TL;DR
In the UAE, businesses may set procedures for handling after-sales requests. “No returns or exchanges” cannot serve as an ordinary change-of-mind policy. Article 34 of Cabinet Decision No. 66 of 2023 generally prohibits this absolute wording, subject only to the three groups of circumstances listed in the Article. Product defects, non-conformity, and services not performed as agreed remain outside the scope of a store disclaimer. The appropriate response depends on the transaction facts, applicable rules, and the latest official publication.
This article addresses a specific operating question: can a UAE store reject an after-sales request simply because its receipt, notice, or order terms say “no returns or exchanges”? The answer is no. A business can establish a handling policy within the legal boundaries governing its responsibilities.
By the end of this guide, you will have a practical route for separating change-of-mind requests from product and service-performance issues. You will also be able to check the three groups of exceptions under Article 34 and turn your receipt terms, customer-service scripts, and approval rules into a process that frontline staff can apply consistently.
When May “No Returns or Exchanges” Be Used?
Article 34 of Cabinet Decision No. 66 of 2023 provides that any condition exempting a supplier from its legal responsibilities or obligations is void, whether it appears in a contract, invoice, or another document relating to a consumer transaction. Item 10 of the Article specifically addresses the wording “no returns or exchanges” and lists only three groups of exceptions, subject to the latest official publication.
First Group: The Consumer Knew About and Accepted the Product Defect at Purchase
Two conditions must be met. The consumer must have known about the defect or fault when purchasing the product and accepted the product in that condition. The fact must also be clearly recorded on the purchase invoice.
A shelf label saying “imperfect item,” a verbal warning from an employee, or a clearance label does not replace the invoice record. The store should retain transaction evidence showing both what was disclosed and that the consumer accepted the product in its stated condition.
Second Group: The Product Cannot Be Restored to Its Condition at Purchase and Resold
This exception may apply where the nature, characteristics, or packaging of the product means that, once returned, it cannot be restored to its condition at the time of purchase and therefore cannot be resold.
The Article also sets a clear boundary. A business cannot rely on this exception if the return or exchange is requested because of a manufacturing defect, non-compliance with standard specifications, or inconsistency with the specifications agreed by the parties, subject to the latest official publication. Labels such as “opened,” “worn close to the body,” or “hygiene-sensitive” do not automatically establish a statutory classification. The store must examine why the product cannot be restored and why the customer is requesting a remedy.
Third Group: Specific Products Listed in the Article
This group includes perishable consumer goods, products made to specifications selected by the consumer, and books, newspapers, and magazines.
The perishable-goods exception does not apply if the product was already visibly spoiled or unfit for consumption on the day of purchase. For a customised product, the business should be able to show that the consumer selected the relevant specifications. Production beginning only after the order was placed does not, by itself, establish that the product falls within this exception.
(Source: Cabinet Decision No. 66 of 2023 Concerning the Executive Regulation of Federal Law No. 15 of 2020 on Consumer Protection, Article 34, July 2023)
⚠️ “Promotional goods” and “the consumer changed their mind” do not create a fourth group of exceptions under Article 34. A business may define evidence requirements, submission channels, and review procedures. The absolute “no returns or exchanges” wording should remain limited to the three statutory groups, subject to the latest official publication.
How Should Change-of-Mind, Product, and Service Disputes Be Routed?
A customer’s reason for requesting a refund determines the first step. Our recommendation is to classify the request first, then verify the evidence and non-excludable obligations before selecting an action.
| Type of request | What to verify first | Handling direction | When to escalate |
|---|---|---|---|
| Change of mind | Product condition, pre-purchase disclosure, additional promises, and whether an Article 34 exception actually applies | Assess under applicable law and the disclosed policy; avoid using absolute wording as the default reason for refusal | The policy conflicts with Article 34 or the facts are unclear |
| Product sold with a known defect | Whether the consumer knew of the defect, accepted the condition, and the invoice clearly recorded it | Consider the Article 34 exception only when all three facts align | The invoice is silent or the parties dispute prior knowledge |
| Product cannot be restored for resale | Product nature, characteristics, packaging, and the reason restoration is impossible | First exclude manufacturing defects, non-compliance with standards, and inconsistency with agreed specifications | Quality, safety, or advertising is disputed |
| Perishable, customised, or printed product | Condition on the purchase date, consumer-selected specifications, and order evidence | Apply only the conditions listed in Article 34 | A perishable item was spoiled or unfit for consumption on the purchase date |
| Defective or misdescribed product | Product information, advertising, invoice, photographs, use, and repair records | Assess repair, replacement, refund, or another applicable remedy | Safety risk, recurring issue, or significant value |
| Service not performed as agreed | Service terms, deliverables, progress, acceptance, and communications | Under Article 29, first determine whether free re-performance is required | The supplier refuses, incorrectly performs, or delays re-performance |
Follow the table from left to right. Rejecting a request as soon as an employee sees “sale,” “opened,” or “customised” skips the facts that determine responsibility. It can also lead staff to apply product rules incorrectly to a service dispute.
Why Should Services Not Be Handled Under Product Return Rules?
A service dispute concerns the agreed performance. The business should compare the agreed scope, timing, output standard, completed work, and whether the problem arose for reasons attributable to the supplier.
Article 29 of Cabinet Decision No. 66 of 2023 provides that where a service-performance problem is attributable to the supplier, the consumer is initially entitled to require the service to be performed again as agreed, free of charge and without additional cost. If the supplier refuses, fails to perform it again correctly, or delays doing so, the consumer is entitled to request a refund of the amount paid, subject to the latest official publication. Where a service involves repairing, maintaining, or operating goods and causes loss of function, loss of the goods, or damage to them, the Article also provides for repair costs or compensation for the corresponding value, subject to the latest official publication.
