Law 18/2024 on waste now has its implementing bylaw — Administrative Resolution No. 34 of 2026, issued by the Director General of Dubai Municipality on 10 February 2026. It names who must keep a waste register: producers of hazardous waste and ANY person having operational control over residential and commercial complexes, hotel and industrial establishments. Those same categories must move waste DAILY to municipality-approved disposal sites. A permit for waste-related activity is issued for one year through the unified digital window. The bylaw carries no fines — and we say where they live.
Verified against official sources on 2026-09-15: the text of Administrative Resolution No. 34 of 2026 comes from the Dubai Legislation Portal (dlp.dubai.gov.ae), credited to the Supreme Legislation Committee of the Emirate, 2026. The portal notes that the English version is a translation and that the Arabic text prevails in case of conflict. This is not legal advice: a specific obligation is judged on its own documents.
When we worked through the waste law No. 18 of 2024, we honestly refused to publish fines: the law leaves them to an implementing bylaw we did not have. That bylaw has now been issued.
The instrument is Administrative Resolution No. (34) of 2026 Issuing the Implementing Bylaw of Law No. (18) of 2024 Regulating Waste Management in the Emirate of Dubai, issued by the Director General of Dubai Municipality on 10 February 2026. It is published in the Official Gazette and comes into force thirty days after the day of publication (Article 19).
And straight to the point: it carries no fines either — more on that at the end.
Who must keep a waste register
Article 2 first describes the register — electronic or paper, with four mandatory items:
- the type of waste — hazardous or non-hazardous;
- the quantity of waste handled daily;
- a description of the production, segregation, sorting and recycling processes;
- details of the approved waste carriers and disposal sites.
It then names the categories that must maintain it:
"1. Hazardous Waste producers; 2. any Person having operational control over residential and commercial complexes, and hotel and industrial Establishments; and 3. any other category determined by a resolution issued by the CEO." — Administrative Resolution No. (34) of 2026, Article 2(c)
The second line is why an apartment owner in a complex should read this bylaw. The duty attaches not to title but to operational control: it falls on whoever actually runs the complex. The cost of that running lands in the service charge — how that works is set out under Law 6/2019.
Daily removal is not a recommendation
Article 3 adds one more duty for those same categories on top of the law: waste generated at an establishment or a building must be transported daily to disposal sites approved by the Municipality. Two ways are allowed: contracting a licensed waste carrier, or using the producer's own vehicle authorised for waste transportation — provided it meets the requirements of the bylaw and the Technical Manuals.
The permit: one year, a digital window, a reasoned refusal
Waste-related activity runs on a permit from the Municipality's Waste and Sewerage Agency. The bylaw sets out both the requirements and the procedure.
| What | As the bylaw puts it |
|---|---|
| requirements for the applicant (Art. 4) | a commercial licence or an initial approval from the Licensing Authority; compliance with environmental and health requirements, including an environmental impact assessment where required; compliance with the standards of the Technical Manuals |
| filing (Art. 5) | through the Unified Digital Window created by Decree No. 13 of 2024; the Agency registers the application and notifies the applicant |
| decision time (Art. 5) | within the timeframe specified for each activity in the approved Technical Manuals |
| refusal (Art. 5) | the applicant is notified with reasons |
| approval (Art. 5) | the applicant is required to pay the prescribed fees |
| validity (Art. 6) | one year, renewable for the same period; a renewal application no later than thirty days from the date of expiry |
| shorter permit (Art. 6) | on the applicant's request and per the Technical Manuals, the Agency may issue a permit valid for less than a year |
Note the definition of Licensing Authority in Article 1: the Department of Economy and Tourism and the authorities supervising Special Development Zones and free zones, such as the DIFC. The same scope formula appears in the urban planning law, the building code decree and the construction safety decree: when the legislator means to cover free zones, it names them.
Volunteer clean-ups: five conditions and ten working days
Law 18/2024 surprised readers by requiring approval even for volunteer cleaning. The bylaw shows how that works (Articles 7 and 8): approval of the Community Development Authority under the volunteer work law No. 5 of 2018; approval of the entity overseeing the site; a written undertaking to comply with the law and with environmental, health and public-safety requirements and to cause no damage; a detailed plan with six items (purpose, target area, expected number of participants, equipment and materials, collection and transport methods, proposed timeline); and clothing or logos customised, with the Authority's approval, so participants are easily identifiable.
The application is determined within ten working days of the applicant being notified that it was registered; notice of approval comes by e-mail, and a refusal comes with reasons.
Containers, labels, vehicles
Article 9 sets the specifications for hazardous waste containers: a leak-proof, tightly sealed cover; colour-coding by waste type per the Agency's standards; resistance to chemicals and corrosive or toxic liquids; materials that do not react with the contents; thick, sturdy walls; a design conforming to UAE standards; resistance to prevailing weather and high temperature variation.
Article 10 lists what a waste label must carry: the type of hazardous waste, its components and composition, applicable warning codes, disposal instructions and anything else specified in the Technical Manuals. Article 11 sends vehicle requirements to those same manuals.
