AFRICAN GROWTH 

AND OPPORTUNITY 

ACT

Insights from Other 

Countries' Preference 

Programs and 

Participation in Trade 

Negotiations

Report to Congressional Requesters

August 2015

GAO-15-701

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-701, a report to 

congressional requesters

August 2015

AFRICAN GROWTH AND OPPORTUNITY ACT

Insights from Other Countries’ Preference Programs 

and Participation in Trade Negotiations

Why GAO Did This Study

AGOA was signed into law in 2000 to 

offer SSA countries trade preferences 

that stimulate export-led economic 

growth and facilitate their integration 

into the global economy. This 

legislation was recently reauthorized, 

and the accompanying Senate report 

stated that the United States should 

seek all opportunities to deepen and 

expand its ties with SSA countries 

through accession by SSA countries to 

the WTO and negotiation of bilateral 

trade agreements. GAO was asked to 

identify lessons learned from other 

countries’ trade preference programs 

and SSA countries’ recent trade 

negotiation experiences. 

This report (1) compares AGOA with

selected countries’ trade preference 

programs in terms of key 

characteristics and performance, and 

(2) examines AGOA countries’ 

participation in trade negotiations. 

GAO reviewed and analyzed 

documents and data, including 

information from the WTO to determine 

what portion of the imports from AGOA 

countries to major trade partners could 

enter under preference programs. 

GAO also interviewed officials from 

U.S. government agencies, African and 

other foreign governments, and 

international organizations. GAO 

selected countries and regions for 

comparison that are major export 

markets for sub-Saharan Africa,

including the EU, China, India, and 

Japan. 

What GAO Recommends

GAO is not making any 

recommendations in this report. 

Agencies’ technical comments on 

GAO’s draft were incorporated into this 

report. 

What GAO Found

The United States’ African Growth and Opportunity Act (AGOA) has differences 

from and similarities to 26 trade preference programs offered by other developed 

and developing countries in three key areas that can affect program performance 

in increasing and diversifying trade.

• Country eligibility. AGOA is unique in that it focuses eligibility on subSaharan African (SSA) countries. Most other countries’ trade preference 

programs do not restrict eligibility to SSA countries. 

• Product coverage. AGOA and some other countries’ trade preference 

programs provide fairly comprehensive coverage of products, but exclude 

some agricultural and other products that are important SSA exports.

• Rules of origin. Like other countries’ trade preference programs, AGOA has 

rules of origin that determine which products qualify for coverage. Some 

countries, including the United States have recently made their rules of origin 

less restrictive, to make it easier for beneficiary countries to take greater 

advantage of these programs.

In 2014, the United States International Trade Commission reviewed studies 

comparing the performance of trade preference programs and found that the 

European Union’s (EU) preference programs have had overall greater success in 

increasing trade with Africa and that AGOA had more success in increasing 

diversification in the range of products exported from Africa. Research on China’s

and India’s trade preference programs suggests that their fairly new programs 

could have significant impacts on SSA trade and that they are among the biggest 

and fastest growing markets for sub-Saharan exports.

As the United States continues to pursue expanded trade and a more two-way 

trade relationship with African partners at the World Trade Organization (WTO) 

and elsewhere; SSA countries’ recent participation in bilateral and multilateral 

trade negotiations provides insights that can inform future U.S. negotiations. For 

example, years of bilateral negotiations between SSA countries and the EU have 

recently resulted in Economic Partnership Agreements with 32 SSA countries. 

Trade experts and SSA and EU officials GAO spoke with provided information 

about these negotiations that indicates that transitioning from non-reciprocal 

trade preference programs, such as AGOA, to two-way trade agreements like the 

Economic Partnership Agreements with SSA countries may require: 

• many years to finalize and implement,

• the establishment of timeframes to end access to trade preference programs,

• a willingness to consider limiting the initial scope of the agreements, and 

• an acknowledgment that aspects of the agreements may have tradeoffs and 

could constrain SSA countries’ ability to integrate into the global economy.

The involvement of SSA countries in recent multilateral negotiations at the WTO 

also yields important insights for U.S. agencies when negotiating with these 

countries. SSA and WTO officials told GAO that several Impediments, such as 

inadequate funding and staffing, can hamper SSA countries’ ability to participate 

fully in multilateral negotiations. However, recent bilateral and multinational 

funded training and other efforts have helped expand SSA country participation 

at the WTO. 

View GAO-15-701. For more information, 

contact Kimberly Gianopoulos at (202) 512-

8612 or GianopoulosK@gao.gov.
Page i GAO-15-701 African Growth and Opportunity Act

Letter 1

Background 3

AGOA Has Differences from and Similarities to Other Countries’ 

Trade Preference Programs and Differences Have Affected 

Program Performance 9

Sub-Saharan African Countries’ Recent Trade Negotiations 

Provide Insights for Future Negotiations 23

Agency Comments 37

Appendix I Objectives, Scope, and Methodology 40

Appendix II Additional Information about Trade Preference Programs of Countries 

That Are Major Importers of Products from Sub-Saharan African 

Countries 44

Appendix III Selected Trade Preference Programs’ Sub-Saharan African Country 

Eligibility 47

Appendix IV Margins of Preference 50

Appendix V Rules of Origin for Select Sub-Saharan African Trading Partners 52

Appendix VI GAO Contact and Staff Acknowledgments 55

Tables

Table 1: World Trade Organization (WTO) List of Preferential 

Trade Programs, by Type 5

Table 2: Number of Countries Eligible for Select Trade Preference 

Programs 10

Contents
Page ii GAO-15-701 African Growth and Opportunity Act

Table 3: Key Characteristics of Trade Preference Programs of 

Countries That Are Major Importers of Products from SubSaharan African (SSA) Countries 45

Table 4: Sub-Saharan African Countries Eligible for Trade 

Preference Programs Offered by Major Sub-Saharan 

African Trading Partners 47

Table 5: Average Tariffs Charged by Developed Countries and 

Select Developing Countries on Key Products from LeastDeveloped Countries 50

Table 6: Rules of Origin for Select Countries 52

Figures

Figure 1: Exports from AGOA Countries to Major Importing 

Countries or Regions, 2010-2014 8

Figure 2: Trade-Weighted Preferential Tariff Coverage of AGOA 

Country Imports for Six Countries in 2012 16

Figure 3: Sub-Saharan African Countries That Have Negotiated 

Regional or Interim Economic Partnership Agreements 

with the European Union 25

Figure 4: Key Events during the Negotiation of Economic 

Partnership Agreements between Sub-Saharan African 

Countries and the European Union 28
Page iii GAO-15-701 African Growth and Opportunity Act

Abbreviations: 

AGOA African Growth and Opportunity Act

AGOA country country eligible for AGOA benefits

ASEAN Association of Southeast Asian Nations 

CARICOM Caribbean Community

DFQF duty-free and quota-free 

DRC Democratic Republic of the Congo 

EAC Eastern African Community 

EBA Everything but Arms

EPA Economic Partnership Agreement

EU European Union

FOB free on board

FTA free trade agreement 

GATT General Agreement on Tariffs and Trade 

GNI gross national income 

GSP Generalized System of Preferences 

IDB Integrated Data Base 

LDC least developed country

LDC program LDC-specific program

LDCT Least Developed Country Tariff 

Mercosur Common Market of the South 

MFN most favored nation 

NGO nongovernmental organization

SAARC South Asian Association for Regional Cooperation 

SACU Southern African Customs Union Southern African

Customs Union 

SADC Southern African Development Community 

SSA sub-Saharan Africa

UNCTAD United Nations Conference on Trade and 

Development 

USAID U.S. Agency for International Development 

USITC U.S. International Trade Commission 

UN United Nations 

USTR Office of the U.S. Trade Representative 

WAEMU West African Economic and Monetary Union

WTO World Trade Organization

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Page 1 GAO-15-701 African Growth and Opportunity Act

441 G St. N.W.

Washington, DC 20548

August 5, 2015

Congressional Requesters

The African Growth and Opportunity Act (AGOA) was signed into law in 

2000 to help promote free markets in sub-Saharan African (SSA) 

countries, stimulate economic development through export-led growth, 

and facilitate SSA countries’ integration into the global economy.1 AGOA 

is a trade preference program that seeks to promote these goals by 

offering eligible SSA countries the ability to export qualifying goods to the 

United States without import duties. As of January 1, 2015, 39 countries 

were eligible for AGOA benefits (AGOA countries). Congress recently 

extended the authorities enacted in AGOA until September 30, 2025.2

We were asked to examine a range of issues relating to AGOA’s 

effectiveness in promoting trade expansion and economic development, 

and factors that affect SSA trade with the United States and other 

countries. We previously addressed several of these issues, such as 

trade-offs associated with changing AGOA according to proposals by the 

President, in recent reports.

Both AGOA and the reauthorization legislation emphasize that it is U.S. 

policy to seek to deepen and expand trade and investment ties between 

sub-Saharan Africa and the United States through the negotiation of free 

trade agreements, among other things. Such agreements have the 

potential to catalyze greater trade and investment, facilitate additional 

investment in sub-Saharan Africa, further poverty reduction efforts, and 

promote economic growth.

