Secondary US tariffs: what changes for exporters shipping to Russia and the CIS
If you manufacture or supply goods that ship to Russia and the CIS, the next few weeks are better spent reviewing your contracts than reading forecasts. The bill passed by the US Congress does not ban industrial or consumer goods from entering Russia — it puts pressure on the countries and the companies around that trade. That is why a consignment now tends to stop at the payment or booking stage rather than at a customs post. For an exporter it shows up as a returned transfer, a shipping line declining a Russia-bound container, a compliance hold inside your own bank, and a buyer who asks to change the bank details and the delivery terms after the specification is already signed. Below is what changes for your shipment and what your Russian buyer will now require from you.
Who the secondary tariffs actually affect
In the early hours of 17 September the US House of Representatives passed a bill tightening sanctions on Russia: 262 votes in favour, 159 against. The Senate had approved the document earlier, on 7 August, and it now goes to the president for signature. It provides for restrictions on the senior political and military leadership and on state-owned companies, as well as secondary sanctions against Russia’s trading partners; a separate block tightens measures against Iran.
The provision that matters to a shipper is the option to impose tariffs of up to 100% on countries that remain the main buyers of Russian oil and gas. This is not a ban on trade with Russia, and it is not a new requirement for your export declaration. It is pressure on the country you ship from — China, India, Türkiye, or a European buyer of energy. Pressure of this kind almost never arrives as a direct prohibition. It arrives through the caution of banks, shipping lines, insurers and compliance departments, including your own, where declining a Russia-bound order is simply cheaper than assessing the risk.
Payments, routes and lead times: where your shipment really stops
The first bottleneck is money. Your bank, or a correspondent bank somewhere in the chain, may spend longer checking the purpose of the payment, ask for the contract and the invoice, and then return the transfer without explaining why. For you that is more than a delay: production does not enter the queue until payment is seen, and the agreed loading slot is gone. Keep alternative bank details in the contract and agree with your buyer in advance that a change of payment route does not count as a breach of your shipment dates.
The second is transport. Routes into Russia today are almost always multi-leg: an ocean leg to a transhipment port, then containers onward through a hub, or a rail or road leg. The more parties in the chain, the higher the chance that one of them revises its policy on Russia-bound cargo — and if you sell on C or D terms, that revision lands on you, not on the buyer. For urgent items it is worth pricing air freight as a backup: it costs more, but it saves the contract when an ocean slot falls through. Sea freight and rail remain the base options for volume, but they should no longer be your only option.
Shipments to Russia usually fail not at the customs post but earlier — because there is a single payment route and a single carrier. Build the second of each in now: looking for them on the day the bank returns your transfer is already too late.
The third is cost. Freight rates react to uncertainty faster than the rules themselves change: they rise on expectation. If you have a long-term contract at a fixed delivered price, a freight increase comes out of your margin on the very next shipment, and a price revision conversation with the buyer follows. Import duties and VAT on the Russian side do not change because of this bill, so any movement in your buyer’s landed cost will be traced straight back to the transport component — be ready to show that component separately.
For Russia-bound cargo the weak link today is the payment and the booking, not the customs post
Incoterms, sensitive goods and the papers your buyer will ask for
Incoterms is the set of international rules for the interpretation of trade terms, and it defines the point at which risk and cost pass to the buyer. In calm times the choice of basis is a pricing question. Right now it is a question of who controls the shipment. On C and D terms you arrange the transport: you pick the line, you carry the consequences if it declines the cargo, and you answer for the delay. On F terms the buyer pays the freight and switches the routing himself when a carrier changes its mind. Expect Russian buyers to push for FOB or FCA now — and in most cases that is in your interest too.
Product scope deserves separate attention. Dual-use items — electronics and components, measuring and test instruments, certain CNC machine tools, chemical raw materials — require care not only over the HS code but over the way the goods are described in the contract and the invoice. You are entitled to ask for end-use and end-user information, and your own compliance team will ask for it as well; how cleanly that is documented decides whether the batch ships or sits on internal review for several weeks. Settle the technical description before the specification is signed, not when the container is already at the port.
