Required Report - public distribution

**Date:** 9/29/2008

**GAIN Report Number:** BA8005

BA8005

**Bahrain**

**FAIRS Country Report**

**Annual**

**2008**

**Approved by:**

![](media/image1.wmf)David Williams

**Prepared by:**

Mohamed Taha

**Report Highlights:**

Sections Updated: Food Laws, Labeling Requirements, Other Specific
Standards, Import Procedures, Government Regulatory Agency Contacts

Includes PSD Changes: No

Includes Trade Matrix: No

Annual Report

Dubai \[TC1\]

\[BA\]

Table of Contents

SECTION I. FOOD LAWS

SECTION II: LABELING REQUIREMENTS

ECTION III: PACKAGING AND CONTAINER REGULATIONS

SECTION IV: FOOD ADDITIVE REGULATION

SECTION V: PESTICIDE AND OTHER CONTAMINANTS

SECTION VI: OTHER REGULATIONS AND REQUIREMENTS

SECTION VII: OTHER SPECIFIC STANDARDS

SECTION VIII: COPYRIGHT AND/OR TRADEMARK LAWS

SECTION IX: IMPORT PROCEDURES

APPENDIX I: GOVERNMENT REGULATORY AGENCY CONTACTS

APPENDIX II: OTHER IMPORT SPECIALIST CONTACTS

**DISCLAIMER:** The Agricultural Trade Office of the USDA/Foreign
Agricultural Service in Dubai, UAE has prepared this report for U.S.
exporters of domestic food and agricultural products. While every
possible care has been taken in the preparation of this report, the
information provided might be dated, as some import requirements are
subject to frequent change. It is highly recommended that U.S. exporters
ensure that all necessary customs clearance requirements have been
verified with local authorities through your foreign importer before the
sale conditions are finalized. Final import approval of any product is
always subject to the rules and regulations as interpreted by the
country of import at the time of product entry.

# 

# SECTION I: FOOD LAWS

Bahrain is a member of the Gulf Cooperation Council (GCC), which also
includes Kuwait, Oman, Qatar, the United Arab Emirates and Saudi Arabia.

**GCC-Wide Developments**

**Food Standards:** The Gulf Standards Organization (GSO) is comprised
of senior standards officials from the six Gulf Cooperation Council
(GCC) member countries and is responsible for developing food and other
standards in the GCC. The GSO food standards committee, which is
currently chaired by Qatar, has been actively updating food standards
over the past two years. Based on the WTO notifications that have been
reviewed thus far, the committee is working to harmonize existing
standards with the guidelines of the Codex Alimentarius and other
international organizations. However, in some cases, differences still
exist between some of the proposed new standards and existing
international guidelines.

In theory, each GCC member should notify the WTO of a proposed new
standard. However, typically one or two member countries submit the
notification. Consequently, interested parties who review these
notifications should bear in mind that, while a notification may be
submitted by a single GCC member, the proposed standard will likely
eventually apply to all GCC member countries. Once a new standard is
approved by the GSO food standards committee, each member country should
officially adopt the standard, thus making it a domestic standard as
well as a GSO standard.

In June 2007, GSO members approved two new standards to replace the
existing food shelf life and labeling standards. The new standards bring
the GCC into closer compliance with the guidelines of Codex Alimentarius
and, for the most part, offer more flexible requirements for importing
foods from foreign markets.

The GSO has created subcommittees to follow-up on other issues related
to food.

1.  Bio-technology subcommittee that is chaired and hosted by the UAE

2.  Labeling subcommittee that is chaired and hosted by Oman.

3.  Additives subcommittee that is chaired and hosted by Saudi Arabia

The GSO also, when the need arises, forms working groups to address
pecific issues. Currently, a group is working to develop a unified GCC
Halal standard. The first part of the standard outlines general Halal
requirements and was notified to the WTO by Bahrain. The second part of
the standard is currently being developed and is expected to cover
issues related to Halal certification.

