UAE Law and Practice Contributed by: Haykel Hajjaji, Julie Teperow, Robin Blaney and Winsome Cheung, Covington & Burling LLP
rate Permit to Import Medicines for Personal Use. The individual must provide a valid prescription and a valid medical report detailing their clinical history. A standard import permit is valid for two months. 7.4 Non-Tariff Regulations and Restrictions Imposed Upon Imports Non‑tariff regulations and restrictions on importation are applied based on the Harmonised System (HS) Code of the product. The UAE is currently undertak- ing a phased implementation of the Gulf Cooperation Council (GCC) Integrated Customs Tariff (“Integrated Tariff”). Under this model, the previous six‑digit HS codes will be replaced with a standardised 12‑digit code used consistently across the GCC. The Inte- grated Tariff framework remains based on the HS. To support correct product classification, Dubai Customs has developed an AI‑powered online platform called Al Munasiq. The legal framework governing the use of both the HS codes and the Integrated Tariff Model is set out in Federal Decree‑Law No 15 of 2022 on the Ratification of the Common Customs Law of the GCC (“Com - mon Customs Law”). In addition, Federal Decree‑Law No 14 of 2021 on the Establishment of the Federal Authority for Identity, Citizenship, Customs and Ports Security regulates the UAE Federal Customs Author- ity. Dubai Customs Notice No 10 of 2025 and Notice No 2 of 2026 outline the phased approach for implement- ing the Integrated Tariff and confirm that the previous eight‑digit code may continue to be used until further notice. 7.5 Trade Blocs and Free Trade Agreements The UAE is a member of the GCC, which operates under a unified customs law implemented in the UAE through the Common Customs Law. Although a uni- fied customs agreement exists, entities must still obtain an import permit when importing products from a GCC member state into the UAE, even if those prod- ucts may be exempt from duties or tariffs. The UAE is also a party to more than 25 Free Trade Agreements (FTAs), including the UAE–Singapore
FTA, the UAE–EFTA FTA, and the UAE–Türkiye FTA, all of which include provisions relating to customs and trade facilitation. 8. Pharmaceutical and Medical Device Pricing and Reimbursement 8.1 Price Control for Pharmaceuticals and Medical Devices Prices of pharmaceuticals and medical devices are controlled by the EDE. Under the Pharma Law, the Pharmaceutical Policy Committee is the dedicated body responsible for proposing policies related to the circulation, pricing, and monitoring of pharmaceuti- cals and medical devices. According to Cabinet Decision No 90 of 2021 on the Implementing Regulation of Federal Law No 8 of 2019, prices set by the EDE or MOHAP may not be discounted or altered, except by the EDE or MOHAP themselves. Once the Implementing Regulations for the Pharma Law are issued, Cabinet Decision No 90 of 2021 will be abrogated. Pharmaceutical prices are regulated under Ministe- rial Decision No 140 of 2013 on the Unification of the Price of Import of Drugs from the Factory at the Country of Origin on a CIF basis, priced in USD (the “Pricing Law”). Under the Pricing Law: • the price of imported pharmaceuticals is tied to the country of origin and is not determined by the distributor or agent; • a standardised reference formula is used to set prices – the Pharmacy Price equals the import price plus 15% of the import price, calculated in Emirati dirham (AED); and • pharmaceuticals sold to the public in pharmacies are then priced according to three categories, depending on the Pharmacy Price. Pricing decisions are published through Ministerial Decisions and may vary by Emirate. For example, the DHA may set different prices from the DOH, although prices may also be established at the federal level.
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