Transformation in the United Arab Emirates: Forefront of Digital Logistics and the Circular Economy
The Latin American Digital Transformation Center (CLTD) and the Strategic Alliance Estonia-UAE: Driving an Efficient, Transparent, and Sustainable Future for Waste Management. The future of global commerce, sustainability, and governmental efficiency in the Middle East is being built today, with the United Arab Emirates (UAE) as its primary operational headquarters.
1. The Critical Challenge: Digital Transformation for Waste Management and Logistics in the UAE
The United Arab Emirates stands at a critical inflection point. The nation generates approximately 21 million tonnes of municipal solid waste annually, with rapid growth driven by urbanization and consumption patterns. Despite being a global leader in innovation and sustainability vision, the UAE’s waste management and logistics sectors face systemic inefficiencies that directly contradict the country’s environmental commitments and development objectives.
We have identified two fundamental challenges that demand urgent, integrated solutions:
1. Inefficient Collection Systems and Operational Cost Recovery Mechanisms: The UAE faces a significant shortfall in efficient waste collection systems and cost recovery mechanisms. Current operations lack integrated digital systems for real-time tracking, route optimization, and transparent reporting. These gaps undermine financial sustainability, limit the investment capacity necessary for infrastructure modernization, and impede the transition from landfill dependency to integrated waste management and valorization across the emirates.
2. Environmental Risk and Landfill Dependency: Historical reliance on landfilling poses considerable threats to groundwater resources, air quality, and coastal ecosystems. This approach directly contradicts the commitments established under the UAE Circular Economy Policy 2021-2031 and Federal Law No. 12 of 2018, which set ambitious and binding national targets for waste reduction, material recovery, and environmental protection.
The Legal and Regulatory Mandate: Federal Law No. 12 of 2018 and Cabinet Resolution No. 39 of 2021
Our proposal is grounded in and designed to facilitate the effective implementation of the UAE’s comprehensive waste management legislative framework. Federal Law No. 12 of 2018 on Integrated Waste Management, aligned with the National Agenda for Integrated Waste Management (2023-2026) and UAE Vision 2050, establishes mandatory national targets that define the urgency and scope of required transformation:
- By 2031: Achieve 80% of municipal solid waste treatment through integrated management, recycling, and valorization; ensure 99% of hazardous waste treatment; achieve 80% of non-hazardous waste treatment; upgrade 90% of landfills to sanitary standards (Cabinet Resolution No. 39 of 2021).
- By 2050: Achieve full circular economy integration across all waste streams, supporting the UAE Net Zero 2050 Strategy decarbonization and resource efficiency objectives.
- Operational and Financial Transparency: Cabinet Resolution No. 39 of 2021 establishes the operational and technical standards for waste segregation at source, treatment processes, waste reduction hierarchies, and final disposal methods, requiring robust data management and real-time monitoring capabilities.
Recent Regulatory Momentum: EPR Pilot and Dubai Law No. 18 of 2024
The UAE regulatory environment has accelerated toward mandatory digital accountability and financial discipline:
- July 2025 EPR Pilot: The UAE launched its first Extended Producer Responsibility (EPR) pilot with 26 companies committing to producer accountability and real-time data sharing on waste collection, signaling a clear shift toward digital tracking and operational transparency.
- Dubai Law No. 18 of 2024: This law mandates GPS tracking on all waste vehicles and implements tiered, market-based pricing structures:
- Mixed waste: USD 27.23 per tonne
- Hazardous waste: USD 136.1 per tonne
- Recyclables: USD 8.17 per tonne
Non-compliance penalties reach AED 500,000, enforcing strict adherence to waste reduction targets and landfill closure by 2027.
These developments demonstrate the UAE’s firm commitment to digital transformation, real-time accountability, and financial mechanisms that incentivize waste reduction and circular economy development.
2. The Integrated Digital Solution: GovTech Platform and eFTI Implementation
The CLTD proposes a comprehensive, two-pillar GovTech (Technology for Government) solution designed to address both waste management inefficiencies and broader logistics digitalization challenges:
Pillar 1: Digital Waste Management Platform
Pillar 2: Electronic Freight Transport Information (eFTI) Law and Implementation
This integrated approach leverages proven European technological leadership—particularly from Estonia and the European Union—adapted and localized for full compliance with UAE federal law and emirate-level regulations. The solution ensures transparency, efficiency, security, and accountability across the entire waste and logistics value chain.
