There is no single UAE rulebook for herbal supplement claims. Two published frameworks matter most for a herbal product sold as a supplement, and a brand should map both before it drafts a label.
EDE has taken over many services from the Ministry of Health and Prevention (MOHAP): 44 services were transferred in full and 13 in part, including renewal of registration for pharmaceutical products derived from natural sources (full) and health advertising licences (part).[3] Older MOHAP guidance therefore still describes the product categories, but submissions now go through the EDE portal for the transferred services.
At GCC level, GSO 2571:2021 is the Gulf technical regulation for food supplements and GSO 2333:2022 sets requirements for health and nutrition claims on food products.[5][6] Their full texts are sold through the GSO store and were not reviewed for this article, so check them against the product before artwork. Requirements in emirates other than Dubai were not reviewed; confirm the route with the relevant authority. This article is educational, not legal advice. Sources checked on 11 November 2026.
Classification comes before claims, and for herbal and Ayurvedic brands it is where most plans change. Dubai Municipality’s guideline includes botanicals and herbs among health supplement ingredients, in tablets, capsules, soft gels, gel caps, liquids and powders. The same guideline lists Ayurvedic products, Chinese medicine products and traditional medicine products as out of scope: they are not considered health supplements.[1]
Several product positions are also out of scope, whatever the ingredients: products indicated for sleeping, sexual enhancement, vomiting or diarrhoea, hangover, throat lozenges intended to soothe or treat the throat, and supplements for people after bariatric surgery. Label illustrations that suggest symptom relief, such as points or dots on the body, are not accepted.[1]
In practice, a herbal capsule positioned as a supplement with general-wellbeing or structure/function wording can follow the health supplement route. A product presented as an Ayurvedic medicine, or with a classical formulation name and therapeutic indications, needs a medicine route, which at federal level now sits with EDE. Confirm the classification with the authority before you fix the formula and the brand name. For how UAE authorities handle borderline products in another category, see our guide to cosmeceutical classification in the UAE.
Annex 3 of the Dubai guideline, “Banned / Not Applicable Ingredients”, lists 81 entries and may be revised frequently.[1] It includes many botanicals that are common in Ayurvedic and herbal formulas. Table 1 lists examples; check the current list for every ingredient.
| Botanical (scientific name) | Common name |
|---|---|
| Withania somnifera | Ashwagandha |
| Phyllanthus emblica | Amla (Indian gooseberry) |
| Terminalia arjuna | Arjuna |
| Shilajit | Shilajit |
| Boerhavia diffusa | Punarnava |
| Gymnema sylvestre | Gurmar leaf |
| Convolvulus pluricaulis | Shankhpushpi |
| Cissus quadrangularis | Cissus quadrangularis |
| Phyllanthus niruri | Phyllanthus niruri |
| Rauvolfia serpentina | Indian snakeroot |
| Cassia senna, Cassia angustifolia | Senna |
| Hypericum perforatum | St John’s wort |
Table 1. Examples of botanicals listed in Annex 3 (Banned / Not Applicable Ingredients) of Dubai Municipality’s health supplement guideline, Version 2.0.[1] Turmeric (Curcuma longa) and black pepper (Piper nigrum) are not on the list.
The guideline defines a claim broadly: any representation that states, suggests or implies that a product has characteristics relating to its origin, nutritional or health properties, nature, production, processing, composition, indication or any other quality.[1] Two kinds of health-related claim are allowed.
For a herbal product, ingredient-based evidence means data on the same plant part, extract type and dose that the product delivers, not on the plant in general. Dubai Municipality may also ask for clinical studies to prove claims or statistics on the label.[1] That is why the extract specification and the claim have to be written together; our guide to standardised herbal extract testing covers the marker assays that tie a claim to a defined extract.
Probiotic ingredients follow the same Dubai guideline but raise their own count and wording questions, covered in our article on probiotic and postbiotic claims in the UAE and GCC. For the full herbal development sequence, see the herbal product development process.
