The regulated alcohol sector in the United Arab Emirates has spent six years moving in one direction. Decriminalization in 2020 reset the legal baseline; Dubai suspended its retail alcohol tax from 2023; and, most recently, practitioner reports describe the Trademark Office accepting applications in a class that had been closed for years. None of this has loosened the country’s advertising rules, which have if anything tightened, and none of it appears to extend to import-duty relief under the India–UAE Comprehensive Economic Partnership Agreement (“CEPA”). This article sets out where each of these threads currently stands, and what the reported opening of Trademark Class 33 means in practice for brand owners deciding whether, and how, to file.

A Liberalizing Industry, Within Limits

Federal Decree-Law No. 15 of 2020 decriminalized the consumption, possession, sale and manufacture of alcohol without a licence for persons legally entitled to drink, and set a uniform federal minimum age of 21. Online sale and home delivery are lawful today, provided licensed operators verify the purchaser’s age, purpose and delivery address.

Licensing, however, remains a matter for each Emirate individually — there is no single federal alcohol licence. Sharjah continues to prohibit the sale and public consumption of alcohol outright, and driving under the influence remains strictly enforced, with penalties reported up to AED 20,000. Alcohol imports also attract a standalone customs duty of 50%, on top of the standard 5% VAT — far outside the GCC common external tariff of 5% that applies to most goods. Dubai Municipality’s 30% retail tax, suspended from 1 January 2023, is a separate, emirate-level charge distinct from this import duty.

Advertising Has Tightened, Not Loosened

The advertising of alcoholic beverages has long been prohibited under UAE media regulation, alongside tobacco and narcotics, across broadcast, print and licensed media. Federal Decree-Law No. 55 of 2023, with Executive Regulations effective 31 October 2024, restates this prohibition on a federal statutory footing and extends it expressly to digital, electronic and social media — closing any prior ambiguity around influencer and online content.

National Media Council guidance goes further still, prohibiting indirect or oblique references to alcohol and requiring clear disclosure of sponsored content (e.g., “#ad”); a general acknowledgment of partnership is no longer treated as sufficient. Penalties now extend up to AED 1,000,000, and no exemption is provided for licensed venues, hotels or retailers — the prohibition applies uniformly across all media activity.

Where CEPA Does Not Reach

CEPA has been in force since 1 May 2022 and eliminates or reduces tariffs on the substantial majority of UAE and Indian tariff lines. No provision identified in the Agreement’s publicly available schedules, the Ministry of Economy and Tourism’s CEPA materials, or associated exporter guidance extends a concession to alcoholic beverages (Chapter 22, HS headings 2203–2208).

CEPA’s tariff mechanism operates principally by reference to the GCC common external tariff of 5%; alcohol’s standalone 50% duty regime sits outside that architecture entirely, consistent with its treatment under the UAE’s other free trade agreements. A conclusive answer requires checking the applicable HS codes against Annexure 2 to the Agreement directly — but on the evidence reviewed, CEPA should not be relied upon as a basis for any tariff concession on alcohol imports or exports.

Trademark Class 33: The Door Has Opened

Until at least 2021, the UAE Trademark Office did not accept applications under Class 33 (alcoholic beverages, excluding beer), a position attributed to public-morals considerations under the Trademarks Law. Class 43 registrations for bar services began to be accepted in practice following the 2020 decriminalization, and commentators anticipated that Class 33 would in time follow.

Practitioner reports first noted in September 2026 state that this position has now changed: the Trademark Office is accepting Class 33 applications covering wines, spirits, liqueurs, alcoholic cider and other alcoholic preparations, with beer continuing to fall under Class 32. Filing follows the ordinary prosecution route — examination, acceptance, publication and the standard opposition window — with no separate forms or evidentiary requirements. This remains unconfirmed by an official Ministry circular or Gazette notice as at the date of this article and should be independently verified, including by way of a test filing.

Filing now carries clear commercial advantages: registration in the class that actually matches the goods sold, alignment with international and Madrid System portfolios that already use Class 33, a stronger footing for customs recordals, watch services and opposition strategy, and priority under the UAE’s first-to-file system, which will not favour brand owners who wait while others test the newly opened class.

A clearance search should be run across both Class 32 and Class 33 before filing, since a number of alcoholic beverage marks were historically registered in Class 32 in the absence of a Class 33 option — sometimes by the brand owner, sometimes by a distributor or an unrelated third party. Existing Class 32 registrations should be retained for their priority date alongside any new Class 33 filing, and related classes — Class 35 (retail and distribution), Class 43 (bar and hospitality services) and Classes 21/32 (barware, mixers and non-alcoholic extensions) — merit consideration for wider protection.

A Practical Filing Checklist

• Priorities house marks, flagship labels and any brand with a launch planned in the next 12–18 months.
• Run clearance searches across Classes 32 and 33.
• File nationally or via the Madrid System, keeping existing registrations alive.
• Prepare Arabic transliterations early — UAE filings require Arabic rendering of non-Arabic elements.
• Set up watch services for third-party filings in the newly opened class.
• Tie each filing to a genuine commercial plan; UAE law permits cancellation of a mark left unused for a continuous period.

One caveat is worth stating plainly: a Class 33 registration protects the mark only. It does not authorise the import, distribution, advertising or sale of alcoholic beverages in the UAE — those activities remain subject to the separate federal and Emirate-level licensing and advertising requirements described above, which differ between Emirates and are administered by separate authorities.

Taking It Forward

For brand owners with an alcohol-adjacent portfolio, the practical next step is a test application under Class 33 through a registered UAE trademark agent — the examiner’s response will confirm the position, and secure priority, faster than continued reliance on secondary commentary. Marketing and influencer engagements should be reviewed against the advertising prohibition described above, independently of the entity’s underlying trading licence, and no commercial or pricing plan should assume a CEPA tariff benefit for alcohol without line-by-line verification of the applicable HS codes. Taken together, decriminalization, the Dubai tax suspension, the consolidated advertising law and the reported Class 33 development read as one continuous liberalization arc for the licensed, regulated side of the industry – worth watching closely as it continues to move.

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