UAE consumer warranty law is not limited to a promise printed on a warranty card. A provider may have duties to repair, replace, refund, provide spare parts, perform maintenance, supply an alternative good, re-perform a defective service, and disclose the warranty in a clear and usable form.
Federal Law No. (15) of 2020 on Consumer Protection, as amended, and Cabinet Resolution No. (66) of 2023, its Executive Regulation, create the main framework. The rules apply to goods and services supplied in the UAE, including e-commerce where the supplier is registered in the UAE. The remedy depends on the type of defect, the warranty status, the number and duration of repair attempts, the supplier’s responsibility, and the evidence available.
Who owes the warranty obligation?
The provider or supplier responsible for selling or supplying the good or service must honour the applicable warranty and after-sales obligations. A commercial agent or distributor must honour the warranties given by the producer or principal and must comply with provider obligations where the commodity or service is supplied through it.
The platform, retailer, authorised agent, importer, manufacturer, workshop, and service provider should allocate responsibilities clearly. A contractual allocation may help between businesses, but it should not be used to deprive a consumer of a mandatory remedy or make the consumer identify the correct entity after a defect appears.
The core remedies when a defect appears
Federal Law No. (15) of 2020 requires the provider, when a flaw is discovered in a commodity or service, to repair, replace, or recover the commodity and reimburse its price, or re-provide the service without charge, in accordance with the Executive Regulation.
For a commodity defect that is attributable to the provider, the Executive Regulation gives the consumer a choice between returning the commodity for a refund, replacing it, or repairing it without charge. The provider must also supply an alternative commodity for the consumer to use without charge until the original is repaired or replaced. If the provider fails to supply the alternative, it must compensate the consumer for the cost of obtaining one.
| Situation | Typical legal response |
|---|---|
| Defect caused by preservation, storage, handling, installation, or another cause for which the provider is responsible | Consumer chooses repair, replacement, or return and refund; alternative good should be provided while the remedy is pending. |
| Repair is carried out | Provider documents the condition, obtains approval for cost and timing, issues a parts invoice, and guarantees the repair and replaced parts for at least 15 days unless a longer period is required by the nature of the service. |
| Recurring defect or multiple failures | New equivalent good or the value at purchase may become due after the regulatory repair thresholds are met. |
| Defective service | Consumer may request correct re-performance, a full refund, or a proportionate refund depending on the failure and benefit received. |
Warranty documents and warranty data
A provider should not advertise a warranty without giving the consumer a document evidencing it. The warranty information should be usable at the point of sale and after the transaction, whether the sale occurred in a store, through a marketplace, or by another digital channel.
Cabinet Resolution No. (66) of 2023 requires warranty data to include the provider’s name and details, purchase or service date, warranty duration, the good’s name, model, and serial number, whether the warranty covers all parts and repair or replacement costs, the consumer’s warranty obligations, and clearly stated exceptions.
“Warranty void” language should not be used as a shortcut to reject a legitimate claim. The provider should identify the actual cause of the failure, distinguish misuse from ordinary defect, and keep the technical basis for the decision. Exceptions should be clear, specific, and consistent with the contract and mandatory consumer protections.
Repair procedure and the consumer’s approval
Before repairs or changes are made, the provider must document the condition of the good when received and record the consumer’s technical comments. It should notify the consumer by a documented means and obtain approval for the repair cost, expected period, and warranty period.
After repair, the invoice should identify the parts replaced, their prices, and whether they are new, used, or refurbished. The repair must be performed professionally, and the repair and replaced parts must be warranted for at least 15 days from delivery to the consumer unless the nature of the part or repair requires a longer period and the failure did not arise from consumer use.
A disciplined intake process should therefore include photographs, serial numbers, accessories, condition notes, consumer instructions, estimate approval, technician findings, parts traceability, testing, delivery confirmation, and the post-repair warranty. A workshop that cannot reconstruct these steps will struggle to defend a disputed rejection.
Recurring failures and when replacement or refund becomes due
If the provider cannot repair a recurring failure during the warranty period, or more than one failure not caused by consumer use, the consumer may be entitled to a new equivalent commodity or its value at the time of purchase.
The Executive Regulation identifies important thresholds. The recurring failure must result in total or partial inability to use the commodity, affect its market value, or affect safety. The provider must have exhausted two repair attempts for a commodity, or three attempts for a vehicle, or the multiple repair attempts must take more than 15 days in each attempt, including the time needed to obtain spare parts.
If the consumer cannot transport a warranty commodity to the provider for repair, the provider bears transportation costs or must send technicians to the consumer’s residence or the location of the commodity. For a vehicle under warranty, additional transport obligations may apply where the first repair has not solved the problem and the consumer cannot reach the authorised workshop.
Spare parts: availability and transparent procedures
The provider must provide necessary spare parts for operation and repair. For parts that consumers demand regularly and continuously, the Executive Regulation sets a period not exceeding seven days from the consumer’s request. For parts whose demand is not usually regular and continuous, the period is not to exceed 14 days, subject to the stated force-majeure and competent-authority qualifications.
The provider must establish a written mechanism for spare parts, maintenance, and warranties in accordance with the manufacturer’s conditions. The mechanism should be written in Arabic in a clear and understandable form, placed prominently at sales outlets and service centres, made available to consumers, and published on the provider’s website. An identical additional language version may be supplied.
The mechanism should explain how to request a part, expected availability, inspection and delivery steps, maintenance appointments, charges, warranty coverage, escalation, and the provider’s contact details. Stock systems should distinguish unavailable, back-ordered, discontinued, substitute, refurbished, and compatible parts rather than using a generic “not available” status.