Health supplements must not be labelled, advertised or promoted for any medicinal purpose, meaning treatment or prevention, implied or otherwise, of any disease or disorder, including its related condition. The rule covers labels, brochures, leaflets, advertisements and any other presentation.[1]
Annex 4 gives examples in 20 disease groups, from cardiovascular disease (including “reduces cholesterol”) and diabetes to gastrointestinal conditions such as constipation and diarrhoea, musculoskeletal conditions (including “anti-inflammatory”), immunisation (“protects body against diseases”), metabolic disorders including obesity, and physiological claims such as “anti-aging” and hormone-related wording. A second list bans words and promises including “Miraculously”, “100% safe”, “Guaranteed”, “Efficacious/Effective”, “Anti-aging”, “Longevity”, “Memory enhancement” and “Anti-stress (unless qualified)”. The guideline says the lists are not exhaustive.[1]
| Draft wording (illustrative) | How it reads under the Dubai guideline | What to do |
|---|---|---|
| “Supports healthy joints” | Structure/function; close to the guideline’s own example | Keep if the extract and dose are backed by ingredient evidence |
| “Anti-inflammatory” or “relieves arthritis” | Prohibited: Annex 4 musculoskeletal group | Remove |
| “Supports the immune system” | Structure/function; listed as an example | Keep with evidence |
| “Protects against infections” | Prohibited: immunisation and infectious disease groups | Remove |
| “Supports normal digestion” | Structure/function | Keep with evidence |
| “Relieves constipation” | Prohibited: gastrointestinal group | Remove |
| “Helps lower cholesterol” | Prohibited: cardiovascular group | Remove |
| “Helps you sleep” | Products indicated for sleeping are outside the health supplement scope | Reposition or take a different route |
| “Clinically proven, effective” | “Efficacious/Effective” is a banned word | Remove; describe the evidence factually only if approved |
| “Enhanced-absorption curcumin” | A product-property claim; not listed as prohibited | Keep only with product-specific data; the authority may request studies |
Table 2. Illustrative wording checked against the Dubai Municipality guideline (FRL reading, not an authority ruling).[1] The science behind absorption claims for turmeric is covered in curcumin bioavailability: piperine, phytosome and other delivery formats.
Under the Dubai guideline, label content must be declared in clear English and/or Arabic. Required elements include brand and product name, manufacturer or UAE agent details, country of origin, active and inactive ingredients (with botanical names, and the scientific name of the plant recommended), pack size, production and expiry dates, storage conditions, daily dose and directions, intended use, a health warning, barcode and batch number. Products must not be presented as conventional food or as a meal replacement, and illustrations inconsistent with prevailing social customs and values are not allowed.[1]
Claims follow the product into marketing. Any advertisement or promotional activity for a health supplement in Dubai needs pre-approval through Montaji, including brochures, campaigns, social media, TV and outdoor advertising; gifts, discount offers and free samples of registered products are exempt.[1] At federal level, the issue and renewal of health advertising licences is among the services partly transferred from MOHAP to EDE.[3]
On halal, EDE lists a halal certificate from a recognised authority among the documents for a healthcare-product marketing authorisation, together with a company statement that the product is free of pig derivatives and other listed substances.[2] Dubai Municipality may request a halal certificate specifying the source of animal ingredients, sets “pork traces (gelatin)” as absent, and lists an alcohol specification of 0.03% (“as simple fermentation – not added”).[1] Capsule shells, glycerin and ethanol used as an extraction solvent therefore need to be settled during formulation; our article on herbal extraction methods covers solvent choice and residues.
A claim is only as strong as the file behind it. For Dubai registration, the dossier includes a free sale certificate, an ingredient report (for a botanical, the scientific name of the plant and the plant part used), an analysis report, GMP or equivalent manufacturing certificates, and a laboratory test report issued by a certified laboratory using accredited methods. Halal and organic certificates, clinical studies and safety assessments may be requested.[1] EDE asks for a WHO-format certificate of pharmaceutical product or a free sale certificate certified by the UAE embassy, a detailed composition certificate, packaging and leaflet copies and a summary of product characteristics.[2]
Annex 2 of the Dubai guideline sets test limits that apply to herbal products, including:
Registration is valid for five years, and later changes to registered particulars must be notified or approved.[1] How heavy-metal results in ppm convert to these per-day limits is worked through in our UAE supplement label claim and overage guide, and why adulteration and contamination checks matter is shown in what herbal supplement recalls reveal about lead and undeclared drugs.
