New U.S.–Bangladesh Reciprocal Trade Agreement adds up to 19% reciprocal tariffs on most Bangladeshi imports plus a preferential schedule for selected HTS lines.

REGULATORY BRIEFING – U.S.–BANGLADESH AGREEMENT ON RECIPROCAL TRADE

1. What changed

• The United States and Bangladesh signed the Agreement on Reciprocal Trade, establishing a new reciprocal tariff regime for bilateral trade.
• For U.S. imports of originating goods of Bangladesh, the United States will:

– Exempt certain specified HTS lines (listed in Schedule 2 to Annex I) from the additional reciprocal tariff established under Executive Order (EO) 14257 of April 2, 2025.

– Apply an additional ad valorem duty (a “reciprocal tariff”) of up to 19% on all other originating goods of Bangladesh, in addition to the normal MFN rate.

• The agreement also contains enforcement provisions allowing the United States to reimpose the full EO 14257 reciprocal tariff rate on some or all Bangladeshi imports if Bangladesh fails to comply with the agreement or enters into certain conflicting trade or digital agreements.
• The agreement will enter into force 60 days after both Parties exchange written notifications that domestic legal procedures are complete (no specific calendar date is given in the text; entry date will be announced separately).

2. Affected products

2.1 Scope of coverage

• The agreement applies to “originating goods of Bangladesh” as defined under rules of origin to be established under Article 6.3 (not yet detailed in the provided text). Only goods meeting those origin criteria will be subject to the reciprocal tariff treatment.
• Schedule 2 to Annex I (“Tariff Schedule of the United States”) lists specific HTSUS subheadings for which the United States will NOT apply the additional reciprocal tariff from EO 14257. Those lines will continue to pay only the normal MFN rate.
• All other originating Bangladeshi goods not listed in Schedule 2 will be subject to an additional ad valorem duty of up to 19% on top of the MFN rate.

Note: The provided excerpt references Schedule 2 but does not reproduce the line-by-line HTS list. Importers must consult the official Schedule 2 PDF to identify exactly which HTSUS subheadings are exempt from the additional reciprocal tariff.

2.2 Likely impacted sectors

Based on Bangladesh’s export profile to the United States, the following sectors are likely to be materially affected unless their HTS lines are specifically exempted in Schedule 2:

• Apparel and textiles (HTS Chapters 61–63)
• Footwear (Chapter 64)
• Certain home textiles and made-ups (Chapters 52–63)
• Leather goods and bags (Chapters 42, 64)
• Some light manufactured goods and industrial products (various Chapters 39, 40, 73, etc.)

Conversely, Schedule 2 may carve out specific lines (for example, certain apparel, industrial goods, or other priority products) from the additional reciprocal tariff. Only those HTS lines listed in Schedule 2 will avoid the EO 14257 add-on.

3. Rate changes

3.1 Baseline: EO 14257 reciprocal tariff

• EO 14257 (Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits) established an additional ad valorem duty on imports from certain countries, including Bangladesh, to be applied on top of MFN rates.
• Under this agreement:

– Paragraph 2 of Schedule 2: For originating goods of Bangladesh that are listed in Schedule 2, the United States “shall not apply the additional ad valorem rate of duty applicable to those goods as provided for in Executive Order 14257 of April 2, 2025, as amended.”

– Paragraph 3 of Schedule 2: “For all other originating goods of Bangladesh, the additional ad valorem rate provided for in Executive Order 14257 of April 2, 2025, as amended, shall be no higher than 19 percent.”

– Paragraph 4 of Schedule 2: The additional EO 14257 rate is applied “in addition to the United States’ MFN rate of duty in effect.”

3.2 Practical duty impact

• For HTS lines listed in Schedule 2 (originating goods of Bangladesh):

– Old: MFN rate + EO 14257 additional reciprocal tariff (rate per EO 14257; not specified here).

– New: MFN rate only (EO 14257 additional rate not applied).

• For all other originating Bangladeshi HTS lines:

– Old: MFN rate + EO 14257 additional reciprocal tariff (potentially higher or variable).

– New: MFN rate + additional ad valorem duty capped at 19%.

Thus, for many Bangladeshi-origin products, the agreement either:

• Eliminates the EO 14257 add-on (for Schedule 2 lines), or
• Reduces it to a maximum of 19% if EO 14257 would otherwise impose a higher rate.

3.3 Potential reimposition of higher rates

• Article 3.2(2): If Bangladesh enters into a new digital trade agreement with a third country that “jeopardizes essential U.S. interests” and consultations fail, the United States may terminate this agreement and “reimpose the applicable reciprocal tariff rate set forth in Executive Order 14257 of April 2, 2025.”
• Article 4.3(4): If Bangladesh concludes a new bilateral FTA or preferential economic agreement with a non‑market country that undermines this agreement and consultations fail, the United States may terminate this agreement and reimpose the EO 14257 reciprocal tariff rate.
• Article 6.4(2): If the United States considers Bangladesh non‑compliant with the agreement and consultations fail, the United States may reimpose the EO 14257 reciprocal tariff rate on certain or all imports from Bangladesh.

In any of these scenarios, the additional duty on affected Bangladeshi imports could rise above the 19% cap or be applied more broadly, depending on EO 14257’s structure.

4. Dates

• Signature date: February 9, 2026 (per PDF filename; confirm in official notice).
• Entry into force: Article 6.6 – 60 days after the Parties exchange written notifications certifying completion of their applicable legal procedures, or another date mutually decided.

– No specific calendar date is provided in the text; importers must monitor USTR and CBP for the formal implementation date.

