The Graham Act authorizes tariffs up to 500% on Russian goods and up to 100% on products from other large energy importers, expanding duties beyond existing levels and targeting the top buyers of Russian energy and nations assisting sanctions evasion.

The act uses statutory authority to impose sanctions on Russia, expand energy-related tariffs, and allow blocking sanctions on vessels, banks, and other entities connected to Russia's energy or defense sectors.

Under Sections 112 and 113, tariffs can reach 500% for Russian goods and 100% for imports from large energy buyers that knowingly purchase Russian energy after mid-October 2026, potentially affecting countries like China, India, Turkey, and EU member states.

The administration must report its implementation plans within 30 days of enactment, creating uncertainty for companies awaiting policy clarification.

There are open legal and practical questions about how broadly the administration will apply the new powers, including whether the law will be used narrowly against Russia/energy or more aggressively to lever concessions from trading partners.

Carveouts may limit immediate disruption for regions such as the EU, potentially sparing certain European beverage imports and influencing U.S. import sourcing decisions.

The legislation extends the Iran Sanctions Act through 2031, granting the President wide discretion with waivers, enabling a range of enforcement approaches from targeted actions to broader trade leverage.

Certain exceptions could narrow impact, including exemptions for countries with under 15% of Russia's gas imports, significant reductions in Russian imports, low-enriched uranium, and non-Russian oil transiting Russia, with wind-down periods and general licenses allowed.

Unclear which countries will be listed, but potential candidates include China, India, the EU, Türkiye, South Korea, and Myanmar, plus others connected to sanctions evasion via the shadow fleet.

Overall, the Act strengthens sanctions authority, but the real-world effect hinges on how waivers are used, how tariffs are implemented, and how relationships with major energy consumers are managed.

Implementation timing sets initial determinations by October 18, 2026, with rate decisions, waivers, and lists expected to test the balance between pressure on Russia and relations with energy partners like China and India.

There are limits and waivers: tariffs must start above zero and can go to 100%, with a national-interest waiver; exemptions exist for gas imports under 15% of Russia’s gas exports, but no crude oil analogue.