As Dubai announces the relaxation of some restrictions, this article looks at what they are and their likely impact.


What are the relaxations in Dubai?
  • Subject to stringent restrictions and protocols, shopping malls, high-street shops, souqs and wholesalers were allowed to reopen on 24 April
  • Family entertainment, prayer rooms and cinemas remain closed 
  • Hotels to operate maximum 30% staff and further hotel-related operation guidance is awaited 
  • Large events, cultural facilities and sports to remain prohibited/closed until further guidance is given
Practicalities: How does reopening work?
Health & Hygiene
  • Sanitisation on a 24 hour basis
  • Temperature screening and checks for anyone entering the premises including staff, contractors and visitors
  • Masks and hand sanitizers: all visitors to wear masks at all times from entry; customers must continue to wear masks whilst in food and beverage outlets; hand sanitizers to be installed; and the purchase of masks to be regulated by malls
  • Standard operating procedures for mall operators & retailers to maintain compliance in the event of dealing with positive cases on site and crowd management (including mandatory designation of isolation rooms)
  • Health and prevention staff education on personal health safety and premise hygiene
  • Item sanitisation after each trial of clothing and no testing allowed for personal care items however retailers are not permitted to implement a 'No Returns' policy for sale of personal items 
  • Smart payment to be promoted as preferred method of payment by making customers aware of smart payment, however, cash payments cannot be rejected
  • Cleaning staff must be available in restrooms to sanitise toilets after each use and must be available to regularly sanitise all entrances, elevators, escalators and other facilities/surfaces prone to high frequency contact
  • Supply chain and storage practices to involve the provision of a designated place to ensure hygiene implementation across the supply chain and storage from the point where items are entered into the mall/store
  • Electronic doors to be the main type of door used, rather than manual doors, at entrances, with 
  • Gold and jewellery: visitors must continue to wear masks whilst trying on items; and items that have been tried must be fully sanitised or quarantined in the event that sanitisation is not possible due to the potential of damaging the jewellery
  • Cleaning measures in food and beverage outlets: only disposable, individually wrapped plastic utensils/dishes/packages may be used; all surfaces, including tables and chairs, must be cleaned with 75% alcohol after each visitor's use
Operations and social distancing
  • Age restrictions: visitors above 60 years old and children between 3 – 12 years old are prohibited from entering the premises
  • Mall facilities:
  • Mall entry / exit: dedicated separate doors for entry and exit; entry points must all be open to avoid crowding at entrances (particularly with mandatory health checks upon entry)
  • changing rooms remain closed (unlike in Germany)
  • elevators – to hold no more than 30% maximum capacity
Timing and visitor/staff restrictions:
  • operating hours limited to 10 hours
  • consumer visiting hours limited to 3 hours per person
  • capacity level of staff limited to 30% of total staff
  • Minimum 2 metres physical distancing to be maintained in all common areas, service desks and customer service (does not apply to family members)
Maximum occupancy: 
  • 30% maximum occupancy of common areas and gross leasable areas
  • food and beverage outlets to reduce seating arrangements to 30% and maintain placing seating and tables minimum 6 foot apart
  • stores 
  • food and beverage outlets must hang red tags at the front door indicating the maximum number of customers allowed inside
  • the provision of buffet dining and shisha is prohibited
  • 75% of mall parking to remain closed
  • Other mall operations
  • entertainment and attractions to remain closed to restrict crowding and all public seating to be removed
  • prohibition on sales & promotional activities during stage 1 of reopening to avoid crowding within a store
  • suspension of valet parking during stage 1
Mall guidance to visitors: 
  • clear communication that visitors are allowed to visit for a maximum of 3 hours per visitor and that there is a cap on total visitors at any one time
  • visitors to maintain discipline and supervision of their children at all times
  • signage and notices should be placed at regular intervals with high visibility and clear instructions
  • Mall management/retailers – management encouraged:
  • to require retailers only to pay rental for lease areas based on a pro-rata charge for the number of hours the store remains open instead of a full day's rental 
  • not to increase rent for retailers who are to renew their lease
Ramadan – additional factors/rules:
  • the timing for the rule relaxation, during the Holy month of Ramadan, suggests that the authorities are potentially relying upon the fact that fewer people would visit food and beverage outlets during the daytime (due to fasting)
  • Dubai has a curfew in force from 10pm – 6am which limits traditional Ramadan festivities and movement during the night 
  • additional rules for Ramadan-related activities: 
  • Iftar and Suhoor gatherings to be restricted to family and close friends
  • physical contact to be prohibited
  • food donations should be made only through authorised charity bodies
  • sharing food outside of household is advised against
  • gatherings for prayers is prohibited and group prayers among immediate household members only is permitted
Initial reaction?
  • Most retailers opened up operations almost immediately with many customers attending stores
  • Compliance is being closely monitored:
  • Dubai Municipality conducts assessments before and after opening
  • on 26 April 2020 the Dubai Economic Department closed 21 establishments, gave out 65 warnings and issued 7 fines
  • Some individual chains are imposing additional rules such as the requirement to wear gloves at all times whilst visiting a store.
  • Whilst in-store promotions are prohibited, online promotions are permitted and many companies are offering big Ramadan online sales 
  • The effects of COVID-19 on international freight and passenger services has led to increased inbound e-commerce shipments -  Emirates Delivers, Emirates Skycargo's e-commerce delivery platform which consolidates purchases from multiple e-retailers overseas into a single package delivery in the UAE, experienced a 20% month-on-month rise in shipments
What next?
  • E-commerce: businesses are significantly shifting their traditional marketing strategies and sales to online audiences, a trend unlikely to be fully reversed, despite the prominence of the mall in Dubai society
  • Traditional Ramadan bazaars, which feature small businesses and local artisans selling their products during Ramadan, will be feeling the effects of reduced operating hours and social distancing rules - DP World has however launched an online platform, Manasah, giving traders the opportunity to sell their goods online during Ramadan – this may be short term workaround, but it might also transform and propel small specialist traders into the wider long-term e-commerce marketplace, following the Tmall model 

Key contact

Lowri Llwyd

Lowri Llwyd

Partner, Corporate Finance
Dubai

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