US orders Russia-related duties but waives them for now

High headline rates are not currently payable

The order sets a 500% additional ad valorem duty on goods from Russia. It also sets a 100% additional duty on goods from the five largest importers making new purchases of Russian-origin crude oil or natural gas from 18 October, and on goods from the five largest countries facilitating Russian oil-sanctions evasion. Those rates would be added to other duties, fees and charges.^[1][2]

However, section 4 of the same order waives every duty provided by sections 112 and 113 of the Act and by the order. The waivers remain in effect until the President, or the Secretary of State in consultation with Treasury and the US Trade Representative as appropriate, determines that further action is warranted. Importers should therefore not treat the headline rates as duties currently due.^[1]

The statute supplies the framework for later activation

Public Law 119-111, enacted on 18 September, authorises a duty of up to 500% on all Russian goods and up to 100% on goods from defined third countries. For the latter category, the Act looks to the five largest recent importers of Russian oil or gas making new purchases after the statutory 30-day point, and to the top five countries facilitating sanctions evasion. It also provides humanitarian, official-business, pre-existing general-licence and other exceptions.^[2]

Section 115 allows the President to waive duties after submitting a national-interest certification and explanatory report to Congress. The Government Publishing Office records those certifications as House Document 119-202 dated 19 October 2026. The executive order separately delegates monitoring and duty functions to the US Trade Representative, supported by State, Treasury and Energy.^[1][2][3]

Compliance consequence

For MNE supply chains, the immediate consequence is monitoring rather than a new customs payment. The waiver may later be lifted without amending the Act, and the order directs continuing review of Russian-energy purchases and sanctions-evasion activity. Importers should map Russian-origin goods, energy-linked sourcing countries and existing tariff exposure, while confirming any future activation against an operative presidential or USTR action rather than relying on the statutory maximum alone.^[1][2]