Disposal sites: three groups of requirements
Article 12 is the longest. The Agency authorises a person to establish, manage and operate a site only if three groups of requirements are met.
Site selection: minimum distances to surrounding areas and facilities per the Technical Manuals; a paved, safe access road to public roads for heavy waste vehicles; controlled entry and exit points; approval of the entity supervising the area confirming conformity with the approved urban plan; geological and hydrogeological studies on soil stability and suitability; evidence the site is not prone to landslide or ground fissure hazards.
Environment and health: an environmental impact assessment with a plan of protective measures, odour reduction and mechanisms for environmental emergencies, plus an environmental authorisation from the Dubai Environment and Climate Change Authority; personal protective equipment for all workers; secure isolation areas for hazardous waste; dedicated facilities for receiving and sorting; treatment facilities using environmentally friendly technologies approved by the Agency; rainwater drainage systems.
Operations and administration: a detailed operational plan; defined working hours and measures to minimise noise and emissions; a camera surveillance system per the specifications of the emirate's security industry regulator; clear warning signage at entrances and in storage areas; an electronic system recording all disposal operations with periodic reports to the Agency; a periodic worker training plan.
Recycled materials: the percentages come separately
Article 13 introduces minimum percentages for the use of recycled materials and the projects where they are mandatory — but contains no percentages: those are set by a resolution of the Director General. Four factors must be taken into account: availability in local markets and the market's capacity to meet demand in time; quality and conformity with approved technical specifications; feasibility of transport at reasonable cost; variation of the percentages by project type and material.
The percentages are reviewed annually or as needed, and where there is a substantial shortage of recycled materials or an unjustified increase in their cost, the Director General may grant a partial or full exemption — justified and temporary, until the grounds fall away.
Technical Manuals and the compliance window
Article 15 approves four manuals — for waste management activities, for waste producers, for the use of recycled materials, and any others that may be required; all are published on the Municipality's official website, and the Agency's CEO may review and update them periodically.
Article 16 gives everyone to whom the bylaw applies six months from its effective date to comply; the CEO may extend that period once for the same length.
Article 18 repeals Administrative Resolution No. 1316 of 1997 (the implementing bylaw of the earlier medical waste order), along with any conflicting provisions of other administrative resolutions.
What we do NOT claim here
- The amounts of fines and fees. They are not in this bylaw. Its preamble names a separate instrument — Executive Council Resolution No. 58 of 2017 approving the fees and fines for waste disposal; we have not read it and quote no amount. Our earlier refusal under Law 18/2024 stands, but it now has an address.
- The contents of the Technical Manuals. That is where the minimum distances to sites, vehicle specifications, per-activity decision timeframes and technical container requirements live. The manuals are published on the Municipality's website; we have not worked through them.
- The minimum percentages of recycled materials. The bylaw names the mechanism and the factors, not the figures: those come by a separate resolution of the Director General, which we have not read.
- The calendar date of entry into force. The bylaw comes into force thirty days after the day of publication in the Official Gazette; we have not verified the date of that publication and will not compute it.
- The contents of the instruments in the preamble — Federal Law No. 12 of 2018 on integrated waste management, Law No. 5 of 2025 on public health, Law No. 11 of 2024 on the Dubai Environment and Climate Change Authority and others. They are named as grounds of issuance.
Sources
- Administrative Resolution No. (34) of 2026 Issuing the Implementing Bylaw of Law No. (18) of 2024 Regulating Waste Management in the Emirate of Dubai — Dubai Legislation Portal: issuance by the Director General of Dubai Municipality on 10 February 2026 and entry into force thirty days after publication (Article 19); definitions of the Waste and Sewerage Agency, the Permit, the Technical Manuals, the Unified Digital Window and the Licensing Authority, which includes the Department of Economy and Tourism and the authorities of Special Development Zones and free zones such as the DIFC (Article 1); the contents of the waste register and the three categories required to keep it, including persons with operational control over residential and commercial complexes and hotel and industrial establishments (Article 2); the duty of daily transport to approved sites by an authorised own vehicle or a licensed carrier (Article 3); requirements for issuing and renewing a permit (Article 4); the filing procedure through the Unified Digital Window, reasoned refusal and payment of fees on approval (Article 5); the one-year validity, thirty days for a renewal application and the option of a shorter permit (Article 6); five conditions for approving a volunteer campaign and the six items of its plan (Article 7); ten working days for the decision and notification by e-mail (Article 8); hazardous waste container specifications (Article 9); the contents of the waste label (Article 10); vehicle requirements referred to the Technical Manuals (Article 11); three groups of requirements for disposal sites, including geological studies, environmental authorisation from the Dubai Environment and Climate Change Authority and camera surveillance per the security industry regulator's specifications (Article 12); the mechanism for setting minimum percentages of recycled materials, the four factors, annual review and temporary exemption (Article 13); approval of four Technical Manuals and their publication on the Municipality's website (Article 15); six months to comply, extendable once (Article 16); repeal of Administrative Resolution No. 1316 of 1997 (Article 18); the preamble reference to Executive Council Resolution No. 58 of 2017 on the fees and fines for waste disposal.
