Explainer · UAE
UAE pharmacies should tell customers about house brands and sales incentives
WellnessSorted's view on pharmacy brand transparency in the UAE: what federal and emirate rules say about conflicts of interest, the disclosure gap, and how to ask questions or complain.
Review type: research summary. This page summarises published research and product labels, cited below.
WellnessSorted's view is simple. When a UAE pharmacy recommends a supplement that it owns, controls or distributes exclusively, the customer should be told. And if staff are paid or rewarded for selling particular products, customers should be told that too. UAE law already treats conflicts of interest seriously, and the pharmacist codes say a recommendation must not be driven by personal benefit. But none of the federal or emirate rules set out below requires a pharmacy to tell the customer either fact. That gap should be closed.
This is an opinion piece setting out WellnessSorted's position. It is not legal advice and it makes no allegation about any pharmacy, pharmacy group or brand. The legal provisions are quoted from official English translations. For the federal laws, the Arabic text prevails.
Our guide to why UAE pharmacies recommend certain brands sets out the published links between several large pharmacy groups and the brands they distribute. Those arrangements are lawful and common in retail all over the world. The problem is not that they exist. It is that a customer at the counter usually has no way of knowing about them.
What the rules already say
Supplements are inside the pharmacy law. Federal Decree-Law No. 38 of 2024, which replaced Federal Law No. 8 of 2019, counts food supplements as pharmaceutical products and defines them as products taken orally that "support the human diet and do not treat, diagnose, or prevent diseases". Several of its rules bear directly on brand recommendations.
- Article 42(3): "Healthcare professionals are prohibited from prescribing or advising any Medical Product for personal gain." Under Article 165, breaching clauses 1 to 3 of Article 42 can be punished by six months to a year in prison, a fine of AED 50,000 to AED 200,000, or both.
- Article 73: a pharmacist must work in line with the national guide to professional conduct and ethics for the pharmacy profession and must be "accurate and honest".
- Article 75(3): a pharmacist may not use "illegal methods to induce patients to purchase Medical Products from the Establishment in which he works".
- Articles 44 and 45: promoting a medical product needs approval from the Emirates Drug Establishment, and the material must be "truthful, not misleading, and supported by evidence".
The professional codes go further. The Ministry of Health and Prevention (MOHAP) code of conduct for pharmacists says a pharmacist "does not promote or supply specific medicines or devices in response to financial benefit, gifts or hospitality" and should step back from a decision when facing "a clear or potential conflict of interest". MOHAP's code of ethics for all health professionals, adopted by Ministerial Resolution No. 1448 of 2017, bans any reward, discount or cash benefit "in return for providing a health service, prescribing a medical product, supplying it, selling it". It also prohibits linking the provision of medicine "in any health or pharmaceutical facility with any financial benefit or profit considerations".
The emirate-level codes say much the same. Dubai Health Authority (DHA) standards that took effect in September 2025 tell health professionals not to "favour or recommend specific medications, devices, or services from particular manufacturers without clear, evidence-based clinical justification", and to disclose actual or potential conflicts of interest "to relevant authorities". The Department of Health Abu Dhabi (DoH) bioethics guidelines of 2024 come closest to a disclosure rule. They say health professionals "must disclose financial interests in products they sell or recommend to patients" and "must avoid being sole distributors of products, as the risk of COI is too great". DoH's 2022 integrity policy requires licensed professionals and facilities to declare conflicts of interest to the facility's management.
Consumer law adds a general duty of honesty. Federal Law No. 15 of 2020 on Consumer Protection gives every consumer the right to "correct information" about what they buy and the right to choose "the most appropriate product" in the market. It defines a misleading advertisement to include "omitting essential or basic information" that leads a consumer into a purchase they would not otherwise have made. Its executive regulations, Cabinet Resolution No. 66 of 2023, require the producer or importer to be named on the pack or at the place of display. They also let the Minister require unit pricing "to secure the consumer right to compare prices".
The transparency gap
Put together, the rules ban recommending a product for personal gain and require pharmacists to manage conflicts of interest. What they do not do is tell the customer anything. None of the federal law, the MOHAP codes, DHA's standards, DoH's integrity policy or the consumer protection regulations requires a pharmacy to tell a customer that a supplement is its own brand, that its group holds the exclusive rights to it, or that staff are rewarded for selling it. Most of the conflict-of-interest duties run upwards, to a manager or a regulator. The DoH bioethics guideline addresses disclosure to patients, but it is framed as ethics guidance for individual professionals in Abu Dhabi, not as a shelf-labelling rule for pharmacy businesses.
The label rule does not fill the gap either. Naming the producer or importer on the pack tells you who made or imported the product. It does not tell you that the importer and the pharmacy share a parent company, or that the pharmacy has agreed to carry that brand on exclusive terms.
How UAE pharmacy staff are paid is not public. We are not aware of published evidence that any UAE pharmacy pays commission on supplement sales, and we make no such claim about any company. That is precisely the point. If incentives exist, customers have no way to find out. If they do not exist, a simple published statement would say so and build trust.
Why it matters
A pharmacy counter is not an ordinary shop counter. Customers ask a pharmacist because they expect clinical judgement, and many will buy what is suggested without comparing. Supplements are usually paid for out of pocket, they are bought repeatedly, and the price per daily dose between two products with the same ingredient and form can differ a great deal. A house or exclusive brand may well be the best choice. The customer is better placed to judge that when they know about the relationship.