Pillar 1: Digital Waste Management Platform for the Circular Economy
We propose a comprehensive digital system deployed first in Ajman (for local regulatory presence and operational integration) and Dubai (for scaling and validating solutions within a major urban hub), with nationwide rollout to follow.
Key Operational Components of the Platform:
| Component | Operational Function | Regulatory and Strategic Alignment |
|---|---|---|
| Tracking and Monitoring (Real-Time Visibility) | Real-time digital platforms for tracking waste flows from source to final treatment facility, monitoring recycling rates, measuring treatment efficiency, and reporting operational metrics to regulatory authorities. | Directly fulfills Federal Law No. 12 of 2018 reporting requirements and Cabinet Resolution No. 39 of 2021 operational and monitoring standards for waste management entities. |
| Logistics Optimization (Route Efficiency) | Route-optimization algorithms utilizing Big Data and Geographic Information Systems (GIS) to reduce collection inefficiencies, minimize unnecessary collection trips, optimize vehicle utilization, and reduce operational fuel consumption and carbon footprint. | Supports UAE Net Zero 2050 Strategy decarbonization objectives and reduces operational costs for waste management service providers and municipalities. |
| Intelligent Monitoring (IoT Infrastructure) | Smart monitoring systems deployed on waste collection vehicles and treatment facilities for real-time data collection, operational visibility, performance measurement, and predictive maintenance capabilities. | Enables data-driven governance and evidence-based policy implementation as required by Cabinet Resolution No. 39 of 2021. |
| Service-User Linkage and Transparent Billing | Digital connection between waste service providers and end-users (citizens, businesses, institutions), enabling transparent billing linked to actual waste generation and service delivery, accurate cost allocation, and service accountability. | Supports the financial sustainability and operational accountability principles established in Federal Law No. 12 of 2018 and aligns with Dubai Law No. 18 of 2024 market-based pricing mechanisms. |
| Circular Economy Platform | Digital marketplace connecting waste generators, formal recyclers, and secondary raw material users, enabling material recovery, waste valorization, and the development of sustainable waste-based industries. | Directly advances the UAE Circular Economy Policy 2021-2031 objectives and promotes the creation of measurable economic value from waste streams as mandated by Federal Law No. 12 of 2018. |
| Citizen Engagement and Transparency | Mobile applications and digital interfaces enabling citizens and businesses to participate in waste segregation, access service information, monitor environmental contributions, and interact with waste management authorities. | Promotes inclusive participation in environmental stewardship and supports the social inclusion objectives of UAE Vision 2050. |
Projected Impact of the Waste Management Platform:
| Impact Area | Key Performance Indicator | Projected Target (Pilot Phase: Ajman & Dubai) |
|---|---|---|
| Operational Efficiency | Improvement in waste collection efficiency through optimized routing and reduced operational costs. | 30% to 50% improvement in collection efficiency within the pilot areas, translating to enhanced municipal revenues and accelerated infrastructure investment. |
| Digital Integration | Volume of waste digitally tracked and managed through the integrated platform. | 80% to 90% of waste streams within pilot areas digitally managed within 24-36 months of implementation. |
| Circular Economy Development | Increase in waste recycling, material recovery, and waste-to-value valorization rates. | 15% to 25% increase in recycling and material recovery within pilot areas, creating new waste-based industries. |
| Environmental Impact | Contribution to landfill reduction and achievement of integrated waste management standards. | Direct support toward the 2031 targets in Federal Law No. 12 of 2018 (80% waste treatment, 90% landfill upgrades) and ultimate landfill closure goal by 2027 established in Dubai Law No. 18 of 2024. |
| Carbon Footprint Reduction | Measurable reduction in greenhouse gas emissions from waste logistics and collection operations. | Quantifiable contribution to UAE Net Zero 2050 Strategy decarbonization targets through optimized routing and reduced operational emissions. |
| Social Inclusion | Formalization and digital integration of informal waste collection actors into the formal circular economy value chain. | 500 to 1,500 informal waste workers integrated into formal sector with digital training, certification, and structured economic participation. |
Pillar 2: UAE Law on Electronic Freight Transport Information (eFTI) — Modernizing Logistics Infrastructure
The Current Logistics Challenge in the UAE
Beyond waste management, the UAE faces a critical logistics sector bottleneck that impedes operational efficiency across all freight and waste transport operations:
- Regulatory Fragmentation: The UAE regulatory framework still operates with mixed paper-based and partially digitized processes, lacking a unified mandatory standard for electronic transport information.
