UAE Nutri-Mark reformulation is the staged product redesign that improves a product’s A-E nutrient-profiling grade under Abu Dhabi’s QCC guideline ADG-044-2024, sequenced SKU by SKU to protect taste, texture and stability. A category-specific points algorithm sets the grade, so model each SKU’s gap first. Abu Dhabi’s launch is announced without a mandatory date in the sources reviewed, and Dubai, Sharjah and federal positions are not established: reformulate to the strictest confirmed target and verify with each authority. [3] [4]
Nutri-Mark Reformulation Sequencing: ADAFSA, Dubai Municipality & Sharjah Nutrient-Profiling Timelines
Dr Shreya Iyer, PhD (Food Science), Director of New Product Development, Food Research Lab
Food formulation, beverage development, ingredient functionality, product stability and reformulation.
Quick Answer
UAE Nutri-Mark reformulation is the staged product redesign that improves a product’s A-E nutrient-profiling grade under Abu Dhabi’s QCC guideline ADG-044-2024, sequenced SKU by SKU to protect taste, texture and stability. A category-specific points algorithm sets the grade, so model each SKU’s gap first. Abu Dhabi’s launch is announced without a mandatory date in the sources reviewed, and Dubai, Sharjah and federal positions are not established: reformulate to the strictest confirmed target and verify with each authority. [3] [4]
1. Why Nutri-Mark Reformulation Diverges Across the Emirates
Enforcement is local, so front-of-pack rules can arrive at different times and in different algorithm versions. Europe is the precedent: seven national schemes across 15 member states [10] and a still-proposed harmonised scheme [9]. Version drift matters: after a Nutri-Score update, breakfast-cereal grades shifted towards D and E with little formulation change [11]. A multi-emirate food compliance timeline must record the algorithm version, not only the deadline.
2. The Regulatory Map — ADAFSA, Dubai Municipality & Sharjah
2.1 Abu Dhabi — Nutri-Mark Under Guideline ADG-044-2024
In the notified draft, the score is negative points (energy, saturates, sugars, salt) minus positive points (fibre, fruit, vegetables and legumes, protein), per 100 g or 100 ml, with separate algorithms for general foods, fats and beverages. Operators must verify declared values through internal quality control or laboratory assessment [1].
The UAE notified the WTO on 3 February 2025, with mandatory labelling from 1 June 2025 [3]; that start was delayed to Q4 2025 [7]. In February 2026, the Abu Dhabi Media Office described Nutri-Mark as launched, grading packaged foods A to E, without stating a mandatory date [2]. QCC’s conditions of use set market-surveillance rights [5]. For ADAFSA food reformulation compliance, ADAFSA has issued a sampling-for-inspection decision; its Nutri-Mark application, grace periods and tolerances are unpublished in the documents reviewed [4] [6].
2.2. Dubai Municipality — Current Labelling Position & Outlook
Dubai Municipality’s label-assessment guide cites UAE.S 9:2019 and UAE.S 2233 but does not establish a front-of-pack grading requirement [8]. This reflects only the source reviewed; confirm Dubai Municipality nutrition labelling requirements directly.
2.3 Sharjah Municipality — Timeline & Enforcement Signals
The Sharjah food-safety programme material reviewed covers certification and does not establish a front-of-pack grading requirement [16]. That is not an exemption; confirm with the municipality. A reported federal draft could not be verified.
3. Which Products Face Triple Compliance — The Category Overlap Matrix
No category is confirmed to face compliance in all three emirates. The notified scope includes dairy, cheese and children’s food.
Table 1. Category overlap matrix: SKU category by emirate.
SKU category | Abu Dhabi | Dubai | Sharjah | Federal |
Sweetened drinks | Beverage algorithm | No category rule; A–E accuracy grading across food products reported, status unconfirmed | No profiling scheme in published procedures | Sweetened milk drinks: sugar limit |
Dairy | Cheese and dairy beverages in scope | Same as above | No profiling scheme in published procedures | Sweetened or flavoured yoghurt and laban: sugar limit. Processed cheese: sodium limit |
Cereals | In scope if child-targeted | Same as above | No profiling scheme in published procedures | None reported |
Packaged snacks | General-foods algorithm | Same as above | No profiling scheme in published procedures | Salted crackers, nuts, pretzels and extruded chips: sodium limit
|
Overlap is potential; Abu Dhabi alone has a defined algorithm, so it sets the reference target. [4] [6]
4. Sequencing Reformulation: Which SKUs and Grades to Tackle First
4.1 Modelling the Grade Gap Before Bench Trials
Run A-E grade-gap modelling in QCC’s calculation tool [4]. Define the gap as the points between a SKU’s score and its target-grade boundary. As an FRL heuristic, not a regulatory formula, rank SKUs by closable points divided by functional risk, because sugar also supplies texture, colour and preservation [13] and salt reduction raises microbiological and processing barriers [12]. That is nutrient-profiling reformulation under ADG-044-2024 as constraint-aware triage.
