Russia-related tariffs remain waived and State can change the relief

U.S. importers should exclude the waived Graham Act duties from current cost estimates while retaining other applicable charges. Recalculate if presidential or delegated State Department action changes the waiver, using the action's scope, effective date and applicable country determinations.
Friday's order resolved the immediate Graham Act tariff question ahead of October 18 by waiving the new duties. Importers can remove that addition from current cost estimates while retaining a contingency for a later change to the waiver.
The October 16 order prescribes additional duties of 500 percent on Russian goods and 100 percent on goods from covered third countries, then waives their application. The President retains authority over further action, and the Secretary of State receives delegated waiver authority, consulting Treasury and USTR as appropriate. USTR monitors country activity and administers delegated tariff powers, but the order names no covered-country list and an agency report does not itself create a payable duty. Other applicable duties and sanctions restrictions retain their separate legal bases.