- Operational Inefficiency: This fragmentation affects waste logistics (including hazardous waste transport), general freight movement, customs efficiency, supply chain transparency, and the UAE’s ability to optimize its position as a regional trade hub.
- Compliance Burden: The absence of a single mandatory electronic transport document perpetuates operational inefficiencies, increases administrative burden on businesses, and limits real-time data-driven governance visibility for authorities.
Our Initiative: Proposal for the UAE eFTI Law
We propose the development and implementation of a UAE Law on Electronic Freight Transport Information (eFTI) aligned with EU Regulation 2020/1056, leveraging the proven expertise of Estonia and the European Union as global leaders in digital government and logistics transformation.
Objectives of the UAE eFTI Law:
| Objective | Description | Benefit to UAE Stakeholders |
|---|---|---|
| 1. Single Mandatory Electronic Transport Document | Establish a uniform electronic transport document (equivalent to a digital consignment note) applicable to all modes of transport—road, sea, air, rail—nationwide across all emirates. | Universal interoperability; simplified customs procedures; reduced administrative burden on businesses; enhanced compliance enforcement. |
| 2. Data Standardization | Define comprehensive, interoperable electronic transport data sets covering all regulatory information required by customs, environmental compliance authorities, safety bodies, and other competent agencies. | Real-time data accessibility; improved customs efficiency; enhanced tracking of hazardous and non-hazardous waste; reduced inspection times. |
| 3. Real-Time Access for Authorities | Ensure direct, real-time access for all competent authorities (customs, MOCCAE, traffic police, environmental compliance bodies) to standardized transport information and compliance data. | Enhanced governance transparency; faster issue resolution; improved supply chain security; better environmental compliance monitoring. |
| 4. Regional and International Interoperability | Enable seamless integration with regional and international logistics platforms and trade partners, supporting the UAE’s role as a world-class regional and global trade hub. | Consolidates the UAE’s position as a leading international logistics center; supports We the UAE 2031 economic competitiveness goals; reduces transaction costs for international trade. |
Implementation Strategy: Phased Rollout
The eFTI Law implementation will follow a structured, risk-managed phased approach:
- Phase 1 (Pilot): Ajman — Proof of concept and local validation of systems integration, aligned with the waste management platform pilot.
- Phase 2 (Scaling): Dubai — Expansion and optimization within a major urban and logistics hub, validating cross-emirate data interoperability.
- Phase 3 (Nationwide Rollout): Implementation across all emirates, establishing the UAE as a fully digitalized logistics and trade environment.
3. Strategic Governance Framework and Public-Private Partnership Model
The implementation of these integrated initiatives operates under a GovTech governance model, establishing close collaboration with federal and emirate-level authorities to ensure regulatory alignment, operational sustainability, and long-term scalability.
Core Government Partners and Stakeholders:
The CLTD aims to secure a partnership with the following government authorities:
- Ministry of Industry and Advanced Technology (MoIAT): Digital transformation coordination, innovation governance, industrial competitiveness objectives, and alignment with the Operation 300bn industrial modernization strategy.
- Emirate-Level Waste Authorities: Localized implementation partnerships including Dubai Municipality, Abu Dhabi’s TADWEER (Integrated Waste Management Centre), Sharjah’s Bee’ah, and Ajman Municipality for pilot execution and operational integration.
The Latin American Digital Transformation Center (CLTD): Implementation Vehicle
- Direct engagement with government regulatory bodies (MOCCAE, MoIAT) for policy alignment and compliance oversight.
- Structured partnerships with private sector waste management operators, logistics companies, and technology providers.
- Transparent financial management of project resources and accountability mechanisms.
- Flexibility in technology deployment and operational optimization as systems mature.
