Congress Hands Trump a 100% Secondary-Tariff Hammer for Russian Oil Buyers: What China-, India- and Turkey-Origin Importers Should Do Now

Congress Hands Trump a 100% Secondary-Tariff Hammer for Russian Oil Buyers: What China-, India- and Turkey-Origin Importers Should Do Now

On Wednesday, September 16, the House passed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 by a vote of 262–159. The Senate had already passed it 86–11 in August, so the bill now goes straight to the president, and a White House official told Bloomberg he plans to sign it in the coming days. It was the last vote the House is expected to take before the November 3 midterms, and it landed one week before President Xi arrives in Washington for the September 24 summit.

Most of the coverage is about Ukraine and the Kremlin's reaction. For importers, the part that matters is narrower and more concrete: the bill creates a five-year statutory authority to impose an additional 100% tariff on countries that buy Russian crude oil, natural gas or petroleum products — including the top five purchasers, a list that includes China, India and Turkey — plus a blanket tariff of up to 500% on goods of Russian origin. Nothing changes at the entry line the day it is signed. But a signed statute is a very different thing from a threat on social media, and the countries in scope are three of the largest East Coast trade lanes. This article covers what the authority actually is, how a 100% line would land on the stacks those origins already pay, why a tariff that may or may not be used is the cleanest case for bonded storage in this entire cycle, and what to do this week. It complements the Section 301 explainer, the excess-capacity delay playbook and the bonded warehouse withdrawals guide.

What the bill does — and what it does not do

Three things are worth separating, because they get blended together in the headlines.

It is an authority, not a tariff. The Act *allows* the president to impose the duties; it does not impose them. Bloomberg reports the White House negotiated broad waivers into the text that give the president wide discretion not to apply the penalties at all. There is no automatic trigger, no published effective date and no Chapter 99 heading yet. If you file an entry on an India-origin machine tool on Monday, you pay exactly what you paid on Friday.

The rates are large by design. As reported, the bill permits a blanket tariff of up to 500% on Russian-origin goods and an additional 100% tariff on the top five importers of Russian energy and on countries that import Russian crude oil or natural gas or facilitate sanctions evasion. The authority sunsets after five years. A Democratic amendment to clarify that the European Union would not be treated as a single "country" for purposes of the top-five list was rejected, which is why Irish and EU officials spent Thursday playing down the risk.

It is a statute, which is the point. Every second-term tariff so far has rested on an executive authority — IEEPA (struck down by the Supreme Court in February), Section 122 (expired July 24), Section 232 and Section 301. This one would be an act of Congress with a five-year life, signed by a president who has already said he wants leverage over Beijing and New Delhi on Russian oil. That is why the U.S. Chamber of Commerce and the National Foreign Trade Council lobbied hard enough to stall the bill on September 3, and why the White House pushed it back onto the floor anyway.

The realistic read: the probability of a 100% line on all China-origin goods next month is low — it would blow through the roughly 20% new-duty ceiling both governments have described as consistent with the October 2025 truce, and the president has the waivers to avoid it. The probability that the authority is *used selectively* — against Turkey, against India in a stalled trade negotiation, against a narrow product list, or as a signed-but-suspended threat — is not low at all. Plan for optionality, not for a single outcome.

The stack today, and with a 100% line on top

A secondary tariff under this Act would be additional — a new layer on every duty the entry already carries. Here is the current picture for the three origins named most often, using a $100,000 entered value and a 3% general rate, no Section 232, no AD/CVD:

Add the pending 7.5% excess-capacity line for China and the top row reaches 148%. Add Section 232 steel or aluminum content at 50% and the India row goes from 63% to 163%. These are not numbers anyone expects to see on a broad basis. They are the numbers that decide whether a container gets entered, held or abandoned if the authority is ever pulled for a lane you are on, and a $100,000 shipment that costs $113,000 in duty is not a shipment — it is a General Order case.

Run your own lines through the tariff stacking calculator and the landed cost calculator before reading the next section, because the strategy depends entirely on whether a 100% line makes your product unsellable or merely painful.

Why a contingent 100% tariff is the textbook bonded case

Most of what this site has written about bonded warehouses in 2026 has come with a warning: bonding does not protect goods you are going to sell anyway, because duty is assessed at the rate in effect on the date you withdraw for consumption, not the date the goods arrived. For a tariff with a known effective date — the forced-labor action, the November 10 exclusion snap-back — the right move for near-term inventory is to enter or withdraw *before* the date, and bond only what may re-export.

This authority is different in one important way: it may never be used, and if it is used it may be lifted quickly. Secondary tariffs are a negotiating instrument. They get imposed to force a purchasing decision in New Delhi or Ankara and suspended the moment one is made. That profile is exactly what a Class 3 bonded warehouse is built for:

• Goods in bond pay nothing until withdrawn, and can stay in bond for up to five years — the same length as the authority itself. If a 100% line is imposed on your origin, you leave the goods where they are and wait it out, or you re-export them to Canada, Mexico or a third market without ever paying U.S. duty on a CBP Form 7512 withdrawal for exportation or transportation and exportation (IE/T&E). If the line is never imposed, you withdraw on your normal schedule and paid nothing for the insurance except storage.
• Partial withdrawals mean you do not have to choose all-or-nothing. Pull the pallets you will sell in the next 30 days at today's rate, and leave the rest under bond where the rate does not attach until you decide. The withdrawals guide walks through the mechanics.
• A warehouse entry (Type 21) preserves the value and classification on the day of arrival. It does not preserve the rate — but it does keep your options open, which is the only thing you can control about a tariff whose existence depends on a presidential determination.

