Trade Policy Brief — May 2026
Published 16 May 2026 · By Dominique Zuffour
AGOA expired. What Madagascar EPZ exporters need to plan for in 2026.
AGOA's most recent reauthorisation lapsed on 30 September 2025 and, as of this brief's publication date, no successor framework is in force. Madagascar exports to the United States are operating under MFN tariff rates, and the apparel sector built around the AGOA edge is exposed in a way it has not been since the 2009 suspension. Here is what we know, what is still uncertain, and what to brief your buyers on this quarter — verify the current policy state with your customs broker before acting on any specific number.
30 Sep 2025
AGOA expiry date
Most recent reauthorisation lapsed. No successor in force.
MFN
Tariff regime now applicable
Most-Favoured-Nation duties replace duty-free preference on US-bound cargo.
~7–32%
Apparel duty range
Cotton, synthetic, and knitwear US MFN rates vary by HS line. AGOA was zero.
Open-ended
China LDC zero-tariff status
Madagascar retains duty-free entry into China — see our China brief.
Timeline
From 2000 to expiry — how we got here.
2000
AGOA enacted
African Growth and Opportunity Act passed by US Congress. Madagascar designated AGOA-eligible from inception, becoming a destination for apparel-sector EPZ investment.
2009 – 2014
Suspension and reinstatement
Madagascar suspended from AGOA following the 2009 political crisis, reinstated in 2014 after the return to constitutional order. EPZ apparel production rebuilt over the decade that followed.
30 Sep 2025
AGOA expires
Most recent reauthorisation lapses. No successor framework in force. Effective 1 October 2025, Madagascar exports to the US lose preferential duty-free entry and revert to Most-Favoured-Nation tariff rates.
Q4 2025 – 2026
Replacement under discussion
Successor legislation discussed in Congress and at USTR. As of May 2026 no replacement programme has been enacted. Operators are planning 2026 production cycles on the assumption of MFN tariffs.
Sector impact
Where the AGOA shock actually lands.
EPZ apparel & garments
high
The single largest exposure. Madagascar's apparel sector was built around the AGOA duty-free edge versus Vietnam and Bangladesh. MFN tariffs on cotton trousers (~16%), synthetic apparel (~32% on some HS lines), and knitwear (~10–18%) erase that edge. Buyers will rebalance unless Malagasy producers absorb part of the duty or buyers absorb the rest.
Vanilla & vanilla derivatives
low
Madagascar vanilla beans enter the US under low or zero MFN rates regardless of AGOA. The US market remains viable. Pricing pressure on vanilla is driven by global supply, not by AGOA expiry.
Seafood & crustaceans
low to medium
Most fresh and frozen seafood enters the US at low MFN rates. Processed seafood and prepared crustacean products face moderate duties — case-by-case HS verification recommended.
Essential oils (ylang-ylang, clove, vanilla extract)
low
Essential oils typically enter the US at zero or near-zero MFN. AGOA loss is not the binding constraint for this category.
Handicrafts, raffia, gemstones
medium
Mixed exposure. AGOA covered a number of artisanal HS lines. Without it, individual product categories revert to varying MFN rates — exporters should re-check tariff classification line by line.
What to do this quarter
A five-point operator checklist.
None of this is theoretical. These are the conversations every Malagasy exporter to the US should have already had with their forwarder, broker, and buyer.
1
Re-verify HS classification for every US-bound SKU
AGOA-era documentation referenced HS codes to claim preferential entry. With MFN now applicable, the same codes drive the duty calculation directly. A misclassification that didn't matter under AGOA can matter now. Have a customs broker re-validate every active SKU shipping to the US.
2
Brief US buyers on the landed-cost change
Many US buyers placed orders against quoted AGOA-duty-free landed cost. They need a written notification of the MFN tariff position, the duty rate by HS code, and a revised landed-cost schedule. Quiet on this and you risk chargebacks, refused shipments, or a buyer walking to a Vietnam alternative without a conversation.
3
Update commercial invoices and customs documentation
Commercial invoices for US-bound cargo should no longer reference AGOA preference claims. Certificate of origin (Form A or equivalent) requirements have changed in practice — confirm with your forwarder and US customs broker what is expected on the entry filing.
4
Clear in-transit AGOA-era shipments promptly
Shipments that physically left Madagascar before 30 September 2025 may have transitional treatment depending on date of US entry and CBP guidance. Coordinate with the US-side broker to clear these without exposure to dispute.
5
Diversify destination markets
Madagascar retains open-ended zero-tariff entry into China under the LDC scheme — see our China zero-tariff brief. Europe (EBA) and the UK (DCTS) preference schemes remain in force. The US is no longer the privileged market it was; rebalancing the export mix is a 2026 strategic question, not a 2027 one.
Questions we get
AGOA after expiry — operator FAQ.
- Has AGOA expired for Madagascar?
- Yes. AGOA's most recent reauthorisation expired on 30 September 2025. Madagascar — like every other previously eligible African country — no longer benefits from AGOA duty-free entry into the United States as of 1 October 2025. Imports from Madagascar revert to Most-Favoured-Nation (MFN) tariff rates unless and until a replacement preference programme is enacted by the US Congress.
- What does this mean for Madagascar EPZ garment exporters?
- Garments shipped from Madagascar's Export Processing Zone into the United States are now subject to MFN tariffs in the range of roughly 7% to 32% depending on HS code (cotton apparel, synthetic apparel, knitwear, and trousers each carry different rates). Under AGOA these products entered duty-free, which made Madagascar competitive with Vietnam, Bangladesh, and Cambodia despite higher production costs.
- Is a replacement programme being negotiated?
- Discussion of an AGOA successor framework has been ongoing in the US Congress and the Office of the US Trade Representative. As of May 2026 no successor legislation has been enacted. Operators should plan their 2026 production and shipping cycles on the assumption that MFN tariffs apply and price contracts accordingly.
- Are Madagascar's vanilla and seafood exports affected?
- Less than garments. Most of Madagascar's vanilla and seafood entered the US at low or zero MFN rates even before AGOA. The AGOA shock falls primarily on labour-intensive manufactured goods — apparel above all.
- Should we reroute Madagascar exports away from the US market?
- It depends on product and buyer. For premium vanilla, essential oils, and high-margin seafood the US market remains viable at MFN rates. For commoditised apparel where Madagascar competed on a duty-free edge, the calculus has shifted — buyers may relocate orders to Vietnam or Bangladesh unless production efficiency or geographic diversification arguments compensate. China is a separate opportunity: Madagascar retains open-ended zero-tariff entry into China under the LDC scheme.
- What documentation should Malagasy exporters prepare now?
- Exporters should re-verify HS classification for every line shipped to the US, confirm MFN tariff applicability, update commercial invoices and customs documentation to reflect the new duty position, and brief their US buyers on the landed-cost change. Pre-AGOA-expiry shipments that left Madagascar before 30 September 2025 should be cleared promptly to avoid being caught by the rate change at US entry.
Need to model the MFN-tariff landed cost on your specific HS lines?
Send us your top SKUs and US destinations and we'll come back with HS classification, applicable MFN rates, and a revised landed-cost schedule you can send to your buyer.