3

 1

Pub. L. No. 106-200, Title I, § 101, May 18, 2000, as amended; codified at 19 U.S.C. § 

3701 et seq.

In this report, we examine (1) how selected

2

Trade Preferences Extension Act of 2015, Pub. L. No. 114-27, June 29, 2015.

3

GAO, African Growth and Opportunity Act: Lessons Learned from Other Countries’ Trade 

Arrangements with Sub-Saharan Africa, GAO-15-393R (Washington, D.C.: Feb. 25, 

2015); African Growth and Opportunity Act: Eligibility Process and Economic Development 

in Sub-Saharan Africa, GAO-15-300 (Washington, D.C.: Feb. 12, 2015); African Growth 

and Opportunity Act: USAID Could Enhance Utilization by Working with More Countries to 

Develop Export Strategies, GAO-15-218 (Washington, D.C.: Jan. 22, 2015); and African 

Growth and Opportunity Act: Observations on Competitiveness and Diversification of U.S. 

Imports from Beneficiary Countries, GAO-14-722R (Washington, D.C.: July 21, 2014). 

Letter
Page 2 GAO-15-701 African Growth and Opportunity Act

countries’ trade preference programs compare with AGOA in terms of key 

characteristics and performance, and (2) AGOA countries’ participation in 

trade negotiations.

To address these objectives, we identified and reviewed documents, 

data, and literature on AGOA and other countries’ trade preference 

programs, trade agreements with AGOA countries, and SSA countries’

participation in multilateral trade negotiations. In addition, we interviewed 

officials from the Departments of Agriculture, Commerce, State, and the 

Treasury; the Office of the U.S. Trade Representative (USTR); the U.S. 

International Trade Commission (USITC); and the U.S. Agency for 

International Development (USAID). We conducted fieldwork in Geneva, 

Switzerland, and Brussels, Belgium. We selected those locations for 

fieldwork based on our ability to interview multiple U.S. and African 

government officials,4 government officials from countries with trade 

preference programs,5

 4

We interviewed African government officials from Ethiopia, Lesotho, Mauritius, Nigeria, 

South Africa, and Uganda—countries we selected because they represent a range of 

sizes, face a range of trade challenges, and actively use AGOA benefits.

and representatives from think tanks and 

multilateral organizations with pertinent expertise. We selected countries 

and regions for comparison that are major export markets for subSaharan Africa including the European Union (EU), China, and India. We 

identified three key characteristics for comparison on the basis of studies 

of preference programs that generally show that these characteristics can 

affect program performance in increasing and diversifying trade and 

increasing program utilization. However, we did not independently assess 

the other countries’ trade preference programs and agreements with SSA 

countries. The information on those programs and agreements is based 

on interviews and World Trade Organization (WTO) and other official 

sources, including a 2014 USITC study of AGOA that includes a 

comprehensive review of economic literature on trade preference 

program performance. Insights discussed herein reflect our analysis of 

the views of those we interviewed as well as those of selected academic 

literature. See appendix I for a more detailed discussion of our scope and 

methodology.

5

We interviewed government officials from Australia, Brazil, Canada, China, and the 

European Union (EU)—countries and regions we selected based on the amount of trade 

they conducted with SSA countries.
Page 3 GAO-15-701 African Growth and Opportunity Act

We conducted this performance audit from June 2014 to August 2015 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Trade preference programs were instituted by several advanced 

economies in the 1970s as temporary measures to help developing 

countries pursue economic growth and development by increasing 

exports and diversifying their economies. Trade preferences, which 

reduce tariffs, or duties, for many products from eligible countries, are 

“nonreciprocal”—i.e., granted unilaterally, without requiring reciprocal 

liberalization for U.S. goods for countries receiving them. In 1968, the 

United States supported a United Nations (UN) resolution to establish a 

mutually acceptable system of preferences. To permit the implementation 

of the generalized preferences, in June 1971, developed countries, 

including the United States, were granted a 10-year waiver from their 

obligations under the global trading system, now embodied in the WTO, 

to trade on a most favored nation (MFN) basis.6

 6

MFN trade is a long-standing principle and a requirement on WTO members promulgated 

in Article I of the General Agreement on Tariffs and Trade (GATT). The article provides 

that contracting parties to GATT must grant each other treatment as favorable as they 

give to any other country in the application and administration of import duties.

Following the granting of 

this waiver, developed countries created Generalized System of 

Preferences (GSP) programs, and Congress enacted the U.S. GSP 

program in January 1975. At the 1979 conclusion of the Tokyo Round of 

Multilateral Trade Negotiations, an agreement with no expiration date 

(known as the Enabling Clause) replaced the waiver. As they developed 

economically, beneficiary countries were to eventually move on from 

unilateral preferences and participate more fully in the global trade 

system, including by undertaking reciprocal trade commitments to 

liberalize their own markets. Under U.S. law, the AGOA program is linked 

to the GSP program in several important ways. For example, some of the 

authorities and limitations on what products can be included in the 

Background

Trade Preference 

Programs
Page 4 GAO-15-701 African Growth and Opportunity Act

program are based on or relate to GSP, and country eligibility for AGOA 

involves first being eligible for GSP. But at the WTO, because the 

Enabling Clause applies to preference regimes that are “generalized, 

non-reciprocal, and non-discriminatory,” a separate U.S. waiver was 

sought for AGOA, as well as other regional preference programs.7

Despite relatively rapid economic growth in developing countries, 

developed countries have reformed and extended their programs and the 

number of preference programs has grown. The WTO’s 2014 World 

Trade Report shows that, over the 2000-2012 period, developing 

countries grew faster than developed countries, and now account for 

nearly half of world exports. Since 2010, Japan, the EU, and Canada 

have reformed and extended most of their preference programs. 

Congress recently passed legislation to extend AGOA and other U.S. 

preference programs by 10 years. Developed countries had already 

added more generous preferences for least developed countries (LDC) to 

their GSP programs by the mid-2000s, and some key developing 

countries have since introduced new trade preferences targeted at LDCs, 

including some in sub-Saharan Africa. For example, both China and India 

have established LDC programs in the last decade. These programs are 

part of broader strategies to strengthen commercial ties, according to 

Chinese government and international organization documents.8

According to the WTO, there are now a total of 27 preferential trade 

programs.9

 7

See WTO, the Decision on Differential and More Favourable Treatment Reciprocity and 

Fuller Participation of Developing Countries, Nov. 28, 1979, GATT Doc. L/4903, known as 

the Enabling Clause, paras. 3(a) and (b).

They can be categorized into three types:

8

For a discussion of these strategies and efforts see, for example, GAO, Sub-Saharan 

Africa: Trends in U.S. and Chinese Economic Engagement, GAO-13-199 (Washington, 

D.C.: Feb. 7, 2013); White Paper on China-Africa Economic and Trade Cooperation 2013, 

English version accessed June 29, 2015,

http://english.gov.cn/archive/white_paper/2014/08/23/content_281474982986536.htm; 

WTO and the Confederation of Indian Industry, India-Africa: South-South Trade and 

Investment for Development, 2013; and International Trade Centre, SITA Newsletter:

Supporting Indian Trade and Investment for Africa, (March 2015), accessed June 29, 

2015, http://www.intracen.org/sita/.

9

Although the WTO Preferential Trade Arrangements database uses the term 

arrangements, we refer to the arrangements as programs for the purposes of this report.
Page 5 GAO-15-701 African Growth and Opportunity Act

• GSP programs, which were put in place by developed countries to 

help all developing countries. Developed countries’ GSP programs 

also include subprograms, GSP-LDC, that offer least developed 

countries more generous preferences than the other GSP 

beneficiaries.

• LDC-specific programs (LDC programs), which were put in place by 

developing countries to help least-developed countries.

• Other preferential trade arrangements, which are offered by 

developed countries and focus on a particular country or subset of 

developing countries within a particular region.

Seventeen countries or groups of countries, such as the EU and the 

Russian Federation, have GSP or LDC programs not restricted to a 

region.10

Table 1: World Trade Organization (WTO) List of Preferential Trade Programs, by Type

Table 1 lists the 27 preferential trade programs by type, 

provider, and date of initial entry into force.

