October 18, 2026

Graham Act Russia Duties Signed Into an Order—and Waived the Same Day

Published October 18, 2026. An executive order signed October 16 sets out the Graham Act's 500% duty on Russian goods and 100% duties on certain buyers and sanctions-evasion facilitators, but waives those duties and most of the Act's sanctions indefinitely. Separately, CBP's HSU 2625 loads Section 232 pharmaceutical ABI records and changes CPSC PGA flags on 15 HTS numbers.

A crude oil tanker lying at anchor near an offshore terminal at dusk
Russia Duties Waived

White House order implements, then waives, Graham Act duties on Russia-linked trade

President Trump signed the executive order "Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026" on October 16, 2026. The White House posted it late that evening (about 8:34 p.m. Eastern), after the cutoff of the previous report. The Act itself was signed on September 18, 2026. White House: executive order (Oct. 16, 2026)

Section 2 of the order sets out three duty increases, each stacked on top of other duties, including AD/CVD and duties under Sections 122, 201, 232 and 301:

  • Russia: duties on goods of the Russian Federation are increased by 500% ad valorem.
  • Buyers of Russian energy: a 100% increase on goods of the five largest importers of Russian-origin crude oil and natural gas, if a country knowingly makes new purchases on or after October 18, 2026. USTR monitors purchases.
  • Evasion facilitators: a 100% increase on goods of the top five facilitators of Russian oil sanctions evasion, which USTR is to identify.

Section 4(a), however, waives "any duties" provided for in Graham Act Sections 112 and 113 "or this order," and the President has certified the waiver to Congress. Sections 4(b) and 4(c) also waive most of the Act's sanctions and restrictions, including Sections 102(a), 102(d), 102(e) and 103 through 111 and 117. The waivers have no end date. They stay in place until the President, or the Secretary of State in consultation with Treasury and USTR, decides otherwise.

Legal status: As published, the duty increases are waived. They are not in effect, and no affected country or product list has been identified. The order does not modify the HTSUS, create Chapter 99 numbers, set an entry date, or direct CBP. Existing sanctions under the Russia national emergency continued on March 24, 2026 (91 FR 15515) are expressly unaffected, including current designations. The order had not yet appeared on Federal Register public inspection when this report was prepared; that list was offline for the weekend.

For entry filers, nothing changes in ACE today. Russian-origin goods remain subject to existing prohibitions, the column 2 rate and any other measures already in force. Compliance teams should note that USTR now has a standing duty to monitor purchases of Russian energy, and the President can lift the waiver without a set review date. Editorial note: a duty could only take effect if the waiver were lifted, and implementation would then likely require further notice and HTSUS changes.

SignedOct. 16, 2026
Russia rate in order+500%, waived
Purchase trigger dateOn/after Oct. 18, 2026

CSMS #70220191: HSU 2625 loads 232 pharma ABI records and changes CPSC flags

CBP issued CSMS #70220191 on October 16, 2026. It announces Harmonized System Update (HSU) 2625, which CBP says was created September 29, 2026 and contains 57 harmonized tariff records and 304 ABI records. The message arrived in the subscribed CBP digest on October 17. The digest did not include an individual bulletin URL for #70220191, so that bulletin page was not opened separately. HSU 2625 contains three groups of changes:

  • Section 232 pharmaceuticals: ABI record updates tied to the Section 232 pharmaceutical duties. Proclamation 11020 sets those duties, implemented through 91 FR 60360 and HTS Revision 20 under headings 9903.04.60–9903.04.70. CBP points filers to CSMS #70054007, its updated guidance of Sept. 28, 2026. The HSU itself does not list the affected records. CSMS #70054007 (Sept. 28, 2026)
  • CPSC flags changed from CP2 to CP1 on 2404.12.0510, 2404.12.0590, 2404.12.1010, 2404.12.1090, 3604.10.9010, 8506.10.0010, 8506.40.1010, 8506.50.0010, 8506.60.0010, 8506.80.0010, 9613.20.0000, 9404.21.0095, 9404.29.1095 and 9404.29.9095.
  • CPSC flag CP2 removed from 9613.80.2010.
  • Pork checkoff: corrections to the assessment rates for live hogs and pork products under the Pork Promotion, Research, and Consumer Information Order. The message does not list the codes.
Scope note: An HSU updates CBP's ABI tariff records. It is not a new USITC HTS Revision and does not change legal duty rates. The CSMS does not explain the operational effect of the CP2-to-CP1 change. Editorial context: under ACE's PGA flag convention, a "2" flag generally means agency data is required and a "1" flag means it may be required. CPSC has stated separately that filers may send no CPSC message even when a code carries CP1 or CP2. CSMS #69177694 (CPSC eFiling, July 8, 2026)
CSMS issuedOct. 16, 2026
Records57 HTS / 304 ABI
CPSC flags changed14 to CP1, 1 removed

Questions about the 232 pharmaceutical records go to [email protected], CPSC flag questions to [email protected], and general HSU questions to [email protected].

Action items

  • Do not apply any Graham Act surcharge to Russian-origin or third-country goods. The duties are waived and have no HTSUS or CBP implementation. Keep applying current Russia sanctions, import bans and column 2 treatment. EO, Sec. 2 and 4
  • Flag supply chains that source from major buyers of Russian crude oil or gas for contingency review. The order names no countries, but USTR monitoring is ongoing and the waiver has no expiry. EO, Sec. 3
  • Refresh ABI tariff tables for HSU 2625, then check CPSC PGA logic for e-liquid and nicotine products (2404.12), fireworks (3604.10), primary batteries (8506), lighters (9613) and mattresses (9404.21/9404.29). CBP CPSC eFiling guidance
  • Reconcile Section 232 pharmaceutical entries filed on or after Sept. 29, 2026 against the updated ABI records and the HTS-to-Chapter 99 mapping attached to CSMS #70054007. CSMS #70054007

FAQ

Is there now a 500% tariff on Russian goods?

No. The order sets out a 500% increase, but Section 4(a) waives duties under the Act and under the order itself. No HTSUS heading or CBP instruction has been issued. White House order

Does October 18, 2026 start a 100% duty on countries buying Russian oil?

No. October 18 marks when new purchases would count under Section 2(b), but that duty is waived. USTR has not identified any country. White House order

Are existing OFAC Russia sanctions relaxed?

No. The order waives sanctions created by the Graham Act. It expressly leaves untouched measures and designations under the existing Russia national emergency (91 FR 15515). White House order, Sec. 4(b)

Does HSU 2625 change any duty rate?

No. It updates CBP's ABI records and PGA flags. Legal rates for Section 232 pharmaceuticals come from Proclamation 11020, 91 FR 60360 and HTS Revision 20. CSMS #70054007

Original sources and dates

  • The White House, "Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026," executive order signed Oct. 16, 2026, posted the evening of Oct. 16 (ET): whitehouse.gov
  • CBP, CSMS #70220191, "Harmonized System Update (HSU) 2625," Oct. 16, 2026, received via the CBP GovDelivery subscription digest on Oct. 17, 2026; no individual public bulletin URL was included.
  • CBP, CSMS #70054007, "UPDATED GUIDANCE: Section 232 Duties on Imports of Pharmaceutical Articles and Ingredients," Sept. 28, 2026: content.govdelivery.com
  • CBP, CSMS #69177694, CPSC PGA Message Set (eFiling), July 8, 2026: content.govdelivery.com