From the Gulf to the EU: what UAE and Saudi manufacturers need before a distributor

A manufacturer in Dubai, Riyadh or Dammam can make a product European buyers want and still lose the first meeting with a distributor. The reason is rarely price. It is usually a missing document, or no clear answer to one question: who in the EU is responsible for this product?

This post lists what EU law asks for before a distributor can list a product from the United Arab Emirates or Saudi Arabia.

Putting it simply: a European distributor checks three things before price. Does the product meet the EU law that applies to it, with documents to prove it? Is an operator established in the EU legally responsible for it (often the distributor itself, as importer)? Who clears customs and pays import VAT? No EU trade agreement with the UAE or Saudi Arabia is in force.

Step one: find the EU law that applies to your product

The EU sets product rules in separate laws, one per product group. Two acts from 2008 give them a common structure, known as the New Legislative Framework.

Regulation (EC) No 765/2008 sets the CE marking rules. Article 30 says the CE marking "shall be affixed only by the manufacturer or his authorised representative", and only to products for which an EU law provides for it. By affixing it, the manufacturer "takes responsibility for the conformity of the product". The Commission's Your Europe portal adds: if no EU law requires it for your product, "CE marking must not be used".

Decision No 768/2008/EC gives the model obligations that the product laws copy. Article R4 of its Annex I is the one a distributor will think about. Before an importer places a product on the market, it must "ensure that the appropriate conformity assessment procedure has been carried out by the manufacturer", that the technical documentation exists and that the product bears the required marking. The importer must also put its own name and address on the product or, where that is not possible, on its packaging or an accompanying document.

So the distributor that imports your goods carries legal duties for them. Some common cases for Gulf exporters:

Electrical and electronic equipment, machinery, PPE, toys, pressure equipment, radio equipment: CE marking under the specific law for each group, with an EU declaration of conformity.
Building materials: where a construction product is covered by a harmonised standard, the manufacturer draws up a declaration of performance, and the CE marking goes on products that have one (Articles 4 and 8 of Regulation (EU) No 305/2011). Regulation (EU) 2024/3110 is replacing it gradually: those articles stay in force until 8 January 2040 for products covered by harmonised standards adopted under the old regulation (Articles 94 and 95(8)).
Medical supplies: the Medical Device Regulation, covered below.
Food packaging: not CE-marked. Food contact materials follow Regulation (EC) No 1935/2004, where specific EU measures require a written declaration of compliance (Article 16). The new packaging regulation also applies (see below).
Wooden furniture and paper products: wooden furniture (several subheadings of heading 9403) and most pulp and paper of Chapters 47 and 48 are listed in Annex I of the Deforestation Regulation (EU) 2023/1115. As amended by Regulation (EU) 2025/2650, its obligations apply from 30 December 2026. Micro and small operators get until 30 June 2027, but not for wooden furniture or paper (Article 38(3)). See our furniture page.

Our guide to certifications and product data covers the documents.

Step two: an economic operator in the EU

Products with CE marking: Article 4 of Regulation (EU) 2019/1020

The Market Surveillance Regulation applies from 16 July 2021 (Article 44). Article 4(1) says a product covered by it "may be placed on the market only if there is an economic operator established in the Union" who is responsible for certain tasks. Article 4(2) lists who can do this:

a manufacturer established in the Union;
an importer, where the manufacturer is not established in the Union;
an authorised representative with a written mandate from the manufacturer;
a fulfilment service provider in the Union, where none of the others is established there.

The operator checks that the declaration of conformity and technical documentation exist, gives documents to the authorities on request, informs them of risks and cooperates on corrective action (Article 4(3)). Its name and contact details must appear on the product, its packaging, the parcel or an accompanying document (Article 4(4)). Article 4 applies to the laws listed in Article 4(5), among them those on machinery, electrical equipment, radio equipment, toys, PPE, pressure equipment and construction products.

Consumer products: the General Product Safety Regulation

The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024 (Article 52). It covers products "intended for consumers or ... likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them" (Article 3(1)). Where another EU law already sets safety rules for a product, the GPSR covers only the risks that law does not cover (Article 2(1)).

Article 16(1) takes the Article 4 rule above and applies it to all these products: a product "shall not be placed on the market unless there is an economic operator established in the Union" responsible for it. That operator must also regularly check the product against its technical documentation and the labelling rules (Article 16(2)).

This matters for furniture, household items or anything that can reach a consumer. See the responsible person rule (GPSR).

Medical devices: a sole authorised representative

The Medical Device Regulation (EU) 2017/745 is stricter. Article 11(1): "Where the manufacturer of a device is not established in a Member State, the device may only be placed on the Union market if the manufacturer designates a sole authorised representative." The mandate is valid only when the representative accepts it in writing (Article 11(2)). An importer alone is not enough: it must itself verify that an authorised representative has been designated (Article 13(2)). See medical supplies.

Chemicals and substances in articles: REACH

REACH (Regulation (EC) No 1907/2006) applies to chemicals and, in some cases, to substances inside finished goods. A producer or importer of articles must register a substance in them when it is present above one tonne per year and "intended to be released under normal or reasonably foreseeable conditions of use" (Article 7(1)). A supplier of an article containing a substance of very high concern on the Candidate List above 0.1% by weight must pass on enough information for safe use, including at least the substance's name (Article 33(1)).

These duties fall on the EU importer. Article 8 lets a manufacturer established outside the EU appoint, by mutual agreement, a person established in the EU "as his only representative" to fulfil the importer's obligations under the registration title. This is relevant for chemicals, cleaning products, coatings and plastics.