Table 2. Example of Nutri-Mark Grade-Gap Modelling for Beverage and Cereal Reformulation
Drink per 100 ml, 0.02 g salt, no other scored nutrients:
Variant | Sugars (g) | Energy (kJ) | N points | Grade |
Baseline | 10.5 | 180 | 3 + 9 = 12 | E |
Sugar cut | 2.0 | 34 | 1 + 1 = 2 | B |
Sugar-free with sweetener | 0.5 | 10 | 0 + 0 + 4 = 4 | C |
In the draft tables, the sweetener swap stops at C because presence adds 4 points. A cereal per 100 g (1,700 kJ, 3.0 g saturates, 28 g sugars, 0.5 g salt, 6 g protein, 4 g fibre) has N = 5 + 2 + 8 + 2 = 17, so protein is excluded: 17 − 1 fibre = 16 (D).
4.2 Protecting Taste, Texture and Stability Through the Cascade
Where feasible, food product developers should set one common formulation target against the strictest applicable requirement, then validate it per requirement and pack. Sugar replacement in food formulation is chiefly a texture problem, because the replacer must retain texture, taste and shelf life [17]. Sugar also lowers water activity [15], so confirm product stability and shelf-life retention on the final matrix.
In the notified draft, protein stops counting once negative points reach 11, and beverages gain 4 points for non-nutritive sweetener presence, so added protein or a sweetener swap may not lift a grade. Nutri-Score’s stricter 2023 sweetener rule [14] shows that thresholds do not transfer: confirm each against the final ADG-044-2024.
5. Why Phased, Market-by-Market Reformulation Backfires
Each reduction step reopens bulk, texture, water activity and shelf life [15] [17], and retuning a SKU for a second target repeats bench trials, stability programmes and verification. Plan gradual cuts to the final target (6–11% went unperceived; Sayas-Barberá et al., 2024).
6. A Phased Compliance Roadmap for Multi-Emirate Portfolios
- Inventory: assign each SKU its algorithm and version.
- Model: score every SKU.
- Prioritise: rank by closable points and functional risk.
- Develop: set a common target; run bench trials and stability.
- Verify: confirm declared values analytically [4].
- Monitor: add other rules as official notices appear.
Food Research Lab’s Nutri-Mark A food reformulation services in the UAE and our food product development work follow this order. A safe-looking points margin can vanish under analytical variability or an algorithm update; Part 2’s FRL Multi-Emirate Compliance Sequencing Framework sets how much margin is enough.
END-TO-END SUPPORT
Take Your Reformulated Product from Grade Target to Validated Shelf Life
From grade-gap modelling and cascade mapping to stability studies and sensory validation, our Nutri-Mark A food reformulation services help food product manufacturers protect product performance during nutrition-led food product development.
Conclusion
Abu Dhabi’s algorithm is the only defined reference, with no mandatory date in the official sources found. Model the gap first, set one target against the strictest requirement where feasible, and validate against each. Talk to Food Research Lab about your UAE Nutri-Mark reformulation programme.
Frequently Asked Questions
It is redesigning a food or beverage to raise its A-E grade under ADG-044-2024 by changing sugar, salt, fat or functionality: product development, not relabelling.
Enforcement is local. The sources reviewed establish Abu Dhabi’s algorithm and milestones, not equivalent Dubai or Sharjah requirements; confirm each with the authority.
Score each SKU in the official calculator, then rank by closable points and functional risk, starting with sweetened drinks, dairy and cereals.
Not confirmed. The sources show a 1 June 2025 original date, a Q4 2025 postponement and a February 2026 launch announcement without a mandatory date. Confirm with QCC.
