27JUL

Trump's toll-payer order targets allied ships

3 min read

09:24UTC

Trump ordered the Navy to stop any vessel that paid Iran's Hormuz toll, a list that includes French and Japanese ships whose governments refused to join the blockade.

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Key takeaway

The blockade threatens to interdict vessels from allies who refused to join it.

France's CMA CGM Kribi and Japan's Mitsui OSK both paid Iran's Hormuz toll in yuan in early April. Under Trump's toll-interdiction order, both vessels, and potentially others from the Philippines and UAE, are targets for US Navy interception in international waters.

CENTCOM's operational order does not include this provision. Whether that reflects a deliberate decision to avoid the most explosive implications of the tweet, or a narrower military reading of the order, is unknown. The gap creates daily legal exposure: any officer who intercepts a French or Japanese vessel under the presidential order, or any officer who does not, acts without clear authority.

The blockade was designed to pressure Tehran. It has instead handed Paris and Tokyo a grievance against Washington . The EU had already rejected Trump's suggestion of a US-Iran "joint venture" on toll collection, citing UNCLOS transit passage rights. France and Japan are now members of the UK's reopening coalition while also appearing on the US interception list for having paid Iran's fees.

Deep Analysis

In plain English

Iran has been charging ships a fee , called a toll , to pass through the Strait of Hormuz. Some European and Asian companies paid this toll to keep their goods moving, including a French shipping company (CMA CGM) and a Japanese energy firm (Mitsui OSK). Trump's social media post said the US Navy should stop any ship that had paid Iran this toll , which would include those French and Japanese vessels. France and Japan are US allies who refused to join the blockade. CENTCOM's actual military order did not include this instruction. So right now, there is a gap between what Trump said should happen to allied ships and what the US military is actually doing. That gap has not been publicly resolved.

What could happen next?

Risk
France could invoke UNCLOS Article 300 (good faith obligations) and file immediate ITLOS proceedings if a CMA CGM vessel is stopped, creating an international court process that would take months but generate immediate diplomatic crisis.
Short term · 0.72
Consequence
CENTCOM's omission of the toll-interdiction provision from its operational order leaves a daily decision gap: every officer on patrol near a toll-paying allied vessel must choose which authority to obey without clear guidance.
Immediate · 0.88
Risk
If France and Japan are both targeted as toll-payers and members of the UK's 40-nation reopening coalition, the US blockade and the UK coalition are in direct operational conflict over the same vessels in the same waterway.
Immediate · 0.8

Source Landscape

This story draws on mixed-leaning sources from United States (includes United States state media)

United States×2

Primary parallel: The 1986 US strikes on Libya were preceded by the Gulf of Sidra dispute, in which the Reagan administration asserted the right to transit waters Libya claimed as internal. When Libya enforced its exclusion zone, the US struck back , but only after Libya fired first. The critical difference from 2026: the US asserted freedom of navigation against a unilateral claim, not the right to interdict vessels that paid a fee to a third party's exclusion claim.

Counter-parallel: The 1973 Arab oil embargo saw the US contemplate interdicting tankers carrying Arab oil to neutral states , a plan ultimately rejected by the Nixon administration's legal counsel as having no basis in Law of the Sea. The 2026 toll-payer order attempts what Nixon's lawyers refused.

The toll-payer provision targets a specific financial architecture Iran built to sustain revenue through the blockade. CMA CGM Kribi paid in yuan on 4 April ; Mitsui OSK's Sohar LNG also transited. If the US actually intercepts either vessel, it would trigger immediate insurance invalidation for all toll-paying transits, collapse the yuan-denominated fee system Iran relies on, and expose French and Japanese shipping companies to US secondary sanctions.

CMA CGM is the world's third-largest container shipping company by fleet capacity. A US interdiction of one of its vessels would force the company to reroute its entire Asia-Pacific portfolio via Cape of Good Hope , adding 10-12 days and estimated $2-3 million per voyage in fuel costs. The knock-on effect for European importers of Asian goods would be measurable within 30 days.

