Importing motor oils and greases into Iraq needs Ministry of Oil approval, because they sit inside the petroleum products statute rather than alongside the parts they are sold with. The same statute requires an importer to hold its own storage and bars one company from handling both imported and locally produced product. Parts run a different route entirely. We establish which of your lines sits where before anyone is shortlisted.
The demand side has one solid official number behind it. The statistics authority recorded 8,287,604 registered private-sector vehicles at the end of 2024, across all governorates including the Kurdistan Region, up from 7.03 million in 2020. There is no published age or model-year distribution, so anyone quoting you an average vehicle age for Iraq is estimating. What the import rules tell us is that the mix is being pushed newer: Kurdish import rules restrict entry to the three most recent model years, and the federal authority has seized vehicles below a permitted model year.
The supply side is where the structure bites, and it bites in two different places. Replacement parts run the general import route. Motor oils and greases do not: they sit inside the petroleum products law of 2006, which covers them by name alongside fuels, requires Ministry of Oil approval to import, obliges an importer to build its own stations and warehouses, and prohibits one company from storing and selling both imported and locally produced product. The penalties are not nominal — between a hundred and three hundred million dinars for unlicensed or non-compliant import, and five hundred million for mixing.
That statute reads as if it was written for bulk fuel, and whether its full weight falls on a pallet of packaged engine oil for retail sale is a question we could not resolve from the text. For a lubricants brand that answer shapes everything, so it goes to the ministry for the specific product rather than to our own reasoning our way to one.
Everything else runs through one licence. A foreign company may bring goods into Iraq for trade only through its registered commercial agent, within that agent’s area, and the agent must be Iraqi with a corporate agent wholly Iraqi-owned. That is not a formality to be arranged later; it is the thing that makes importing lawful.
Both halves then pass through the same gate, and it is a licensing one. Under the 2017 commercial agency law a foreign company may bring goods into Iraq for trade only through its registered agent, and only within that agent’s area. The agent must be Iraqi; a corporate agent’s capital must be wholly Iraqi-owned; the agreement must come from the manufacturer or from a company formally authorised to grant sub-agencies, so there is no more than one link in the chain. Acting as an agent without a licence carries a fifteen million dinar penalty, and the licence is renewed in the first sixty days of each year.
Conformity is where the published record and the market disagree, and the useful thing is to report that rather than pick a side. The inspection companies appointed to run Iraq’s pre-shipment programme list vehicle parts, tyres and lubricants among the goods needing a certificate. Every regulated-product list we could actually obtain — four editions of it — covers food, and in one case cosmetics and paints, and contains none of those categories. The Kurdish programme is explicit that parts, tyres, batteries and oils are in scope, but its published scope dates from 2014. Get your own codes confirmed; do not take a category-level answer from anyone, including us.
The agency statute is unusually specific and worth reading before any meeting. The agent must be an Iraqi national with a commercial office in Iraq, chamber of commerce membership, a trade name, no disqualifying conviction, and at least one certified agency contract; a company agent must have capital entirely owned by Iraqis. The contract has to come from the manufacturer, or from the company formally authorised to grant sub-agencies, so a regional master distributor usually cannot sit in the middle. The licence is renewed in the first sixty days of each year, and acting without one carries a fifteen million dinar penalty.
Two provisions people miss. The agent must keep a special book of profits, commissions and transfers to Iraq, registered and sealed page by page and presented to the tax authority at each year end, and the Ministry of Trade sends each licensed agent’s commission statements to the tax commission — so your commercial terms are visible to the Iraqi revenue by design. And an agency contract can be deregistered where the foreign principal is blacklisted for breaching its obligations to Iraq, a principal-side risk with no published criteria behind it.
On conformity the record is genuinely contradictory, and a page that smoothed that over would be doing you a disservice. The inspection companies appointed to the pre-shipment programme advertise vehicle parts, tyres and lubricants as regulated. The four published regulated-product lists we obtained, the most recent covering 607 goods, are food lists. The Kurdish programme is explicit that parts, tyres, batteries and automotive oils are in scope, and that used vehicle spare parts are prohibited outright — but that document was issued in 2014. The resolution is to get your own customs codes checked, and to treat how a candidate answers that question as part of the assessment.
Each of these is a document or a named approval. The oils list and the parts list diverge early, which is why a single appointment across both halves of a range is worth examining rather than assuming.
Each is a document to request or a fact to establish. Several concern your own position rather than the candidate’s competence.
Work out which of your lines fall inside the petroleum products regime and which do not. Oils and greases need ministry approval and bring structural obligations on the importer; parts do not. A candidate that is excellent on one side may not be licensed for the other, and a single national appointment can quietly leave half your range without a lawful route in.
The statute covers motor oils and greases by name but reads as drafted for bulk fuel. Whether its storage and separation obligations apply in full to packaged retail lubricant is the question that decides the shape of the business. Put it to the ministry for your specific product rather than accepting a distributor’s account of its own licensing.
