Commercial Contracts

Selling to Consumers

UAE consumer protection law gives buyers rights that a contract cannot take away. The two that matter commercially: a seller must **display prices clearly and honour them**, and a consumer is entitled to **repair, replacement or refund** where goods are defective. Terms of sale purporting to exclude those rights are unenforceable and are a poor signal to the regulator.

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Selling to Consumers

Terms of sale, refunds and consumer protection

UAE consumer protection law gives buyers rights that a contract cannot take away. The two that matter commercially: a seller must display prices clearly and honour them, and a consumer is entitled to repair, replacement or refund where goods are defective. Terms of sale purporting to exclude those rights are unenforceable and are a poor signal to the regulator.

ItemDetail
Seller[COMPANY NAME], licence [NUMBER]
Selling[Goods / services / both]
Channel[Store / website / app / marketplace]
Jurisdiction[Mainland / free zone — note e-commerce licensing]
Prices displayed inclusive of VAT?[Y/N]required for consumer-facing prices
Return window offered[NUMBER] days
Warranty offered[PERIOD]
Complaints contact[NAME], [EMAIL], [PHONE]
Version and date[NUMBER], [DATE]

1. Rights You Cannot Exclude

RightPosition
Goods fit for purpose and as describedA term saying otherwise is unenforceable
Repair, replacement or refund for defective goodsThe consumer’s remedy — not the seller’s discretion
Clear, accurate price displayPrices must be displayed and honoured
Prices inclusive of VAT for consumer salesAdding VAT at checkout to a displayed price is a problem
Accurate information about the productIncluding origin, contents and specifications
Warranty honoured as advertisedWhatever the seller promised
Complaint route to the authorityThe consumer can escalate regardless of your terms
Arabic information where requiredLabelling and key information

1.1A term excluding all liability for defective goods, or making refunds discretionary, does not work and does real damage if a complaint reaches the regulator. Write terms that reflect the position rather than terms that overreach and then get ignored.

2. Price Display

2.1Prices shall be displayed clearly, in dirhams, and inclusive of VAT for consumer sales.

2.2The price displayed is the price charged. Additional charges — delivery, installation, service — shall be disclosed before the consumer commits.

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Notes for use

These notes accompany the template and explain the drafting choices, the compliance points and the mistakes most often made with this document. They appear as a final page in the Word file, intended to be deleted before the document is executed.

You cannot contract out of consumer rights

Terms excluding liability for defective goods, or making refunds discretionary, are unenforceable and signal bad faith if a complaint reaches the regulator. Write terms that describe the actual position — they are more useful to your staff and more credible to your customers.

Separate the statutory remedy from the goodwill window

A change-of-mind return window is a commercial policy you choose and can limit. Repair, replacement or refund for defective goods is a statutory right you cannot narrow. Conflating them is why staff refuse valid claims because "the 14 days have passed" — and that is what generates complaints to the authority.

Display prices inclusive of VAT

For consumer sales, the price shown must be the price paid. Adding VAT at checkout to a displayed price, or revealing charges late in the flow, is a contravention as well as a conversion problem.

Honour the displayed price

Refusing to sell at a displayed price, or charging more at the till, is a contravention. Where a price was genuinely displayed in error, decline the order and refund rather than charging the higher amount.

Discount advertising is regulated

Where a sale price is advertised against a previous price, that previous price must genuinely have been charged, and several emirates require permits for promotional campaigns. Keep the evidence of the earlier price — it is what an inspection asks for.

E-commerce needs the activity on the licence

Selling online requires the licence to cover it. A trading company adding an online channel may need an amendment, and payment gateways will ask for the licence before onboarding. Sort this before launch, not after the first order.

State exclusions before purchase

Perishables, personalised items and hygiene products can reasonably be excluded from a change-of-mind policy — but the exclusion must be visible before the customer buys, not printed on the receipt afterwards.

Arabic information may be required

Labelling, key product information and certain consumer-facing content require Arabic. This applies to physical products and, depending on the channel, to online listings. Confirm for your product category.

Keep the transaction record

Where a complaint reaches the authority, you will be asked for the order record, the communications and how the complaint was handled. The absence of a record is treated as an absence of process.

Marketing consent is separate from purchase

A customer buying something has not consented to marketing. Ask separately, record it, and observe the Do Not Call rules before calling or texting a UAE number — those obligations sit on top of data protection consent.

Review the complaint register for patterns

One complaint is an incident; the same product, the same branch or the same staff member recurring is a pattern. A quarterly review catches the systemic issue that a series of individual resolutions hides.

Train staff on what they can refuse

Most consumer disputes escalate because a front-line member of staff applied a returns window to a defective product. A one-page internal guide distinguishing the two prevents more complaints than any policy document.

Manufacturer warranties are in addition

A manufacturer warranty does not replace the seller’s obligations. Directing a customer with defective goods to the manufacturer, and treating that as the end of your responsibility, is a common and incorrect practice.

Free zone sellers still face consumer obligations

Selling to consumers in the UAE engages consumer protection requirements regardless of where the seller is licensed. Being in a free zone is not an exemption from how you must treat customers.

Current as of

Reflects UAE law and practice current as of {{DATE OF USE}}. Consumer protection requirements, price display and promotion rules, e-commerce licensing, Arabic labelling requirements and complaint routes differ by emirate and change — confirm the current position with the relevant economic department or the Ministry of Economy before publishing consumer-facing terms.

This is a ready-to-use template provided for convenience. Laws and requirements change, and every situation is different — please have it reviewed by a qualified professional (a lawyer, corporate secretary, or accountant as relevant) before you rely on it.