Consensus view: The German Council on Foreign Relations (DGAP) and France's Institut Français des Relations Internationales (IFRI) both assess the toll-payer provision as the most legally aggressive element of the blockade: interdicting a vessel flagged by a sovereign state that paid a fee to transit a waterway constitutes an act of hostility against that state under UNCLOS and the 1944 Chicago Convention's principle of sovereign immunity over flagged vessels.

IFRI's Marc Hecker notes that CMA CGM Kribi, as a Malta-flagged vessel with French ownership, creates a dual-jurisdiction dispute between France and Malta.

Counter-view: The Heritage Foundation's James Jay Carafano argues that any vessel paying Iran's Hormuz toll is providing material support to a state the US has designated as a terrorism sponsor, and that IEEPA authority , however lacking in formal instruments , gives the executive branch latitude to treat toll payment as a sanctions violation. He cites the 2019 secondary sanctions on Iranian oil buyers as precedent for targeting third-country commercial actors.

Key tension: Whether paying Iran a transit fee is a commercial transaction protected by freedom of navigation, or a material contribution to a sanctioned state that the US can prohibit extraterritorially , a question no court has yet ruled on in the context of a contested waterway.

First Reported In

Update #67 · Trump blockades Iran on a tweet

CENTCOM / Al Jazeera· 13 Apr 2026

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Causes and effects

This Event

Trump's toll-payer order targets allied ships

Interdicting allied flag vessels in international waters would rupture Western alliance relations more severely than any action since the war began.

Led to

US warship seizes Iranian cargo ship Touska

The Spruance seizure extended blockade authority from Trump's 12 April Truth Social post (ID:2284) to a kinetic ship-taking threshold without any new signed instrument.

Occurred 19 Apr 2026

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France and Japan file flag-state protests

Trump's toll-interdiction order omitted from CENTCOM's operational order (ID:2284) is the direct trigger for the French and Japanese formal flag-state protests: both vessels appeared on the presidential list CENTCOM chose not to implement.

Occurred 14 Apr 2026

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Iran tanker tests Cooper blockade claim

Trump's omitted toll-interdiction provision (ID:2284) is the authority gap that allowed the Agios Fanourios I and the sanctioned Iranian supertanker to attempt transit.

Occurred 15 Apr 2026

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Different Perspectives

Slovakia

Slovakia says it dropped its hold-out on the 21st sanctions package only after Ursula von der Leyen personally signed written gas-price and supply guarantees. The Council of the European Union's own 17,238-character release on the package names neither Slovakia nor any guarantee, leaving Bratislava's account unconfirmed by the institutional record.

EU regulator on capacity mechanisms

Brussels is watching Germany's StromVKG first 4.5 GW capacity auction move toward its 8 September bid deadline without a resolved state-aid clearance for the 9 GW 2026 programme's gas-plant subsidies. A negative spark spread this deep on cheap gas strengthens the case for subsidised dispatchable capacity, the same case still awaiting a state-aid ruling.

French power exporters

French day-ahead cleared EUR 41.13/MWh on Sunday 26 July, EUR 43.09 below Germany, on wind more than doubling and a demand trough, not on any nuclear recovery. The desk expects the discount to hold only as long as French wind and weekend demand repeat, not as a durable nuclear-cost advantage.

European gas storage operator

A storage operator stopped bidding for prompt TTF cargoes on 21 July, reading the strike-halt unwind as the start of a fuel-side correction rather than a floor. It expects the gap between prompt and forward gas to keep narrowing as the war premium continues leaving the curve.

German gas-fired power fleet

German gas-fired plants cut output from 4.37 GW to 2.85 GW between 24 and 27 July, even as TTF fell 8 per cent, because below roughly minus EUR 40/MWh the fuel price stopped deciding dispatch. The fleet expects no relief until wind eases or StromVKG's first 4.5 GW auction adds capacity.

French industrial power consumers

France's day-ahead discount to Germany has nearly closed as TTF and EUA rise together on both sides of the border, eroding the arbitrage French industry relied on through the summer. A standing negative spark removes the German demand buffer that kept that spread wide.