If your UK MHRA Certificate of Free Sale (CFS) was rejected in the United Arab Emirates, the reason is usually simple — and avoidable.
In practice, rejections rarely happen because of the Apostille.
Instead, they happen because the UK solicitor certification is weak, unclear, or incomplete.
This article explains the process in plain language, step by step.
More importantly, it shows you how to avoid rejection before submission.
Why the UAE Asks for a UK MHRA Certificate of Free Sale
First, UAE authorities need proof that a regulated product is lawfully sold in its country of origin.
For that reason, they often ask for a Certificate of Free Sale issued by a trusted regulator.
In the UK, that regulator is the Medicines and Healthcare products Regulatory Agency (MHRA).
As a result, UK-issued CFS documents are widely used in UAE applications for:
- medical devices
- IVDs
- cosmetics
- other regulated healthcare products
Why UK CFS Documents Are Rejected in the UAE
UAE authorities do not review documents like a checklist.
Instead, they assess regulatory responsibility.
So the key question is not:
“Is there an Apostille?”
It is:
“Who is professionally responsible for confirming this document is authentic?”
If that responsibility is unclear, rejection follows — even if an Apostille is already attached.
The #1 Cause of Rejection: Weak Solicitor Certification
Most rejected CFS files contain wording like this:
“I certify that this document was produced to me as a printout.”
This wording causes problems because it proves almost nothing.
Specifically, it does not confirm:
- where the document came from
- whether it matches MHRA records
- whether it is authentic
- whether the solicitor accepts responsibility
Therefore, for regulated products, UAE authorities regularly reject such certifications.
Why a UK Apostille Does Not Solve This Problem
At this point, many exporters ask:
“But the document has a UK Apostille — why was it rejected?”
The answer is straightforward.
A UK Apostille, issued by the Foreign, Commonwealth & Development Office (FCDO), does not verify document content.
It only confirms:
- who signed the document
- that the signer is authorised
So, if the solicitor statement is weak, the Apostille only confirms a weak statement.
In short:
An Apostille cannot repair poor certification.
Why an MHRA Certificate of Free Sale Cannot Be Apostilled Directly
This step often causes confusion.
An MHRA CFS:
- is issued as an electronic PDF
- has no wet signature
- has no physical seal
Because of this, the FCDO cannot Apostille the MHRA document itself.
Instead, a UK solicitor or notary must first certify it.
Only then can the Apostille be issued.
What UAE-Accepted Solicitor Certification Must Say
To meet UAE expectations, the solicitor certification must be clear and explicit.
Specifically, it should confirm that the solicitor has:
- reviewed the MHRA Certificate of Free Sale
- checked it against MHRA records
- confirmed its authenticity
- accepted professional responsibility for that confirmation
This step is the foundation of the entire process.
If it is done properly, everything else becomes straightforward.
Correct UK MHRA CFS Legalisation Process for the UAE
To avoid rejection, follow this order:
Step 1 — MHRA Issues the CFS
The MHRA issues the certificate electronically.
Step 2 — UK Solicitor Certification
An SRA-regulated, FCDO-recognised UK solicitor certifies the document using regulator-acceptable wording.
Step 3 — UK Apostille (FCDO)
The FCDO Apostille verifies the solicitor’s signature.
Step 4 — UAE Embassy or MOFA Legalisation
Because the UAE is not a Hague Apostille Convention country, embassy or MOFA legalisation is required after the Apostille.
If Step 2 is weak, all later steps fail.
Why “Low-Cost” Certification Often Leads to Rejection
At first glance, minimal certification looks faster and cheaper.
However, it creates real risk.
Common problems include:
- no clear accountability
- no authenticity verification
- no regulatory confidence
As a result, rejected CFS documents can delay:
- registration
- shipment
- market entry
Often, delays last months, not days.
Final Takeaway
When a UK MHRA Certificate of Free Sale is rejected in the UAE, the issue is almost never:
“Did we get an Apostille?”
The real question is:
“Did the solicitor clearly verify authenticity and accept responsibility?”
If the answer is yes, acceptance usually follows.
If not, rejection is likely — regardless of how many stamps are attached.
Strong solicitor certification is the key.
Everything else depends on it.e foundation.
The Apostille only works if that foundation is sound.
What Ginkgo Advisory Can Do
Ginkgo Advisory helps ensure UK MHRA Certificates of Free Sale are accepted overseas, including in the United Arab Emirates.
We focus on regulatory acceptance, not just document processing.
In practice, we:
- review your MHRA Certificate of Free Sale to identify rejection risks
- arrange proper UK solicitor certification with clear, regulator-accepted wording
- coordinate the UK Apostille through the Foreign, Commonwealth & Development Office (FCDO)
- manage UAE embassy or MOFA legalisation where required
- correct weak or rejected certifications without restarting the entire process
As a result, your documents move through regulatory review cleanly, confidently, and without repeat submissions.
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