Name Provider(s)

Date of initial entry into 

force

Generalized System of Preferences (GSP)

Generalized System of Preferences - Australia Australia 1/1/1974

Generalized System of Preferences - Canada Canada 7/1/1974

Generalized System of Preferences - European Union European Union 7/1/1971

Generalized System of Preferences - Iceland Iceland 1/29/2002

Generalized System of Preferences - Japan Japan 8/1/1971

Generalized System of Preferences - New Zealand New Zealand 1/1/1972

Generalized System of Preferences - Norway Norway 10/1/1971

Generalized System of Preferences - Russian Federation, Belarus,

Kazakhstan

Russian Federation, Belarus, 

Kazakhstan

1/1/2010

Generalized System of Preferences - Switzerland Switzerland 3/1/1972

Generalized System of Preferences - Turkey Turkey 1/1/2002

Generalized System of Preferences - United States United States 1/1/1976

 10The WTO Preferential Trade Arrangements database compiles information that is 

required from WTO members about their nonreciprocal trade preference program. WTO 

Preferential Trade Arrangements database, accessed June 23, 2015, 

http://ptadb.wto.org/?lang=1. It does not include the EU’s Cotonou arrangement 

preferences for the Africa, Caribbean, and Pacific region because they are no longer 

available.
Page 6 GAO-15-701 African Growth and Opportunity Act

Name Provider(s)

Date of initial entry into 

force

Least Developed Country (LDC)-Specific

Duty-Free Tariff Preference Scheme for LDCs India 8/13/2008

Duty-free treatment for African LDCs - Morocco Morocco 1/1/2001

Duty-free treatment for LDCs - Chile Chile 2/28/2014

Duty-free treatment for LDCs - China China 7/1/2010

Duty-free treatment for LDCs - Chinese Taipei Taipei, Chinese 12/17/2003

Duty-free treatment for LDCs - Kyrgyz Republic Kyrgyz Republic 3/29/2006

Preferential Tariff for LDCs - Republic of Korea Korea, Republic of 1/1/2000

Other Preferential Trade Arrangement (PTA)

African Growth and Opportunity Act United States 5/18/2000

Andean Trade Preference Act United States 12/4/1991

Caribbean Basin Economic Recovery Act United States 1/1/1984

Commonwealth Caribbean Countries Tariff Canada 6/15/1986

Former Trust Territory of the Pacific Islands United States 9/8/1948

South Pacific Regional Trade and Economic Cooperation 

Agreement

Australia, New Zealand 1/1/1981

Trade preferences for countries of the Western Balkans European Union 12/1/2000

Trade preferences for Pakistan European Union 11/15/2012

Trade preferences for the Republic of Moldova European Union 1/21/2008

Source: World Trade Organization database of preferential trade arrangements. | GAO-15-701

Various factors can affect the performance of a trade preference program. 

These factors can be either (1) internal to the program, being key 

characteristics of the program itself, or (2) external to the program, being 

specific to the country or region in which the program is operating.

Key program characteristics that can affect trade preference programs’

performance include the following:

• country eligibility, or the ability of a country to qualify for participation 

in the program;

• product coverage, which delineates products that may receive tariff 

preferences;

• rules of origin, which ensure that benefits of a preference program 

accrue to intended recipients by specifying a proportion of an 

imported product’s value that must be produced in the preference 

beneficiary country.

Factors That Can Affect 

Trade Preference Program 

Performance

Trade Preference ProgramSpecific Characteristics
Page 7 GAO-15-701 African Growth and Opportunity Act

The nature of these characteristics directly conditions whether developing 

country exporters can utilize trade preference program benefits.

Trade experts also note that there are a range of factors external to trade 

preference programs and intrinsic to each recipient country that can also 

affect trade preference program performance. These include

• infrastructure—whether the country has adequate transportation, 

communication, and energy networks available to producers and 

exporters;

• governance, or the legal, regulatory and policy environment conducive 

to promoting market activity and international trade;

• regional integration—a country’s ability to engage in commerce and 

production with neighboring countries to facilitate supply chains and 

movement of goods to market; and

• access to finance to support investment and production.

Success in improving on these development-related factors within 

preference beneficiary countries can make them more ready to meet the 

challenges and access the benefits of global integration. U.S. agencies 

provided over $5 billion in the 2001-2013 period to bolster AGOA 

countries’ capacity to engage in and benefit from trade.

Other factors are also important drivers of trade between particular 

partners. Notably, trade experts have stated that factors such as the 

relative size of each country’s economy, respective rates of economic 

growth, geographic proximity, and cultural and historic ties between 

countries affect trade levels and are—in some cases—at least as 

important as program characteristics.

The United States is one of the major markets for AGOA countries’

exports, but its rank among SSA’s export markets has declined as those

of China and India have risen. Figure 1 shows the total amount of exports 

from AGOA countries to their major trading partners from 2010 to 2014. 

While the total dollar value of exports to many of the AGOA countries’

major trading partners decreased in 2013, in part because of falling 

commodity prices, the EU remained by far the largest market for AGOA 

country exports. AGOA country exports to the United States fell 

significantly after 2011 while AGOA country exports to China and India 

grew. As a result, by 2014, both China and India outranked the United 

States as AGOA country export markets. Other major export markets for 

Country-Specific Factors

Major Export Markets

for AGOA Countries
Page 8 GAO-15-701 African Growth and Opportunity Act

AGOA countries include Brazil, Japan, South Korea, Australia, and 

Canada.

Figure 1: Exports from AGOA Countries to Major Importing Countries or Regions, 2010-2014

Note: Nominal U.S. dollar values are not adjusted for inflation.
Page 9 GAO-15-701 African Growth and Opportunity Act

AGOA has several notable differences from and similarities to other 

countries’ nonreciprocal trade preference programs, including programs 

in Canada, China, the EU, and India. (See app. II for a comparison of key 

characteristics of selected trade preference programs by country.) 

Available studies of AGOA and the EU’s preference programs suggest 

that these differences have affected program performance in terms of 

creating new trade flows (trade creation), increasing the range of products 

that are traded (diversification), and program utilization.

AGOA’s country eligibility requirements are unique among those of other 

countries’ preference programs, in terms of geographic focus, income 

eligibility thresholds, and other policy and procedural requirements. 

Therefore, some countries that are eligible for AGOA are not eligible for 

other developed countries’ programs, whereas some countries deemed 

ineligible for AGOA receive preferences in China and India. (App. III 

shows the eligibility of SSA countries for selected trade preference 

programs by country.)

Unlike most trade preference programs offered by other countries, AGOA 

restricts eligibility for participation to SSA countries. Of the 27 preferential 

trade arrangements in existence, 10 are specific to a region or country. 

The remaining 17 trade preference programs are not restricted to a 

region.11 Of the 10 regionally focused programs, only 2, AGOA and 

Morocco’s duty-free treatment for African LDCs, are specific to subSaharan Africa; the other 8 provide preferential benefits to other regions 

or countries.12

 11For the purposes of this report, we focused our comparisons on various countries’

preference programs primarily based on information contained in the WTO Preferential 

Trade Arrangements database. For additional information, see app. I.

Table 2 compares the total number of countries and total 

number of SSA countries eligible for AGOA and selected GSP-LDC and 

12Morocco’s preferential tariff treatment for African LDCs was initiated in 2001. Morocco 

canceled all debt of African LDCs owed to Morocco and provided full exemption from 

import duties for 33 SSA LDCs on 61 select products including non-roasted coffee, cocoa, 

and cotton.

AGOA Has 

Differences from and 

Similarities to Other 

Countries’ Trade 

Preference Programs 

and Differences Have 

Affected Program 

Performance

Country Eligibility for 

AGOA Differs from That 

of Others’ Programs in Its 

Focus on Sub-Saharan 

Africa, Its Income Eligibility 

Thresholds, and Other 

Requirements for 

Participation

Geographic Focus
Page 10 GAO-15-701 African Growth and Opportunity Act

LDC trade preference programs. The United States’ AGOA, followed by 

the GSP-LDC program in several developed countries, serve the most 

SSA countries.

Table 2: Number of Countries Eligible for Select Trade Preference Programs

United 

States

United 

States Australia Canada China EU India Japan

South 

Korea Morocco

Russian 

Federation

Trade 

preference 

program

AGOA GSP-LDC GSP-LDC GSP-LDC LDC EBA LDC GSPLDCLDC African 

LDC DutyFree

GSP-LDC

Number of 

beneficiaries

39 43 50 48 40 49 27 48 48 33 49

Number of 

eligible SSA 

countries 

39 33 33 33 30 33 21 33 33 33 33

Legend: AGOA = African Growth and Opportunity Act; GSP = Generalized System of Preferences; LDC = least-developed country; EBA = Everything 

but Arms; EU = European Union; SSA = sub-Saharan African

Source: United Nations and World Trade Organization data. l GAO-15-701

Note: GAO accessed the WTO database of preferential trade arrangements in June 2015, which 

includes the most recent numbers reported by each country to the WTO.

The income threshold for a country to be eligible for AGOA is less 

restrictive than the threshold for other developed countries’ trade 

preference programs based on income classifications determined by the 

World Bank and the United Nations. Countries may be eligible for AGOA 

(or the U.S. GSP) unless they are classified by the World Bank as highincome countries.13 In addition, to determine whether to designate an 

eligible country as a beneficiary country, the President also considers the 

economic development, per capita gross national product, living 

standards, and other economic factors deemed appropriate. AGOA 

coverage ranges from the poorest countries to those that are more 

economically advanced and is not limited to only LDCs.14

 13For fiscal year 2015, the World Bank defines high-income countries as those countries 

with a gross national income (GNI) per capita of $12,746 or more. Upper-middle-income 

countries are those with a GNI per capita of $4,126 to $12,745. The World Bank uses GNI 

because it is considered a useful and easily available indicator that is closely correlated 

with other, nonmonetary measures of the quality of life. 

14Countries must be GSP-eligible to receive AGOA’s trade benefits. However, GSP 

eligibility does not imply AGOA eligibility. Because of GSP eligibility requirements, AGOA 

beneficiary countries that reach high-income status become ineligible, but a 1 to 2-year 

transition period is provided to the recipient.

