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The Graham Act: What Is Known and What Remains Pending
12 October 2026
New U.S. legislation establishes tariff authorities that could affect imports from Russia and certain other countries. How these provisions will apply remains subject to implementation details, including affected countries, applicable rates and exceptions.
Signed into law on September 18, 2026, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, commonly called the Graham Act, expands Russia-related sanctions and tariff authorities. For importers, its potential application extends to goods from countries that purchase Russian energy or facilitate Russian oil sanctions evasion.
We are sharing this overview to keep customers informed as further guidance becomes available. The maximum rates outlined below should not be interpreted as confirmed duties on your shipments.
What tariffs does the Act provide for?
The legislation establishes two main tariff provisions:
- Up to 500% in additional duties on Russian-origin goods.
- Up to 100% in additional duties on goods from certain other countries that meet the law’s criteria.
These duties would apply in addition to other applicable duties. The percentages represent maximum rates under the legislation, rather than confirmed rates for every affected import. Exceptions and presidential waiver authority could also affect implementation.
The potential exposure extends beyond energy products. The tariff provisions broadly cover goods imported from affected countries, which could affect businesses sourcing finished products, components or raw materials from those markets.
Which countries could be affected?
The law targets countries meeting specific criteria related to Russian energy purchases and sanctions evasion. These include countries among the five largest importers of Russian crude oil or natural gas that continue qualifying purchases, as well as the top five countries facilitating Russian oil sanctions evasion. Coverage is subject to statutory conditions and exceptions.
China and India have received attention because of their substantial purchases of Russian energy. However, potential exposure should not be confused with a confirmed country designation or tariff rate.
The legislation requires a review of major Russian crude oil and natural gas importers within 180 days of the initial imposition of duties and every 180 days thereafter. These reviews could affect country coverage and applicable duties, making ongoing monitoring important beyond the initial implementation period.
What happens on October 18?
The Act sets a 30-day deadline for tariff action following enactment, corresponding to October 18, 2026. That deadline should not be treated as confirmation that the maximum tariffs will begin applying to all potentially affected shipments on that date.
Actual exposure will depend on implementing actions, including country determinations, tariff rates and applicable exceptions or waivers.
The sources reviewed for this update did not identify a published official country list or final tariff rates. Importers should confirm the latest requirements before making shipment or entry decisions.
What about Iran?
The Act also extends the Iran Sanctions Act of 1996 through December 31, 2031. This extension is separate from the Russia-related tariff provisions discussed above.
How can importers prepare?
While implementation details remain pending, businesses can prepare by reviewing their sourcing and shipment information:
- Map sourcing exposure. Identify the countries of origin for imported products, especially where purchases are concentrated in a small number of markets.
- Review upcoming shipments. Gather purchase orders, expected arrival dates, customs values and product classifications to support an exposure assessment when guidance becomes available.
- Consider potential cost scenarios. Where useful for internal planning, evaluate hypothetical duty increases to understand possible effects on margins, pricing and cash flow. These scenarios should remain separate from confirmed cost forecasts.
- Coordinate internally. Ensure procurement, finance and logistics teams understand which details are confirmed and which remain pending.
- Consult your customs brokerage team. Confirm applicable guidance before changing entry practices or assuming a shipment qualifies for an exception.
These steps support preparation while details develop. Decisions about changes to sourcing or shipment plans should reflect confirmed requirements and your business’s circumstances.
