This article applies to selling in: United Arab Emirates

Food Supplements

Note: This material is for informational purposes only. It is not intended as legal advice. We encourage you to consult your legal counsel if you have questions about the laws and regulations concerning your products.

Food supplements are foods that intend to supplement a normal diet. Supplements have ingredients that have a nutritional or physiological effect, which means that they create a physical effect in the human body. Examples of food supplements include vitamins, minerals, trace elements, amino acids, fiber, plants or herbal extracts.

To ensure these products are safe for use, there are many different requirements for their composition and presentation. These additional requirements are laid down in several laws in the United Arab Emirates (UAE), the main one being Guidelines for Vitamins and Mineral Food Supplements CAC/GL 55:2015 (UAE.S GSO CAC GL 55:2015). This Directive is implemented by national legislation in each Gulf Cooperation Council (GCC) member state, so there can be slight differences in approach for each jurisdiction. One example of this relates to what constitutes a food supplement and which ingredients can be contained in a food supplement.

Food Supplements are sold in dosage form as tablets, capsules, coated tablets, or powders and liquids intended to be ingested in small, measured amounts. In contrast to regular foods, food supplements require a recommended dosage along with other mandatory information and warnings for consumers, for example, that they should be stored out of the reach of small children.

Food Supplement restrictions

Food supplements are a restricted product type on Amazon. You must obtain approval to sell food supplements, and not all sellers are permitted to do so. At this time, we are not accepting applications to sell food supplements. If you are interested to learn more about selling food supplements on Amazon, you may contact us.

Additionally, in the UAE a national pre-market registration is required by the food control section of Dubai Municipality or other municipalities in the UAE before a food supplement can be listed and sold on Amazon for that jurisdiction.

Below is an overview of what is required for the sale and labelling of food supplements, for sellers who are approved to do so.

Requirements to list Food Supplements

  • The products you sell must be new.
  • All products must be intended for sale within the UAE and compliant with all laws and regulations of the GCC (or of local countries).
  • Each product requires a valid barcode (product identifier) registered and associated with the product.
  • You must list products under the correct “Product Type” within the Health and Personal Care Inventory File Template so that your listings are correctly categorized and display the correct, relevant information to customers.

The list below clarifies the type of products that should be uploaded under Food Supplements, but it is not exhaustive. If you cannot find your product in this list, or if you are unsure which Product Type to list your product under, contact Seller Support.

  • Nutritional supplements
  • Nutrition bars and drinks
  • Vitamin supplements
  • Sports nutrition and supplements
  • Slimming and weight loss aids (subject to relevant regulatory requirements)

You can also refer to our Help page on Personal Care Appliances Product Types and our list of permitted and prohibited listings for Drugs, Drug Paraphernalia and Dietary Supplements.

Labeling requirements

The following information should be included on the labelling of a Food Supplement, in addition to the information required under Gulf States Organization (GSO) regulation GSO 9 “Labeling of prepackage food” or Emirates Authority For Standardization & Metrology (ESMA) UAE.S FDS 9/2016 on “food information for consumers”.

  • The indication “food supplement”
  • The name(s) of nutrients or substances that characterize the product and have a nutritional and/or physiological effect
  • The portion recommended for daily consumption
  • A warning not to exceed the stated recommended daily dose
  • A statement that food supplements should not be used as a substitute for a varied diet
  • A statement that the product should be stored out of reach of young children
  • The amount of the ingredients with a nutritional or physiological effect present in the product. These must be declared in numerical form and per portion of the product as recommended for daily consumption.
  • The information on vitamins and minerals must also be expressed as a percentage of the reference intake values listed in food information for consumers.

Claims

Only nutrition and health claims that have been approved under GSO/CAC/GL1 “General Guidelines on Claims on nutrition and health claims made on food” (the ‘Regulation’) can be used on the label.

The aim of the Regulation is to protect consumers from misleading and false claims made on products and harmonize the rules across the GCC to facilitate trade.

Nutrition claims

A nutrition claim is any claim that states, suggests, or implies that a food has particular beneficial nutritional properties due to the presence, absence, increased or reduced levels of energy, or of a particular nutrient or other substance. Nutrition claims provide factual information about the nutritional composition of the food, for example “source of calcium”, “low fat”, “high fiber”, or “reduced salt”.

Only nutrition claims listed in the Annex to the Regulation can be made on food and only if the product meets with the specific conditions of use for that claim. For example, “low fat” can only be made on products containing no more than 3g of fat per 100g for solids or 1.5 g per 100 ml (liquids).

Health claims

A health claim is any claim that states, suggests, or implies that a relationship exists between a food category, a food or one of its ingredients, and health. Only health claims that have been authorized by GSO are permitted. The GSO contains a list of specific health claims and the outcome of their assessment, whether authorized or not, as well as their conditions of use. An example of a specific health claim would be “calcium helps maintain normal bones”. More general, non-specific claims, such as “good for you” or “healthy”, may be allowed if they are accompanied by a relevant specific authorized health claim listed in the GSO register, provided they meet the specific conditions of use.