Income Eligibility Thresholds
Page 11 GAO-15-701 African Growth and Opportunity Act

Some developed countries, such as those in the EU and Canada, base 

eligibility for their GSP programs on more restrictive income thresholds 

than AGOA. Previously, both the EU and Canada considered countries 

classified as “upper-middle-income” by the World Bank as eligible for their 

programs. However, after revising the programs, both the EU and 

Canada began to graduate from their programs upper-middle-income 

countries classified as such for at least 3 years for the EU and 2 years for 

Canada.15

All of the developing countries’ programs also have more restrictive 

income eligibility thresholds than AGOA, as they focus exclusively on 

LDCs. Notably, China and India, two of Africa’s most rapidly growing 

export markets in Asia, have both put in place preference programs for 

LDCs, with many African nations among the beneficiaries.

For example, Gabon, Mauritius, and South Africa are eligible 

for benefits under AGOA but are no longer eligible for benefits or have 

graduated under the EU and Canadian GSP programs.

16

AGOA and other countries’ preference programs have some differences 

in their procedural and policy requirements for determining country 

eligibility. For AGOA, an annual review is used to decide whether a 

country remains eligible for AGOA benefits by determining whether the 

country has met certain criteria. Among other things, these criteria include 

having established, or made continual progress toward establishing:

According to 

the WTO, India was the first developing country to offer a preference 

scheme for LDCs. China’s preference scheme entered into force in July 

2010 and is open to 40 LDCs, of which 30 are SSA countries.

• A market-based economy that protects private property rights, 

incorporates an open rules-based trading system, and minimizes 

government interference in the economy through measures such as 

price controls, subsidies, and government ownership of economic 

assets.

• The rule of law, political pluralism, and the right to due process, a fair 

trial, and equal protection under the law.

• Protection of internationally recognized worker rights, including the 

right of association, the right to organize and bargain collectively, a 

 15The income classifications for the EU and Canada are as defined by the World Bank.

16The UN classifies a total of 48 countries as LDCs; 34 of these 48 countries are in Africa.

Procedural and

Policy Requirements
Page 12 GAO-15-701 African Growth and Opportunity Act

prohibition on the use of any form of forced or compulsory labor, a 

minimum age for the employment of children, and acceptable 

conditions of work with respect to minimum wages, hours of work, and 

occupational safety and health.

• Economic policies to reduce poverty, increase the availability of health 

care and educational opportunities, expand physical infrastructure, 

promote the development of private enterprise, and encourage the 

formation of capital markets through micro-credit or other programs.17

Several countries, including the Central African Republic, Eritrea, and 

South Sudan, have lost eligibility to participate in AGOA as a result of this 

annual review. For more information, see our recently issued report 

assessing the AGOA eligibility determination process.18

Because the programs of other countries, such as China and India, have 

procedural and policy requirements that differ from those of AGOA,19

• Eritrea, the Gambia, Somalia, and Sudan are eligible for India’s 

preferences, but currently ineligible for AGOA. Eritrea and the Gambia 

lost AGOA eligibility because of human rights abuses in 2004 and 

2015, respectively. Somalia and Sudan have not been eligible for 

AGOA and, according to U.S. agency officials, have not expressed an 

interest in the program. A recent analysis of pre-versus-post-program 

trends in India’s trade indicates that these partners’ exports to India 

grew faster than global exports in certain preference products (such 

as leather hides and skins for Eritrea and Somalia).

some countries that are ineligible for AGOA are eligible under India’s and 

China’s preference programs. For example:

• Central African Republic, Democratic Republic of the Congo (DRC), 

Eritrea, and Sudan are eligible for China’s preference program, but 

are currently ineligible for AGOA. Central African Republic lost AGOA 

eligibility in 2004 following a coup, and the DRC lost AGOA eligibility 

in 2011 because of human rights concerns. UN data indicate that 

 1719 U.S.C. § 3703(a)(1).

18GAO-15-300. 

19According to Chinese government documents, China’s preferences are extended to all 

least-developed SSA countries with which China has diplomatic relations. To gain 

eligibility into India’s preference scheme, individual LDC members must submit a letter of 

intent to the Government of India.
Page 13 GAO-15-701 African Growth and Opportunity Act

China’s trade with these partners ranged from $29.3 million for 

Central African Republic to $2.8 billion for the DRC and $5.9 billion for 

Sudan (North and South) in 2014.

The United States, Canada, the EU, and Japan’s preference programs 

provide comprehensive duty-free coverage for almost all products that 

enter their country or region from eligible LDC beneficiaries, including 

most SSA countries. However, for SSA countries that are not considered 

LDCs, product coverage is less comprehensive. Key developing 

countries, notably China and India, have taken steps to offer more 

comprehensive product coverage under their preference schemes than 

before. However, the United States, the EU, Japan, and others continue 

to exclude products considered important to SSA countries, such as 

certain agricultural goods as well as some textiles and apparel.

WTO and our analysis indicates that AGOA countries have 

comprehensive preferential access under existing preference schemes, 

and that AGOA’s coverage compares favorably with that of developed 

and developing country schemes. Developed country preference 

programs, including AGOA, the EU’s EBA, Canada’s GSP-LDC, and 

Japan’s GSP-LDC, provide duty-free coverage of more than 97 percent of 

tariff lines (which signify specific products) for LDC beneficiaries. A recent 

comparative analysis prepared by the WTO Secretariat indicates that, at 

97.5 percent, AGOA’s product coverage for LDCs compares favorably 

with the United States’ GSP-LDC program as well as with other 

developed countries’ LDC programs. 20

Several AGOA countries, such as Ghana and Kenya, are not LDCs, and 

thus qualify only for regular GSP in other developed countries’ programs, 

which are less generous in terms of product coverage than GSP-LDC 

programs. For example,

For example, the United States’

GSP-LDC program covers 82.6 percent of tariff lines, while Japan’s GSPLDC program covers 97.9 percent, Canada’s 98.6 percent, and the EU’s 

EBA program 99.0 percent.

• Canada’s regular GSP provides duty-free treatment for 492 tariff lines 

versus the 2,426 lines included under its GSP-LDC program.

 20In June 2015, the U.S. GSP program was renewed through 2017.

AGOA and Other 

Countries’ Programs Offer 

Fairly Comprehensive 

Duty-Free Coverage of 

Products, But Exclude 

Some Important SSA 

Exports

Comprehensive Coverage
Page 14 GAO-15-701 African Growth and Opportunity Act

• The EU’s regular GSP provides duty-free treatment for 2,994 lines 

versus the 6,932 lines under its LDC-oriented EBA.

Generally, the product coverage of China and India’s programs is less 

than that of developed country programs, but expanding. For example, in 

2010, China informed the WTO that its market access scheme to 

eliminate tariffs had expanded to cover 60 percent of tariff lines and in 

2013 released an official statement indicating that all 30 LDCs in Africa 

with diplomatic ties to China would have a zero-tariff treatment covering 

this 60 percent, or 4,762 items. China also stated plans to further open its 

market to LDCs by expanding coverage to 97 percent of all tariff lines, by 

the end of 2015. India’s initial scheme, until its revision in April 2014, 

phased in duty-free access to 85 percent of its tariff lines over a 5-year 

period beginning in 2008 and ending in October 2012.21 It also offered 

reduced duties on 9 percent of its tariff lines. Furthermore, according to a 

WTO report, many developing countries such as China and India charge 

higher tariffs on imports than more developed countries. This practice 

makes the margin of preference available to beneficiaries under their 

preference programs high (as discussed in app. IV), which can translate 

into significant impact in terms of economic and trade growth.22

We conducted an analysis of trade-weighted preference program 

coverage in six of the leading AGOA markets based on the latest data 

available, for 2012—which showed that, with the exception of those of 

Australia, about 90 percent or more of AGOA countries’ exports in terms 

 21Specifically, items eligible for duty-free treatment under India’s scheme had a 20 percent 

reduction in duties in the first year, a 40 percent reduction in the second year, a 60 

percent reduction in the third year, an 80 percent reduction in the fourth year, and a 100 

percent reduction in the fifth year.