How the UK handles incentives
The UK pharmacy regulator, the General Pharmaceutical Council (GPhC), writes incentives directly into its standards. Its standards for pharmacy professionals say pharmacists should "declare any personal or professional interests and manage these professionally" and "consider and manage appropriately any personal or organisational goals, incentives or targets and make sure the care they provide reflects the needs of the person". Its standards for registered pharmacies put the duty on the business: "Incentives or targets do not compromise the health, safety or wellbeing of patients and the public, or the professional judgement of staff."
Those standards came under public scrutiny in 2016. The Guardian reported allegations that managers at Boots, the UK's largest pharmacy chain, were treating the NHS cap of 400 paid medicine use reviews per pharmacy as a target, including for patients who did not need them. Boots denied the allegations and said: "We make it clear to our colleagues that these services should not be undertaken inappropriately." The Guardian then reported that the GPhC was calling in evidence. Whatever the facts in that case, it shows why a regulator should state plainly how targets and incentives are to be managed, and why they are best brought into the open.
Other markets treat undisclosed commercial links as a consumer issue. In the United States, the Federal Trade Commission's endorsement guides say that when a connection between an endorser and a seller "might materially affect the weight or credibility of the endorsement", and the audience would not expect it, the connection "must be disclosed clearly and conspicuously". A pharmacy counter recommendation is not an advertisement in that sense, but the principle carries over.
What we are calling for
- Shelf and online labels. Pharmacies should mark products that are their own brand or that their group distributes exclusively, on the shelf tag and on the product page. A short standard wording, such as "own brand" or "distributed exclusively by our group", would be enough.
- A published incentives statement. Each pharmacy group should publish whether staff receive any payment, bonus or target linked to sales of specific supplement brands, and how it keeps such schemes from affecting advice.
- Clarity from regulators. The Emirates Drug Establishment, MOHAP, DHA and DoH should say how Article 42(3) of Federal Decree-Law No. 38 of 2024 and the professional codes apply to sales targets and brand incentives in community pharmacies.
- Unit pricing for supplements. The Ministry of Economy and Tourism already has the power under Cabinet Resolution No. 66 of 2023 to require unit pricing. Applying it to supplements would let customers compare a house brand with an alternative at a glance.
What you can do now
Until the rules change, a few questions at the counter go a long way. You are entitled to correct information about what you buy, and a good pharmacist will answer these without hesitation.
- Is this your own brand, or one your group distributes exclusively?
- Is there an equivalent from another supplier with the same ingredient, form and daily amount, and what does each cost per day?
- Why this product for me, rather than the alternative?
- Are staff given any target or reward for selling this brand?
If you believe a product was described or promoted in a misleading way, you can complain to the Ministry of Economy and Tourism through its Resolve Consumers Complaints service on its website or smart app, or by calling 800 1222. Cabinet Resolution No. 66 of 2023 sets out what a complaint should contain: your name and address, the name and address of the business, the type of offence and any evidence or related documents, such as a receipt.
Concerns about a pharmacist's conduct go to the health regulator for the emirate. In Dubai, that is the Dubai Health Authority, on 800 342 (800 DHA). In Abu Dhabi, it is the Department of Health, on 800 555; its contact page also points to the TAMM platform. The Sharjah Health Authority regulates healthcare providers in Sharjah. MOHAP has said community pharmacies remain under its jurisdiction after medical product regulation moved to the Emirates Drug Establishment. In Dubai, Dubai Municipality requires prior approval for health supplement advertising and takes comments and complaints on 800 900. Questions about whether a product is registered for sale go to the Emirates Drug Establishment.
Sources
Opened on 5 November 2026. These are the documents this page relies on.
- Federal Decree-Law No. (38) of 2024 Governing Medical Products, Pharmacists and Pharmaceutical Establishments (English translation)Ministry of Health and Prevention
- Pharmacists Professional Code of ConductMinistry of Health and Prevention
- Ministerial Resolution No. (1448) of 2017 on Adoption of Code of Ethics and Professional Conduct for Health ProfessionalsMinistry of Health and Prevention
- Standards for Code of Ethics and Professional Conduct for Health Professionals, version 1 (effective 3 September 2025)Dubai Health Authority
- Healthcare Workforce Bioethics Guidelines (2024)Department of Health Abu Dhabi
- Policy on Integrity and Benefit Disclosure (September 2022)Department of Health Abu Dhabi
- Federal Law No. (15) of 2020 on Consumer Protection (English translation)Ministry of Economy and Tourism
- Cabinet Resolution No. (66) of 2023 on the Executive Regulations of Federal Law No. (15) of 2020 on Consumer Protection (English translation)Ministry of Economy and Tourism
- Technical Guidelines for Health Supplements, version 2 (May 2024)Dubai Municipality
- Standards for pharmacy professionals (May 2017)General Pharmaceutical Council
- Standards for registered pharmacies (June 2018)General Pharmaceutical Council
- Boots staff under pressure to milk the NHS for cash, says pharmacists' union (13 April 2016)The Guardian
- Boots could face regulator's investigation after Guardian report (17 April 2016)The Guardian
- 16 CFR 255.5 Disclosure of material connectionsElectronic Code of Federal Regulations (US)
- Resolve Consumers Complaints (service card)Ministry of Economy and Tourism
- Contact DHADubai Health Authority
- Contact UsDepartment of Health Abu Dhabi
- MOHAP announces the transfer of selected services to Emirates Drug EstablishmentMinistry of Health and Prevention
- Health regulatory authoritiesThe Official Portal of the UAE Government (u.ae)