The cost of that option is bonded storage per pallet plus the entry filing. For India- and Turkey-origin cargo at 13% today, the cost of being wrong in the other direction — entering $100,000 of goods for consumption two days before a 100% line publishes — is a $100,000 duty bill you could have avoided by leaving them in bond another week. Compare against the duty deferral calculator using your own storage quote and volume.

There is also a second bonded angle that has nothing to do with strategy. If a 100% line *does* land on a lane, a share of the cargo already on the water will be refused by consignees who cannot afford the duty. That cargo does not disappear; it goes to a General Order warehouse at the carrier's or NVOCC's expense, and the GO clock starts. Carriers and forwarders with India, Turkey or China exposure into the Southeast should know where their GO capacity is before they need it.

The seven-step checklist for this week

1. Sort your SKUs by origin exposure. China, India and Turkey are the named lanes; Bloomberg's list of the top five Russian energy buyers "includes" them, which means there are two more, and the EU-as-one-country question is open. Do not assume a Vietnam or Malaysia line is safe until the determination is published.
2. Model three scenarios per lane: today's rate, today plus the layers already on the calendar (7.5% excess capacity for China, the November 10 exclusion lapse), and each of those plus 100%. Importers running multi-line invoices generally do this in classification software such as Zonos, which saves a scenario per entry date rather than rebuilding the sheet every time a notice posts. (Disclosure: this is an affiliate link — FreightFigures may earn a commission if you sign up, at no additional cost to you. See our affiliate disclosure.) For a single line, the free tariff stacking calculator is enough.
3. Split inventory into "sell in 30 days" and "everything else." The first bucket gets entered or withdrawn for consumption on schedule; there is no reason to pay storage to defer duty on goods you are shipping to customers next month. The second bucket is the candidate for bond.
4. Convert arriving containers to warehouse entries at the port rather than at destination. A Type 21 entry filed at Charleston, with the container moved in-bond to the warehouse, keeps the goods under CBP custody from the terminal; a consumption entry at the port followed by a "we'll figure it out later" is the one option that closes the door. The Type 21 step-by-step covers the filing.
5. Check your continuous bond limit. A 100% line doubles-plus the duty exposure your surety is covering. If your continuous bond is sized to a 13% India stack, a secondary tariff makes it insufficient overnight and CBP will demand a rider. Run the customs bond calculator at the "with 100%" rate to see the gap.
6. Watch three dates, not one. The signing (this week, per the White House); the September 24 Trump–Xi summit, where Russian oil purchases are an obvious agenda item; and the UN General Assembly the same week, where the Ukraine track will be visible. A determination under the Act would most likely follow a failed negotiation on one of those tracks, not precede it.
7. Confirm re-export routing in advance. If you would rather re-export than pay 100%, know now which of your products can move to a Canadian or Mexican distributor, what the paperwork is, and which bonded facility can file the IE or T&E. The in-bond transit guide covers the movement types.

The Charleston angle

India is one of the largest non-China Asian lanes into the Port of Charleston, Turkey arrives on the Mediterranean services that call the Southeast, and a large share of China-origin volume that used to route through the West Coast now arrives via Suez on the East Coast. All three named origins are, in other words, Charleston origins. Two consequences follow. First, consignees on those lanes are the ones who most need a bond-first, withdraw-as-you-sell plan in place before any determination publishes, because the window between a determination and an effective date in this cycle has been as short as four days. Second, if a 100% line ever lands on one of those lanes, the carriers' General Order volume at Wando Welch and North Charleston goes up the same week.

C&C Warehouse is a CBP-bonded and General Order facility minutes from the Port of Charleston. It receives in-bond containers off the terminals, files Type 21 warehouse entries, handles partial withdrawals so you can pull next month's stock and leave the rest under bond, files re-export withdrawals for cargo that is better off leaving the country than paying the duty, and takes GO cargo from carriers and NVOCCs. If you have China-, India- or Turkey-origin containers landing at Charleston in the next 60 days, the form below reaches the operations desk directly; tell us the origin, the arrival window and how much of the load you expect to sell in the first 30 days, and we will tell you which pallets belong in bond and which do not. For background on the port, start with the Port of Charleston importer's guide.

FAQ

Is the 100% tariff in effect? No. As of September 19, 2026, the bill has passed both chambers and awaits the president's signature. Signing creates the authority; a separate presidential determination would be required to impose any tariff, and none has been announced.

Which countries could be hit? The Act covers the top five importers of Russian petroleum products and any country that imports Russian crude oil or natural gas or facilitates sanctions evasion. Bloomberg reports the top-five list includes China, India and Turkey. Whether the EU counts as one country was left open after a clarifying amendment was rejected.

Does the 100% replace the existing Section 301 tariffs? No. It would be an additional line on top of MFN, Section 301, Section 232 and any AD/CVD already on the entry.

Would goods already in a bonded warehouse be protected? Goods in bond are not assessed duty until withdrawn for consumption, so they can be held through a tariff and withdrawn after it is lifted, or re-exported without paying U.S. duty. They would still pay the 100% if withdrawn for consumption while it is in effect.

How long does the authority last? Five years from enactment, as reported.

Is there a bonded and General Order warehouse near the Port of Charleston that can hold India-, Turkey- or China-origin cargo through a determination? Yes. C&C Warehouse is a CBP-bonded and General Order facility minutes from the port that receives in-bond containers, files Type 21 entries, handles partial and re-export withdrawals and accepts GO cargo.

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