22For example, two empirical studies of the potential impact of offering duty-free, quotafree coverage project that gains for LDCs, particularly in Africa, increase significantly if 

Brazil, China, and India provide 100 percent duty-free access. For example, in 2009 David 

Vanzetti and Ralf Peters estimated that OECD liberalization would increase LDC exports 

by $4.1 billion, but there are additional gains of $1.9 billion when Brazil, China, and India 

also provide duty-free access (see David Vanzetti and Ralf Peters, “Duty-free and quotafree market access for LDCs,” presented at the 53rd AARES Annual Conference, Cairns 

Queensland, 11-13, February 2009, 

http://ageconsearch.umn.edu/bitstream/47646/2/Vanzetti.Peters.pdf). The two studies are 

summarized in National Council of Applied Economic Research (2014); A Simulation 

Analysis of India’s Duty-Free Trade Preference Scheme: A focus on African LDCs; Issue 

Paper No. 34; International Centre for Trade and Sustainable Development, Geneva, 

Switzerland, 5, which reports on more recent modelling that finds African LDCs would see 

gains from further liberalization of India’s preference scheme. 
Page 15 GAO-15-701 African Growth and Opportunity Act

of value qualified for duty-free treatment or reduced duties under the 

selected preference programs (see fig. 2). The analysis assumes that all 

products that are eligible for duty-free treatment are duty-free, and thus 

represents trade-weighted product coverage. With respect to India, a 

sizeable share (89 percent) of the value of AGOA country exports were 

eligible for preferences, that at the time (2012) were in the form of 

reduced duties. India has been phasing its scheme by reducing duties; 

reportedly 92.5 percent of LDC exports were given preferential market 

access as of October 2012.23

 23Vinaye Ancharaz and Paolo Ghisu, International Centre for Trade and Sustainable 

Development, Deepening India’s Engagement with the Least Developed Countries: An Indepth Analysis of India’s Duty-free Tariff Preference Scheme, Issue Paper 31, October 

2014.
Page 16 GAO-15-701 African Growth and Opportunity Act

Figure 2: Trade-Weighted Preferential Tariff Coverage of AGOA Country Imports for Six Countries in 2012

Our finding corresponds with the key findings of an October 2014 WTO 

Secretariat report, which provides indicators of the global extent of dutyfree product coverage for particular African countries under major 

available preference schemes.
Page 17 GAO-15-701 African Growth and Opportunity Act

AGOA, as well as the trade preference programs of other countries,

including South Korea, Australia, and Japan, excludes some products 

that have high export potential and are considered important to enhancing 

growth in SSA beneficiaries’ economies, such as certain agricultural 

goods. Coverage of such products is important for two reasons. First, the 

WTO Secretariat has noted that textiles and apparel—key LDC exports—

face the highest average tariffs in developed countries. Second, many 

African countries rely on just a few products for the bulk of their exports,

and if preference schemes exclude those products from coverage, the 

programs effectively provide no benefit to them.

WTO and UNCTAD analyses suggest that AGOA’s coverage of 

agriculture products for beneficiary countries is less extensive than that of 

some other developed countries’ programs. According to the Foreign 

Agricultural Service of the U.S. Department of Agriculture, 240 tariff lines 

are presently excluded from the U.S. GSP and AGOA and most are 

subject to tariff rate quotas, and, as a result, are not fully liberalized. The 

agricultural products excluded from AGOA include certain products within 

the general categories of beef, dairy, vegetables, peanuts, oilseed 

products, sugar and sweeteners, cocoa products, tobacco, wool, cotton, 

flax, and other processed agricultural products. However, the recently 

passed AGOA reauthorization legislation permits the President to provide 

Product Exclusions

Key findings of an October 2014 WTO Secretariat report 

• African countries dominate the list of individual LDCs that by 2012 

enjoyed duty-free treatment for 90-100 percent of the value of their 

non-oil, non-arms exports to developed economies.

• African nations such as Lesotho, Mozambique, Angola, Guinea 

Bissau, Malawi, Senegal, and Tanzania were among those LDCs 

that recorded increases in the share of the value of exports 

imported duty-free between1996 and 2012.

• While many non-African countries also saw increases, the dutyfree share for some such countries in 2012 was less than that for 

African LDCs. For example, the duty-free share for Cambodia, 

Bangladesh, and Myanmar ranged between 60 and 80 percent.

Legend: WTO = World Trade Organization; LDC =Least-developed country

Source: GAO analysis of WT/COMTD/LDC/W/59. l GAO-15-701
Page 18 GAO-15-701 African Growth and Opportunity Act

duty-free access under the GSP and, by extension, for AGOA on certain 

previously excluded products, such as cotton for least-developed 

beneficiary developing countries.24

Several other countries’ preference programs also exclude some 

agricultural goods that are considered important to African country 

economies. A WTO Secretariat report found that

• Canada excludes dairy, eggs, and poultry; and

• Japan excludes rice, sugar, fishery products, and articles of leather. 25

Although India excludes certain exports of interest to LDCs, it covers key 

products that at least one trade source determined to be of immediate 

interest to Africa. These products include cotton, cocoa, cane sugar, 

ready-made garments, and fish.

AGOA’s product coverage of textiles and apparel for those LDCs that 

qualify appears to include more items than that of some other U.S. 

programs. This coverage is considered a key feature that contrasts

AGOA with other programs.

Our analysis, along with trade reports on rules of origin, shows that each 

preference program has specific rules of origin requirements with varying 

value-added requirements and calculation methods, making it difficult for 

beneficiaries to comply with a given program or use multiple programs 

(see app. V). The WTO reports that restrictive rules of origin can nullify 

the value of preferences, and as a result, several countries have taken 

steps to make their program’s requirements more flexible.

All countries offering preference programs permit products that are wholly 

grown or produced within a beneficiary country to receive preferences. 

But for products that include foreign inputs, each program country uses its 

own methodology to determine whether sufficient local processing was 

performed on non-originating material for a product to be considered 

“local” or originating from a beneficiary. For example, the United States 

 24Trade Preferences Extension Act of 2015, Pub. L. No. 114-27, June 29, 2015.

25WTO, Market Access for Products and Services of Export Interest to Least-Developed 

Countries, WT/COMTD/LDC/W/59, October 23, 2014.

Rules of Origin Vary by 

Preference Provider, 

Making It Difficult for 

Beneficiary Countries

to Use the Programs
Page 19 GAO-15-701 African Growth and Opportunity Act

requires that a product must be imported directly from an AGOA 

beneficiary country and that the sum of the cost or value of the materials 

produced in one or more AGOA beneficiary countries plus the direct costs 

of processing operations performed in those countries may not be less 

than 35 percent of the appraised value at the time it enters the United 

States (is imported). In contrast, according to one trade policy expert,

China’s rules of origin are stricter than those of AGOA because, at least 

40 percent of value must be added in the exporting country, compared 

with the 35 percent regional value-added requirement for AGOA. In 

addition, China requires external inputs to undergo substantial 

transformation so that the resulting product would no longer enter under 

the same four digit code of the Harmonized System.26

Cumulation—permitting beneficiary countries to combine inputs from 

multiple sources to meet the local sourcing requirements—can ease the 

restrictiveness of rules of origin. Some developed countries’ preference 

programs provide wide scope for cumulation of inputs to reach the 

required minimum. Others, such as Japan’s, have restrictive cumulation 

rules. Specifically, five Southeast Asian countries are considered as a 

single territory for rules of origin purposes and may cumulate production 

under Japan’s GSP, but no cumulation among the other 146 GSP 

participants is allowed.

Some developed countries have made efforts to make cumulation rules 

less restrictive. For example, the EU and Canada (1) widened the scope 

for cumulation of inputs to attain their required value-added threshold (in 

Canada’s case, across GSP and GSP-LDC preference beneficiaries and, 

in the case of the EU, with Free Trade Agreement/EPA partners), and (2) 

relaxed certain product-specific rules for LDC beneficiaries. An LDC 

group paper submitted to the WTO Rules of Origin Committee in October 

2014 indicated that reforms by Canada and the EU have resulted in 

increased utilization of preferences, manufacturing capacity, and numbers 

of highly skilled jobs in LDCs. The recently passed AGOA reauthorizing 

legislation also modifies cumulation rules to help increase utilization.

In the EU’s case, the European Commission noted that the changes were 

the product of a long and extensive review process that ultimately led it to 

 26Sam Laird, International Centre for Trade and Sustainable Development, A Review of 

Trade Preference Schemes for the World’s Poorest Countries, Issue Paper 25, October 

2012, 35.
Page 20 GAO-15-701 African Growth and Opportunity Act

postpone implementation of one proposed reform: changing from a 

paper-based system that enables beneficiary customs authorities to issue 

required certificates that qualify goods for entry under the EU preference 

programs, to an electronic one that would require exporters to register 

and place more responsibility on beneficiary country exporters that are 

registered in the EU’s new electronic system for compliance. This paperbased system was one of the aspects of the EU preference program that 

African governmental representatives we met in Brussels told us makes 

the EU program easier to use than AGOA.

Making rules of origin requirements more consistent across preference 

programs could make it easier for beneficiary countries to use multiple 

programs, but efforts to standardize them have faced challenges. 

According to African officials we met with, multiple rules makes it more 

difficult for exporters to make use of available preference programs. They 

also increase the administrative burden associated with using 

preferences and may conflict with supply chain realities by requiring 

countries to adapt their manufacturing practices to meet different program 

requirements. As a result, the WTO LDC group has been pressing 

developed countries to ensure that preferential rules of origin applicable 

to imports from LDCs will be transparent, simple, and contribute to 

facilitating market access for non-agricultural products. WTO members 

agreed to work on this topic at the December 2013 ministerial conference 

in Bali and in 2015 LDCs have urged progress. However, there is no 

requirement to harmonize preferential rules of origin at the WTO and 

there has been reluctance on the part of the preference-granting 

countries to standardize the process, according to trade experts.

