AGOA renewal does not restore Cameroon

Congressional extension of a unilateral trade preference resets the statutory sunset for countries already inside the programme, but it leaves terminated countries outside the border gate.[S01][S35] Enacted on 18 May 2000 as Title I of the Trade and Development Act of 2000 (Public Law 106-200), AGOA operates by amending Title V of the Trade Act of 1974 (the Generalized System of Preferences, or GSP, statute) and adding textile, apparel and monitoring provisions in 19 U.S.C. 2466a, 19 U.S.C. 2466b and 19 U.S.C. 3701 to 3741.[S01][S05][S0402] Whereas the general United States GSP programme expired on 31 December 2020 without subsequent renewal, AGOA had previously been extended through 30 September 2025 by the Trade Preferences Extension Act of 2015 (Public Law 114-27, enacted 29 June 2015).[S01][S05] When Congress did not pass reauthorising legislation before the end of fiscal year 2025, AGOA's statutory authority lapsed after 30 September 2025.[S01]

Between 1 October 2025 and 2 February 2026, preferential duty-free treatment under AGOA ceased at United States ports of entry.[S01][S0401] On 3 February 2026, Congress enacted Division I, Section 5019 of the Consolidated Appropriations Act, 2026 (Public Law 119-75), amending Section 506B of the Trade Act of 1974 (19 U.S.C. 2466b) and Section 112 of AGOA (19 U.S.C. 3721) by striking 30 September 2025 and inserting 31 December 2026.[S01][S0401] Seven months later, on 2 September 2026, Congress enacted Division B, Section 2008 of the Continuing Appropriations and Extensions Act, 2027 (Public Law 119-103), which struck 2026 and inserted 2028 across the general termination provision in 19 U.S.C. 2466b, the general apparel authority in 19 U.S.C. 3721(g), the regional apparel article programme in 19 U.S.C. 3721(b)(3)(A), and the third-country fabric programme in 19 U.S.C. 3721(c)(1).[S35] As shown in Exhibit 14, the statutory authorisation clock and Cameroon's country-eligibility clock have run on separate tracks since 1 January 2020.[S01][S02][S35][S0401]

The timeline in Exhibit 14 establishes that neither the February 2026 retroactive reauthorisation nor the September 2026 extension altered the roster of terminated countries.[S01][S35][S0401] What Exhibit 14 cannot establish is whether or when a future annual eligibility review might reinstate Cameroon, because country designation is governed by executive review of statutory compliance criteria rather than by appropriations extenders.[S01][S0402]

4.2 Retroactive reauthorisation creates working-capital friction even for eligible suppliers

For factories in countries that did hold beneficiary status in late 2025 and early 2026, the four-month lapse between 30 September 2025 and 3 February 2026 demonstrated that a retroactive congressional fix is not commercially equivalent to continuous legal authority.[S01][S0401] Under Section 5019(a)(2)(A) of Public Law 119-75, any entry of a covered article made after 30 September 2025 and before 3 February 2026 to which duty-free treatment under Section 506A of the Trade Act of 1974 (19 U.S.C. 2466a) or Section 112 of AGOA (19 U.S.C. 3721) would have applied on 30 September 2025 qualified for liquidation or reliquidation as though the entry had occurred on 3 February 2026.[S0401] However, Section 5019(a)(2)(B) and (C) required the importer to file a formal reliquidation request with the Commissioner of U.S. Customs and Border Protection (CBP) within 180 days after enactment containing sufficient information to locate or reconstruct the entry, and gave CBP up to 90 days after liquidation or reliquidation to pay the refund, explicitly without interest of any kind.[S0401]

In operational terms, an apparel importer bringing garments into the United States during the 126-day lapse had to post cash deposits at the most-favoured-nation (MFN) tariff rate at entry, finance that outlay for up to nine months while filing post-enactment reliquidation claims, and absorb the interest cost in full.[S0401] Moreover, Section 5019(a)(2)(D)(i) defined a "covered article" strictly as an article from a country designated by the President as a beneficiary sub-Saharan African country under Section 104 of AGOA (19 U.S.C. 3703) as of the day before the enactment of Public Law 119-75, locking out any shipment from a non-beneficiary country such as Cameroon.[S01][S0401]

4.3 A two-year legislative horizon is shorter than a textile factory investment cycle

Even for eligible countries, the legislative pattern of 2025 and 2026 shortened the planning window.[S01][S35] Whereas the AGOA Acceleration Act of 2004 (Public Law 108-274) and the Trade Preferences Extension Act of 2015 (Public Law 114-27) provided multi-year horizons to 2015 and 2025 respectively, the two 2026 enactments attached short extensions to appropriations bills: first an eleven-month extension to 31 December 2026 in Public Law 119-75 that omitted structural reforms proposed in earlier 119th Congress bills, and then a two-year extension to 31 December 2028 in Public Law 119-103.[S01][S35]

Industrial textile investments require far longer payback periods.[R10] In Cameroon, the announced Camtext SA integrated cotton-to-textile project (an announced third-party venture reported on 12 November 2025 at US$300 million, or 180 billion XAF, to process 12,000 tonnes of cotton fibre a year across Garoua and Dibamba) carries an estimated return on investment near 11 years and targets optimal capacity around 2033.[R09][R10] A capital programme requiring 11 years to recover capital cannot treat a unilateral tariff concession expiring on 31 December 2028 as a foundational revenue pillar.[R10][S01][S35] Moreover, during a 22 April 2026 congressional hearing and a 29 April 2026 Federal Register request for comments on AGOA modernisation, the United States Trade Representative (USTR) signalled support for moving toward a "more reciprocal AGOA", meaning post-2028 access may carry new bilateral conditions.[S01]