International Technical Partnership: The Solomon Brokerage Firm
The CLTD is supported by a strategic international technical partnership combining regional expertise and European technological leadership:
| Partner Organization | Location | Core Expertise and Contribution |
|---|---|---|
| The Solomon Brokerage Firm | Tallinn, Estonia | European technological leadership in digital government and advanced logistics digitalization. Extensive experience implementing European Commission standards, including EU Regulation 2020/1056 (eFTI) implementation, and proven track record in developing compliance strategies for waste and logistics digitalization across complex regulatory environments. Broad engagement in regional digital transformation projects and educational program development. |
4. Financial Framework and Long-Term Sustainability
The successful execution of these integrated initiatives requires a robust, transparent, and strategically structured financial approach.
A. Overall Financial Strategy
Our approach is built on public-private collaboration under a GovTech governance model, with strategic positioning to the Ministry of Climate Change and Environment (MOCCAE) and Ministry of Industry and Advanced Technology (MoIAT). The success of this model is based on articulation with key partners, including Emirate-level waste authorities (Dubai Municipality, Abu Dhabi’s TADWEER, Sharjah’s Bee’ah, Ajman Municipality), as well as the broader federal and emirate governments.
Investment Attraction and Human Capital Development
- Investment: The CLTD structure is conceived as a Special Purpose Vehicle (SPV) or Public-Private Partnership, facilitating the attraction of venture capital and institutional investment. We are actively seeking cofinancing with Abu Dhabi Fund for Development or UAE Development Bank for concessional financing, with an estimated total project investment of US$2,000,000. Additionally, financing mechanisms for waste management infrastructure and digital transformation are leveraged under Federal Law No. 12 of 2018.
- Regulation: In parallel, we are proposing a UAE Law for eFTI Implementation, which seeks to harmonize the UAE legal framework with EU Regulation 2020/1056 standards, strengthening alignment with international logistics and customs best practices while supporting the UAE 2031 economic competitiveness objectives.
- Training and Capacity Building: We address the need to invest in specialized workers through the development of digital training and certification programs via a Learning Management System (LMS) with European-quality content, ensuring technical workforce development across the waste and logistics sectors.
The CLTD’s vision is to lay the foundation for the digital and financial transformation of the waste and logistics sectors in the UAE, building a new industry architecture based on efficiency, transparency, sustainability, and international competitiveness, while positioning the UAE as a regional model and knowledge hub for the Middle East.
B. Long-Term Financial Sustainability
The project is fundamentally designed to be self-sustaining through multiple revenue and efficiency mechanisms:
- Operational Revenue Optimization: Enhanced operational efficiency from the digital waste management platform is projected to deliver a 30% to 50% improvement in collection efficiency and waste service delivery. This directly translates to increased municipal and emirate revenues from waste management fees and service recovery, as established in Cabinet Resolution No. 39 of 2021 financial frameworks.
- Cost Efficiencies: Route optimization, reduced administrative overhead, predictive maintenance of equipment, and elimination of redundant collection trips are projected to deliver 10% to 20% reduction in operational costs for waste management service providers, creating financial surplus for reinvestment.
- Legal Funding Mechanisms: Cabinet Resolution No. 39 of 2021 establishes operational and financial frameworks enabling waste management entities to manage dedicated revenue streams and establish sustainable financing mechanisms. The digital platform enables transparent tracking of these revenues and compliance with financial accountability requirements.
- Circular Economy Value Creation: The digital circular economy platform enables the development of waste-to-value industries (material recovery, recycling, co-processing), creating measurable economic value from waste streams and generating new revenue streams from waste valorization as contemplated in Federal Law No. 12 of 2018.
C. Public-Private Trust for Integrated Solid Waste Management
A dedicated governance entity will serve as the implementation and ongoing financial management mechanism, operating under the authority of Federal Law No. 12 of 2018 and Cabinet Resolution No. 39 of 2021. This entity ensures:
- Transparent financial management and accountability to government authorities and development partners.
- Structured revenue allocation: cost recovery for operational expenses, reinvestment in system improvement and expansion, and contingency reserves.
- Compliance with federal and emirate-level regulatory requirements for waste management financing and reporting.
- Clear mechanisms for benefit-sharing between government, private operators, and development partners.
D. Additional Financing Opportunities
- Green Climate Fund (GCF): Eligibility for climate adaptation and mitigation financing, particularly for waste reduction, landfill closure, and greenhouse gas emissions reduction components aligned with UAE Net Zero 2050 Strategy.
- UAE Development Bank Sustainable Infrastructure Financing: Concessional long-term financing for infrastructure development and digital transformation supporting environmental and development objectives.