Although we identified many studies on trade preference programs, 

relatively few studies compared their performance, and the results of 

these studies varied. Performance of preference programs is judged in 

economic literature in terms of their success in increasing exports (trade 

creation), increasing the range of products exported (diversification), and 

the extent to which available preferences are being used by recipients 

(utilization). With regard to these indicators, a 2014 USITC study27

 27USITC, AGOA: Trade and Investment Performance Overview, Publication No. 4461, 

April 2014.

of 

AGOA summarizing available comparative performance literature 

between the United States and the EU noted that in general (1) EU 

The Few Studies that 

Compare AGOA and Other 

Preference Programs’

Performance Suggest 

That Program Differences 

Affect Performance
Page 21 GAO-15-701 African Growth and Opportunity Act

preferences had a greater effect on trade creation than U.S. programs; 

(2) U.S. preferences were more likely to help African suppliers diversify 

their exports by increasing the range of products traded than EU 

preferences; and (3) average utilization rates for preference programs of 

Australia, Canada, the EU, and the United States were often very high—

even for small preference margins and small trade flows, according to the 

underlying research study cited in the USITC study. We also found a 

limited number of studies providing insights on the performance of some 

other countries’ preference programs, including those of India and China.

In general, many trade experts agree that AGOA has been beneficial in 

helping expand trade between SSA countries and the United States. 

However, our prior work and available evidence suggest that AGOA has 

been only modestly effective in achieving its stated goals.28

The USITC identified several studies that found that when compared with 

the United States, the EU has had greater overall success in increasing 

trade with Africa. One study attributed this result to EU imports being 

more responsive to price changes than U.S. imports.

Studies of the 

EU’s preference programs suggest that they also have had modest 

success in expanding trade with the beneficiaries of the programs.

29 Another study 

concluded that the EU trade policy was more successful in creating SSA 

country exports in part because of the shorter distance and SSA 

countries’ longstanding colonial ties with the EU.30

 28GAO, U.S.-Africa Trade: Options for Congressional Consideration to Improve Textile 

and Apparel Sector Competitiveness under the African Growth and Opportunity Act, 

GAO-09-916 (Washington, D.C.: Aug. 12, 2009); International Trade: U.S. Trade 

Preference Programs Provide Important Benefits, but a More Integrated Approach Would 

Better Ensure Programs Meet Shared Goals, GAO-08-443 (Washington, D.C.: Mar. 7, 

2008); and USITC, AGOA: Trade and Investment Performance Overview, 43.

29Maria Cipollina et al., “Do Preferential Trade Policies (Actually) Increase Exports?”

(paper presented at the Agricultural & Applied Economics Association’s 2013 AAEA & 

CAES Joint Annual Meeting, Washington, D.C., August 2013), 16–18, 

http://ageconsearch.umn.edu/bitstream/150177/2/CipollinaLabordeSalvatici_conf_MPacc2

.pdf.

30Lars Nilsson, Comparative Effects of EU and U.S. Trade Policies on Developing Country 

Exports, European Commission Director General for Trade Working Paper, December 

2005, accessed July 9, 2015, 

http://trade.ec.europa.eu/doclib/docs/2006/september/tradoc_129998.pdf.

Trade Creation
Page 22 GAO-15-701 African Growth and Opportunity Act

The USITC noted that although these studies show the EU as more 

effective in increasing trade overall, other studies suggest that results are 

different when examined by sector. For example, one study found that 

after the United States put in place the “third-country fabric” provision 

enabling certain AGOA beneficiaries to use imported fabric for apparel 

production, AGOA created about seven times more apparel exports than 

the EU’s programs.31

USITC identified several studies that generally concluded that U.S. 

preferences under AGOA were more successful than the EU’s in helping 

African suppliers diversify exports. One study from 2011 concluded that 

the EU’s GSP program provided an overall small effect on increasing 

exports, but no effect on diversification.

But in the case of agriculture, the EU was found to 

be more effective at raising agricultural exports than the U.S. preference 

program.

32

A number of studies identified in the USITC report found that overall, the 

United States’ AGOA and GSP programs and the EU’s GSP program 

both had high utilization rates for SSA LDCs. As mentioned earlier, 

utilization is the extent to which available preferences are being used by 

recipients and is considered a key indicator in comparing program 

performance. Low utilization rates suggest possible disincentives for 

countries using available preferences.

Among the possible 

explanations the authors offer are the EU’s then relatively-strict rules of 

origin for GSP.

Information on developing countries’ programs is limited, but some 

studies are available. For example, an October 2014 study on India found 

that after taking out petroleum, exports to India by beneficiaries and in 

preferential products have grown faster than exports of non-beneficiaries 

and of non-preference products. However, the same study found that

 31Paul Collier and Anthony J. Venables, Rethinking Trade Preferences: How Africa Can 

Diversify Its Exports, Center for Economic Policy Research Discussion Paper 6262, May 

2007.

32Xavier Cirera, Francesca Foliano, and Michael Gasiorek, The Impact of GSP 

Preferences on Developing Countries’ Exports in the European Union: Bilateral Gravity 

Modelling at the Product Level, 2011,” accessed June 2, 2015,

http://www.researchgate.net/publication/241767503_The_impact_of_GSP_Preferences_o

n_Developing_Countries’_Exports_in_the_European_Union_Bilateral_Gravity_Modelling_

at_the_Product_Level .

Diversification

Utilization

Emerging Research on 

Developing Countries’

Programs
Page 23 GAO-15-701 African Growth and Opportunity Act

more than half of the SSA beneficiary countries were not well placed to 

utilize India’s programs. The study determined that it was difficult to 

conclude whether India’s preference scheme had had the desired impact 

on beneficiary country exports, largely because African LDC exports to 

India remained low.33

Sub-Saharan African (SSA) countries’ recent participation in bilateral and 

multilateral trade negotiations provides insights that can inform future 

negotiations. The bilateral Economic Partnership Agreement (EPA) 

negotiations highlight trade-offs that the EU and SSA countries 

considered to successfully conclude agreement negotiations. The 

negotiating choices the EU faced were complicated by the fact that 

countries with access to preferences that do not require them to liberalize 

access to their own markets have limited incentive to negotiate reciprocal 

agreements, according to trade experts with whom we spoke.34

Examining recent WTO negotiations provides insights about impediments 

to SSA country participation in multilateral negotiations, efforts to 

overcome those impediments, and the impact of those efforts. In light of 

upcoming trade events that will focus on issues of interest to African 

countries, the United States has a window of opportunity to draw insights 

from these negotiations that may help preserve U.S. interests.

The negotiations between SSA countries and the EU that have resulted in 

EPAs indicate that achieving the goal of transitioning from unilateral trade 

preference programs to reciprocal trade agreements with SSA countries 

may require35

• many years to finalize and implement,

• the establishment of time frames to end access to trade preference 

programs,

 33Ancharaz and Ghisu, Deepening India’s Engagement, 3.

34We also reported in 2008 that the assurance of continued preferential access to the U.S. 

market has at times, created a disincentive to negotiation of reciprocal free trade 

agreements. See GAO-08-443. 

35Congress has stated in the original AGOA legislation and in its reauthorization that it is 

the policy of the United States to continue seeking to negotiate bilateral free trade 

agreements with sub-Saharan African countries.

Sub-Saharan African 

Countries’ Recent 

Trade Negotiations 

Provide Insights for 

Future Negotiations

Insights from Recent 

Trade Negotiations 

between SSA Countries 

and the EU Could Inform 

the Direction of Future 

Trade Negotiations
Page 24 GAO-15-701 African Growth and Opportunity Act

• a willingness to consider limiting the initial scope of the agreements, 

and

• an acknowledgment that aspects of the agreements may have tradeoffs and could constrain SSA countries’ ability to integrate into the 

global economy.36

Several African government officials and trade experts we spoke to stated 

that the EPAs could serve as a stepping-stone for other countries to 

negotiate with SSA countries reciprocal agreements that include wider 

liberalization of African markets.

One insight from the EPA negotiations that could apply to other countries’

negotiations with SSA countries is that negotiations and implementation 

of reciprocal trade agreements may take many years to finalize. 

According to EU officials, EPA negotiations with SSA countries lasted far 

longer than expected. In September 2002, the EU and SSA countries (as 

well as other countries) began negotiating EPAs and after more than a 

decade of negotiations, according to the European Commission, the EU 

has concluded the first EPAs with some African regional groups.37 As of 

May 2015, the EU had concluded negotiations for EPAs with three African 

regions: West Africa, the Southern African Development Community 

(SADC), and the Eastern African Community (EAC).38 In addition, the EU 

has an interim EPA with 4 countries in the Eastern and Southern Africa 

region. In July 2014, Cameroon became the only country in the Central 

Africa region to ratify an interim EPA with the EU.39

 36Although SSA countries have concluded several bilateral and regional trade 

agreements, we are focusing on the EPAs because they closely mirror the U.S. 

circumstance of having preference programs and deciding whether and how to negotiate 

reciprocal agreements as a transition from unilateral trade preferences or alongside them.

Figure 3 shows which 

SSA countries have negotiated EPAs with the EU. As of May 2015, 32 

SSA countries had negotiated regional or interim EPAs with the EU.

37The European Commission is the executive branch of the EU. 

38The EU has also negotiated EPAs with other countries in the Africa, Caribbean, and 

Pacific region. 

39LDC countries that have not signed EPAs do not lose trade preferences under the EU’s 

Everything but Arms program.

