Introduction: Why UAE.S 192:2019 Matters for Every Food Business in Dubai
UAE.S 192:2019 is the UAE national standard governing the use of food additives. Based on the Codex Alimentarius General Standard for Food Additives (GSFA), it defines which additives are permitted in food products sold in the UAE, the maximum levels at which they may be used, and how they must be declared on product labels. For food businesses operating in Dubai — where Dubai Municipality enforces food labeling requirements with particular rigor — understanding this standard is essential for product registration, market access, and ongoing compliance.
The standard applies to all prepackaged food products sold in the UAE, whether manufactured domestically or imported. It covers the full range of food additives — preservatives, colorings, emulsifiers, stabilizers, flavor enhancers, sweeteners, and processing aids — and establishes specific requirements for how each category must be labeled. This guide breaks down the key provisions and provides practical guidance for food businesses navigating the standard.
Understanding E Numbers: The International Numbering System
Food additives are identified by their E numbers — a coding system developed by the European Union and subsequently adopted by the Codex Alimentarius Commission as the International Numbering System (INS). UAE.S 192:2019 uses this numbering system, and food labels in the UAE must declare additives using either their E number, their specific chemical name, or both.
The E number system is organized by additive category. E100-E199 covers colorings. E200-E299 covers preservatives. E300-E399 covers antioxidants and acidity regulators. E400-E499 covers thickeners, stabilizers, and emulsifiers. E500-E599 covers pH regulators and anti-caking agents. E600-E699 covers flavor enhancers. E900-E999 covers miscellaneous additives including glazing agents, gases, and sweeteners. E1000-E1599 covers additional chemicals.
For each additive, UAE.S 192:2019 specifies the food categories in which it may be used and the maximum permitted level. Not all additives permitted under the Codex GSFA are permitted in the UAE — the standard includes a negative list of additives that are banned or restricted beyond Codex provisions, reflecting local regulatory priorities. Food businesses must verify that every additive in their product formulation is permitted under UAE.S 192:2019 for the specific food category in question, and that the usage level does not exceed the maximum permitted level.
Flavor Classification: Natural, Nature-Identical, and Artificial
One of the most nuanced areas of UAE.S 192:2019 — and one that frequently trips up food businesses — is the classification of flavors. The standard recognizes three categories of flavoring substances, and the labeling requirements differ for each. Natural flavors are derived entirely from natural sources through physical, microbiological, or enzymatic processes. They must be labeled as "natural flavor" or "natural [source] flavor" (e.g., "natural vanilla flavor").
Nature-identical flavors are chemically synthesized but have the same molecular structure as naturally occurring flavor compounds. While nature-identical flavors are permitted in the UAE, they must not be labeled as "natural." The label should use the term "nature-identical flavor" or simply "flavor" without the "natural" qualifier. Artificial flavors are synthesized compounds that do not occur in nature. They must be labeled as "artificial flavor" and, in some cases, may trigger additional labeling requirements (such as a statement that the product contains artificial flavoring).
The distinction matters because consumer perception and regulatory scrutiny differ significantly across these categories. Products labeled as "natural" when they contain nature-identical or artificial flavors are in violation of labeling standards and may be subject to enforcement action. Food businesses must obtain accurate flavor specifications from their suppliers and ensure that the label declaration matches the actual classification of the flavoring used in production.
Banned and Restricted Ingredients Under UAE Standards
UAE.S 192:2019 includes provisions for ingredients and additives that are banned or restricted in the UAE. These include certain synthetic colorings that have been linked to health concerns — potassium bromate (E924), which is banned as a flour treatment agent, is a notable example. Several azo dyes that are permitted in some markets are restricted or require warning labels in the UAE. Sudan dyes (I, II, III, and IV), which are industrial colorants not intended for food use, are strictly prohibited and are the subject of active enforcement and surveillance.
For imported products, the ban list can be particularly challenging. A product legally manufactured and sold in its country of origin may contain an additive that is not permitted in the UAE. Food businesses importing products into Dubai must compare the product's formulation against UAE.S 192:2019 before shipment — not upon arrival, when rejection and return costs are significantly higher.
Businesses should maintain a regularly updated database of banned and restricted additives under UAE law. This database should be cross-referenced against ingredient specifications for every product in the portfolio. When ingredient suppliers change their formulations — which happens more frequently than many businesses realize — the additive database should be checked again to verify that the new formulation remains permissible.
Labeling Requirements for Food Additives Under UAE.S 192:2019
The standard requires that all food additives present in a product be declared in the ingredient list. Each additive must be identified by its functional class name (e.g., "preservative," "emulsifier," "antioxidant") followed by either its specific name, its E number, or both. For example, a preservative might be declared as "Preservative (Sodium Benzoate)" or "Preservative (E211)" or "Preservative (Sodium Benzoate, E211)."
Processing aids — substances used during production but not intended to be present in the final product at significant levels — have different labeling rules. In general, processing aids do not need to be declared on the label unless they are allergenic (e.g., enzymes derived from milk or eggs) or unless they remain in the final product above a defined threshold. However, best practice — and the expectation of Dubai Municipality inspectors — is to err on the side of disclosure, particularly for processing aids that may have allergen implications.
