§ Dossier · Compliance
From Spain farm to Dubai consumer, in ten steps.
Every path passes through the same regulated core: classify the product, register it, release the shipment, and invoice correctly. Who carries which step is the variable, not whether it happens. Under any partner-led arrangement, delete nothing — just reassign the owner column.
Before shipping
- 01Freeze the SKU
Lock recipe, label artwork, shelf life, batch coding. Changes post-registration cost weeks.
Owner Founders
- 02Classify the HS code
A customs broker confirms the right Chapter 15 sub-line for extra virgin, refined, or blended oil. Wrong code = wrong duty at the border.
Owner Customs broker
- 03Build the SKU dossier
Ingredients, nutrition, allergens, shelf-life basis, country of origin, packing specs, supplier certificate of analysis, claim substantiation.
Owner Spain-side team
- 04Pre-check the label Confirm
Against UAE rules — Arabic sticker compliance, net content, storage conditions, batch & best-before placement.
Owner Dubai Municipality + broker
Structure
- 05Decide importer + seller of record
Two distinct legal roles. Confirm in writing which entity holds each. Both cannot be 'we'll figure it out later'.
Owner Founders + partner
Spain side
- 06Obtain the Spain EORI
Required for every commercial export customs declaration out of Spain. Free to obtain via the Spanish tax agency.
Owner Spain-side team
UAE entry
- 07Register on ZAD
Federal food-accreditation registration per SKU. Done by the entity that will be importer of record.
Owner Importer
- 08Register on Montaji+ (Dubai)
Dubai operational layer — this is what you actually touch for consignments, testing requests, and release.
Owner Importer
- 09Consignment release
Per-shipment approval to move goods into the market. Separate from, and after, product registration. First shipment usually takes longer than steady state.
Owner Dubai Municipality
Selling
- 10VAT registration + compliant invoicing
Register with the Federal Tax Authority. Issue tax invoices in the required format. Non-resident rules apply for Spain-direct sellers — generally more friction, not less.
Owner Seller of record
Notes on the regulated core
- Licence ≠ readiness. A free-zone licence can be issued in days; compliant consumer sale still requires the rest of this workflow. Plan at the workflow level, not the licence level.
- Abu Dhabi is a separate system. ADAFSA / FIEMIS parallels Dubai. Scaling beyond Dubai adds a second registration layer.
- 100% foreign ownership is real. On mainland, the old 51% sponsor rule is gone for most activities. Don't let older forum posts scare you into a free-zone shortcut.
- E-commerce rules apply to UAE-resident sellers. Arabic disclosure obligations and consumer-protection rules apply primarily to UAE-resident businesses. Selling from Spain into UAE sits outside that net but creates its own friction.