The United Arab Emirates is preparing to adopt an Extended Producer Responsibility (EPR) framework in 2026. While much of the discussion around EPR centres on financial obligations and fee structures, the practical challenge for agrifood producers and suppliers is fundamentally one of data. The framework’s monitoring, reporting, and verification requirements demand a level of supply chain visibility that many companies in the region simply do not possess. For producers operating across the UAE’s agrifood sector, the question is no longer whether to digitise supply chain operations, but how quickly they can do so before compliance deadlines arrive.
This article examines the data requirements embedded in the EPR framework, evaluates the limitations of legacy tracking systems, and assesses the role of technologies and food traceability systems in enabling compliance. It also considers the broader commercial value that full supply chain traceability offers.
What the EPR framework demands in terms of data
The UAE’s EPR framework will assign legal responsibility for post-consumer waste management to producers, importers, and distributors. In practice, this means food and beverage producers will need to systematically track the volume, material composition, and end-of-life pathway for every unit of packaging they place on the market. This obligation extends beyond simply reporting waste volumes, as financial obligations are based on the recyclability and environmental impact of materials used. For instance, producers using easily recyclable mono-materials may qualify for fee reductions, while those using composite materials will not.
Accurate reporting will necessitate granular data on packaging design, source materials, and recycling compatibility. But calculating these obligations accurately requires detailed, verifiable product-level data that most legacy systems were never designed to capture. This challenge is further complicated by Federal Decree-Law No. (11) of 2024 On the Reduction of Climate Change Effects, which requires all UAE entities to measure, report, plan, and enable greenhouse gas emission reductions by May 2026. The convergence of these regulatory obligations renders it critical for agrifood producers to maintain auditable data trails covering both the lifecycle of their products and the emissions associated with their operations.
Why legacy tracking systems fall short
Most agrifood supply chains in the Gulf region still rely on fragmented, manual, or semi-automated tracking systems. Inventory management may be handled by one platform, logistics by another, and waste disposal by a third, with records frequently kept in hardcopy format, locked within specific systems or stored in isolated spreadsheets. These data silos create three fundamental problems for EPR compliance.
First, they make it difficult to establish the chain of custody required to demonstrate that a product’s end-of-life was managed in accordance with approved procedures. If a producer cannot trace a unit of packaging from the point of sale through to collection, sorting, and/or recycling, it cannot provide the verifiable evidence that MOCCAE requires.
Second, fragmented systems make accurate fee calculation almost impossible. Eco-modulated fees depend on precise data about material composition and recyclability at the product level. When this information is scattered across disconnected databases, the risk of reporting errors, and ensuing penalties, rises considerably.
Third, legacy systems are inherently retrospective. They record what has already happened, often with significant time lags. Most EPR frameworks rely on the ongoing monitoring of collection rates and performance indicators, which requires near-real-time data.
The highly fragmented nature of the UAE’s agrifood supply chain adds to these challenges. With products moving through multiple intermediaries between production and retail, each handoff point represents a potential gap in data continuity. Without integrated digital systems that maintain a consistent thread from manufacturer to end-of-life processor, producers may be unable to meet their reporting obligations.
Modern food traceability systems
Modern food traceability systems can register, connect, and analyse vast volumes of data as products and materials flow through complex, non-linear global supply chains. These systems are typically built on standardised frameworks such as the GS1 Global Traceability Standard, which is actively promoted in the UAE by GS1 UAE. These systems ensure that product identification, location data, and handling events are captured consistently across jurisdictions without competing against quality benchmarks like ISO or those imposed by the Global Food Safety Initiative (GFSI). At the operational level, sensors, digital imagery, and robotics enable continuous, accurate data capture across farms, warehouses, factory floors and processing facilities.