**Customs and Tariffs:** In January 2003, the "GCC Unified Customs Law
and Single Customs Tariff" (UCL) was released. The UCL established a
unified customs tariff of five percent on nearly all processed food
products. Under the UCL, live animals, fresh fruits and vegetables, some
seafood, grains, flour, tea, sugar, spices and seeds for planting are
exempt from tariffs. It also established a single entry point policy. In
other words, a product entering any GCC member market would pay the
appropriate duty only at point of entry and would then be permitted duty
free transit among GCC member countries. In practice, this policy is
employed only with unopened containers transshipped between GCC markets.
Partial shipments tend to be subject to the five percent import duty
again in the country of destination. However, it is expected that all
goods, even partial shipments from opened containers, will eventually
receive single-entry treatment once customs procedures are fully unified
within the next year or two.

**Food Import Procedures:** During 2007, the GCC Food Safety Committee
developed a "Guide for Food Import Procedures for the GCC Countries."
This guide is meant to unify the applied procedures for clearing food
consignments as well as unifying the required import certificates for
different types of foods. The intent is to help facilitate the movement
of food products within the GCC once customs unification is fully
implemented. The United States and a number of other countries commented
extensively on this proposed set of procedures. Implementation of the
requirements has been delayed as GCC members study the comments. GCC
officials are currently planning to implement the requirements in early
2009.

**Bahrain Developments**

Bahrain is the only GCC country that has adopted, via the Ministry of
Commerce decree No. 3 dated February 2004, the Codex General Standard
for the Labeling of Prepackaged Foods (Codex Stan 1-1985, Rev.1-1991) as
a national standard. It is not yet clear if the revised GSO standards
for labeling GSO 9/2007 and shelf life GSO 150/2007 will override this
decree when eventually adopted by the Ministry of Commerce. If the new
standard does override the previous decree, Arabic labeling will become
mandatory for all food products as will production dating. A more likely
scenario is that the Government of Bahrain will permit either Codex
guidelines or GSO standards for product labeling and shelf life. The new
standards are currently with the Legal Department of the Ministry of
Commerce and Industry for review. Officials state that it is just a
matter of time before the standards officially approved.

The Public Health Directorate (PHD), Ministry of Health (MOH), in
conjunction with the Directorate of Standards and Metrology, Ministry of
Commerce (MOC) are responsible for formulating food regulations. The
Directorate of Agencies and Industrial Property, MOC, is responsible for
formulating and enforcing trademark and agency laws. The Directorate of
Customs & Ports, Ministry of Finance and National Economy (MOFNE), is
responsible for enforcing local agency laws. The Public Health
Directorate, Food & Water Control Section (FWC), MOH, is responsible for
enforcing food safety regulations. For example, the FWC is responsible
for inspecting all imported fresh and processed food products, verifying
compliance with label regulations and, if deemed necessary, drawing
samples and laboratory testing the products.

The Food Safety Committee, an interagency committee composed of
representatives from the MOH, the Directorate of Standards and
Metrology, Director of Consumer Protection, MOC and the Directorate of
Agriculture, Ministry of Municipal Affairs & Agriculture (MMAA), decides
all food safety and control issues, including the imposition of product
bans.

**SECTION II: LABELING REQUIREMENTS**

Bahrain currently follows Codex Alimentarius labeling guidelines.
Consequently, unlike other GCC countries, production dating is not
required. However, this could change once Bahrain adopts GSO 9/2007 for
labeling and GSO 150/2007 for shelf life. Currently, the food label must
include on the original label or primary packaging with the following
information:

1\. Product and brand name

2\. Ingredients and additives, in descending order of proportion

3\. Net content in metric units (volume in case of liquids)

4\. Manufacturer\'s name and address

5\. Country of Origin

6\. Lot identification

7\. Expiry date (best or sell by dates are also acceptable)

8\. Instructions for use (if any)

9\. Special storage, transportation and handling instructions

(Note: There are no local nutritional labeling requirements. The U.S.
nutritional panel is acceptable.)

