc-aws.s3-eu-west-1.amazonaws.com/gso-1943-2024-en.html
- Gulf Standardization Organization. (2024). GSO 2528:2024: Cosmetic Products — Technical Regulation of Cosmetic and Personal Care Products Claims. Official GSO 2528:2024 record
- Rebbaniboni, N., Amarapalli, D., Parveen, A., & Prasanthi, D. (2024). Comprehensive cosmetic regulations comparison of selected emerging markets with US. International Journal of Drug Regulatory Affairs, 12(4), 33–42. https://www.ijdra.com/index.php/journal/article/view/714
- Arikatla, S., Gaibawad, A., Penchala, M., & Prasanthi, D. (2026). Labelling and safety requirements for cosmetics—Comparison in USA, EU, ASEAN, GCC and CIS countries. Research Journal of Topical and Cosmetic Sciences, 17(1), 51–59. https://doi.org/10.52711/2321-5844.2026.00010
- Morel, S., Sapino, S., Peira, E., Chirio, D., & Gallarate, M. (2023). Regulatory requirements for exporting cosmetic products to extra-EU countries. Cosmetics, 10(2), 62. https://doi.org/10.3390/cosmetics10020062
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