| Step | Question | Output |
|---|---|---|
| 1. Classify | Health supplement, healthcare product or medicine? Is any part of the presentation Ayurvedic or traditional medicine? | Agreed route (Dubai Municipality, EDE or medicine route) |
| 2. Screen ingredients | Is any botanical on Annex 3? Are vitamins and minerals within Annex 1? | Cleared ingredient list with plant parts |
| 3. Draft claims | Does any wording touch an Annex 4 disease group or banned word? | Claim list, each with its evidence source |
| 4. Specify the extract | Are plant part, extract type, dose and marker defined and tested? | Specification and certificate of analysis |
| 5. Test | Does the product meet Annex 2 microbiology, heavy-metal and adulterant limits in an accredited laboratory? | Laboratory test report |
| 6. Label and advertise | Do label, website, social and retail listings match the registered file? Is halal documented? | Approved label; advertising approval; halal certificate |
Table 3. FRL’s six-step claims checklist, based on the Dubai Municipality guideline and EDE requirements.[1][2]
Formulator’s note: fix the claim list before the formula. Choosing the plant part, extract, dose and standardisation target after the claims are agreed keeps the label, the dossier and the test plan aligned; changing a claim late means reopening the evidence. A worked example of this sequence is in our curcumin supplement UAE registration case study.
Herbal supplement claims in the UAE turn on classification. In Dubai, botanical health supplements can carry general health and structure/function claims backed by ingredient evidence, but Ayurvedic and traditional-medicine products sit outside the health supplement scope, 81 ingredients are banned or not applicable, and 20 disease groups are off-limits. Screen the botanicals, draft claims against Annex 4, specify the extract to support them, and make the label, advertising and halal file match the registration.[1][2]
Food Research Lab’s herbal formulation service develops herbal and botanical supplements with the UAE route built in from the first prototype: classification, Annex 3 screening, claim wording, extract specification and the dossier evidence each claim needs. Microbiology, heavy-metal and marker testing is run or arranged through accredited partner laboratories. We work from Chennai, India, for brands launching in the UAE and GCC.
Our regulatory and scientific research team reviews claims, labels and advertising copy against the Dubai Municipality guideline and EDE requirements, and our UAE market support page sets out how we work with brands in the region. You can also contact us with your formula, intended claims and target emirates.
In Dubai, Dubai Municipality registers health supplements, including botanical products, through its Montaji system under its 2024 technical guideline. At federal level, the Emirates Drug Establishment issues marketing authorisations for healthcare products, including dietary supplements and herbal products not intended to treat or prevent disease. Many former MOHAP services, including natural-source product registration renewal, have moved to EDE.[1][2][3]
Yes, within limits. Dubai Municipality allows general health claims and structure/function claims, such as supporting the immune system or maintaining joint mobility, when they are backed by sound scientific evidence for the ingredient and, when necessary, the finished product. Claims to treat, prevent or cure any disease or disorder, including implied ones, are prohibited on labels and in advertising.[1]
No. Dubai Municipality’s health supplement guideline lists Ayurvedic products, Chinese medicine products and traditional medicine products as outside its scope. A herbal product presented as a supplement with wellbeing or structure/function wording can follow the supplement route, but one presented as an Ayurvedic or traditional medicine needs a different route, so confirm classification with the authority first.[1]
Not as a health supplement ingredient in Dubai at present. Withania somnifera (ashwagandha) appears in Annex 3, Banned or Not Applicable Ingredients, of Dubai Municipality’s 2024 guideline, alongside amla, arjuna, shilajit, punarnava and gymnema. The list may be revised frequently, so check the current version and confirm any alternative route with the authority before formulating.[1]
For an EDE healthcare-product marketing authorisation, a halal certificate from a recognised authority is a listed requirement. Dubai Municipality may request one for health supplements, sets pork traces as absent and lists an alcohol limit of 0.03%. Capsule shells, glycerin and ethanol-based extracts are the points to document during formulation, before the dossier is assembled.[1][2]
Yes. Dubai Municipality requires pre-approval through Montaji for any advertisement or promotional activity for a health supplement, including brochures, press, campaigns, social media, TV and outdoor advertising. Gifts, discount offers and free samples of registered products are exempt. Advertising must not make medical claims or go beyond the claims approved for the registered product.[1]