The ministry’s text, as Ulysmedia printed it, says that the republic is outside the tariff measures provided for by the document, that the ministry and the interested state bodies continue systematic work to protect and promote the state’s external economic interests, and that regular contacts with the American side are maintained to discuss questions of mutual interest. The outlet had sent its request while the bill was still in Congress and asked 3 things: whether the ministry saw a risk, whether Astana had sought clarifications, and whether exemptions had been discussed. Only the first gets an answer, and it is one clause long.
The law orders duties of up to 100% within 30 days of enactment on goods from any country that was among the 5 largest importers by volume of Russian crude oil or natural gas over the 12 months before enactment and keeps buying after the 30th day. That first ranking counts crude and gas together; the reviews every 180 days after it rank them apart. For gas there is an exemption, and it needs two conditions at once: imports below 15% of Russia’s gas exports, and significant steps to reduce them.
Only the first gets an answer, and it is one clause long.
Kazakhstan’s own figures put it near the cut. Its purchases from Gazprom were 4 billion cubic metres in 2025 and are planned at 11 billion in 2026, vice-minister of energy Kaiyrkhan Tutkyshbayev said on 16 September, with about 9 billion discussed for 2027. On a flat monthly profile that is about 9 billion cubic metres inside the law’s 12-month window, and CAW’s count of 18 September placed Kazakhstan fourth or fifth on that measure after China, Turkey and Belarus, beside Uzbekistan and within 1 billion cubic metres of France, Hungary and Japan, each of them at about 8 billion.
Gazprom itself said on 25 September that its pipeline sales to the near abroad grew 29% in the first half of the year, mainly on Kazakhstan. Kazakhstan passes the 15% test, at roughly 7% of Russia’s gas exports on CAW’s estimate; with imports rising, it has not shown that it meets the significant-steps one. Its exports to the United States ran at about $95 million a month in 2026, on the US Census count, which is what a duty would touch.
An amendment by Steny Hoyer and Marcy Kaptur that would have named the countries, Kazakhstan among them, did not enter the final text, Ulysmedia noted. What did enter it is the ranking rule, and the ranking is the US Trade Representative’s to publish: the written justification with the methodology is due to Congress by 8 October and the first duties by 18 October. Whether the ministry’s sentence rests on an American assurance, on the first wave’s combined ranking, or on a decision to buy less, the answer does not say.