Original labels should be printed in Arabic, but exceptions do exist for
small lots and ethnic foods. Bilingual labels are permitted, provided
one of the languages is Arabic (e.g. Arabic/English). In addition,
Arabic language stickers are permitted in lieu of Arabic or bilingual
labels provided the sticker:

\- Is extremely difficult to remove.

\- Includes all label information.

\- Does not cover the original label.

\- Does not contradict information on the original label.

The sell by date must be engraved, embossed, printed or stamped directly
onto the original label or primary packaging at the time of production,
using indelible ink. U.S. bar coding is not accepted in lieu of the
expiration date. The expiration date must be printed in the following
order, depending on the shelf life of the product:

‑ Day/month/year for products with a shelf life of less than 3 months.

\- Month/year for products with a shelf life longer than 3 months.

Dates written in digit form are preferred. However, dates written using
words such as "September 24, 2005" also are acceptable. American dating
(month/day/year) is not acceptable and using it could result in the
rejection of the products dated in such a manner.

Bahrain will pre-approve food labels prior to import. Pre‑import
approval is strongly encouraged since it can significantly speed import
clearance, particularly for new‑to‑market products and brands.
Consignments with minor labeling infractions may be granted a one‑time
waiver, if petitioned, provided the products are found to be safe for
human consumption. Small consignments of 20 or less cartons, as well as
ethnic food products, may be exempt from Arabic label requirements,
provided prior authorization is obtained from the PHD/MOH.

Ministerial Order No. 2/1989 governs the importation of specialty food
products, such as certain diet and health foods and foods for diabetics
and infants. Under this order, all specialty foods must be
pre‑registered with the Directorate of Pharmacies and Drug Control,
Ministry of Health, prior to import. Specialty food labels must contain
detailed information regarding ingredients (e.g., vitamins, supplements,
minerals, etc.), nutritive value per 100 grams and instructions for use
and proper storage. The U.S. nutritional panel is acceptable. There are
no Recommended Daily Allowance label requirements.

Products shipped in bulk or institutional‑sized containers are subject
to all labeling requirements. Fresh produce cartons are exempt from
Arabic language label requirements.

**SECTION III: PACKAGING & CONTAINER REQUIREMENTS**

General requirements for packaged special foods are covered under GS
654/1996, GS 839/97, and GS 1024/2000.

**SECTION IV: FOOD ADDITIVE REGULATIONS**

Bahrain's Minister of Commerce & Industry issued Decree No. 22, dated
June 21, 2005, that approved Codex Standards CXS 192:1995 as the
"General Standard on Food Additives and Class Names and the
International Numbering System for Food Additives" and CXS 107:1998 as
the "General Standard for Labeling of Food Additives When Sold as Such."
The common name and index number of all food color additives contained
in a product must be noted on the product label. European \"E\" numbers
are accepted.

**SECTION V: PESTICIDE AND OTHER CONTAMINATES**

Bahrain's Minister of Commerce & Industry issued Decree No. 22, dated
June 21, 2005, that approved Codex Standards CXS 193:1995 for "General
Standard for Contaminants and Toxins in Food" and CXS 229:1993 for
"Analysis of Pesticide Residues and Recommended Methods" as national
standards.

**SECTION VI: OTHER REGULATIONS AND REQUIREMENTS**

All meat and poultry products must be accompanied by an Islamic (Halal)
slaughter certificate issued by an approved Islamic center in the
country of origin.

All imported eggs must be individually stamped with the supplier name or
country of origin.

Unofficially, poultry products are granted a 20 percent tolerance for
salmonella bacteria. Inspection officials routinely test for salmonella
and will reject a shipment if salmonella is detected in more than 20
percent of samples taken.

