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Which Countries Could the Graham Act’s Russian-Oil Tariffs Reach?
The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 requires duties of up to 100% on all goods from the largest buyers of Russian crude or gas that keep buying. What the law says, which countries bought the most in the 12 months before it, and what happens by 18 October.
No country had been named and no duty imposed under the Act by 6 October 2026. The deadline is 18 October 2026, unless the President waives the duty (Sec. 113 and 115).
Photo: The US Capitol at night, 8 December 2023. John Brighenti via Wikimedia Commons, CC BY 2.0.
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- Maximum duty on all goods
- 100%
- Review of the importer lists
- 180 days
Up to 100%, on top of existing duties; the Act sets no minimum.
The top 5 crude and top 5 gas importers are redetermined every 180 days after duties start.
The law
What does the Act do to countries that buy Russian oil and gas?
- 1
The Act became law on 18 September 2026 as Public Law 119-111. Section 113 requires the President, within 30 days, to raise the duty on all goods from certain countries to a rate of up to 100%, on top of existing duties.
Public Law 119-111, Sec. 113 · White House, 18 September 2026
- 2
A country is covered if it was among the five largest importers by volume of Russian crude oil, or of Russian gas, in the 12 months before enactment and knowingly buys again from the 30th day after enactment; or if it was among the “top 5 countries facilitating Russian oil sanctions evasion” in that period. For this test the Act defines crude oil as Harmonized System code 2709 and natural gas as code 2711, ‘petroleum gases and other gaseous hydrocarbons’, which covers pipeline gas and LNG but also liquefied petroleum gas (propane and butanes).
- 3
The Act names no country and sets no criteria for ranking the top 5 facilitators. A written justification must reach six congressional committees at least 10 days before a duty is imposed.
- 4
The President may waive any duty after certifying to Congress that a waiver is in the national interest and sending a report (Sec. 115). Ending a duty on a country needs a certification in a report to Congress and a congressional review of 30 days, or 60 days if the report is sent between 10 July and 7 September; the duty stays in place during that period (Sec. 117).
- 5
By 6 October 2026 no country had been named and no duty imposed: there was no presidential document, US Trade Representative notice or Treasury action under the Act in the Federal Register or on the agencies’ sites.
The test
Which countries are the largest buyers of Russian crude and gas?
The Act does not name the countries, and by 6 October 2026 no US agency had published a ranking. These tables show the public estimates for the latest 12 full months before enactment, September 2025 to August 2026. They use each country’s own trade data where it exists, and ship-tracking data from Kpler, as published by CREA and the KSE Institute, where it does not. The Act ranks countries by total volume. Its test refers only to ‘a foreign country’ and does not say how the EU is treated. These tables count each EU member on its own. The Congressional Research Service notes that the ordinary meaning of ‘country’ may weigh against treating the EU as one, while the US Trade Representative has acted against the EU as a whole under Section 301, and it leaves the question open. Counted as one, the EU would rank second for Russian gas and fifth for Russian crude.