Health claims cannot:

  • imply that health could be affected by not consuming the food
  • make reference to the rate or amount of weight loss
  • make reference to recommendations of individual doctors or health professionals
  • Encourage or condone excess consumption of a food
  • Imply that a balanced diet cannot provide the necessary nutrients
  • Induce doubt around the safety and/or nutritional adequacy of other foods

Refer to changes in bodily functions, which could give rise to or exploit fear in the consumer. In general, claims must not be false, ambiguous or misleading, encouraging or condoning excess consumption of a food, or imply that a balanced diet cannot provide the necessary nutrients. Claims cannot give rise to doubt about the safety and/or nutritional adequacy of other foods. They cannot refer to changes in bodily functions that could give rise to or exploit fear in the consumer.

Nutrition and health claims are only permitted if the average consumer can be expected to understand the beneficial effects as expressed in the claim. As above, if general wellbeing claims are used (such as “superfoods”, “antioxidants”, ‘good for you”), then these must be accompanied by a specific health claim, that is they need to explain why it is considered a “superfood”. For example, mackerel as part of a healthy balanced diet can be considered a superfood because it is a source of Omega-3 fatty acids (contains x mg of eicosapentaenoic acid and docosahexaenoic acid per 100 g and per 100 kcal). Omega 3 contributes to normal heart function.

Medicinal claims

Food supplements cannot claim the property of preventing, treating, or curing human disease or refer to such properties. Such medicinal claims are never permitted for food supplements. Only products licensed as medicinal products can bear such claims.

Novel foods and banned ingredients

The CAC/GL 23 “Guidelines for Use of Nutrition and Health Claims” and “GSO CAC/GL 55:2015 Guidelines for Vitamin and Minerals Food Supplements” list the vitamins and minerals and their chemical forms permitted for use in the manufacture of food supplements. For additional vitamins and minerals to be considered for inclusion on this list, they would need to be authorized by the commission following a safety assessment by GSO or ESMA.

“Novel Foods” are foods that have not been consumed to a significant degree by humans in the EU before 15 May 1997. A novel food can be newly developed, innovative food, food produced using new technologies and production processes, as well as food that is or has been traditionally eaten outside of the EU. Examples of novel food include new sources of vitamin K (menaquinone) or extracts from existing food (Antarctic krill oil rich in phospholipids from Euphausia superba), agricultural products from third countries (e.g. chia seeds, noni fruit juice), or food derived from new production processes (UV-treated foods such as milk, bread, mushrooms and yeast).

A safety assessment must be conducted and pre-market authorization must be given before a novel food can be marketed in the GSO countries.

The Guidelines for vitamins and minerals food supplements (UAE S. GSO CAC GL 55:2015) list the compositional requirement of vitamins and minerals. Vitamins/provitamins and minerals whose nutritional value for human beings has been proven by scientific data and whose status as vitamins and minerals is recognised by FAO and WHO and their chemical forms permitted for use in the manufacture of food supplements can be used in food supplements. The sources of vitamins and minerals may be either natural or synthetic and their selection should be based on considerations such as safety and bioavailability. In addition, purity criteria should take into account FAO/WHO standards, or if FAO/WHO standards are not available, international Pharmacopoeias or recognized international standards. In the absence of criteria from these sources, national legislation may be used.

In addition to novel foods, certain other ingredients are also not permitted in food supplements.For example, the following substances are not permitted as ingredients in the manufacture of food supplements:

  • Certain banned and restricted herbal ingredients, particularly those for medicinal use, such as ephedra herb and kava kava,
  • Medicinal ingredients, including ingredients authorized as traditional herbal medicines, and
  • Medicinal levels of otherwise permitted ingredients.
  • Alcohol and ingredients from non-halal sources.
  • List of substances which are banned to be used in body building foods (Appendix 2 in UAE.S GSO2209/2012).
  • Any other internationally banned materials.

Products for sale on Amazon cannot contain any unauthorized ingredients (for example, unauthorized vitamins or minerals, additives, or flavorings), novel foods, or banned ingredients.

Safe upper limits

To ensure that food supplements are safe for consumption, the manufacturer must take into account the upper safe levels established by scientific risk assessment and data on vitamin and minerals intake from other foods, while also taking into account what is considered an adequate vitamin and mineral intake for an average person. GSO has published scientific opinions about upper safe levels for various vitamins, minerals, and other substances. Most member states have legal maximum limits for vitamins and minerals, while others provide only guidance only. For example, GSO countries provide a guideline on upper limits for vitamins and minerals for food products in the GCC region (Vitamins and Minerals Permitted for use in foodstuff GSO 2539/2020).

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