Bahrain Standard 988/1998, which is identical to GS 988/1998, defines
the permitted level of radioactivity in foodstuffs. Irradiated food
products are permitted but the label must include the international
irradiated foods logo. A certificate of irradiation type and level is
required for these foods.

Bahrain health authorities randomly inspect food products in retail
outlets. In addition to visually inspecting labels, samples are taken
and analyzed to ensure that product ingredients match those listed on
the label. This procedure is conducted without the knowledge of the
importer. If a discrepancy is found, the importer is informed and the
product removed from the market and destroyed at the importer\'s
expense.

**SECTION VII: OTHER SPECIFIC STANDARDS**

"Sample" consignments face no special requirements. Samples destined for
food shows or other types of promotional events are exempt from local
label requirements. However, health certificates and invoices noting
that the products are not for sale and are of no commercial value must
accompany them.

Alcoholic beverages and pork, as well as food products containing
alcohol or pork, are strictly regulated. For example, retail outlets can
only sell pork products from special counters that are clearly marked.
Only four companies are licensed to import alcoholic beverages. These
companies may retail the product directly through their own
establishment or market to institutional end users, such as hotels and
licensed restaurants. Supermarkets are prohibited from selling alcoholic
beverages. Media are prohibited from advertising alcoholic products,
although in‑house promotion in a liquor store or licensed restaurant is
permitted.

**SECTION VIII: COPYRIGHT AND/OR TRADEMARK LAWS**

Legislative Decree No. 10/1992, amended by Legislative Decree No. 8 of
1998, governs commercial agencies. Importation of a brand officially
registered to a local agent is less strictly regulated than before. At
present any trader may import a product that is registered in another
firm's name, provided the registered agent is paid a commission, the
maximum of which is 5 percent. The Ministry of Commerce (MOC) may reduce
or even exempt the payment of any commission. The principal may
terminate an existing agency agreement. The agent is responsible for
proving to a grievance committee that his activities resulted in an
apparent success in promoting the product. The Directorate of Customs
and Ports will release a consignment only if imported by the registered
agent or if the importer obtains written permission from the registered
agent, after paying the commission. The MOC may waive this commission
for certain products, if deemed in the public's interest.

The Agencies and Industrial Property Directorate of the Ministry of
Commerce handles trademark registration, which usually can be completed
within a short time. Although a foreign company can register its
trademark directly with the directorate, usually a local, specialized
accounting or law firm is retained to conduct such work.

**SECTION IX: IMPORT PROCEDURES**

Nearly all of Bahrain\'s food imports enter the country via the main
port of Mina Salman, located in the capital, Manama. The port boasts
state‑of‑the‑art facilities and equipment. Imports from Saudi Arabia, a
major supplier of food products to Bahrain, usually arrive via the
25-mile long King Fahad causeway, which links Bahrain to its neighbor.
Bahrain International Airport also receives a considerable amount of
food products, particularly fresh fruits and fresh vegetables, chilled
meats and deli products.

Fresh products are usually cleared within 24 hours of arrival and all
other food products within as little as two days to a week, depending on
the type of laboratory analysis required.

The following documents are required for food imports:

‑ Commercial invoice

‑ Packing list

‑ Bill of Lading

‑ Health certificate from the country of origin

‑ Halal slaughter certificate (for meat, poultry and their products)

‑ Certified certificate of origin (see below)

A U.S./Arab chamber of commerce and the Bahrain Embassy, or one of its
consulates, in the United States, must notarize the certificate of
origin. Another Arab embassy or consulate may be used, if a Bahraini
government mission is not located near the exporter. If no other Arab
government mission is located near the exporter, a statement from the
local American chamber of commerce will suffice. A U.S./Arab chamber of
commerce, however, must still notarize the certificate of origin.