However, while sensors capture raw data and GS1 standards provide the structural syntax for communication, an Enterprise Resource Planning (ERP) system is required to consolidate and operationalise this information at the organisational level. Critically, generic ERP platforms are often insufficient for the food and beverage sector, as many treat inventory as static, non-perishable assets. Food-specific ERPs must account for perishable inventory lifecycles, volatile commodity pricing, complex biosecurity regulations, and catch-weight variability. For instance, a core capability of these systems is the automated management of expiration dates and shelf-life controls: by tracking the exact production date and degradation curve of every batch, these systems enforce First-Expired-First-Out fulfilment protocols that intelligently route products closest to expiration to market first rather than defaulting to conventional First-In-First-Out logic. Similarly, these systems need to be able to distinguish between true scrap (i.e., unusable waste destined for landfill) and by-products or co-products that can be monetised.
It is also worth noting that many food-centric ERPs also incorporate sustainability modules that allow operators to record water and waste intensity data, classify water types, and comply directly with frameworks such as the Corporate Sustainability Reporting Directive (CSRD) and the Carbon Border Adjustment Mechanism (CBAM) from within their financial ledgers. Naturally, these capabilities can be further enhanced by artificial intelligence, which improves demand and waste forecasting by analysing historical data, seasonal patterns, and consumption trends to reduce overproduction. This is key, as overproduction is one of the primary drivers of packaging waste in the agrifood sector.
However, deploying traceability systems in agribusiness environments is not without its challenges. Farms and agribusinesses are often located in rural or remote areas where network connectivity is unreliable or non-existent, leading to severe data latency. At the same time, the sheer volume of heterogeneous data generated by disparate systems can overwhelm legacy IT infrastructures, creating data silos that are difficult to integrate and analyse without advanced cloud computing and AI-driven analytics. It also bears mentioning that these systems must also be capable of interfacing with the UAE’s National Waste Database, launched by MOCCAE. For producers, this database functions as both a reporting mechanism and an enforcement tool, and any traceability infrastructure that cannot feed data into it will fall short of compliance requirements.
The cost of integrating digital traceability systems is substantial, but it remains significantly lower than the potential costs of non-compliance. The UAE’s climate change legislation carries serious financial consequences: fines for deliberate reporting violations under integrated waste management regulations range from AED 100,000 to AED 1,000,000, while non-compliance with climate disclosure obligations can attract penalties of up to AED 2,000,000. Administrative sanctions can extend to the suspension of licences and closure of facilities for repeat offenders. While avoiding these penalties is often reason enough to act, the operational benefits from EPR-ready infrastructure go considerably further.
Supply chains digitised to meet EPR requirements inevitably become more efficient, more predictable, and more responsive to market conditions. Ultimately the kind of integrated traceability systems that EPR requires enables the development of revenue-neutral or revenue-positive operational models that reduce input costs and may even generate new value from waste streams. Mars’ flagship plant in Dubai clearly illustrates this point. Their internal waste management improvements, underpinned by integrated data systems, have enabled them to significantly reduce packaging and production waste, eliminating significant disposal costs and enabling them to achieve zero waste to landfill status, while generating value from recovered materials in the process. This is consistent with broader industry evidence which indicates that food companies utilising sector-specific ERP software can experience up to 45% higher revenue growth compared to those operating on generic systems.
Building digital readiness for a circular economy
The UAE’s EPR framework presents agrifood producers with a data problem. The regulatory architecture demands transparency, granularity, and timeliness in supply chain reporting that cannot be achieved through manual processes or fragmented legacy systems. The systems required to meet these demands are available and proven, but they require meaningful investment and operational change. Producers that invest now will avoid penalties while capturing the operational efficiencies and cost savings that data-driven supply chains deliver. Those that rely on legacy systems will find themselves in increasingly untenable positions as enforcement mechanisms intensify.
At Farrelly Mitchell, our innovation and agtech specialists provide strategic, technical, and commercial expertise to help agribusiness owners and managers navigate digital transformation and regulatory compliance. Our traceability, supply chain optimisation, and sustainability services enable producers to build the data infrastructure required for EPR compliance while capturing the operational efficiencies that digitisation delivers. With a proven track record across the agrifood value chain, we combine local market insights with global best practices to address complex challenges and capitalise on emerging opportunities. Contact our experts today to discuss how we can support your business’ continued growth and profitability.