Reciprocal Agreement 

Negotiations and 

Implementation May Take 

Many Years to Finalize
Page 25 GAO-15-701 African Growth and Opportunity Act

Figure 3: Sub-Saharan African Countries That Have Negotiated Regional or Interim Economic Partnership Agreements with 

the European Union

In addition to entailing lengthy negotiations, the EPAs also contain multiyear phase-in periods before the reciprocal terms enter into effect, 

according to trade experts from one organization. This phase-in period 

acknowledges that the transition from unilateral trade preferences to 

reciprocal agreements will require a significant adjustment, especially for 
Page 26 GAO-15-701 African Growth and Opportunity Act

the poorest SSA countries.40 According to trade experts, the African 

signatories have committed to open between 75 (for West Africa region 

countries) and 98 percent (for Seychelles) of their markets to the EU, but 

this access phases in over a period of between 11 and 25 years, 

depending on the country or region.41

Based on the experience of EPA negotiations, getting SSA countries to 

sign reciprocal agreements with the intent to help them integrate more 

fully into the global economy may require countries to institute concrete 

time frames for ending access to their other preference programs (see fig. 

4).

For African signatories, however, 

improved EU market access begins immediately upon concluding an 

agreement.

According to trade experts, original EU plans established 2007 as the 

target date for signing interim EPAs between the EU and SSA countries, 

but various obstacles delayed negotiations, including disincentives 

associated with unilateral preferences the SSA countries were already 

receiving from the EU. The experts said the EU set 2007 as its target 

date, in part because it was the year the EU’s trade preferences with SSA 

countries under the Cotonou Agreement and the associated WTO waiver 

were scheduled to expire, but it did not formalize a consequence if 

 40Recently countries in the Africa, Caribbean, and Pacific region met with EU officials to 

discuss enactment and implementation of EPAs. According to trade experts, there is an 

anticipated window of 2 years during which the concluded EPAs will be legally scrubbed, 

submitted to legislatures for enactment, and go into full legal effect. Countries that do not 

meet this deadline, in principle, could revert to less-comprehensive GSP benefits. Once 

the process is complete, the duty-phase-outs to which both sides committed will enter into 

effect. This will, in essence, give EU suppliers an edge over those of the United States in 

the African market, although the extent will depend on how deeply and quickly cuts take 

place, which varies by product. For example, eventually the EU will not face tariffs on most 

products (except certain fresh agricultural products, prepared foods, and chemicals) in 

South Africa, whose applied MFN tariffs averaged 7.6 percent in 2013, and whose WTO 

bound rates average 19 percent. 

41Although the WTO requires free trade agreements (FTAs) to cover “substantially all 

trade,” it has not set a benchmark as to what level of liberalization is “substantially all 

trade,” leaving it a point for negotiation. 

Time Frame for Ending

Access to Unilateral 

Preference Programs Was 

Needed to Ensure Progress
Page 27 GAO-15-701 African Growth and Opportunity Act

agreements were not concluded by that year.42

 42According to trade experts, the Cotonou Agreement extended until 2008 trade 

preferences offered by the Lomé Conventions since the 1970s. Under the Cotonou 

Agreement, all imports of manufactured goods from African, Caribbean, and Pacific 

countries could enter the European Union duty-free, although they were still restricted by 

“demanding” rules of origin. According to EU officials, the EU moved toward EPAs 

because their preferences for the Africa, Caribbean, and Pacific region as established by 

the Cotonou Agreement were contested and the WTO found them to be biased toward 

those countries and thus incompatible with EU WTO obligations. 

Between 2008 and 2014, 

trade experts reported that EPA negotiations continued, but only 5 of the 

19 SSA countries that initialed interim EPAs signed and ratified them. For 

example, Zambia initialed an interim EPA, but did not subsequently sign 

or implement it. Cameroon signed an interim EPA in 2009, but did not 

ratify it until July 2014. According to trade experts we spoke to and 

literature we reviewed, when a unilateral trade preference is available,

developing countries have less incentive to make domestic policy and 

regulatory reforms to meet the requirements of trade agreements. Trade 

experts also stated that there were a number of sticking points for which 

satisfactory compromises were difficult to find. For example, in the 

negotiations between the EU and SADC, market access issues and 

safeguards in the agricultural sector were sticking points. In addition, EU 

officials and other trade experts we met with indicated that SSA countries 

that already benefited from unilateral preferences had a disincentive to 

negotiate a reciprocal agreement with the EU that would require them to 

give up their ability to protect their industries or to lose tariff revenue, 

which constitutes a higher proportion of total government revenue than in 

developed countries.
Page 28 GAO-15-701 African Growth and Opportunity Act

Figure 4: Key Events during the Negotiation of Economic Partnership Agreements 

between Sub-Saharan African Countries and the European Union

Trade experts stated that to expedite EPAs with SSA countries, the EU 

mandated a time frame for ending access for some SSA countries to its 

unilateral preference programs. According to trade experts and EU 

officials, the agreements were not ratified by the time the Cotonou 

preferences expired in 2007, so to prevent trade disruption, the EU 

passed legislation in 2008 that allowed provisional access to EPA 

preferences. In May 2013, additional legislation gave SSA countries until 

October 1, 2014, to ratify EPAs with the EU or automatically fall under the 

less favorable GSP program that the EU gives unilaterally to all 

developing countries. In addition, trade experts reported that as a result of 
Page 29 GAO-15-701 African Growth and Opportunity Act

the new EU GSP that entered into force on January 1, 2014, any uppermiddle-income countries would no longer have access to unilateral trade 

preferences on the EU market. Some African government officials with 

whom we met said they felt that they and other African country officials 

had no choice but to sign EPAs and their successes in negotiating were 

limited by the time frame imposed upon the negotiations. U.S. officials 

also stated that African officials told them they felt obliged to sign the 

EPAs because they could not afford to lose preferential access to the EU 

market.

To successfully negotiate reciprocal agreements with SSA countries, EPA 

negotiations demonstrated that EU willingness to consider limiting the 

initial scope of the negotiations helped avoid an impasse that could have 

resulted in failed negotiations. The United States abandoned its previous 

attempt at negotiating a more comprehensive, or “high standard” free 

trade agreement (FTA) with SACU, and did not pursue an FTA with the 

EAC after it became clear that the EAC was not ready or willing.43

To successfully conclude negotiations of EPAs with SSA countries, EU 

officials said the EU agreed to limit the initial scope of EPA negotiations, 

but the agreements also included language that allowed the parties to 

continue negotiations in other areas covered by more comprehensive 

FTAs. Initially, according to trade experts with whom we met, the 

negotiating topics the EU was seeking were similar to those found in 

more comprehensive FTAs, such as intellectual property rights. Recent 

U.S. FTAs have more than 20 chapters, while EPAs between the EU and 

SSA countries contain 8. Ultimately, EU and SSA countries agreed to 

focus EPA negotiations on reciprocal trade in goods (and developmental 

cooperation) according to EU officials and other trade experts. The 

experts also reported that EPAs with SSA countries did not include 

language detailing agreed-upon terms for issues such as investment, 

services, public procurement, and intellectual property rights. According 

to EU officials with whom we met, many African countries were not 

prepared to agree to terms in these areas. The officials said they 

excluded these areas to avoid further delaying the conclusion of EPAs 

 43Francisco Sanchez, former Undersecretary of International Trade, U.S. Department of 

Commerce, responses to questions submitted for the record by Senator James M. Inhofe. 

S. HRG. 112–653 (2012) 60-61. AGOA directed the President to develop a plan to 

negotiate and enter into FTAs with SSA partners, but negotiations have not yet been 

successful.

Willingness to Consider 

Limiting Initial Scope of 

Negotiations Helped the

EU Reach Agreement

with SSA Countries
Page 30 GAO-15-701 African Growth and Opportunity Act

with SSA countries. The EPAs include a “rendezvous clause,” according 

to trade experts, which states that signatories may continue negotiations 

after the conclusion of EPAs to amend them. However, the experts stated 

that the agreements do not include a timeline for concluding terms for the 

other issue areas and it is therefore unclear how long it may take to 

negotiate more comprehensive trade agreements.

EPAs between the EU and SSA countries contain some features that 

create challenges for SSA countries’ integration into the global economy, 

according to trade experts and officials we met with from SSA countries 

and the EU. For example, although full or expanded access to EU 

markets may help SSA countries integrate more fully into the global 

economy, EPAs may diminish SSA countries’ leverage in future 

negotiations with other trading partners, according to trade experts. The 

EPA negotiations demonstrate that negotiating reciprocal agreements 

with SSA countries may involve some trade-offs that could impose 

burdens as SSA countries open their markets further to EU imports and 

affect SSA countries’ relations with other trading partners, including the 

United States.44

Trade experts and EU and African officials with whom we met reported 

that EPAs may have some positive effects on African economies and are 

therefore consistent with the EU goal to help SSA countries to further 

integrate into the global economy. For example, under EPAs, most SSA 

countries have full duty-free and quota-free market access in the EU,

while others have greater access than they did before they signed an 

EPA, according to trade experts. The trade experts reported that even 

South Africa, which has less duty-free access than most SSA countries, 

has improved access for agricultural products such as wine, sugar, and 

fruit, as well as industrial products, notably motor vehicles. According to 

EU and African officials with whom we met, that greater access helps 

SSA countries export goods that they already produce and that are 

excluded by other trade preference programs.

 44According to a trade expert, a WTO study from 2000 found that trade liberalization is 

generally a positive contributor to poverty alleviation and that it allows people to exploit 

their productive potential, assists economic growth, curtails arbitrary policy interventions,

and helps to insulate against shocks in the domestic economy. However, that same study 

found that most trade reforms will create some losers (some even in the long run) and that 

poverty may be exacerbated temporarily.