A consignment rejected for being unfit for human consumption must be
re‑exported (but not to another GCC country) or destroyed, normally
within two to three months of arrival. Products denied entry due to
labeling infractions may later be cleared upon appeal, provided the
infraction was minor. New‑to‑market and ethnic food products with minor
labeling infractions have been cleared for import on a one‑time basis.
Serious labeling infractions will result in rejection of a shipment with
no real chance of successful appeal. Major labeling infractions include:
label tampering, missing or incorrectly printed expiry date or date
printed on the sticker rather than original label/packaging.

Bahrain applies 100 percent inspection on new-to-market products, high
risk products and products that failed a previous inspection. All other
products are subject to a random sampling review that does include a
laboratory analysis periodically.

In January 2003, Bahrain implemented the \"GCC Unified Customs Law and
Single Customs Tariff\" (UCL). The UCL established a unified customs
tariff of five percent on practically all processed food products. Under
the UCL, live animals, fresh fruits and vegetables, seafood, grains,
flours, tea, sugar, spices and seeds for planting are exempt from any
import duty. During 2006, Bahrain signed a Free Trade Agreement with the
United States. Food products of U.S. origin that remain in Bahrain are
exempt from the five percent GCC tariff.

The Directorate of Agriculture, MMAA, inspects live animals and plants,
feedstuffs and horticultural products at the port of entry.

**APPENDIX I: GOVERNMENT REGULATORY AGENCY CONTACTS**

I. Ministry Of Health

Dr. Abdulla Ahmad Abdulla Ali Food products inspection

Head of Food & Water Control Section

Ministry of Health

P.O. Box 12

Manama, Bahrain

Tel: (973) 17-273‑683

Fax: (973) 17-279-253

**Mrs. Leila Abdul-Rahman** Health foods licensing and inspection

Director of Pharmacies and Drug Control

Ministry of Health1

P.O. Box 12

Manama, Bahrain

Tel: (973) 17-258-668

Fax: (973) 17-259-357

II\. Ministry Of Municipalities Affairs & Agriculture

**Dr. Abdul Aziz M. Mohamed** Plants and seed licensing

Plant Protection Director

Ministry of Municipalities Affairs &

Agriculture

P.O. Box 251

Manama, Bahrain

Tel: (973) 17-691-251

Fax: (973) 17-695-734

**Mr. Hassan M. Abdul Karim** Agricultural projects and policy

Assistant Undersecretary

Agricultural Production

Ministry of Municipalities Affairs

and Agriculture

P.O. Box 251

Manama, Bahrain

Tel: (973) 17-690-668

Fax: (973) 17-695-734

**Dr. Salman Abdulnabi** Veterinary regulations

Head, Veterinary Services Livestock and pet import licensing

Ministry of Municipalities Affairs

and Agriculture

P.O. Box 251

Manama, Bahrain

Tel: (973) 17-691-256

Fax: (973) 17-694-673

III\. Ministry Of Commerce

**Ms. Mona Al-Zeera** All standards, including food standards

Director of Standards & Metrology

Ministry of Commerce

P.O. Box 5479

Manama, Bahrain

Tel: (973) 17-523-030

Fax: (973) 17-530-730

**Mohammad D. Al‑Shaer** Trademark and agency regulations

Director of Agencies

and Industrial Property

Ministry of Commerce

P.O. Box 5479

Manama, Bahrain

Tel: (973) 17-530-335

Fax: (973) 17-536‑479

**APPENDIX II: OTHER IMPORT SPECIALIST CONTACTS**

**Mr. Ali Ibrahim Al-Mahmeed** Customs/Duties

Director General of Customs

Directorate of Customs & Ports

P.O. Box 15

Manama, Bahrain

Tel: (973) 17-727‑178

Fax: (973) 17-725‑556

**Mr. Abdulnabi Awad** Trade regulations and data

Director, Foreign Trade and Information

Bahrain Chamber of Commerce & Industry

P.O. Box 248

Manama, Bahrain

Tel: (973) 17-229‑555

Fax: (973) 17-216‑45310