USTR’s 2024 Russia WTO report confirms continued Russian import bans, retaliatory tariffs, and discriminatory internal taxes that materially affect U.S. imports.

Regulatory Briefing – USTR 2024 Report on Implementation and Enforcement of Russia’s WTO Commitments

1. Scope and Nature of Changes

This USTR report is an analytical and enforcement-status document, not a new U.S. regulation. It:

• Describes Russia’s current tariff, non‑tariff, SPS/TBT, and internal tax measures and their consistency with WTO rules.
• Documents Russian actions that restrict or distort imports from the United States.
• Summarizes U.S. enforcement steps (e.g., WTO disputes) and planned monitoring.

It does NOT itself change U.S. MFN/Column 1/Column 2 duty rates, HTS structure, or Chapter 99 provisions, nor does it create new U.S. import bans or quotas. However, it is relevant for:

• Understanding the trade environment for U.S. exporters to Russia.
• Anticipating potential future WTO or unilateral U.S. actions (e.g., disputes, countermeasures) that could eventually affect U.S. import tariffs or Chapter 99 measures.

2. Key Russian Measures Affecting U.S. Goods

2.1 Retaliatory Tariffs on U.S. Industrial Products

• In July 2018, Russia imposed retaliatory MFN tariffs of 25–40% on various U.S.-origin industrial products in response to U.S. Section 232 steel and aluminum measures.
• These rates are above Russia’s normal MFN applied rates but are described as within its WTO bound ceilings.
• The United States initiated a WTO dispute (DSU case launched August 27, 2018; panel established December 18, 2018; composed January 25, 2019). Russia requested suspension of the panel’s work in June 2023; the panel suspended work effective June 23, 2023.
• Product coverage is described generically as “various industrial products”; specific HS lines are not listed in the report.

Impact on U.S. trade:

• These are Russian import tariffs on U.S. exports, not U.S. import duties. They do not change U.S. HTS duty rates but materially reduce the competitiveness of U.S. goods in Russia.

2.2 Russian Agricultural Import Bans (Quantitative Restrictions)

• Since August 6, 2014, Russia has maintained a broad ban on imports of many agricultural and food products from the United States and certain other countries.
• Covered categories include (as described):
• Certain beef, pork, poultry, fish and seafood products.
• Fruits and nuts.
• Vegetables.
• Some sausages.
• Most prepared foods.
• Country coverage: initially U.S., EU, Canada, Australia, Norway; later expanded to Ukraine, Albania, Montenegro, Iceland, Liechtenstein, and in November 2024, New Zealand.
• In July 2023, Russia added additional fish and seafood products to the banned list.
• In September 2024, Russia extended the ban through December 31, 2026.

Impact:

• These are Russian import bans on U.S. exports; they do not alter U.S. import tariffs or admissibility rules.

2.3 Russian Export Restrictions and Duties

• Russia has imposed or maintained export bans, quotas, or duties on a wide range of products, including:
• Agricultural products: rice and rice groats (export ban, currently to December 31, 2024, not applied to EAEU members, and subject to further extension); rapeseed, soybeans, sunflower seeds and oil, sunflower oilcake (export duties in effect until August 31, 2026); various grains and oilseeds at different times.
• Industrial products: certain lumber (including logs), ferrous and non‑ferrous scrap (ferrous waste and scrap, stainless scrap and waste, scrap of other alloy steel, scrap of tungsten).
• These measures can affect global supply and pricing of fertilizers, grains, and metals, indirectly influencing U.S. import prices and sourcing strategies, but they are not U.S. import restrictions.

2.4 EAEU Common External Tariff and Russia’s WTO Bindings

• Russia has bound all 11,170 tariff lines in its WTO schedule and, as of January 1, 2020, implemented all bindings.
• Average bound MFN rates:
• All goods: ~7.5%.
• Industrial goods: 7.0%.
• Agricultural goods: 10.8%.
• Average applied MFN rates:
• All goods: ~6.5%.
• Industrial goods: 6.1%.
• Agricultural goods: 9.7%.
• Russia has completed ITA implementation, eliminating tariffs on IT products (computers, semiconductors, etc.).