Packaging: Regulation (EU) 2025/40

The Packaging and Packaging Waste Regulation (EU) 2025/40 has applied since 12 August 2026 (Article 71). The regulation calls anyone who makes packaging or a packaged product a "manufacturer" (Article 3(1)), so a Gulf exporter of boxed goods counts too. Before packaging is placed on the market, the manufacturer must carry out the conformity assessment procedure and draw up the technical documentation (Article 15). Since 12 August 2026, food-contact packaging containing PFAS at or above the limits in Article 5(5) may not be placed on the market.

Separately, extended producer responsibility applies to the "producer": broadly, the operator that first makes the packaging or packaged products available in a Member State (Article 3(1)) — usually your EU distributor. If you sell directly to end users in a Member State, you can be the producer yourself. Producers must register in each Member State where they do this (Article 44) and pay into the national schemes (Article 45). Agree in your contract who registers and who pays.

Step three: customs and VAT

EU customs law speaks of the declarant, not the "importer of record". As a rule, the declarant must be established in the EU (Article 170(2), Union Customs Code). In the classic distribution model the distributor is the declarant: it buys from you, imports the goods and pays duty and import VAT.

EORI number. EU operators register where they are established (Article 9, Union Customs Code). Per the Commission, operators outside the EU that lodge customs declarations register in "the EU country in which they intend to carry out their first customs operation".
Customs representative. Anyone may appoint one; as a rule, the representative must be established in the EU (Article 18).
Customs duty. A customs debt arises when goods are released for free circulation (Article 77). Without a trade agreement in force, there is no agreement-based preferential rate for goods from the UAE or Saudi Arabia. Nor do the GCC countries benefit from the Generalised Scheme of Preferences, as high-income economies. Look up the rate for your product code in Access2Markets before you quote.
Import VAT. Goods entering the EU are an "importation of goods" (Article 30, VAT Directive). VAT is payable by the person the Member State of importation designates (Article 201). A VAT-registered business can deduct import VAT on goods it uses for taxed sales (Article 168(e)). For your distributor, this is usually a cash-flow cost, not a final cost.

A new Union Customs Code, Regulation (EU) 2026/2108, applies from 21 September 2027, with some provisions earlier or later (Article 287), and introduces a defined "importer" (Article 5, point (13)). Quoting DAP (Delivered at Place) to the distributor's warehouse keeps customs and import VAT with the EU party; our Incoterms, VAT and import guide explains DAP and DDP. It is written for US manufacturers, but the EU rules are the same. Confirm your own case with a customs broker and a tax adviser.

The trade relationship in November 2026

UAE. The Commission lists the EU–United Arab Emirates Free Trade Agreement as "Being negotiated". Negotiations were formally launched on 28 May 2025; the first round took place on 24 June 2025. The Commission's documents page lists seven rounds, the latest in July 2026, and says the full text "will be made public once negotiations have been concluded". On 1 November 2026 no later round was listed. The agreement is not concluded and not in force.

Saudi Arabia and the GCC. The EU and the Gulf Cooperation Council launched free trade negotiations in 1990 and suspended them in 2008. The Commission lists the agreements with Saudi Arabia, Bahrain, Kuwait, Oman and Qatar under "Agreements on hold". It calls the UAE agreement a possible "building block for a future regional FTA with the GCC" and has commissioned a sustainability impact assessment for EU–GCC negotiations, but only the UAE agreement is listed as being negotiated.

In practice, a manufacturer in either country sells to the EU like any exporter without a trade agreement. The product rules above apply to every product placed on the EU market, with or without one.

Why the distributor route works

A distributor solves most of the above in one contract. As importer it can be the EU operator for CE-marked and consumer products. It holds stock near the customer, gives documentation and support in the local language and handles after-sales service. You do not need an EU company to start.

Public contracts show how strong local presence is. In a Cresques analysis of TED contract award notices for supplies published from 2 November 2023 to 30 October 2026, 95.2% of awards by buyers in Germany went to companies registered in Germany. In Poland, 98.7% went to companies registered in Poland. An award here is one winner on one lot, and the winner's country is the country of registration published in the notice. These are two examples, not all countries; our methodology explains the data. A locally registered winner can still belong to a foreign group. See also what a distributor expects from a new supplier and the pages for Germany and Poland.

Where Cresques fits

Cresques shows which companies have won public supply contracts for your product category in each of 30 EU and EEA countries, with the award notices behind every name. For each profile you open, it researches whether the company is an independent distributor, a manufacturer or a manufacturer's subsidiary, and it drafts a first message in the local language, with how to send it lawfully there. It is open to manufacturers from any country. You pay by card in euro or US dollars, and business customers outside the EU pay no VAT. Every new account gets 10 credits once, enough for one market map. See pricing and what you get.

Checklist before your first distributor meeting

List the EU laws that apply: CE marking laws, construction products, medical devices, REACH, food contact, packaging, deforestation.
Prepare the declaration of conformity (or of performance) and the technical documentation.
Decide who is the EU economic operator: the importing distributor, an authorised representative with a written mandate, or your own EU company. For medical devices, a sole authorised representative.
Check substances of very high concern above 0.1% and whether you need a REACH only representative.
Check packaging: technical documentation and PFAS evidence for food-contact packaging; who registers and pays as producer in each country.
Prepare labels and instructions with room for the importer's name and address, in the local language.
Look up your duty rate in Access2Markets and quote DAP unless you have an EU customs set-up.
Confirm the trade status on the DG Trade pages before planning around a future agreement.
Shortlist distributors on evidence, not competitors.
Ask a customs broker and a tax adviser about your case before the first shipment.