The following analysis was taken in part from NCBFAA Legislative Advisor, Sandler, Travis, & Rosenberg, P.A.:

On August 6th, President Trump issued an Executive Order citing the International Economic Emergency Powers Act (IEEPA) authority, imposing an additional 25% tariff on India because it imports Russian oil and oil products. It is important to note that this is not an increase to the IEEPA Reciprocal Tariff that was announced last week. This is a separate tariff imposed under IEEPA to address India’s imports of Russian oil and oil products. As such, we will refer to this tariff as the IEEPA Russian Oil Tariff. 

As of the effective date below, all goods from India will be subject to the MFN Duty, any applicable antidumping or countervailing duty, Section 201 Duty, the IEEPA Reciprocal Duty (25%), and the IEEPA Russian Oil Tariff (25%), unless an exemption applies.  

IEEPA – Russian Oil Tariffs on India

A summary of the IEEPA Russian Oil Tariffs is included below.

IEEPA authority based on a national security threat caused by Russia’s war with the Ukraine pursuant to Executive Order 10466.  

RATE: 25% ad valorem IEEPA Russian Oil Tariff

EFFECTIVE DATE: Effective 12:01 AM EDT on August 27th, 2025
(21 days after the issuance of the E.O.)

STACKABILITY: This 25% IEEPA Russian Oil Tariff will be in addition to the 25% IEEPA Reciprocal Tariff and any other duties applicable (e.g. MFN, ADD/CVD, etc.).

EXCEPTIONS

1. Goods In Transit:
   • Goods that are loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 AM EDT on August 27th, 2025 (21 days after the date of the EO), AND are entered for consumption or withdrawn from warehouse for consumption before 12:01 AM EDT on September 17th, 2025 will NOT be subject to the 25% additional IEEPA Russian Oil Tariff upon entry into the US.
2. Goods subject to Section 232 Duties:
   • Goods subject to Section 232 Duties in effect, which currently includes, steel, aluminum, autos, auto parts, and copper, or established in the future, will NOT be subject to the 25% additional IEEPA Russian Oil Tariff upon entry into the US. 
3. Goods identified in Annex II of Executive Order 14257 (Reciprocal Tariffs):
   • Articles listed in Annex II to Executive Order 14257 of April 2nd, 2025 (Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits), as amended, will NOT be subject to the 25% additional IEEPA Russian Oil Tariffs. 
4. Goods exempted under 50 U.S.C. 1702:
   • Goods that are for personal use, donations of food, clothing and medicine intended to relieve human suffering, merely informational materials, etc., will NOT be subject to the 25% additional IEEPA Russian Oil Tariff upon entry into the US.  

FTZ Goods

Products admitted to an FTZ after 12:01 AM EDT on August 27th must be admitted in privileged foreign status. Goods eligible for admission to an FTZ under domestic status are exempt from the tariffs.

Modification (Increase or Decrease)

INCREASE: If a country retaliates against US goods as a result of these tariffs, the President may increase or expand the scope of the tariffs.

DECREASE: If Russia or a country impacted by this order (India) is to address the international emergency, the President may decrease or limit the scope of the tariffs.

Duty Drawback

There is no express prohibition to claiming duty drawback on these tariffs.

Continued Monitoring

The Trump Administration will continue to monitor countries importing Russian oil and may expand the scope of coverage to other countries in the future.

RIM logistics, ltd. will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative if you have any further questions.