Tariffs, state export control and Hormuz converge: ASEAN operators face a hard October

US tariff regime resets for ASEAN exporters

The 90-day US reciprocal tariff pause has expired, per USTR Federal Register notice (verified 18 August). The suspended rates were Vietnam 46%, Indonesia 32%, Thailand 36% and Cambodia 49%, and bilateral deals remain incomplete for most ASEAN markets. Separately, a 10% Section 122 global surcharge takes full effect for all companies on 29 September 2026, replacing the IEEPA-based regime, per Zonos US Import Tariff Tracker (11 September).

Decision: have finance and customs teams re-cost every US-bound SKU under the new structure and confirm importer-of-record compliance. Inference: because the surcharge applies to nearly all US trading partners, origin-based arbitrage within ASEAN may narrow, so pricing and sourcing reviews should start now.

10% Section 122 global tariff surcharge, effective 29 September

Indonesia moves strategic commodity exports to a state entity

Government Regulation 24/2026 restricts exports of coal, palm oil and ferroalloys to a designated SOE entity (DSI) acting as owner or sole intermediary, displacing foreign-held export-facing roles, per HLC Publications (29 August). President Prabowo told parliament on 20 May that the entity would also hold export price-setting authority by September 2026, per Indonesia's Export Control Plan analysis (24 July). That analysis flags risk to Japan and Korea long-term supply contracts.

Decision: foreign companies with direct export contracts should map which contracts need restructuring and open talks with DSI now. Buyers in Japan and Korea should stress-test alternative supply. Inference: price-setting by the state entity could change contract economics, so review pricing clauses first.

Hormuz closure keeps energy costs and supply risk elevated

Iranian forces declared the Strait of Hormuz closed from 4 March 2026, with at least 17 merchant ships damaged, and a US-led naval escort operation continues, per Congress.gov / Library of Congress (31 August). Saudi Aramco reported Q2 hydrocarbon output of 9.5 mmboed, down from 12.780 mmboed a year earlier, with crude at $108 per barrel, per Energies Media (19 August).

Decision: energy-intensive operators should lock in fuel and feedstock cover and test budgets against sustained triple-digit crude. Inference: with output this far down, supply tightness is unlikely to ease quickly, so contingency sourcing deserves board attention.

$108/bbl Crude price cited in Aramco Q2 2026 results

Steel diversion and rare earth deadline shape manufacturing

China exported over 131 million tonnes of steel in 2025, up 13.8% from 115 million, with ASEAN receiving a disproportionate share, per the OECD Steel Outlook 2026 (verified 28 August). China's pause on rare earth and graphite export controls lapses on 10 November 2026, per Council on Foreign Relations / Coface (9 September). Indonesia's 100 GW solar programme groundbreaking is imminent, per Indonesia Business Post (5 August).

Decision: local steel producers should prepare trade-remedy evidence, and manufacturers using magnets or graphite anodes should secure inventory before 10 November. Inference: the solar build-out may lift demand for materials and equipment, which makes supply security more valuable.

131 MMT China steel exports in 2025, up 13.8%

Halal and EU rules set the compliance calendar for consumer and agri exporters

Indonesia's halal mandate for imported goods starts in mid-October. Sources differ on the date: 17 October per Ilomata International Journal (16 September) and 18 October per ANTARA News (18 September) and Emerhub (3 September). ANTARA reports the Trade Minister said imported goods can still enter ahead of the phase. On the EU side, EUDR applies from 30 December 2026 for large and medium operators, per Regulation (EU) 2025/2650 (21 September), and CS3D transposition was due 26 July, per EU Directive 2024/1760 (12 August).

Decision: treat 17 October as the working deadline, confirm BPJPH-recognized certification for every affected SKU, and begin EUDR digital due diligence for palm derivatives. Inference: EU buyers will likely ask ASEAN suppliers for audit evidence early.

30 Dec 2026 EUDR start for large and medium operators

Rates, sanctions and logistics rules add cost and timing risk

The Fed meets 15 to 16 September after a 9-3 July vote to hold at 3.50%-3.75%, per FedRateCalc (9 September). CME FedWatch showed a 58.6% hold probability, and hawkish Jackson Hole remarks widened US-Asia rate differentials, per CME FedWatch (3 September). Treasury suspended five Iran-related general licenses from 8 September, per Orrick (7 September). EU states must collect a per-parcel fee on distance-sale consignments by 1 November, per Consilium (9 September), and COSCO resumed Red Sea transits on 28 July, per Linerlytica / The Loadstar (13 August).

Decision: hedge near-term dollar exposure, screen Gulf-linked payments, and price the EU parcel fee into e-commerce margins. Inference: COSCO's return suggests Red Sea routing is reopening, so test it as an option against current routes.

1 Nov 2026 Latest start for EU per-parcel handling fee