Carry-over additives — additives that are present in the final product because they were components of an ingredient (e.g., an emulsifier in the chocolate chips used in a cookie) — must also be declared if they serve a functional purpose in the final product. If the carry-over additive is present at levels below which it could have a functional effect, declaration may not be required, but this determination must be based on a documented assessment.
Distributor Responsibilities: When You Do Not Control the Formulation
Distributors and importers who sell products manufactured by third parties face a particular challenge: they are responsible for the accuracy of the label, but they may not have direct control over the product formulation. Under UAE law, the entity whose name appears on the label — whether manufacturer, importer, or distributor — bears legal responsibility for labeling compliance.
This means that distributors must conduct due diligence on every product they bring to market. Obtain the complete product specification from the manufacturer, including the full ingredient list with E numbers, additive concentrations, and flavor classifications. Verify that every additive in the formulation is permitted under UAE.S 192:2019 for the relevant food category. Confirm that the label — both Arabic and English versions — accurately reflects the formulation.
Distributors should also establish contractual provisions requiring manufacturers to notify them of any formulation changes before they are implemented. A manufacturer who substitutes one preservative for another without informing the distributor can put the distributor in violation of UAE labeling law — with the distributor bearing the enforcement consequences. Documented supplier agreements and regular product audits are essential risk management tools.
Common Compliance Pitfalls and How to Avoid Them
Enforcement data from Dubai Municipality reveals several recurring compliance issues related to food additives. Using additives not permitted for the specific food category — an additive may be permitted in beverages but not in dairy products, for instance — is one of the most common violations. Exceeding the maximum permitted level of an additive, often due to the cumulative effect of carry-over additives from multiple ingredients, is another frequent finding.
Mislabeling flavors — declaring a nature-identical or artificial flavor as "natural" — generates enforcement actions. Using food colorings that are banned in the UAE but permitted in the country of manufacture leads to product rejection at customs. Failing to declare carry-over additives that have a functional effect in the final product is also a common issue. Additionally, incomplete Arabic translation of additive names, leading to discrepancies between the English and Arabic labels, triggers violations during inspections.
Avoiding these pitfalls requires a combination of technical knowledge (understanding which additives are permitted and at what levels), documentation management (maintaining current formulation data for every product), and communication (ensuring that label text accurately reflects the formulation). Businesses that centralize this information in a digital platform — where formulation data, additive regulations, and label text are linked and cross-referenced — are far less likely to encounter these issues.
Step-by-Step Compliance Checklist
Food businesses can use the following checklist when preparing or reviewing products for the Dubai market. First, obtain the complete formulation for the product, including all ingredients, additives (with E numbers and concentrations), flavoring substances (with classification as natural, nature-identical, or artificial), and processing aids.
Second, verify each additive against UAE.S 192:2019 for the specific food category. Confirm that the additive is permitted for that category and that the usage level does not exceed the maximum permitted level. Third, check the cumulative additive load — if multiple ingredients contain the same additive (through carry-over), calculate the total level in the final product.
Fourth, classify all flavoring substances correctly and ensure that the label declaration matches the classification. Fifth, check the formulation against the UAE's banned ingredient list. Sixth, prepare the ingredient list for the label, declaring all additives by functional class name and specific name or E number. Seventh, translate the label into Arabic, ensuring that additive names, flavor classifications, and all other mandatory elements are accurately translated.
Eighth, review the label holistically for compliance with all UAE labeling requirements — not just additive-related provisions. This includes product name, net weight, manufacturing and expiry dates, storage conditions, country of origin, nutritional information, and allergen declarations. Ninth, submit the label for Dubai Municipality product registration (if required) and respond to any queries or revision requests promptly.
Using Digital Tools for Additive Compliance
For businesses with large product portfolios, managing additive compliance manually is impractical. A single product may contain 20 or more additives, each of which must be verified against category-specific permission lists, checked for usage levels, and correctly declared on the label. Multiply this by dozens or hundreds of SKUs, and the task becomes overwhelming.
Digital recipe management platforms address this challenge by maintaining additive data at the ingredient level and rolling it up to the product level automatically. When a recipe is entered into RecipeBuilder, the system identifies all additives present — whether added directly or carried over from compound ingredients — and generates the appropriate declarations for the ingredient list. This ensures that the label accurately reflects the full additive profile of the product, reducing the risk of omissions and errors that can lead to enforcement actions.
Conclusion: Additive Compliance Is a Detail Game
UAE.S 192:2019 is a technically detailed standard that requires food businesses to have precise knowledge of what goes into their products and how it must be declared. The margin for error is narrow — an additive that is permitted in one food category may be banned in another, and a flavor that is nature-identical cannot be labeled as natural. Businesses that invest in maintaining accurate, up-to-date formulation data and that use systematic processes to verify compliance will navigate the standard successfully. Those that treat additive compliance as a one-time label review exercise will find themselves repeatedly encountering issues that could have been prevented with better systems and more rigorous processes.