Ask for the licence and the registered contract. Check the area it covers, because the statute limits importation to the agent’s own area. Note when the sixty-day renewal window falls: a lapse is not an administrative problem, it is the loss of the right to import.
The contract must come from the manufacturer or from a company formally authorised to grant sub-agencies, with no more than one link. If your Iraqi arrangement sits under a regional distributor, establish whether it can be registered at all.
Do not accept that parts or oils are, or are not, in the pre-shipment programme. The appointed bodies and the published lists disagree. Ask for the entry on the current list, by code, and watch how readily it is produced.
Baghdad registration covers the country for ownership, but enforcement in the Kurdistan Region needs a separate Kurdish registration, and there is no customs recordal to lean on. Counterfeiting is described as widespread. Registering before appointing is the cheapest protection in this market.
Automotive duty moved to 15% with the new tariff schedule applied from January 2026, hybrid exemptions were revoked, and the dinar was devalued in October. Any landed-cost model older than this year is describing a different market.
Ask which bank, which correspondent, and whether dollar access has been restricted. Domestic transactions must be in dinars, so your distributor collects in a currency it cannot pay you in, and the customs system it clears through is the same one that governs its access to official-rate dollars.
One appointment, one contract, and half the range turns out to need an approval from a different ministry and a structure the distributor does not have. The penalties for getting this wrong run into hundreds of millions of dinars, and they fall on the importer whose name is on the entry.
The agency licence is renewed inside a sixty-day window each year. Miss it and the right to import goods for trade goes with it. From your side it looks like an unexplained supply stop.
Unregistered, it is not recognised by Iraqi courts or authorities, so neither party can enforce it. Firms trade for years on paperwork that would not survive first contact with a dispute.
In one week of February 2026 the customs authority reported seizing ninety vehicle-loads of goods non-compliant with controls, among them oils; in April 2025 it seized four trucks of goods banned from import, among them batteries. Neither statement says counterfeit. Non-compliant and banned are enough.
Ownership follows registration, there is no customs recordal, and seizure requires a court order on your information. A principal that appoints before registering its own marks has handed the option to someone else, and will then need a separate Kurdish registration to do anything about it in the Region.
A federal agency registration and a Kurdish one are different things, the conformity programmes are different, and goods lawfully imported into the Region have been seized moving south. Whether the Region still applies the earlier agency law is itself contested — the claim rests on one secondary source and sits in tension with the repeal provision of the 2017 statute.
Yes. The import permit requirements published by the trade ministry name motor oils and lubricating greases as needing Ministry of Oil approval, and the 2006 petroleum products law covers motor oils and greases of all kinds by name. That law also obliges an importer to build its own stations and warehouses and bars a single company from storing and selling both imported and locally produced product, with penalties from a hundred to three hundred million dinars for unlicensed import and five hundred million for mixing.
That is exactly the question we would want answered in writing before you commit. The statute is explicit about its obligations and equally clearly drafted with bulk fuel in mind. We could not resolve from the text whether the full weight applies to packaged retail lubricant. For a lubricants brand the answer changes the business model, so it goes to the ministry for your specific product, not to a consultant’s summary.
The honest answer is that the record contradicts itself. The inspection companies appointed to run the programme advertise vehicle spare parts, tyres and lubricants as regulated. Every published regulated-product list we obtained, across four editions, is a food list. The Kurdistan programme is explicit that parts, tyres, batteries and automotive oils are covered and that used spare parts are prohibited, but that document was issued in 2014. Check your own customs codes against the current list rather than relying on any general statement.
Be careful with this. The agency statute limits a registered agent’s importation to its own area, the Kurdistan Region operates separate conformity and company registration, and goods lawfully imported into the Region have been seized moving into federal governorates. Whether the Region still applies the earlier agency law is contested. Plan it as two markets and be pleasantly surprised rather than the reverse.
The law says a principal may not terminate or decline to renew without justifying cause, and it prescribes no remedy for breach of that — there is no compensation formula anywhere in the statute. The rules have been described as untested and we found no reported Iraqi judgment applying them. There is also a deregistration route where the parties agree without prejudice to either, and a ninety-day mechanism after the registrar notifies the agent that the term has expired.
Materially. A new tariff schedule applied from 1 January 2026 across the federal crossings, with automotive duty at 15% and hybrid exemptions revoked. The federal customs system now runs at all twenty-two federal crossings and is tied to access to dollars at the official rate. And the dinar was devalued in October 2026. There is also a first amendment to the agency law in progress, approved by cabinet in November 2025 and through a first parliamentary reading in September 2026, not yet enacted.
An agency that is the import licence, an oils regime run by a different ministry, and a conformity scope the published lists and the inspection companies describe differently. Worth establishing before a container moves.
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