Trade Policy Brief — Updated June 2026
Published 16 May 2026 · Updated 18 June 2026 · By Dominique Zuffour
AGOA is back — but only through 2026. What Madagascar EPZ exporters should do now.
AGOA lapsed on 30 September 2025, but on 3 February 2026 it was reauthorised through 31 December 2026 — retroactively to the lapse date — so Madagascar's duty-free apparel preference into the United States is restored. Importers who paid Most-Favoured-Nation duties during the four-month gap can file refund claims. Two cautions temper the relief: the reauthorisation runs only to year-end 2026 with no extension yet beyond it, and AGOA-eligible goods are not exempt from the 2025 US reciprocal tariffs. Here is what to action this quarter — and why the 2027 question is already on the table. Verify the current policy state and any specific rate with your customs broker before acting.
3 Feb 2026
AGOA reauthorised
Duty-free restored through 2026, retroactive to 30 Sep 2025 (P.L. 119-75).
31 Dec 2026
Current expiry date
A one-year reauthorisation only. No extension beyond 2026 is yet enacted.
10–30%
Reciprocal tariffs still apply
AGOA goods are not exempt from the 2025 US reciprocal tariffs — duty-free is not the whole picture.
Open-ended
China LDC zero-tariff status
Madagascar retains duty-free entry into China — see our China brief.
Timeline
From 2000 to the 2026 cliff — 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 lapses
The most recent reauthorisation expires. For four months — October 2025 through January 2026 — Madagascar exports to the US lose duty-free entry and pay Most-Favoured-Nation rates at the border.
3 Feb 2026
Reauthorised — retroactively
President Trump signs the Consolidated Appropriations Act, 2026 (P.L. 119-75). Section 5019 reauthorises AGOA through 31 December 2026 and restores duty-free benefits retroactively to 30 September 2025. Importers who paid duties during the gap can file refund claims.
31 Dec 2026
The cliff ahead
The current authorisation expires again at year-end. No extension beyond 2026 is enacted; USTR has signalled a 'modernisation' aligned with America First trade policy. Long-term access is unresolved — plan the 2027 export mix now.
Sector impact
Where AGOA exposure actually concentrates.
EPZ apparel & garments
high
The single largest exposure. Madagascar's apparel sector was built around the AGOA duty-free edge versus Vietnam and Bangladesh. That edge is restored for 2026 — but if the preference lapses at year-end, MFN tariffs on cotton trousers (~16%), synthetic apparel (~32% on some HS lines), and knitwear (~10–18%) erase it again. Note too that the 2025 US reciprocal tariffs apply on top of the AGOA position, not instead of it — model both layers before quoting landed cost.
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's status.
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 covers a number of artisanal HS lines. If the preference lapses, individual product categories revert to varying MFN rates — exporters should re-check tariff classification line by line either way.
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
File refund claims for duties paid during the gap
The reauthorisation is retroactive to 30 September 2025. If you or your US importer of record paid MFN duties on shipments entered between October 2025 and the February 2026 reauthorisation, those duties are recoverable. Work with the US-side broker to file refund claims (post-summary corrections / protests) before the CBP window closes.
2
Restore AGOA preference claims on your documentation
Commercial invoices and the Certificate of Origin (Form A / AGOA Textile Certificate of Origin) should once again claim AGOA preference on US-bound cargo. Confirm with your forwarder and US customs broker exactly what CBP expects on the entry filing now that benefits are restored.
3
Re-verify HS classification for every US-bound SKU
HS classification drives both AGOA eligibility and the duty you would pay if the preference lapses — and it determines exposure to the 2025 US reciprocal tariffs, which apply to AGOA goods regardless. A misclassification cuts both ways. Have a customs broker re-validate every active SKU shipping to the US.
4
Brief US buyers on the full landed-cost picture
Duty-free preference is back, but landed cost is not simply zero: the 2025 reciprocal tariffs still apply on top of the AGOA position, and the preference itself is only secured through December 2026. Give buyers a written, HS-code-level landed-cost schedule that states both layers and the year-end expiry.
5
Plan the 2027 export mix now
AGOA is secured only through 31 December 2026, with no extension yet legislated. Madagascar retains open-ended zero-tariff entry into China under the LDC scheme — see our China zero-tariff brief — and Europe (EBA) and the UK (DCTS) preference schemes remain in force. Building optionality before the cliff is a 2026 decision, not a 2027 one.
Questions we get
AGOA after reauthorisation — operator FAQ.
- Has AGOA expired for Madagascar?
- No — not currently. AGOA lapsed on 30 September 2025, but on 3 February 2026 Congress reauthorised it through 31 December 2026 (Section 5019 of P.L. 119-75, the Consolidated Appropriations Act, 2026), retroactive to the lapse date. Madagascar's duty-free preference into the United States is restored for 2026, and importers who paid Most-Favoured-Nation duties during the October 2025–February 2026 gap can file refund claims. The reauthorisation runs only to year-end 2026; access beyond that is not yet legislated.
- What does this mean for Madagascar EPZ garment exporters?
- For 2026, EPZ garments again enter the United States duty-free under AGOA, restoring the edge versus Vietnam, Bangladesh, and Cambodia that briefly lapsed. Two caveats: the preference is secured only through 31 December 2026, and AGOA-eligible goods are not exempt from the 2025 US reciprocal tariffs (reported in the 10%–30% range on many African goods), so landed cost is not simply zero-duty. Model both the AGOA preference and the reciprocal-tariff layer per HS code.
- Is AGOA secure beyond 2026?
- Not yet. The February 2026 reauthorisation is a one-year measure expiring 31 December 2026. The US Trade Representative has signalled intent to 'modernise' AGOA in line with the administration's America First trade policy, and any extension requires fresh legislation from Congress. Operators should plan 2027 production and sourcing on the assumption that long-term access is unresolved.
- Are Madagascar's vanilla and seafood exports affected?
- Less than garments, and largely unchanged by AGOA's swings. Most of Madagascar's vanilla and seafood entered the US at low or zero MFN rates even before AGOA, so the programme's lapse and restoration matter less here. The AGOA question falls primarily on labour-intensive manufactured goods — apparel above all.
- Should we reroute Madagascar exports away from the US market?
- Less urgent than during the lapse, but still a live 2026 question because AGOA is secured only through year-end. For premium vanilla, essential oils, and high-margin seafood the US market remains viable regardless. For commoditised apparel that competes on a duty-free edge, build optionality before the December 2026 expiry — China offers open-ended LDC zero-tariff entry, and the EU (EBA) and UK (DCTS) preference schemes remain in force.
- What documentation should Malagasy exporters prepare now?
- Restore AGOA preference claims on commercial invoices and the Certificate of Origin (Form A / AGOA Textile Certificate) for US-bound cargo, re-verify HS classification for every line (it drives both AGOA eligibility and the reciprocal-tariff calculation), and — if duties were paid during the October 2025–February 2026 gap — coordinate with the US-side broker to file refund claims while the window is open.
Need to model your true landed cost — AGOA preference plus reciprocal tariffs — on specific HS lines?
Send us your top SKUs and US destinations and we'll come back with HS classification, the AGOA preference position, the applicable reciprocal-tariff layer, and a landed-cost schedule you can send to your buyer.