- Regional Development Partnerships: Alignment with multilateral development bank priorities for circular economy scaling and inclusive development in the Middle East region.
5. Transformative Impact: Tangible Benefits Across Multiple Dimensions
Environmental Impact and Climate Commitment
- Carbon Footprint Reduction: Measurable reduction in greenhouse gas emissions and carbon footprint from waste collection logistics and operations through optimized routing, reduced vehicle utilization, and transition from landfill-based waste disposal to integrated waste treatment and material recovery.
- Landfill Reduction and Closure: Direct contribution to the elimination of open-air landfills and transition to sanitary landfill standards (90% upgrade target) and ultimate landfill closure by 2027 as established in Dubai Law No. 18 of 2024 and Federal Law No. 12 of 2018.
- Material Recovery and Resource Protection: Promotion of material recovery and waste valorization reduces extraction of virgin materials, protects natural resources, and decreases landfill dependency, supporting UAE Circular Economy Policy 2021-2031 objectives and UAE Net Zero 2050 Strategy decarbonization targets.
- Ecosystem Protection: Improved waste management practices and reduced landfilling directly protect groundwater resources, air quality, and coastal ecosystems from contamination and environmental degradation.
Economic Impact and Industrial Development
- Creation of Waste-Based Industry: The digital circular economy platform enables the emergence of new industries centered on material recovery, waste valorization, and secondary raw material markets, creating measurable economic value from waste streams.
- Municipal Revenue Optimization: Improved collection efficiency (30-50%) and transparent billing directly increase municipal and emirate revenues from waste management services, creating financial resources for infrastructure modernization and service improvement.
- Operational Cost Reduction: Private sector waste operators benefit from 10-20% operational cost reductions through route optimization, predictive maintenance, and reduced administrative burden, improving business profitability and competitiveness.
- Green Jobs and Technical Capacity: The transition to digital waste management and circular economy infrastructure creates skilled employment opportunities in technology deployment, data analytics, waste processing, and material recovery operations.
- Industrial Competitiveness: Implementation of the eFTI Law and digital logistics infrastructure boosts national industry competitiveness through efficient, sustainable logistics aligned with MoIAT’s Operation 300bn industrial modernization strategy, reducing supply chain costs and improving delivery timelines.
Social Impact and Inclusive Development
- Improvement of Public Services: Citizens and businesses experience improved waste management service quality, transparency, and responsiveness through digital platforms, real-time service tracking, and direct engagement channels.
- Enhanced Transparency and Accountability: Real-time data visibility and digital reporting mechanisms enable transparent governance, evidence-based policy implementation, and accountability of public and private sector actors in waste management.
- Social Inclusion and Formalization: The digital circular economy platform creates structured opportunities for informal waste collection actors (estimated 500-1,500 workers) to integrate into the formal economy with training, certification, and formal economic participation, enhancing social inclusion and dignity of work.
- Citizen Participation in Sustainability: Mobile applications and digital engagement platforms enable citizens and businesses to participate actively in waste segregation, environmental stewardship, and circular economy participation, building a culture of sustainability.
Logistical and Trade Impact
- Consolidation as Regional Logistics Hub: Implementation of the eFTI Law establishes the UAE as a world-class regional logistics hub with robust, transparent digital infrastructure harmonized with EU standards and international best practices, attracting regional and international logistics operators and service providers.
- Enhanced Supply Chain Security and Traceability: Real-time digital tracking and standardized data elements improve security, traceability, and transparency in the transport of goods and hazardous waste across the UAE and regional supply chains.
- Customs Efficiency and Trade Facilitation: Digitized import/export procedures and mandatory electronic transport documentation reduce customs processing times, lower transaction costs for businesses, and improve the UAE’s Logistics Performance Index (LPI).
- International Trade Competitiveness: Full interoperability with European and international logistics standards positions UAE companies and operators for seamless participation in global supply chains and enhanced competitiveness in international trade.
Strategic Positioning and Regional Leadership
- UAE as Digital and Environmental Transformation Leader: Successful implementation positions the UAE as a regional and global demonstrator of integrated digital transformation for circular economy development and logistics modernization, attracting international recognition, partnerships, and investment.
