Trade Update: IEEPA Changes, India Duties, AGOA Reinstatement, and Bangladesh Agreement
Client Trade & Tariff Update – February 12, 2026
Below is a summary of several recent trade developments involving IEEPA/Reciprocal duties, Executive Orders, and reinstated preferential trade programs. Please review carefully, as some changes are official and active, while others are announced but not yet implemented.
India – Proposed Reduction of Reciprocal Tariff to 18% (Not Yet Active)
Reports indicate the proposed reduction of the IEEPA-Reciprocal tariff on Indian goods to 18% stems from a February 2026 U.S.–India trade understanding announced following a leader-level call. Followed by a Truth Social post by the President.
As of now, no formal implementing measure or CBP guidance has been issued. Until an official proclamation, Federal Register notice, or HTSUS update is published, the currently effective tariff provisions remain controlling for entry purposes.
India – Additional 25% IEEPA Duty (Russian Oil) Removed
A White House Executive Order dated February 6, 2026, removed the additional 25% IEEPA duty previously imposed on Indian-origin goods in connection with the purchase of Russian oil.
Effective: Goods entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EST, February 7, 2026
Key Points
· The additional 25% duty under EO 14329 has been terminated.
· HTS headings 9903.01.84–9903.01.89 are no longer applicable.
· Refunds of previously collected duties will follow standard CBP procedures.
The applicable IEEPA-Reciprocal duty for India is now 25% total (base rate only), unless a future reduction becomes official.
Bangladesh – Reciprocal Duty Reduced to 19% - Status: Announced – Not Yet Implemented by CBP
The United States and Bangladesh signed a reciprocal trade agreement establishing:
· New IEEPA-Reciprocal rate: 19% (reduced from 20%)
· Eligibility for Annex III product-specific exclusions
· Annex II statutory exclusions continue to apply
AGOA, HOPE, and HELP Programs Reauthorized - CSMS #67647279
On February 3, 2026, the President signed H.R. 7148, extending duty-free treatment through December 31, 2026 for:
· African Growth and Opportunity Act (AGOA)
· Haiti HOPE
· Haiti HELP
Program Resumption Dates
· February 6, 2026 (12:01 a.m.): SPI “D” available for AGOA claims
· February 9, 2026 (12:01 a.m.): Quota filing resumed for AGOA and Haiti programs
Retroactive Duty Refunds Available
Applies to eligible goods entered during the lapse: October 1, 2025 – February 3, 2026
Refunds apply only to:
· General (Column 1) ad valorem duties
Refunds do NOT apply to:
· MPF
· IEEPA/Reciprocal duties
· AD/CVD
· Section 232 duties
Filing Deadline:
All refund requests must be submitted by August 2, 2026 (180 days from enactment).
Filing Summary
· Unliquidated entries: File PSC + accelerated liquidation
· Liquidated (within protest period): File protest
Liquidated (past protest period): Submit written DIS request
Important
· No Federal Register notice has been published.
· No CBP CSMS guidance has been issued.
Continue applying current published rates until CBP provides formal instructions.
Important Compliance Reminder
A tariff change is not legally effective until one of the following occurs:
· A Federal Register Notice is published, and/or
· CBP issues formal guidance (e.g., CSMS message), and
· The change is implemented in the HTSUS
Announcements from the White House, USTR, trade groups, or social media do not authorize immediate changes to import processing.
We will continue monitoring all developing trade deals and will notify you as soon as official guidance is issued.
For assistance and additional questions, please reach out to Janel Group's Compliance Team or a Janel Group Representative.
Director of Trade Compliance
Senior Compliance Analyst