Impact:

• These are Russia’s import tariffs on all origins; they do not change U.S. HTS or U.S. duty rates.

3. Russian Internal Measures with Trade Effects

These measures affect U.S. exports to Russia and may be relevant for WTO litigation or future countermeasures, but they do not directly change U.S. import tariffs or HTS classifications.

3.1 Automotive “Recycling Fee” and Excise Taxes

• Recycling fee: applied to a range of vehicles (passenger cars, agricultural/forestry machinery, construction equipment). Russia removed an explicit exemption for EAEU‑made vehicles but:
• Continues to increase the fee.
• Provides subsidies that effectively reimburse domestic (non‑foreign‑owned) producers, creating de facto discrimination.
• September 2024: recycling fee increased by 70–80% for passenger cars purchased for resale, light commercial vehicles, trucks, buses, trailers, and semi‑trailers, effective October 1, 2024.
• Excise tax on automobiles (July 2024 changes):
• Cars <150 hp: tax increased from 51 rubles/hp (~US$0.53) to 61 rubles/hp (~US$0.64); maximum ~9,150 rubles (~US$95.31) for a car just under 150 hp.
• Cars >150 hp: tax increased to 593–1,740 rubles/hp (~US$6.07–18.13/hp), implying:
• ~88,033 rubles (~US$917.01) for 151 hp.
• ~871,740 rubles (~US$9,080.63) for >500 hp.
• Russia plans to increase these excise rates by 4% annually over the next three years.
• Russia has acknowledged it does not produce passenger cars with engine power over 300 hp, so the highest rates fall almost entirely on imported vehicles.

3.2 Domestic Software and IT Tax Preferences

• VAT exemption for royalties on domestic software.
• Reduced corporate tax and social security contribution rates for domestic IT firms.
• Mandatory pre‑installation of specified Russian software on certain devices (smartphones, computers, tablets, smart TVs), plus a Russian app store.
• Restrictions and preferences for domestic software in government and critical infrastructure procurement.

3.3 Government Procurement and SOE Import Substitution

• 15% price preference for EAEU‑origin goods in government procurement; 30% preference for EAEU‑origin radio‑electronic products.
• Bans on procurement of certain imported goods where EAEU‑origin alternatives exist (machinery, vehicles, medical devices, pharmaceuticals, IT hardware/software, consumer electronics, construction materials, some agricultural products).
• Quotas requiring SOEs to source 40–90% of certain goods domestically.

3.4 SPS and TBT Barriers

• SPS: Russia maintains non‑science‑based measures (e.g., zero tolerance for ractopamine, trenbolone acetate, salmonella; near‑zero tetracycline limits; mandatory in‑Russia testing; restrictive biotech approvals; bans on U.S. animal feed, feed additives, and pet food).
• TBT: Non‑notified technical regulations (e.g., alcoholic beverages, GLONASS‑compatible avionics), burdensome GMP certification for human and veterinary pharmaceuticals, and labeling/traceability regimes that complicate customs clearance.

4. U.S. Import Side – Current Status

4.1 U.S. Imports from Russia

• U.S. goods imports from Russia in 2023: US$4.6 billion (down 68.3% from 2022 and 84.4% from 2012).
• Composition shift:
• Fertilizers: ~30% of 2023 imports (up from 12% in 2022).
• Inorganic chemicals: ~28% of 2023 imports (up 30% vs. 2022).
• The report attributes the sharp decline primarily to U.S. sanctions, export controls, and import bans adopted in response to Russia’s invasion of Ukraine, plus reputational risk.

Note: Specific U.S. HTS codes, Chapter 99 provisions, and duty rates for Russian-origin goods are governed by separate U.S. statutes, executive orders, and CBP/OFAC guidance, not by this USTR report. Those measures include, for example, revocation of PNTR and application of Column 2 rates to many Russian goods, and targeted import bans (e.g., on certain energy products, gold, etc.), which are not detailed in this document.

