United Arab Emirates
What does a UAE company need before selling into the European Union?
A DIFC or ADGM entity is a third-country entity for EU purposes. What Gulf companies must appoint before selling or deploying in the European Union.
The pitfall
Free zone compliance does not travel
Companies established in the DIFC or in ADGM operate under data protection regimes of their own, and often assume that compliance there carries across to Europe. It does not. For European purposes, an entity in a free zone is an entity established outside the Union like any other. The question European law asks is not which regime you already satisfy — it is whether you offer goods or services to people in the Union, or reach them in another way.
There is no adequacy decision for the United Arab Emirates. Transfers of personal data from the Union therefore need safeguards of their own, and that question sits alongside the representation question rather than replacing it.
Verifying who you are appointing
Whoever acts as your European point of contact will appear in your privacy notice, on your packaging or in a filing with an authority. It is worth checking that the person is verifiable. Marouane Bezdi is registered at the Brussels Bar, with a Brussels office and identifiable professional details. The mandate is written, and its scope is fixed before anything begins.
Scope
Services most likely to apply
- GPSR responsible person for e-commerce and consumer goods
- GDPR Article 27 representation
- Distribution and reseller contracts
- AI Act authorised representative for fintech and AI
- EU trade mark filing
Working together
The role of your existing UAE counsel
Your current advisers keep the relationship and the strategy. We take the European-side mandate and report back in English. Where you would rather we deal with the company directly, we do that instead — it is settled before we start, not afterwards.
For foreign law firmsPreparation
What to prepare before we speak
Your privacy notice. Your record of processing, if one exists. A description of the activity that reaches the Union. The Member States you target. Whether any EU entity, importer or reseller already exists. And whatever prompted the question — a customer questionnaire, a marketplace notice, a letter from an authority.
FAQ
Frequently Asked Questions
Start with a scope review
EU market entry assessmentThis page describes how these obligations generally work. Whether one applies to you depends on facts a web page cannot capture — your supply chain, your contracts and the role you actually play in them.