Foreign Exchange Allocation in Iran: Why an Unrecognised IRC Blocks Payment

1. Key takeaways

Import payment in Iran depends on the foreign exchange allocation of the Central Bank, and the foreign exchange allocation list is derived directly from the list of items that have completed identification code registration. GRZAN’s judgment: this is the most damaging link in the Iranian compliance chain, because it hard-binds an administrative action — identification code registration — to the commercial lifeline of whether payment can be made at all. A company that ships before confirming that its item has entered the foreign exchange allocation list faces a compound loss: goods at the port, payment that cannot be remitted, and clearance that cannot be completed. On top of the allocation mechanism sit two further commercial exposures. First, the coexistence of an official exchange rate and a market rate means import costs vary with the applicable rate mechanism, so contracts should fix an exchange-rate benchmark and an adjustment clause; the source material deliberately gives no figures, and applicable rates and mechanisms must be taken from current official publication. Second, the feasibility of the settlement route is constrained by the international financial environment and should be assessed as a separate issue, not merged into the registration compliance workstream. Each of the three exposures is manageable — but only if it is identified before the goods move.

• Foreign exchange allocation is administered by the Central Bank and the allocation list is derived from items that have completed identification code registration.
• Items without completed identification code registration are removed from the foreign exchange allocation list reported to the Central Bank of Iran.
• An unrecognised IRC leaves the item deactivated and hidden from imed.ir, compounding the payment problem.
• Iran has an official exchange rate and a market rate in parallel; contracts should specify the exchange-rate benchmark and an adjustment clause, with no figures given here and current official publication governing.
• Payment channel feasibility is a distinct commercial-and-compliance issue and should be evaluated separately from registration compliance.

2. Legal basis

The mechanisms described here rest on the linkage between identification code registration and the foreign exchange allocation list, on the IRC deactivation and imed.ir hiding mechanism, and on the general authorisation requirement of the 1955 law. The items below state each basis and its verification status.

1. Foreign exchange allocation linkage mechanism: items that have not completed identification code registration are removed from the foreign exchange allocation list reported to the Central Bank of Iran — see public industry database records of the Iranian pathway; the official Iranian document number has not been released through public channels, so this item is a practical estimate.
2. IRC deactivation and imed.ir hiding mechanism — this is a practical estimate.
3. Law on Regulation of Medical, Pharmaceutical and Food and Beverage Affairs, FAOLEX LEX-FAOC227692, dated 20 June 1955, Article 3.

3. Expert insights

Insight 1: the compliance action and funding availability are institutionally bound together. In most markets, registration and payment are 2 separate questions; in Iran, they are designed as a series connection. The policy intent of this design is to align import categories with the country’s foreign exchange priorities. Medical devices, as a humanitarian category, usually enjoy a relatively high priority — but the precondition is that every registration action has been completed. Companies that treat the compliance workstream and the payment workstream as parallel and unrelated discover that the second depends entirely on the first, and that no amount of banking effort can substitute for a missing identification code registration.

Insight 2: the exchange rate mechanism adds uncertainty to quotations. Iran has a pattern in which an official exchange rate and a market rate coexist, and import costs change with the applicable rate mechanism. Specific rate values and the applicable mechanism must follow current official publication; this article gives no numbers. The practical consequence for contracts is that quotations should state clearly which exchange-rate benchmark applies and how prices adjust when the rate moves beyond an agreed band. A quotation that silently assumes one rate while settlement follows another turns every shipment into a renegotiation.

Insight 3: the real-world constraints on the payment channel need their own assessment. The feasibility of the settlement route is constrained by the international financial environment; it is a question at the intersection of commerce and compliance, and it should be evaluated as an independent issue rather than being conflated with registration compliance. A compliant product with a compliant importer can still face a settlement path that does not work in practice. Assessing the route early — before commitments are made — separates problems that compliance work can solve from problems it cannot, and lets the company price or decline the residual risk knowingly. It also protects the customer relationship, because payment difficulties discovered after a signed supply commitment are far harder to manage than ones surfaced during contracting.

4. Practical recommendations

• Confirm the foreign exchange list before shipment: arrange the shipment only after the item has entered the foreign exchange allocation list.
• Fix the exchange-rate benchmark and an adjustment clause in the contract: agree which rate mechanism applies and how prices adjust when fluctuation exceeds the agreed band.
• Evaluate the payment channel independently: treat the settlement route as a separate issue and run it in parallel with the registration compliance workstream.
• Maintain an item-level foreign exchange status tracker: track the foreign exchange status of every item individually, linked with its IRC status.

5. Verification checklist

• □ Before shipment, the item was confirmed to be on the foreign exchange allocation list of the Central Bank of Iran
• □ The contract states the exchange-rate benchmark and a fluctuation adjustment clause
• □ The feasibility of the payment channel has been assessed as an independent issue
• □ An item-level foreign exchange status tracker has been established
• □ Foreign exchange status is checked in linkage with the IRC and identification code status

Regulatory information verified as of 29 October 2026.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Iranian market. Our team coordinates local import arrangements, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com