18 October deadline: up to 100% tariffs on big buyers of Russian oil

Eight days out: what the 18 October Russian oil tariff deadline means for China, India and US lanes
President Trump has until about 18 October to act under a new law that allows duties of up to 100% on all goods from the five biggest buyers of Russian crude oil or natural gas. He signed the Lindsey O. Graham Sanctioning Russia and Iran Act on 18 September. Required measures are due within 30 days, according to law firm Clyde & Co. The duty can apply to countries that make new purchases on or after 18 October, according to Squire Patton Boggs.
China and India are the two names that matter for freight. Together they sent the US more than $400 billion of goods last year.
Our view is simple. A full 100% duty on Chinese or Indian goods this month is unlikely. The bigger story is that the threat is now written into law, comes back every six months, and has a sanctions arm aimed squarely at ships and ports. Forwarders should plan for a recurring risk, not a single cliff on 18 October.

What the law actually does

The tariff part has two pieces, according to Squire Patton Boggs.
The first covers Russia itself. Duties on Russian-origin goods can rise by up to 500%, on top of existing duties. But US goods imports from Russia fell from $29.6 billion in 2021 to $3.8 billion in 2025, so the direct effect is small.
The second is the one that matters. It allows extra duties of up to 100% on all goods from two groups of countries. One is the five largest importers of Russian crude or gas in the 12 months before the law was signed, if they make new purchases from 18 October. The other is the five countries giving the most help with evading Russian oil sanctions. These are “secondary tariffs”: duties on a third country for doing business with the real target.
A few details shape how this plays out:

• No starting rate is set. The law sets a ceiling, not a number. Later rates, set by the US Trade Representative, must stay above zero and at or below 100%, according to Squire Patton Boggs.
• The duties stack. They apply in addition to any other duties, fees or taxes, according to Clyde & Co.
• Congress gets warning. Lawmakers must receive 10 days’ notice of any duty or adjustment, with the rationale and method, according to Squire Patton Boggs.
• The list is reviewed every 180 days. That puts the first review around mid-March 2027, by our count from the signing date.
• There is a waiver. The President can waive tariffs where that is “in the national interests of the United States,” according to Clyde & Co.
• There is a gas carve-out, but not for oil. A country can escape if its imports are under 15% of Russia’s total gas exports and it has taken significant steps to cut them. No equivalent exists for crude, according to Squire Patton Boggs.

The law passed 86–11 in the Senate and 262–159 in the House, according to Squire Patton Boggs. Margins like that suggest, in our view, the tool will outlast this deadline.

Who is in the frame

The likely top five crude buyers are China, India, Slovakia, Hungary and Azerbaijan, according to Squire Patton Boggs, which calls the list indicative. Turkey is also cited as a large importer. On gas, the firm lists China, France, Japan, Hungary and Belgium. Clyde & Co names China, India, France, Spain and Turkey among the countries at risk.
The European names are less likely to bite, in our view. Hungary and Slovakia take Russian pipeline crude under an exception to the EU oil embargo, according to Squire Patton Boggs. Clyde & Co says EU countries phasing out Russian gas may be able to avoid the tariffs.
China and India are different, and the money shows why:

• China bought €5.8 billion of Russian crude in August 2026, according to Squire Patton Boggs. The US imported $308.7 billion of Chinese goods in 2025.
• India bought €4.1 billion of Russian crude in August. The US imported $103.8 billion of Indian goods in 2025.

India’s dependence has jumped this year. Russia’s share of India’s crude imports rose from 18.7% in February to nearly 50% by July, or 2.96 million barrels a day, according to The National. India’s Middle East imports fell 63% to 1.26 million barrels a day, the paper reported. Russian barrels filled the gap. “Replacing Russian crude at current volumes would be challenging or impossible,” Sumit Ritolia, lead analyst at Kpler, said, according to The National.
China has more room. About 800,000 barrels a day of its Russian crude arrives by pipeline under long-term contracts that tariffs on seaborne cargoes would not touch, according to The National.

