The US puts Graham Act secondary tariffs on Chinese goods over Russian oil
The test Between 26 Oct 2026 and 25 Oct 2027, the waiver in section 4 of Executive Order 14436 is lifted for China and the 100% duty under section 2(b) or 2(c) of that order takes effect on goods of China.
Not under way · Confidence: medium · Reviewed 25 Oct 2026 · Scores from 1 to 10
This page answers: What could happen, how it is scored, and who is exposed?
Using this page
- Read the two scores: Likelihood and Impact are kept apart.
- Check what is happening, each fact with its source.
- Use the calendar for the dates to watch.
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Likelihood ↓ Since 16 Oct 2026: EO 14436 waived the duties with no end date [1].
Impact is the average of the four parts, rounded, plus one point when Canada is directly hit on two or more channels, up to 10.
Two separate scales from 1 to 10. Strature never multiplies or merges them.
What changed
Dated, newest first
- Senators of both parties criticised the waiver; a House bill to block it was introduced on 16 Oct; Congress in recess until after 3 Nov. [3]
- EO 14436 sets a 100% duty on goods of the largest five importers buying Russian crude or gas on or after 18 Oct 2026, and waives it until the President or Secretary of State decides further action is appropriate. [1]
- China bought EUR 9.1bn of Russian fossil fuels in September 2026 (EUR 6.0bn crude, EUR 1.2bn LNG, EUR 894m pipeline gas, EUR 635m coal); 55% of the top five's revenue. [4]
- MOFCOM: Kuala Lumpur arrangement extended to 10 Jan 2027; recommended tariff cuts, not yet in force, on about US$30bn each way. [6]
- The Board of Trade, chartered in May 2026, was put into operation in September 2026. [7]
- MOFCOM opposed unilateral and secondary sanctions over the act and reserved the right to take all necessary measures. [10]
- H.R. 5334 passed the Senate 86-11 (7 Aug) and the House 262-159 (16 Sep) and was signed on 18 Sep 2026; up to 100% on goods of the five largest importers of Russian crude and gas. [2]
Why it matters
A US law signed on 18 September 2026 requires duties of up to 100% on goods from the five largest buyers of Russian oil and gas, unless the president waives them. China is by far the largest buyer: EUR 9.1bn of Russian fossil fuels in September 2026. On 16 October the president set the duties and waived them in the same order, with no end date; a fresh US-China trade truce makes their use on China unlikely within a year.
Why Likelihood 3 Pushes: senators of both parties oppose the waiver; a House bill to block it (16 Oct). Brakes: the president's indefinite waiver and the truce extended to 10 Jan 2027 block it; China is the costliest buyer to hit.
Why Impact 7 Threshold case: 100% duty on goods of China; US$308.7bn of 2025 US imports, gross.
Where it sits
How it spreads
Between 26 Oct 2026 and 25 Oct 2027, the waiver in section 4 of Executive Order 14436 is lifted for China and the 100% duty under section 2(b) or 2(c) of that order takes effect on goods of China.
Not under wayChannels 4 on the card
- CanadaNo Canadian loss on file; diverted Chinese goods could reach Canada (not sized).
- US imports100% extra duty [1] on US$308.7bn (2025) of goods from China [5].
- The truceDuties would break the 28 Sep 2026 arrangement [6] and invite counter-measures on US$106.0bn of US exports [5].
- Oil flowsChina weighs Russian crude against US market access; India, Türkiye, Saudi Arabia and the EU are the other top-five buyers in CREA's September ranking.
Goods 3
Sectors 2
- Energy and pipelines
- Ports and logistics
Countries 4
- China primary
- United States primary
- Russia
- Canada
Who is exposed
- Countries
- China, United States, Russia
- Sectors
- Energy and pipelines, Ports and logistics
- Goods
- Crude oil, LNG, Refined fuels
Three scenarios and their signposts
- S1
The waiver holds
The truce rolls on and the Board of Trade starts work.
