At a glance
- Effective date
- 2026-09-18
- What changed
- On October 16, 2026, President Trump issued Executive Order 14436, “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026,” addressing the tariff and sanctions requirements established under the Graham Act, which was signed into law on September 18, 2026.
- Who is affected
- U.S. importers sourcing goods directly from Russia or from countries that may be designated under the law’s secondary tariff provisions.
- Business impact
- The Executive Order establishes significant additional duties on Russian goods and goods from certain countries connected to Russian energy trade and sanctions evasion but simultaneously waives the application of those duties.
Recommended actions
What importers should do next
- Review direct and indirect exposure to Russian-origin products.
- Assess suppliers in countries that purchase Russian crude oil or natural gas.
- Evaluate tariff-stacking risks and relevant contract provisions.
- Strengthen country-of-origin documentation and supply chain tracing.
- Monitor Presidential actions, agency guidance, and CBP instructions.
Key takeaway
As a result, the new 500% and 100% Graham Act tariffs are not currently being applied. The waiver does not contain a specified expiration date and remains in effect until the President or Secretary of State, in consultation with the Secretary of the Treasury and the U.S. Trade Representative, as appropriate, determines that further action is warranted.
Current Update: President Trump Waives New Russia-Related Tariffs Under the Graham Act
On October 16, 2026, President Trump issued Executive Order 14436, “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026,” addressing the tariff and sanctions requirements established under the Graham Act, which was signed into law on September 18, 2026. The Executive Order establishes significant additional duties on Russian goods and goods from certain countries connected to Russian energy trade and sanctions evasion but simultaneously waives the application of those duties.
Tariffs Established by the Executive Order
Executive Order 14436 provides for the following additional duties, subject to the waiver:
- Russian-origin goods: An additional 500% ad valorem duty on goods imported from the Russian Federation.
- Major purchasers of Russian energy: An additional 100% ad valorem duty on goods from the five largest importers of Russian-origin crude oil and natural gas where the country knowingly makes new purchases of Russian-origin crude oil or natural gas on or after October 18, 2026.
- Sanctions-evasion facilitators: An additional 100% ad valorem duty on goods from the five leading facilitators of Russian oil sanctions evasion.
Presidential Waiver
Section 115 of the Graham Act authorizes the President to waive duties and other sanctions under the Act when the statutory requirements are satisfied. President Trump determined that issuing the waiver is in the national interests of the United States and stated that the required certification and supporting report had been submitted to Congress.
Section 4(a) of Executive Order 14436 therefore waives the application of the duties under Sections 112 and 113 of the Graham Act as well as the duties established by the Executive Order itself.
The Executive Order also waives a broad range of sanctions and restrictions established under other provisions of the Graham Act.
Existing Russia Sanctions Remain in Effect
The waiver does not represent a general suspension of existing U.S. sanctions against Russia.
What This Means for U.S. Importers
For now, importers should not apply the new 500% or 100% Graham Act duties solely on the basis of Executive Order 14436 because their application has been waived.
However, the potential tariff exposure remains significant because the waiver can be revisited. The Executive Order directs the U.S. Trade Representative, working with the Departments of State, Treasury and Energy and other appropriate officials, to monitor Russian-origin oil and natural gas purchases and countries facilitating Russian sanctions evasion and to report circumstances that could warrant further Presidential action.
How Crane Trade Consulting Can Help
Crane Worldwide Logistics can assist customers in evaluating the potential customs and trade-compliance implications of the new guidance and reviewing available product, sourcing, and import information to help determine how the guidance may apply to their transactions. For additional consultation on a case-by-case basis, please contact https://www.craneww.com/logistics-technology/tarfiff-response-unit/.
Disclaimer
This advisory is provided for informational purposes only and does not constitute legal advice. The information is based on publicly available government sources, including the White House, Executive Order 14436, October 16, 2026. Trade regulations, filing requirements, duty payment procedures, and administrative processes may be modified, clarified, or supplemented through subsequent Federal Register notices, CBP guidance, or other government actions. Importers should consult qualified legal counsel and trade compliance professionals before making decisions based on evolving customs compliance requirements.
Previous Update
On September 18, 2026, the President signed into law H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, establishing a broad new sanctions and tariff framework targeting Russia, Russian-affiliated entities, and certain foreign countries that continue to purchase Russian energy or facilitate sanctions evasion. The law was signed on September 18, 2026, and most provisions must be implemented within 30 days of enactment, unless waived by the President. Of particular importance to importers, the law authorizes:
- Additional duties of up to 500% ad valorem on all goods imported from Russia
- Additional duties of up to 100% ad valorem on imports from certain countries that purchase Russian crude oil or natural gas or facilitate sanctions evasion
- Application of these duties in addition to existing duties, including Section 232, Section 301, AD/CVD, and other applicable tariffs.