Why we don’t expect a full 100% this month

Three reasons.
First, the White House has not said what it will do. Asked whether Trump would act by 18 October, Energy Secretary Chris Wright told CBS: “Look, he leaves every decision till the end. He’ll evaluate the trade-offs,” according to APA. He added that Trump “is looking to how to end that conflict and how to lower prices for Americans every day.” That is not the language of a decision already made.
Second, the trade-offs are real. Brent crude had been above $100 a barrel for seven straight sessions when the law was signed, according to The National. Hitting the two biggest buyers of Russian oil could push prices higher at the pump. “The White House is likely to be cautious about imposing tariffs in the near term,” Neil Quilliam, an associate fellow at Chatham House, said, according to The National. Bloomberg reported that planned duties on China would be held back until Trump met Xi Jinping, according to The National.
Third, the law is built for leverage. “The tariff provisions may therefore serve initially as negotiating tools,” Squire Patton Boggs wrote. The firm also noted that the White House “offered no indication of the rates it intends to set or the waivers it may grant.”
So the likeliest first moves are the cheaper ones: a low or deferred rate, a waiver tied to talks, or action on ships rather than whole countries.

Last time: India’s 25%

There is a recent test case. In August 2025, Trump used emergency powers to put an extra 25% tariff on Indian goods over Russian crude purchases, according to Squire Patton Boggs. He withdrew it on 6 February 2026, after India committed to stop those purchases.
Two things followed. India’s Russian crude imports fell, from about 1.84 million barrels a day in November 2025 to about 1.04 million in February 2026, according to Kpler data cited by Open magazine. By July, with Gulf supply down, Russian barrels were back at nearly half of India’s imports. Separately, the Supreme Court ruled in Learning Resources v. Trump that those emergency powers do not authorise tariffs, according to Squire Patton Boggs.
The lesson we draw: tariff pressure did change buying, but it did not stick once the oil market shifted. The difference now is the legal footing. “The Graham Act places much of the US sanctions regime against Russia on an express statutory footing,” Squire Patton Boggs wrote. A court cannot strike this down on the grounds the Supreme Court used against emergency-power tariffs.

What it means for forwarders and lanes

India–US. This is the lane most exposed in the near term, in our view. India is the buyer with the least room to switch, and the US bought $58.9 billion of Indian goods in the first seven months of 2026, according to The National. Electrical machinery, including smartphones assembled for US brands, was the largest category in the first half. If a notice to Congress appears naming India, expect shippers to rush cargo out before the 10-day window closes. That means short bursts of demand on India–US ocean and air capacity, followed by a lull.
Transpacific. A 100% duty stacked on existing China tariffs would freeze a large share of trade. We think it is the least likely outcome this month, given the Xi talks. But the 180-day review means China stays on the list as a live risk into 2027. Shippers on long contracts should check their tariff-change clauses.
Ships and ports. This is where we expect action first. The law allows blocking sanctions, which freeze assets and bar US persons from dealing with the target, on non-US vessels and their owners, operators, managers, officers and insurers that knowingly carry Russian-origin oil, gas or coal, whatever price is paid, according to Squire Patton Boggs. Port owners or operators that let sanctioned vessels dock or receive services can be sanctioned too. “Knowledge” includes what a person should have known, which raises the bar for due diligence.
For most forwarders, the direct exposure is small. The indirect exposure is not. Expect banks, insurers and carriers to ask more screening questions on vessel history, ownership and port calls. Clyde & Co warns that non-US companies that knowingly support the purchase, loading, shipment, financing or insurance of sanctioned Russian energy could expose their home countries to secondary tariffs.
Europe. Hungary and Slovakia are on the crude list, but we expect waivers to keep EU trade largely out of this round.

Our call

We expect no across-the-board duty on Chinese or Indian goods to be in force by 31 October. We expect the first concrete action, within six weeks, to be designations of “shadow fleet” tankers, the older ships with murky ownership and insurance that move sanctioned oil, along with some of the firms that service them. If any country-level duty is announced in this round, we think it will be aimed at India, set well below 100%, and tied to talks. The bigger test for freight comes at the first 180-day review, around mid-March 2027, when the buyer list is reassessed and the White House has to decide again.

Sources

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• National Law Review / Squire Patton Boggs — Sanctions by Statute: The Graham Act and Tariffs on Russia’s Energy Buyers, 24 Sep 2026 \
• Clyde & Co — The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 becomes law, 23 Sep 2026 \
• APA — US doesn’t rule out imposing secondary sanctions on Russia’s trade partners by Oct 18, 5 Oct 2026 \
• The National — Trump tariff law targets Asian buyers of Russian oil as Gulf supply falls, 18 Sep 2026 \
• Open — Donald Trump Backs Russia Sanctions Bill Targeting India Oil Trade, 14 Jul 2026