Maintenance under warranty and substitute goods
The provider must state in writing a specific period for completing maintenance work on goods under warranty, based on the nature of the maintenance or reason for repair. If repair takes more than seven days, the provider should provide a similar alternative good free of charge for the period when the consumer cannot use the original, unless another compensation mechanism is agreed or included in the warranty process and the defect did not arise from consumer conduct.
For periodic maintenance, the provider should use appropriate equipment, trained personnel, and techniques consistent with the manufacturer’s instructions. It should provide communication channels, disclose maintenance cost and timing, give an estimate on request, explain inspection, labour, replacement-part, and other paid charges, make spare-part prices verifiable, and retain replaced parts for delivery to the consumer before payment unless the consumer authorises appropriate destruction.
Services: re-performance, refund, and damage caused during repair
For a defective service, the provider must honour the service warranty for a reasonable period appropriate to the service or the longer agreed period. If it fails, the consumer may choose a full refund where the service was not implemented or was materially failed, a proportionate refund reflecting the benefit received or deficiency, or correct re-performance in the contracted manner.
If a repair, maintenance, or operation service damages the commodity or impairs all or part of its function, the provider must bear the repair charges or compensate the consumer for the commodity or damaged part, subject to the applicable facts and legal rules. The service record should identify the pre-service condition, instructions given, work performed, parts used, testing, and handover condition.
Goods without a valid warranty or agent coverage
The Executive Regulation addresses goods that lack a product warranty, goods where the spare-part warranty conflicts with the full-product warranty, and goods that lack the warranty of the commercial agent or distributor. If the defect or failure is discovered within 30 days from the date it appears, the supplier must return the relevant goods and refund the price, subject to the exact statutory conditions and evidence.
This rule makes warranty-status disclosure important. A provider should not sell or advertise “warranty” in a way that hides whether coverage comes from the manufacturer, local agent, retailer, service provider, or a limited parts-only arrangement.
Administrative penalties for warranty failures
Cabinet Resolution No. (66) of 2023 includes an annex of financial penalties. The official schedule lists, among other examples:
| Compliance failure | Listed penalty |
|---|---|
| Failure to provide required spare parts, maintenance, replacement, or refund under the warranty obligation | AED 250,000 |
| Failure to provide after-sales service within the specified period | AED 250,000 |
| Failure to repair, replace, return, refund, or re-perform a service without charge when a defect is found | AED 250,000 |
| Failure to provide necessary spare parts for operation and repair | AED 300,000 |
| Failure to establish the written spare-parts, maintenance, and warranty mechanism | AED 100,000 |
| Failure to specify a written maintenance-completion period for goods under warranty | AED 50,000 |
| Failure to provide the consumer with a warranty document | AED 100,000 |
These are schedule entries, not a substitute for checking the current Arabic text, legal reference, competent authority, and facts of the case. Administrative action may sit alongside refunds, product withdrawal, compensation, contractual claims, and other enforcement measures.
Evidence and complaint handling
Providers should assign one case owner for each warranty complaint and maintain a complete file: invoice, warranty document, purchase date, serial number, defect report, intake condition, consumer communications, technical diagnosis, repair attempts, parts request, approval, alternative-good record, refund or replacement decision, and delivery or collection evidence.
Do not close a complaint merely because a workshop issued a technical opinion. If the consumer disputes the defect or quality, the Consumer Protection framework allows inspection or laboratory procedures through the competent authority in appropriate cases. Preserve the item and the evidence needed for an independent review.
Practical compliance checklist
- Issue a complete warranty document with provider details, duration, covered parts, costs, obligations, and exceptions.
- Publish an Arabic spare-parts, maintenance, and warranty mechanism at service points and online.
- Track the seven-day and 14-day spare-parts windows, repair periods, and the seven-day alternative-good trigger.
- Use documented intake, diagnosis, approval, parts, repair, testing, and handover records.
- Escalate recurring defects after two commodity repair attempts, three vehicle attempts, or repeated attempts exceeding the regulatory time threshold.
- Offer the consumer the legally available repair, replacement, refund, re-performance, or alternative-good remedy without imposing unauthorised charges.
- Train customer-service and workshop teams not to reject claims with vague “misuse” or “warranty void” language.
- Reconcile warranty advertising, sales invoices, agent promises, online terms, and service-centre practice.
- Audit spare-parts stock, prices, replacement-part status, and supplier or manufacturer support.
- Review the current Arabic law, Executive Regulation, administrative-penalty annex, sector rules, and any product-specific decisions before publication or enforcement response.
How HZ Legal can help
Hossam Zakaria Legal Consultancy can assist with UAE warranty and after-sales policy reviews, consumer-remedy assessments, spare-parts and maintenance mechanisms, dealer and agent obligations, complaint files, administrative investigations, refund and replacement disputes, and product-recall readiness. Visit HZ Legal to discuss your consumer-protection obligations.
Official sources and verification
- Federal Law No. (15) of 2020 on Consumer Protection, including warranty, defect, replacement, refund, after-sales, and commercial-agent obligations.
- Cabinet Resolution No. (66) of 2023, the Executive Regulation, including warranty data, repair procedure, spare parts, alternative goods, recurring failures, maintenance, and after-sales duties.
- Cabinet Resolution No. (66) of 2023 administrative-penalty annex, including financial penalties for warranty, spare-parts, maintenance, and refund failures.
- UAE Ministry of Economy & Tourism consumer-protection legislation page, including the Consumer Protection Law and Executive Regulation.
Editorial verification before publication: Confirm the current Arabic text, any amendments, commodity-specific warranty decisions, competent local authority, product-sector requirements, and the exact penalty entry applicable to the facts. Remedy timing can depend on the defect, warranty status, repair history, vehicle or commodity category, consumer conduct, and evidence.
Prepared on 10 October 2026. General legal information, not advice on a particular warranty claim or consumer dispute.