References
[1] Abu Dhabi Agriculture and Food Safety Authority. (2024). ADAFSA regulates food and fodder sampling for control and inspection in Abu Dhabi [News release]. https://www.adafsa.gov.ae/en/mediahub/news/Pages/27062024.aspx
[2] Abu Dhabi Media Office. (2026, February 18). Healthy Living oversees implementation of 25 strategic initiatives to support citizens and residents of Abu Dhabi to lead healthier lives [News release]. https://www.mediaoffice.abudhabi/en/health/healthy-living-oversees-implementation-of-25-strategic-initiatives-to-support-citizens-and-residents-of-abu-dhabi-to-lead-healthier-lives/
[3] Abu Dhabi Quality and Conformity Council. (2024). Abu Dhabi guideline ADG 44/2024 (1st ed.). https://jawdah.qcc.abudhabi.ae/en/Registration/QCCServices/Services/STD/ADG/ADG-044-2024-En.pdf
[4] Abu Dhabi Quality and Conformity Council. (2025a). Abu Dhabi guideline for the use of the Nutrition Mark [Draft notified to the World Trade Organization, 3 February 2025]. Australian Government Department of Agriculture, Fisheries and Forestry. https://micor.agriculture.gov.au/Dairy/Documents/UAE%20-%20labelling%20-%20Feb%202025%20-%20notified%20document.pdf
[5] Abu Dhabi Quality and Conformity Council. (2025b). General conditions for use of the Nutri-mark. https://jawdah.qcc.abudhabi.ae/en/Registration/QCCServices/Services/ProductCS/General/QCC-CoU01-01Conditions%20for%20use%20of%20the%20Nutri-mark%20Nov%202025.docx
[6] Department of Agriculture, Fisheries and Forestry. (2025a, June 6). MAA 2025-12: Milk and milk products: United Arab Emirates: New labelling requirements for dairy cheese and beverages effective 1 June 2025 [Market access advice]. https://www.agriculture.gov.au/biosecurity-trade/export/controlled-goods/dairy/din/2025-12
[7] Department of Agriculture, Fisheries and Forestry. (2025b, July 16). MAA 2025-15: Milk and milk products: United Arab Emirates: Abu Dhabi delays new labelling requirements for dairy cheese and beverages [Market access advice]. https://www.agriculture.gov.au/biosecurity-trade/export/controlled-goods/dairy/din/2025-15
[8] Dubai Municipality. (2023). How to apply for Food Label Assessment on the IRS system [Guide]. https://www.dm.gov.ae/wp-content/uploads/2023/12/IRS-eng.pdf
[9] European Commission. (n.d.). Food information to consumers – legislation. Food Safety. https://food.ec.europa.eu/safety/labelling-and-nutrition/food-information-consumers-legislation_en
[10] Gokani, N., & Garde, A. (2023). Front-of-pack nutrition labelling: Time for the EU to adopt a harmonized scheme. European Journal of Public Health, 33(5), 751–752. https://doi.org/10.1093/eurpub/ckad087
[11] Lenssen, K. G. M., & de Boer, A. (2026). Changes in front-of-pack food information but limited product formulation following a Nutri-Score algorithm update: A longitudinal case study in breakfast cereals. Journal für Verbraucherschutz und Lebensmittelsicherheit, 21(3), 289–292. https://doi.org/10.1007/s00003-026-01619-2
[12] Lorén, N., Niimi, J., Höglund, E., Albin, R., Rytter, E., Bjerre, K., & Nielsen, T. (2023). Sodium reduction in foods: Challenges and strategies for technical solutions. Journal of Food Science, 88(3), 885–900. https://doi.org/10.1111/1750-3841.16433
[13] Mahato, D. K., Magriplis, E., Sharma, N., & Gamlath, S. (2024). Editorial: Sugar reduction strategies in foods: Sensory, nutritional and safety evaluation. Frontiers in Nutrition, 11, Article 1370781. https://doi.org/10.3389/fnut.2024.1370781
[14] Merz, B., Temme, E., Alexiou, H., Beulens, J. W. J., Buyken, A. E., Bohn, T., Ducrot, P., Falquet, M.-N., García Solano, M., Haidar, H., Infanger, E., Kühnelt, C., Rodríguez-Artalejo, F., Sarda, B., Steenbergen, E., Vandevijvere, S., & Julia, C. (2024). Nutri-Score 2023 update. Nature Food, 5(2), 102–110. https://repository.sciensano.be/items/af58cbe7-97d3-4d9f-9e07-f005feba9376
[15] Sayas-Barberá, E., Paredes, C., Salgado-Ramos, M., Pallarés, N., Ferrer, E., Navarro-Rodríguez de Vera, C., & Pérez-Álvarez, J. Á. (2024). Approaches to enhance sugar content in foods: Is the date palm fruit a natural alternative to sweeteners? Foods, 13(1), Article 129. https://doi.org/10.3390/foods13010129
[16] Sharjah Municipality. (n.d.). Sharjah Food Safety Program. https://portal.shjmun.gov.ae/en/pages/sfsp.aspx
[17] van der Sman, R. G. M., Jurgens, A., Smith, A., & Renzetti, S. (2022). Universal strategy for sugar replacement in foods? Food Hydrocolloids, 133, Article 107966. https://doi.org/10.1016/j.foodhyd.2022.107966
📑 Table of Contents
- Why Nutri-Mark Reformulation Diverges Across the Emirates
- The Regulatory Map — ADAFSA, Dubai Municipality & Sharjah
- Which Products Face Triple Compliance — The Category Overlap Matrix
- Sequencing Reformulation: Which SKUs and Grades to Tackle First
- Why Phased, Market-by-Market Reformulation Backfires
- A Phased Compliance Roadmap for Multi-Emirate Portfolios
- Conclusion
- Faq
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