- Replicability Across the Middle East: The model is designed to be scalable nationwide (all emirates) and replicable across other Middle Eastern countries facing similar waste management and logistics challenges, positioning the UAE as a knowledge hub and regional leader in sustainable development.
- Support for UAE Vision 2050 and We the UAE 2031: Direct contribution to long-term national development objectives for economic competitiveness, environmental sustainability, and digital leadership.
6. Implementation Roadmap and Timeline
The successful execution of this integrated transformation requires a carefully structured, phased implementation approach:
Phase 1: Foundation and Pilot Development (Months 1-6)
- Stakeholder engagement and formal partnership agreements with MOCCAE, MoIAT, Ajman Municipality, and Dubai Municipality.
- Detailed technical design and localization of the digital waste management platform for Ajman pilot area.
- Development of eFTI legislative proposal and regulatory consultation with federal authorities.
- Recruitment and training of project management and technical implementation teams.
- Procurement and deployment of IoT monitoring infrastructure and digital platform software.
Phase 2: Pilot Implementation and Validation (Months 7-18)
- Launch of waste management digital platform in Ajman with selected waste operators and municipalities.
- Deployment of real-time tracking, route optimization, and billing systems; testing of circular economy marketplace features.
- eFTI Law development and stakeholder consultation; presentation to federal and emirate authorities.
- Monitoring, measurement, and continuous improvement of platform functionality based on real-world operational feedback.
- Documentation of lessons learned and optimization recommendations for Dubai scaling phase.
Phase 3: Scaling and Regional Expansion (Months 19-36)
- Launch and expansion of the digital waste management platform in Dubai, incorporating optimization insights from Ajman pilot.
- Integration of eFTI Law implementation in Ajman and Dubai pilots; phased rollout to other emirates.
- Validation of operational efficiency gains, cost savings, and environmental impact metrics.
- Development of training programs and certification standards for waste management personnel and logistics professionals.
- Engagement with development partners and private sector stakeholders for expansion financing and operational scaling.
Phase 4: Nationwide Integration and Sustainability (Months 37+)
- Nationwide rollout of digital waste management platform across all emirates with localized adaptation.
- Full implementation of the UAE eFTI Law across all emirates and all transport modes.
- Establishment of permanent governance structures (Public-Private Trust for Integrated Solid Waste Management) for long-term operation and financial management.
- Integration with regional and international logistics networks; scaling of circular economy industries.
- Continuous monitoring, performance measurement, and reporting to federal and emirate authorities.
7. Alignment with UAE Strategic Priorities
This integrated proposal directly supports and advances multiple critical UAE national and developmental priorities:
| UAE Strategic Initiative | Alignment and Contribution | ||||||
|---|---|---|---|---|---|---|---|
| UAE Vision 2050 | Direct contribution to sustainable development, environmental protection, and economic competitiveness objectives through digital transformation of critical infrastructure sectors (waste management and logistics). | ||||||
| UAE Net Zero 2050 Strategy | Measurable reduction in greenhouse gas emissions from waste and logistics sectors; transition from landfill dependency to integrated waste treatment and material recovery; support for decarbonization targets across the economy. | ||||||
| UAE Circular Economy Policy 2021-2031 | Direct advancement of waste reduction, material recovery, waste valorization, and circular economy industry development; creation of measurable economic value from waste streams. | ||||||
| Federal Law No. 12 of 2018 and Cabinet Resolution No. 39 of 2021 | Facilitation of effective implementation of mandatory waste management targets (80% treatment by 2031, 90% landfill upgrades, 99% hazardous waste treatment); provision of digital infrastructure for compliance monitoring and reporting. | ||||||
| Operation 300bn (MoIAT Industrial Modernization) | Boost to national industrial competitiveness through digital logistics infrastructure, supply chain optimization, and reduced operational costs for manufacturing and trade sectors. | ||||||
| We the UAE 2031 Economic Competitiveness Goals | Consolidation of the UAE as a world-class regional logistics hub; enhancement of customs efficiency and trade facilitation; development of new waste-based industries and circular economy value chains. |
| Organization | Location | Contact Details |
|---|---|---|
| The Solomon Brokerage Firm | Tallinn, Estonia | Email: info@solomonbrokerage.com Phone: +372 5332 9390 Website: www.solomonbrokerage.com |
© 2026 The Solomon Brokerage Firm (Estonia). All Rights Reserved.
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