Disclaimer
This advisory is for informational purposes only and does not constitute legal advice. Companies should consult legal counsel and trade compliance professionals regarding the application of these new sanctions and tariff measures to specific transactions.
Implementation Timing
The law requires implementation within 30 days of enactment, meaning tariff measures could become effective by approximately October 18, 2026, subject to Presidential action and implementing guidance from CBP and other agencies.
Additional Tariffs on Russian-Origin Goods
Section 112 of the Act directs the President to increase duties on imports from the Russian Federation. The statute authorizes tariff rates of up to 500% ad valorem on goods imported from Russia. Unlike previous sanctions programs that focused on specific sectors or products, the tariff authority applies broadly to Russian-origin goods and may be imposed in addition to existing duties, including Section 232, Section 301, AD/CVD, and other applicable fees, taxes, or charges.
Secondary Tariffs on Countries Purchasing Russian Energy
Section 113 creates a new form of "secondary tariff" mechanism intended to pressure countries that continue to support Russian energy exports. The legislation authorizes the President to impose duties of up to 100% ad valorem on imports from countries that purchase Russian-origin crude oil, purchase Russian-origin natural gas, or facilitate evasion of Russian oil-related sanctions. These tariffs are not limited to energy products. If imposed, they may apply broadly to imports from affected countries.
Important Consideration
The law establishes a maximum tariff level, not an automatic 500% tariff. The President retains discretion regarding the actual tariff rate imposed, provided it does not exceed the statutory ceiling. The President may waive sanctions and tariff provisions if deemed in the national interest of the United States. As a result, the practical impact of the law will depend heavily on future Executive Branch implementation decisions and country-specific determinations.
What the Law Provides
Additional Tariffs on Russian-Origin Goods
Section 112 of the Act directs the President to increase duties on imports from the Russian Federation. The statute authorizes tariff rates of up to 500% ad valorem on goods imported from Russia. Unlike previous sanctions programs that focused on specific sectors or products, the tariff authority applies broadly to Russian-origin goods and may be imposed in addition to existing duties, including Section 232, Section 301, AD/CVD, and other applicable fees, taxes, or charges.
Secondary Tariffs on Countries Purchasing Russian Energy
Section 113 creates a new form of "secondary tariff" mechanism intended to pressure countries that continue to support Russian energy exports. The legislation authorizes the President to impose duties of up to 100% ad valorem on imports from countries that purchase Russian-origin crude oil, purchase Russian-origin natural gas, or facilitate evasion of Russian oil-related sanctions. These tariffs are not limited to energy products. If imposed, they may apply broadly to imports from affected countries.
Countries Most Likely to be Affected
The statute specifically targets countries that are among the largest 5 purchasers of Russian energy or among the top 5 countries facilitating Russian oil sanctions evasion. Public commentary regarding the law has highlighted countries such as China and India as potentially affected, although the final determination remains subject to Presidential review and implementation decisions.
Implications for Importers
Importers should therefore recognize that:
- Not all authorized tariffs may be imposed;
- Different countries could face different tariff rates;
- Tariff implementation may evolve over time through Presidential actions, agency guidance, and CBP instructions.
Companies should immediately assess:
- Direct sourcing of Russian-origin products.
- Exposure to suppliers located in countries that are major purchasers of Russian crude oil or natural gas.
- Existing tariff stacking risks involving Section 232, Section 301, IEEPA, AD/CVD, and other applicable duties.
- Long-term sourcing strategies involving potentially affected countries.
- Contract provisions addressing tariff escalation and force majeure considerations.
- Country-of-origin documentation and supply chain tracing requirements.
Even companies with no direct Russia trade may face increased costs if imports originate from countries that become subject to the Act's secondary tariff provisions.
Disclaimer
This advisory is for informational purposes only and does not constitute legal advice. Companies should consult legal counsel and trade compliance professionals regarding the application of these new sanctions and tariff measures to specific transactions.
How Crane Trade Consulting Can Help
Crane Trade Consulting is actively monitoring these developments and is available to assist importers with Tariff exposure assessments, Country-of-origin reviews, Supply chain impact analysis, Sanctions compliance reviews, sourcing strategy and mitigation planning, and Customs compliance guidance.
Disclaimer
This advisory is for informational purposes only and does not constitute legal advice. Companies should consult legal counsel and trade compliance professionals regarding the application of these new sanctions and tariff measures to specific transactions.
Need help understanding your exposure?
Crane Trade Consulting can help assess tariff impacts, validate exclusions and develop practical mitigation strategies.