Then there is your buyer’s side of the paperwork, which starts with yours. Import into the EAEU requires certification: TR CU certificates or declarations of conformity, and state registration for some categories. Those documents are issued in Russia, but they are built on documents only you can supply — technical datasheets, the manufacturer’s declaration, quality management certificates, samples for laboratory testing and correct product labelling. When your buyer asks for them, that is not bureaucracy: without them the goods are stopped at customs clearance, and storage at the border is paid for by the day.
Situation and what to do
| Situation | What you risk | What to do |
|---|---|---|
| One correspondent bank in the payment chain | Payment returned, production slot and booking lost | Agree back-up bank details with the buyer and fix them in the contract |
| Contract on C or D terms | You choose the line and carry the delay if it declines Russia-bound cargo | Consider moving to an F term and hand routing control to the buyer |
| A single transport leg | Cargo stops, no alternative to switch to | Price a back-up route in advance, including air for the urgent part of the order |
| Price in the contract includes delivery | Freight increases hit your margin, then force a price revision | Split the goods price and the transport component in the contract |
| Sensitive goods without a precise description | Internal compliance review at your end, shipment delayed by weeks | Agree the technical description and end-use details before the specification |
| Certification documents not prepared for the buyer | Goods held at the EAEU border, storage costs, claims from the buyer | Send datasheets, manufacturer’s declaration, labelling and test samples early |
What the exporter should do
- Pull your live contracts for Russia and the CIS and write down for each one: delivery term, currency, bank, route and shipment date. It takes a day and immediately shows where you have a single point of failure.
- Have the conversation with your buyer about back-up payment details and record the agreement in the contract, not in an email thread between account managers.
- Check the HS code and the technical description of the goods, especially for electronics, equipment and chemical raw materials. Make sure the wording on the invoice matches the datasheets — a mismatch between the two is one of the most common reasons a consignment is held at the border.
- Assemble the document pack your buyer needs for clearance and certification: contract and specification, invoice, packing list, certificate of origin, datasheets, manufacturer’s declaration, labelling artwork and samples for testing. Send it before the goods move, not after.
- Price a second route: another transhipment port, rail, air for the urgent part of the batch. Count the full door-to-door time, not just the rate.
- Review the shipping plan for the quarter with your buyer: bring forward what is critical for his production and avoid stacking the whole volume into one large consignment.
- Put a reserve for transport into the budget and decide in advance who carries a freight increase — you or the buyer. Rebuilding a chain is slow and expensive, but it stays manageable if the numbers are done early.
Frequently asked questions
Does this mean we will be barred from shipping to Russia?
No. The document does not prohibit suppliers in India, China or Türkiye from trading with Russian companies. It creates a risk of higher tariffs for their countries when exporting to the US, and some counterparties will play safe on their own initiative.
Will import duty or VAT change for our goods entering Russia?
No. These are measures under US law. Your buyer’s customs payments in the EAEU are calculated under the same rules as before — what changes is the reliability of the supply chain, and the freight component of the landed cost.
Why is our Russian buyer suddenly asking to switch to FOB or FCA?
Because on F terms he books the vessel and can reroute the cargo himself if a carrier refuses Russia-bound containers. It also removes from you the risk of being blamed for a delay you cannot control.
Do we need anything extra in our export declaration?
Nothing new follows from this bill. What matters is accuracy: the goods description, the HS code and the end-use information should be consistent across the contract, the invoice and the technical documents.
The goods are already on the water and the payment has bounced. What now?
Tell the carrier and the buyer’s customs broker immediately, so the container does not sit accruing demurrage or run past the temporary storage limit at the port. In parallel, start the payment through the back-up route.
Should our buyer look for another supplier?
Not abruptly, and the same logic applies to you: it is wiser to find and test an alternative route or partner on a small trial shipment than to search for a replacement from scratch when an order is already burning.
Summary
The document passed by Congress does not target your export declaration; it targets the environment around your trade. Secondary tariffs of up to 100% are aimed at countries buying Russian energy, and the first to be cautious will be banks, shipping lines and insurers. Duty and VAT rates on import into the EAEU do not change — the reliability of the chain does. Review your delivery terms, the payment route, the back-up transport leg and the description of sensitive goods while there is still time, and get the certification documents to your buyer before the goods reach the border. Send us a request and we will go through your specific shipment with you, or look at the full range of logistics and customs clearance services.
We will plan the route and handle customs clearance in Russia for your shipment, so your buyer gets the goods released on time and you get one point of contact.
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