• Bangladesh implementation timelines (relevant to admissibility and risk, but not direct U.S. duty rates):

– Border technology and paperless trade: by 2030 (Article 2.11(4)).

– Various SPS, biotech, labor, and environmental commitments have 180‑day, 24‑month, 3‑year, 5‑year, etc. timelines, but these primarily affect market access and enforcement, not U.S. tariff rates.

5. Required actions for importers, brokers, and compliance teams

5.1 HTS classification and origin review

• Identify all products imported from Bangladesh and confirm:

– Correct HTSUS classification.

– Whether the goods qualify as “originating goods of Bangladesh” under rules of origin to be issued under Article 6.3.

• Obtain and review Schedule 2 to Annex I (U.S. Tariff Schedule) to determine whether your HTS lines are listed:

– If listed: Plan for MFN-only duty (no EO 14257 add-on) once the agreement is in force.

– If not listed: Plan for MFN + additional ad valorem duty (up to 19%) under EO 14257 as modified by this agreement.

5.2 Duty rate and cost modeling

• For each Bangladeshi-origin HTS line:

– Determine current MFN rate.

– Determine current EO 14257 additional rate (from the EO 14257 implementation documents).

– Compare with the new regime:

• Schedule 2 lines: MFN only.
• Non‑Schedule 2 lines: MFN + capped 19% additional duty.
• Update landed cost models, pricing, and sourcing decisions accordingly.

5.3 Entry filing and programming

• Monitor CBP for:

– Any new Chapter 99 provisions or special program indicators (SPI) that will be used to claim the reciprocal tariff treatment or to identify goods subject to the capped 19% rate.

– Implementation instructions (CSMS messages, Federal Register notices) specifying:

• Effective date for entries.
• Whether the treatment applies based on entry date, export date, or date of importation.
• Any certification or documentation requirements to prove Bangladeshi origin.
• Coordinate with software providers and brokers to:

– Update tariff tables with new combined MFN + reciprocal rates.

– Add logic to apply or not apply the EO 14257 additional duty based on HTS and origin.

5.4 Supplier and contract management

• Communicate with Bangladeshi suppliers about:

– Origin documentation and any rules-of-origin requirements once published.

– Potential cost impacts and whether suppliers can adjust pricing or shift production to mitigate higher U.S. duties.

• Review long‑term contracts and Incoterms to determine who bears the risk of increased U.S. duties (buyer vs. seller) and whether duty escalation clauses apply.

5.5 Risk monitoring – potential reversion to higher tariffs

• Track USTR and White House announcements regarding:

– Bangladesh’s compliance with labor, environment, digital trade, and national security commitments.

– Any U.S. determination that Bangladesh has entered into conflicting agreements with non‑market countries or digital partners.

• Be prepared for:

– Rapid reimposition of higher EO 14257 reciprocal tariffs on some or all Bangladeshi imports if the United States invokes Articles 3.2(2), 4.3(4), or 6.4(2).

– Need to reprogram systems and re‑model costs if the agreement is terminated or suspended.

5.6 Forced labor and admissibility considerations

• Article 2.9(1) requires Bangladesh to adopt a prohibition on imports of goods made with forced or convict labor; it may recognize U.S. Section 307 determinations.
• While this does not directly change U.S. duty rates, it signals closer alignment on forced labor enforcement and may:

– Increase scrutiny on certain Bangladeshi supply chains.

– Lead to more information sharing that could affect Withhold Release Orders (WROs) or other U.S. enforcement actions.

• Importers should:

– Strengthen due diligence on Bangladeshi supply chains (especially apparel, textiles, and agriculture).

– Maintain documentation to respond to any CBP inquiries on labor conditions.

6. References and source documents

Primary USTR materials (as referenced in the press release):

• Agreement text (PDF):

– "AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THE PEOPLE’S REPUBLIC OF BANGLADESH ON RECIPROCAL TRADE" (Final 09FEB2026)

– Example link (from prompt): https://ustr.gov/sites/default/files/files/Press/Releases/2026/U.S.%20BGD%20Agreement%20on%20Reciprocal%20Trade%20Final%2009FEB2026%20LETTER.pdf

• Tariff schedule (critical for HTS impact):

– U.S. Tariff Schedule – Schedule 2 to Annex I (HTSUS lines exempt from EO 14257 additional duty and subject to MFN only).

– Bangladesh Tariff Schedule – Schedule 1 to Annex I (for exporters to Bangladesh; not directly relevant to U.S. import duty calculation but relevant for reciprocal treatment).

• Additional USTR documents:

– Joint Statement on United States–Bangladesh Agreement on Reciprocal Trade.

– Fact Sheet summarizing key commitments and sectoral impacts.

• Executive Order 14257 (for baseline reciprocal tariff structure):

– EO 14257 of April 2, 2025, “Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits.”

7. Key takeaways for compliance teams

• This agreement does not create a traditional FTA preference (no general duty‑free treatment); instead, it modifies and caps the additional reciprocal tariffs imposed under EO 14257 for Bangladeshi-origin goods.
• The main operational tasks are:

– Mapping your Bangladeshi HTS lines to Schedule 2.

– Determining which products will see the EO 14257 add‑on removed vs. capped at 19%.

– Updating systems and contracts to reflect new combined MFN + reciprocal rates as of the agreement’s entry‑into‑force date.

• Ongoing monitoring is essential because non‑tariff commitments (labor, environment, digital, national security) can trigger reimposition of higher EO 14257 tariffs if the United States finds Bangladesh non‑compliant or aligned with conflicting partners.