Middle East conflict and the Strait of Hormuz: Impacts on foreign trade

The Middle East conflict does not automatically change Brazilian customs legislation. For importers and exporters, the most immediate impacts tend to occur in day-to-day operations, including increased logistical risk, pressure on freight and insurance costs, greater volatility in energy costs, and tighter compliance controls by banks, insurers, shipowners, and other supply chain stakeholders.

The issue has gained even greater relevance following official international reports of incidents involving merchant vessels in the Strait of Hormuz, including casualties and formal navigation warnings. The region remains one of the world's main energy corridors and continues to be strategic for the global flow of oil and liquefied natural gas. At the same time, the Middle East remains relevant for sectors within Brazil's export portfolio, especially agribusiness.

In Brazil, the main legal framework remains

Law Nº 13.810/2019

, regulated by

Decree Nº 9.825/2019

, which addresses compliance with sanctions arising from United Nations Security Council resolutions.

In practice, however, companies' analysis should not be limited to the legal text alone. In crisis scenarios, risks should be assessed across three fronts: sanctions with effects in Brazil, administrative control and permitting rules, and private or operational restrictions imposed by banks, insurers, shipowners, trading companies, and payment platforms.

Although the conflict does not automatically trigger changes in Brazilian customs rules, it increases the impact of existing operational failures. In a more unstable geopolitical environment, errors in tariff classification, customs parameterization, or licensing tend to generate even higher costs.

In this context,

Portal Único Siscomex

remains the main reference for administrative treatment, LPCO requirements, permitting authorities, and other operational parameters. In the oil, petroleum products, and biofuels sectors, attention should be even greater, since

ANP

acts as the permitting authority in the administrative stages of imports and exports involving these products.

Increased maritime risk may lead carriers and insurers to review premiums, cargo acceptance criteria, documentary requirements, and route planning, resulting in higher costs and less predictable lead times.

In addition, volatility in energy prices may put pressure on freight, warehousing, inland transportation, industrial costs, and export pricing. Transactions involving oil, petroleum products, gas, and biofuels require additional attention regarding tariff classification, origin, supplier, administrative treatment, and regulatory requirements.

Even when a transaction is permitted in Brazil, it may still face barriers in the international financial and maritime system. For this reason, due diligence should cover not only the buyer and seller, but also the vessel, logistics operator, insurer, financial intermediaries, and other related parties.

The main message for Brazilian foreign trade is clear: the focus should not be on the expectation of an immediate regulatory change, but on strengthening operational risk management.

In practice, this includes reviewing exposure to countries, ports, and routes connected to the Gulf, confirming insurance coverage — including war risk coverage — revalidating shipowners, banks, and other counterparties, checking consistency among NCM, LPCO, DUIMP or DU-E, and the corresponding permitting authority, as well as reviewing contractual clauses related to deadlines, force majeure, route changes, and extraordinary costs.

The Middle East conflict and the risks in the Strait of Hormuz reinforce the need for a more preventive approach to foreign trade. Even without immediate changes to Brazilian customs legislation, the operational impacts may be significant and require a rapid response from companies.

Strengthening governance, compliance, and risk management is essential to reduce exposure, preserve operational continuity, and support safer decision-making.

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