Crude oil
| Country | Russian crude imported, September 2025 to August 2026 | Source |
|---|---|---|
| 1. China | 112.6 Mt | CREA (Chinese customs and Kpler) · Seaborne 71.0 and pipeline 41.6. KSE Institute’s seaborne figure agrees. |
| 2. India | 88.2–89.1 Mt | KSE Institute, Russian Oil Tracker · All seaborne. CREA (Kpler) gives 89.1. Indian customs report 80.7 for the 11 months to July 2026. |
| 3= Belarus | about 11 Mt | OPEC Annual Statistical Bulletin · Estimate: 220 kb/d of crude imports in calendar 2025, by the Druzhba pipeline from Russia. No source covers the 12 months; Belarus publishes no trade data by partner. |
| 3= Türkiye | 10.6–11.1 Mt | Eurostat (Türkiye’s own data) · Türkiye reports 10.26 for September 2025 to July 2026; August from KSE Institute and CREA. All seaborne. About 10.4–10.6 in the Act’s exact window. |
| 5. Slovakia | 3.3–3.7 Mt | Eurostat (Slovakia’s own data) · Slovakia reports 3.32 for September 2025 to July 2026; August not yet reported. Druzhba pipeline. An EU member, counted on its own. |
| 6–9 Syria | 2.1–2.7 Mt | CREA (Kpler) · No official data. The lower figure is read from a KSE Institute chart. Ranks 6 to 9 overlap and their order depends on the source. |
| 6–9 Egypt | 2.0–2.6 Mt | CREA (Kpler) · Egyptian customs report more than Kpler for February to June 2026, so Egypt could pass Syria. |
| 6–9 Hungary | about 2.0 Mt | Eurostat (Hungary’s own data) · Hungary reports 1.96 for September 2025 to July 2026, with no flows in February and March; August is not yet reported, and CREA records none that month. Druzhba pipeline. An EU member. |
| 6–9 Brunei | 1.6–2.4 Mt | CREA (Kpler) · Seaborne. No official data for these months, but Brunei’s own customs (UN Comtrade) report 0.95 for calendar 2025, against 1.54 in CREA’s data for that year, so the upper figure may be high. The lower figure is read from a KSE Institute chart. |
Natural gas
| Country | Russian gas imported, September 2025 to August 2026 | Source |
|---|---|---|
| 1. China | about 51–55 bcm | Gazprom Annual Report · Power of Siberia pipeline: 38.8 in calendar 2025 (Gazprom). Chinese customs, via CREA, record about 10% more by weight in these 12 months than in 2025 (33.8 Mt against 30.8 Mt), which would mean about 42.5. Plus about 12.4 of LNG (9.1 Mt, CREA). |
| 2. Türkiye | 18.7 bcm | Eurostat (Türkiye’s own data) · All 12 months reported. TurkStream and Blue Stream pipelines. About 18.3 in the Act’s exact window. |
| 3. Belarus | about 15.9 bcm | OPEC Annual Statistical Bulletin · Estimate: total gas imports in calendar 2025; Russia is the only supplier. No source covers the 12 months. |
| 4. France | 8.3–8.6 bcm | KSE Institute, Russian LNG Tracker · 6.1–6.2 Mt of LNG from Yamal (KSE Institute and CREA, both Kpler). No full official figure: French customs report Russian LNG only for September to December 2025 (1.42 Mt). An EU member. |
| 5. Uzbekistan | 7.5–9.5 bcm | Gazprom Annual Report · Our estimate: 6.48 in calendar 2025 (Gazprom), rising in 2026. Could rank 4th to 6th. |
| 6. Japan | 7.3–8.2 bcm | CREA (Kpler) · 5.4–6.0 Mt of LNG from Sakhalin-2; Japanese customs give the upper end. |
| 7. Hungary | 6.1–7.4 bcm | CREA (pipeline flows) · Via TurkStream and Serbia. Customs figures, by origin, give the lower end. An EU member. |
| 8. Belgium | 6.2 bcm | Eurostat (Belgium’s own data) · LNG at Zeebrugge. All 12 months reported. An EU member. |
Crude in million tonnes (Mt); gas in billion cubic metres (bcm), with LNG converted at 1.36 to 1.38 bcm per Mt. Ranges show the spread across sources. The Act sets no unit, and its window, 18 September 2025 to 17 September 2026, is about two weeks later than the months shown. The gas figures count pipeline gas and LNG only, not the liquefied petroleum gas and other gases that HS code 2711 also covers. Belarus rests on 2025 figures, because no source covers it for these months. China’s pipeline gas starts from Gazprom’s 2025 figure, because Chinese customs report it only by weight. Uzbekistan’s own reports to UN Comtrade cover 9 of the 12 months, but most of their weights are UN Comtrade estimates and their total, about 1.5 Mt, is far below Gazprom’s 6.48 bcm for 2025, so the table estimates Uzbekistan from Gazprom’s figure. Bulgaria is left out: Eurostat’s energy statistics record 14.3 bcm of its gas imports as coming from Russia in the ten months reported, but its customs data show only 2.3 Mt (about 3.2 bcm) from Russia in September 2025 to July 2026; most of the difference is gas passing through Bulgaria on the TurkStream route. Kazakhstan has no measured figure after April 2026 and could fall anywhere from 5th to 11th for gas. Counting only measured trade data, the five largest buyers would be China, India, Türkiye, Slovakia and Syria for crude, and China, Türkiye, France, Japan and Hungary for gas. Ship-tracking figures are revised each month; these were read on 6 October 2026.
