At a glance
- Effective date
- 2026-09-18
- What changed
- A new sanctions and tariff framework authorizes additional duties of up to 500% on Russian-origin goods and up to 100% on imports from certain countries that purchase Russian energy or facilitate sanctions evasion.
- 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
- Companies could face higher landed costs, tariff stacking, sourcing disruption, additional country-of-origin documentation requirements, and greater supply chain compliance obligations.
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
The law establishes maximum tariff levels rather than automatically imposing tariffs at those rates. Actual exposure will depend on future implementation decisions and country-specific determinations.
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.
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.
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.
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.