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Source: US Global Legal Monitor

(Oct. 9, 2020) On September 24, 2020, the Municipality of Dubai, one of the nine emirates of the United Arab Emirates, issued Circular No. 45 of 2020 regulating the operation of food establishments, including restaurants, food courts, and cafes. The purpose of the new regulation, The National reported, is to combat the spread of COVID-19 while supporting the Municipality’s food establishments.

In recent months the Municipality of Dubai has cracked down on food establishments that do not follow health and safety measures to protect their customers from the spread of COVID-19. For instance, it reportedly shut down a restaurant in an area called “Blue Waters Island” for not applying social distancing among its customers. As of September 30, 2020, the number of cases of COVID-19 in the United Arab Emirates had reached 93,090, according to the National Emergency Crisis and Disasters Management Authority.

Circular No. 45 addresses staff, facilities, customers, social distancing, food catering, and buffet-style service.


Under the new regulation, staff members in food establishments must wear face masks and provide masks to customers if needed, and must strictly adhere to hand washing before and after serving customers. (Circular arts. 1, 6.)

If a staff members tests positive for COVID-19 that staff member is prohibited from returning to work until the Department of Health grants him or her written permission and a medical certificate stating that the staff member’s subsequent COVID test result was negative. If one of the customers or a staff member has COVID-19-like symptoms the manager of the food establishment must inform the Department of Health immediately. (Circular arts. 3, 8.)


All food establishment facilities must be sanitized and disinfected before opening and on a daily basis. All common contact surfaces and common areas of the facility, such as escalators, elevators, rails, counters, countertops, tables, chairs, door handles, and light switches, must be sanitized and disinfected after each use or at least once every hour. Customers’ tables must be sanitized and disinfected after they leave. (Circular arts. 9, 11, 13.)

Social Distancing

Food establishments must maintain two meters (six feet) between customers’ dining tables at all times. The establishments may use physical separators (barriers) instead of distancing measures if it is difficult to maintain the six-foot distance. Table capacity must not exceed more than eight people. Establishments must maintain social distancing among customers in the waiting area until they are seated. Signs must be posted informing customers that safe social distancing is six feet; markings must also be displayed on the floor throughout the entire establishment. (Circular arts. 17, 18, 22, 23, 43.)


Customers are not allowed to stay inside a food establishment for more than three hours and must wear face masks at all times, except when they are having their meals. If a customer does not adhere to these safety measures, the manager of the food establishment has the right to make him or her leave. Customers who leave because they violated health safety measures have no right to request a refund for food orders they already made. (Circular arts. 25, 28, 29.)

Food Catering

Food catering companies must not cater food to a private residence for more than ten people. (Circular art. 37.)

Buffet-Style Serving

Food establishments are allowed to provide buffet-style service to customers. However, customers must not share or touch serving utilities. Managers of the food establishment must ensure that customers in the buffet line adhere to the six-foot social distancing requirement. (Circular art. 38.)