Sec. 113(c) · Congressional Research Service, Legal Sidebar LSB11474
Timeline
What happens by 18 October, and after?
The Act is signed into law as Public Law 119-111.
Last day for the written justification to six congressional committees if a Sec. 113 duty is to start on 18 October (it must arrive at least 10 days before).
Deadline for duties on goods from Russia (up to 500%, Sec. 112) and from countries described in Sec. 113 (up to 100%). Purchases from this day count as new purchases under the importer test.
Within 180 days of first imposing Sec. 113 duties, and every 180 days after, the US Trade Representative, consulting the Secretaries of State and Energy, lists the top 5 importers of Russian crude and of Russian gas for the previous 12 months, and duties apply to them. The facilitator list has no such review.
Division A ends, except Sec. 201, which keeps the Iran Sanctions Act in force to 31 December 2031.
The second list
Who could be on the “top 5” facilitator list?
The Act defines countries facilitating Russian oil sanctions evasion as countries where foreign persons located, operating or organised there knowingly help get around sanctions on Russian-origin oil, including by financing or shipping it or serving shadow-fleet vessels (Sec. 113(i)(2)). It sets no criteria for picking the top 5 and no later review of that list. When the official list appears, the monitor will set it beside its own record of US, EU and UK measures by country.
The four countries
Where do India, the UAE, Türkiye and China stand?
| Country | Crude buyer rank | Gas buyer rank | What it means |
|---|---|---|---|
| China | 1st | 1st | The largest buyer of both. Duties would also need new purchases from 18 October 2026 and no waiver. |
| India | 2nd | Not among the largest | Meets the volume test for crude only. CREA records no Russian pipeline gas or LNG imports in the period. |
| Türkiye | 3rd, joint with Belarus | 2nd | On both lists. The gas exception spares a country that took less than 15% of Russia’s gas exports and has taken significant steps to cut them; it does not apply to crude. |
| UAE | Not among the largest | Not among the largest | CREA records no Russian crude or gas imports in the period, only oil products and a little coal. The UAE could be covered only through the separate “top 5” facilitator list. |
Ranks from the tables above. A rank alone does not trigger a duty: the country must also knowingly make new purchases from 18 October 2026, and the President may waive any duty after certifying to Congress that a waiver is in the national interest (Sec. 113(c) and 115).
CREA data, September 2025 to August 2026 · Graham Act buyer ranking (CSV) · Public Law 119-111, Sec. 113 and 115
Method
Data, method and sources
Download the data
How the monitor works
- Every record is a US, EU or UK measure as the authority published it, linked to the official page or act.
- Window: measures dated 1 January 2024 or later, to the list dates on the method page.
- Programme (Russia or Iran) is the authority’s own tag or regime; measures under other programmes are left out.
- Hong Kong is shown apart from mainland China, from the address the authority gives.
- Every record was checked a second time against an official source; corrections are made within two working days and logged.
How to cite. The Geopolitical Economist (2026). Third-Country Sanctions Monitor. Version 1, updated 7 October 2026. https://geopoliticaleconomist.com/research/trackers/third-country-sanctions
Change log
Published as version one: four countries, US, EU and UK measures since January 2024.
Not legal advice. A listing records an official action by the authority named; it is not a finding by this publication. Check the official list before acting. Corrections: write to [email protected] with the record ID and your source; corrections are made within two working days and logged on the method page.