- S2
Pressure without use
USTR reports rising Chinese purchases and Congress pushes back, but the waiver stays.
- S3
Use on China
Talks with Moscow or Beijing collapse and the waiver is lifted for China.
| Path | Signpost |
|---|---|
| S1 | A numbered Chinese text extending the 24% suspension past 10 Nov 2026 |
| S2 | A bill against the waiver brought to the floor of either chamber after Congress returns in November 2026 |
| S3 | A determination under section 4(d) of EO 14436 |
No probability is given for the three paths.
Forecasts
Strature forecast linked to this risk
Strature forecast F-0209: 10% (2 Oct 2026) · resolves by 10 Jan 2027
Where the card uses it Strature forecast F-0209: 10% (2 Oct 2026) resolves
A forecast is a probability on a dated question. The Likelihood score above is a separate judgement and is never turned into a percentage.
The forecast register lists every forecast and how it is scored.
Dates to watch
The dates to watch
A dot is a day, a bar a month or a year; a hollow mark is tentative. The line marks today.
- 3 Nov 2026 US midterm elections; Congress returns afterwards [3] Declared · Outside event
- 10 Nov 2026 China's suspension of its 24% extra duty on US goods ends unless extended [8] Declared · Outside event
- 10 Jan 2027 Extended Kuala Lumpur arrangement ends; Strature forecast F-0209: 10% (2 Oct 2026) resolves [6] [9] Tentative · Strature date
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The other side
A waiver that holds keeps the truce and the recommended tariff cuts on about US$30bn each way [6] on track and keeps US imports of Chinese consumer goods cheaper. If the duties were used, suppliers outside China, Mexico and Southeast Asia among them, would gain US orders (Strature reading).
Connected in Strature
- China: Borrowing for the Past
- US–China trade
- Crude oil
- LNG
- Refined fuels
- China
- United States
- Russia
- Canada
- The US lifts its Graham Act waiver and puts secondary tariffs on a buyer of Russian oil Driven by: Parent: the same waiver decides any buyer; this card is the China limb.
- Russia's war reaches NATO's eastern flank Driven by: The war and the talks decide whether the waiver holds.
Sources
10 sources, numbered as the text cites them
- Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (EO 14436). The White House · 16 Oct 2026 · Official · confidence high · retrieved 25 Oct 2026
- US President signs Russia and Iran sanctions bill with new tariff powers. Baker McKenzie · 21 Sep 2026 · Commentary · confidence high · retrieved 25 Oct 2026
- Trump's decision to waive Russian sanctions outrages Congress, but no quick counter seen. AP via PBS NewsHour · 17 Oct 2026 · News · confidence high · retrieved 25 Oct 2026
- September 2026: Monthly analysis of Russian fossil fuel exports and sanctions. CREA · 16 Oct 2026 · Think tank · confidence high · retrieved 25 Oct 2026
- Trade in Goods with China. US Census Bureau · 2026-08 · Official · confidence high · retrieved 25 Oct 2026
- China announces 10 outcomes from latest trade talks with US. Global Times · 28 Sep 2026 · News · confidence medium · retrieved 25 Oct 2026
- Fact Sheet: President Donald J. Trump advances a fair and reciprocal relationship with China while hosting historic state visit. The White House · 25 Sep 2026 · Official · confidence high · retrieved 25 Oct 2026
- Announcement No. 10 of 2025 of the State Council Tariff Commission (24% suspended for one year from 10 Nov 2025). State Council Tariff Commission (HK TID circular, official excerpt) · 5 Nov 2025 · Official · confidence high · retrieved 26 Oct 2026
- Strature register, F-0209 (C-005, key question KQ-25). Strature · 2 Oct 2026 · Think tank · confidence high · retrieved 25 Oct 2026
- China says opposes unilateral sanctions with no authorization from UN. CGTN · 19 Sep 2026 · News · confidence medium · retrieved 26 Oct 2026
Reviewed 25 Oct 2026 · version 1 · last change: reviewed · All risks