5. Dates and Timeframes

Key Russian measure dates (for context):

• August 6, 2014: Initial Russian agricultural import ban on U.S. and other countries.
• 2014–2024: Annual extensions and expansions of the food import ban; latest extension to December 31, 2026.
• July 2018: Russian retaliatory tariffs (25–40%) on certain U.S. industrial products.
• August 27, 2018: U.S. initiates WTO dispute against Russian retaliation.
• June 23, 2023: WTO panel work on that dispute suspended at Russia’s request.
• March 2022 onward: Multiple Russian export bans/quotas/duties on industrial and agricultural products.
• July 6, 2024: Extension of Russian export ban on rice and rice groats to December 31, 2024.
• September 2024: Extension of Russian food import ban to December 31, 2026.
• October 1, 2024: Effective date of 70–80% increase in Russian recycling fee for many vehicles.

6. Required Actions for U.S. Import/Trade Compliance Teams

Because this report does not itself change U.S. import law, there are no immediate HTS reclassification or duty‑rate changes required. However, compliance and trade strategy teams should:

6.1 For Companies Still Importing from Russia

• Confirm current U.S. sanctions and import bans:
• Review OFAC sanctions programs and BIS export controls related to Russia.
• Verify whether specific Russian-origin products (e.g., energy, metals, gold, certain industrial inputs) are subject to U.S. import prohibitions or special licensing.
• Confirm applicable U.S. duty treatment:
• Check whether the product is subject to Column 2 rates or any special Chapter 99 provisions (e.g., Russia-related measures enacted after revocation of PNTR).
• Validate HTS classification and duty rates in the current HTSUS.
• Assess supply risk:
• For products like fertilizers, inorganic chemicals, and metals, factor in Russian export restrictions and potential further tightening when planning sourcing and inventory.

6.2 For U.S. Exporters to Russia (and Their U.S. Brokers)

• Recognize that Russian measures described here (retaliatory tariffs, import bans, SPS/TBT barriers, labeling, GMP, encryption licensing) significantly restrict market access and may make shipments commercially or legally non‑viable.
• Ensure full compliance with U.S. export controls and sanctions before considering any Russia‑bound transaction.

6.3 Monitoring and Policy Planning

• Monitor USTR, CBP, and Federal Register for:
• Any new Section 301/232/201 or other trade remedy actions that might be justified by Russia’s WTO‑inconsistent measures.
• Any new Chapter 99 provisions or HTS amendments targeting Russian-origin goods.
• Use the report’s detail to support internal risk assessments and scenario planning for:
• Further U.S. tariff actions on Russian goods.
• Potential WTO‑authorized retaliation in the future.

7. References and Source Documents

Primary report:

• USTR, “2024 Report on the Implementation and Enforcement of Russia’s WTO Commitments” (December 2024):

https://ustr.gov/sites/default/files/2024%20Report%20on%20the%20Implementation%20and%20Enforcement%20of%20Russia%E2%80%99s%20WTO%20Commitments%20final.pdf

Related WTO and legal references (for deeper analysis):

• WTO Tariff Profile – Russian Federation (for bound vs. applied rates and HS coverage).
• WTO Dispute Settlement documents on Russia’s retaliation against U.S. Section 232 measures (panel established December 18, 2018; work suspended June 23, 2023).
• Treaty on the Functioning of the Customs Union in the Framework of the Multilateral Trading System (19 May 2011).

8. Bottom Line for Regulatory Briefing

• This USTR report is informational and enforcement‑oriented; it does not itself amend U.S. tariffs, HTS codes, or Chapter 99.
• It confirms that U.S. imports from Russia are already sharply reduced due to separate U.S. sanctions and import bans, and that Russia maintains multiple WTO‑problematic measures against U.S. exports.
• Compliance teams should treat this as context for risk and policy monitoring, not as a direct trigger for tariff or classification changes on U.S. import entries.