(Source: Cabinet Decision No. 66 of 2023 Concerning the Executive Regulation of Federal Law No. 15 of 2020 on Consumer Protection, Article 29, July 2023)
A store should avoid broad statements such as “no refunds once a service has started.” It should also establish responsibility before promising a full refund. Determine whether the performance problem is attributable to the supplier, then assess free re-performance, the outcome of that re-performance, and the conditions for a refund in the order set by Article 29.
How Can a Store Turn the Regulatory Boundary into an Operational Process?
A workable after-sales policy should cover at least six elements:
- Scope: Address ordinary goods, products sold with known defects, customised products, perishable goods, and services separately.
- Reason for the request: Distinguish a change of mind from a product defect, misdescription, service not performed as agreed, or a safety risk.
- Evidence: Check the invoice first and explain how orders, payment records, or membership records may establish the transaction.
- Action: Route the case, according to the facts, to repair, replacement, refund, free service re-performance, a request for further evidence, or a reasoned refusal.
- Statutory exceptions: Match the policy strictly to the three groups in Article 34 rather than adding broad categories such as “sale,” “opened,” or “hygiene product.”
- Escalation: Refer safety issues, recurring defects, misleading advertising, significant values, and complex facts to management or legal counsel.
Use a “principle + situation + action” format. Start by stating that the store handles after-sales requests in accordance with applicable rules. Then explain the evidence, approval owner, and escalation point for each type of dispute. The internal Chinese management position, consumer-facing English or Arabic terms, point-of-sale receipt, website policy, and customer-service scripts should all express the same rule.
💡 Replacing “no returns or exchanges” with a softer sentence addresses only the wording. The store should also align request classification, evidence retention, approval authority, remedy sequence, and complaint escalation.
What Are the Five Most Common Mistakes Chinese Businesses Make?
Mistake 1: Printing an Absolute Clause on Every Receipt
“No returns or exchanges under any circumstances” fails to distinguish the Article 34 exceptions from product defects and service-performance problems. It encourages employees to make refusal the default response.
Mistake 2: Treating a Discount as a New Statutory Exception
A discount changes the price. Responsibilities relating to product defects, non-conforming specifications, or disclosure continue to apply. If a product is discounted because of a known defect, the business must still satisfy the conditions concerning knowledge at purchase, acceptance of the condition, and a clear invoice record under Article 34, subject to the latest official publication.
Mistake 3: Letting the Store Notice and Invoice Record Diverge
An employee’s explanation or a shelf label cannot substitute for a clear invoice record. For products sold with a known defect, the disclosure, acceptance of the condition, and transaction document should align.
Mistake 4: Using the Same Script for Goods and Services
Product disputes focus on defects, specifications, and whether an item can be restored. Service disputes also require the business to follow the free re-performance and subsequent refund route under Article 29, subject to the latest official publication. One “no returns” script cannot cover both.
Mistake 5: Giving Frontline Staff No Authority Boundaries
If staff members must both classify a request and decide complex responsibility questions, similar complaints can produce inconsistent outcomes. Frontline employees should record the case, verify the evidence, and act within their authority. Higher-risk matters should be escalated promptly.
Frequently Asked Questions
Q: Can a Store Reject a Request If the Customer Has No Paper Receipt?
The absence of a paper receipt should not be an automatic ground for refusal. First check whether an order, payment record, membership system, or other material can establish the transaction. Then continue the assessment according to the reason for the request. Where the store seeks to rely on the first group of exceptions under Article 34, it must pay particular attention to whether the known defect was recorded on the purchase invoice, subject to the latest official publication.
Q: Can Discounted Goods Be Marked “No Returns or Exchanges Under Any Circumstances”?
A discount alone does not support this absolute wording. Promotional status is not one of the three groups of exceptions listed in Article 34. If the reduced price reflects a defect disclosed at purchase, the consumer must have known about and accepted the defect, and it must be clearly recorded on the invoice, subject to the latest official publication.
Q: Are Opened Personal-Use or Hygiene-Sensitive Products Always Non-Returnable?
The label alone does not decide the issue. The store must assess whether the nature, characteristics, or packaging of the product genuinely prevents it from being restored to its condition at purchase and resold. It must also exclude manufacturing defects, non-compliance with standard specifications, and inconsistency with agreed specifications before relying on the relevant Article 34 exception, subject to the latest official publication.
Q: What If a Service Is Partly Completed and the Customer Demands a Full Refund?
First determine whether the performance problem is attributable to the supplier. If Article 29 applies, address the consumer’s initial request for free re-performance. If the supplier refuses, fails to perform the service again correctly, or delays doing so, proceed according to the refund rule in the Article, subject to the latest official publication. Other disputes should be assessed against the agreement, performance evidence, and applicable rules.
What Should Store Managers Do Next?
- Search receipts, store notices, order terms, and customer-service templates for absolute wording.
- Check each proposed exception against the three groups in Article 34 rather than creating additional categories.
- Build a “reason—evidence—action—owner” routing table from actual complaints.
- Add Article 29’s free re-performance and subsequent refund route to the service-dispute process.
- Align multilingual consumer terms with the internal operating position.
- Retain the policy version and effective date, and review declined requests regularly.
We can help your business examine receipts, store notices, website policies, and customer-service scripts in the context of actual transactions. The work identifies conflicting terms and defines evidence requirements, decision authority, and escalation routes. Matters requiring a legal conclusion on an individual case should be reviewed by appropriately qualified legal counsel.
An after-sales policy turns legal boundaries into a consistent, reviewable operating process.
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Last updated: September 2026. This content is for informational purposes only and does not constitute legal or tax advice. UAE policies may change; please refer to the latest publications of the relevant authorities. For professional consultation, please contact the MIRISE team.