Reciprocal Agreements May 

Contain Features That Create 

Challenges for SSA Countries’

Integration into the Global 

Economy
Page 31 GAO-15-701 African Growth and Opportunity Act

However, African officials and other trade experts have expressed that 

EPAs may have adverse effects on the economic development of some 

SSA countries. In many of our meetings, African officials expressed 

concern over the loss of tariff (and other) revenue that is a significant 

amount of their governments’ budgets as a result of the requirement that 

they provide the EU greater market access. Studies assessing the impact 

of EPAs on the African signatories have found that they will impose a 

fiscal burden on the countries, though the risk level differs from country to 

country. Recent meta-analysis of such studies found that the fiscal impact 

could be very high for eight countries (Benin, Cape Verde, Comoros, 

Djibouti, the Gambia, Ghana, Guinea-Bissau, and Togo), and that fiscal 

impact could be low for seven other SSA countries (Botswana, Lesotho, 

Malawi, Namibia, Nigeria, Swaziland, and Zambia.) The meta-analysis 

also found that the impact would depend on what steps the countries took 

to adjust during the phase-in period.45

The terms of EPAs may also create challenges for SSA countries 

because, according to trade experts, their relative benefit to the SSA 

countries may diminish as the EU negotiates agreements with other nonSSA countries. The EU is negotiating trade agreements with other 

developed countries that may erode margins of preference for SSA 

countries. The experts reported that the agreements also focus on 

development of better rules and regulations not captured in EPAs that 

could increase competition with SSA countries in the EU market.

Because the EPAs also contain a 

“standstill clause” that prohibits countries from enacting new customs 

duties or raising tariffs beyond those provided in the EPA agreement, the 

EU may be more insulated than other countries, including the United 

States, should the loss of tariff revenue become a fiscal problem.

In addition, trade experts reported the following about how EPA terms 

may constrain African countries’ leverage in trade negotiations with other 

countries, including the United States:

• EPAs contain a Most Favored Nations (MFN) clause stating that if 

African EPA signatories negotiate trade agreements in the future with 

other developed or large developing countries, they would have to 

 45Sanoussi Bilal, Melissa Dalleau and Dan Lui, Trade Liberalisation and Fiscal 

Adjustments: The Case of EPAs in Africa, ECDPM Discussion Paper No. 137 (November 

2012), accessed May 18, 2015, http://www.ecdpm.org/dp137. 
Page 32 GAO-15-701 African Growth and Opportunity Act

extend any more favorable treatment offered to those countries to the 

EU as well.

• Key trading partners that would potentially want to deepen their trade 

relationship with SSA countries may be less interested in doing so if 

they know that they will not have any margin of preference over the 

EU.

• One think tank said that the MFN clause is against the spirit of the 

EPA itself, which states that the EPA is a way of fostering the 

integration of signatories into the global economy.

• However, at the insistence of African negotiators, most of the EPAs 

contain language stating that implementation of the MFN clause in 

EPAs is not automatic, but must be negotiated on a case-by-case 

basis.

Trade experts report that EPAs may also negatively affect other trading 

partners and multilateral trade negotiations. World Bank simulations of 

the impact of the West Africa EPA on Nigeria project that most of the 7-20 

percent increase in imports from the EU will divert trade from the rest of 

the world, including the United States.46 The EPAs that are currently in 

place also set precedents in terms of rules and exclusions that may act as 

disincentives to multilateral liberalization, according to trade experts. For 

example, the experts state that the SADC EPA permits SSA countries to 

levy export taxes in certain circumstances. In addition, the EPA contains 

a protocol that secured EU and South African protection of geographical 

indications for numerous products, including mainly food and alcohol.47 In 

general, the United States has opposed export taxes and expanding 

mandatory protection of geographical indications.

 46Soamiely Andriamananjara, Paul Brenton, Jan Erik von Uexküll, and Peter Walkenhorst, 

Assessing the Economic Impacts of an Economic Partnership Agreement on Nigeria, The 

World Bank Policy Research Working Paper 4920, April 2009.

47Geographic indications refers to a form of Intellectual Property Rights that protects the 

use of place names associated with products produced within its members states, such as 

“Champagne”, “Tequila” or “Roquefort”.
Page 33 GAO-15-701 African Growth and Opportunity Act

An examination of the involvement of SSA countries in recent multilateral 

negotiations at the WTO yields insights about impediments to SSA 

country participation in multilateral negotiations, efforts to overcome those 

impediments, and what impact SSA country participation could have in 

future WTO negotiations. Although capacity constraints have impeded 

SSA country participation in multilateral trade negotiations, efforts to 

address those impediments have been increasing. In part as a result, 

SSA country participation at the WTO has been expanding.

SSA countries face a number of impediments to full participation in trade 

negotiations, especially at the multilateral level. Officials from multilateral 

organizations, NGOs, and AGOA-eligible countries we met with noted

that, although SSA countries vary in their level of participation, many of 

the countries lack capacity in the following areas, making full participation 

difficult.

• Funding: African officials and other trade experts we met with said 

that many of the SSA countries, especially those considered LDCs, 

find it difficult to afford the costs associated with participating in 

multilateral trade negotiations, such as transportation to and from 

Geneva and maintaining staff there.

• Staffing levels: Some SSA countries do not have a permanent mission 

with staff to represent them in Geneva. Many others, including LDCs 

and small countries, have only a few staff to represent them in 

meetings and negotiations at the WTO, numerous UN agencies, and 

other multilateral organizations. Officials from several AGOA-eligible 

countries told us they often miss important meetings—sometimes 

including trade negotiations—because many of those meetings are 

scheduled concurrently.

• Expertise: WTO negotiations include numerous complex topics, and 

according to WTO and African government officials with whom we 

met, some SSA countries’ negotiators lack specialized training and 

experience to negotiate effectively.

• Communication: Some SSA countries lack effective communication 

and coordination between negotiators and government officials in their 

domestic capitals, according to African officials and trade experts with 

whom we met. As a result, in some cases negotiators in Geneva have 

worked toward positions that contradicted the priorities of government 

officials at home.

Recent Multilateral Trade 

Negotiations Involving 

SSA Countries Provide 

Insights That Could Inform 

Future Negotiations

Impediments Have Limited 

African Participation in

Trade Negotiations
Page 34 GAO-15-701 African Growth and Opportunity Act

Efforts to overcome impediments to African participation in trade 

negotiations have been increasing. According to one WTO trade expert, 

the number of WTO-sponsored capacity-building activities for African 

countries increased from 324 in 2000 to 1,513 in 2010, a nearly five-fold 

increase. Trade experts and African officials shared numerous examples 

of training courses, services, and programs designed to build African 

capacity to negotiate more effectively and implemented by the WTO, 

UNCTAD, the World Bank, nongovernmental organizations (NGOs), and 

bilateral trade partners. For example, the WTO hosts and funds a 

program called Geneva Week twice a year, paying for African officials 

from countries without permanent representation in Geneva to fly in and 

participate in trade negotiations and training courses focused on topics 

such as the WTO structure and negotiation process. NGOs and 

multilateral organizations also provide analysis at the request of African 

delegations that helps them better understand key issues and relevant 

context surrounding particular trade negotiations. Several African officials 

with whom we met said many SSA countries also relied on research and 

analytic support by NGOs such as the South Center.

Another effort to overcome impediments to participation in trade 

negotiations has been the development of groups that negotiate on behalf 

of multiple countries. SSA countries belong to groups such as the African 

group, the LDC group, and the ACP group that establish consensusbased priorities and negotiate on behalf of the groups’ members. 

According to several African government officials, smaller countries that 

previously felt unable to effectively participate in multilateral trade 

negotiations have had their priorities better represented in negotiations 

through these groups.

According to government officials from the United States and AGOAeligible countries, as well as officials from trade-related multilateral 

organizations and think tanks, overall African participation at the WTO is 

expanding and many African negotiators are negotiating more effectively, 

in part as a result of efforts to overcome impediments.48

 48According to a WTO Secretariat official, however, African participation overall at the 

WTO is relatively low. She found that African nations account for 42 of the WTO’s current 

members and about 15-20 of them have been individually active in core WTO work. See 

Joan Apecu Laker, African Participation at the World Trade Organization: Legal and

Institutional Aspects, 1995-2010, Graduate Institute of International and Development 

Studies, vol. 13 (The Netherlands: Koninklijke Brill NV, 2014).

Officials provided 

Efforts to Overcome 

Impediments Are Increasing 

and Have Contributed to 

Expanded SSA Country 

Participation at the WTO
Page 35 GAO-15-701 African Growth and Opportunity Act

the following examples of greater SSA official presence at the WTO and 

of priorities that African officials have successfully negotiated in 

multilateral negotiations.

• According to trade experts, African countries or groups have been 

visible in current rounds of global trade negotiations on topics such as 

cotton, intellectual property rights, public health, and special and 

differential treatment.49

• A WTO trade expert found that although the share of African 

chairmanships at the WTO between 1995 and 2010 was low overall, 

Africans made up at least 25 percent of the chairmanships of several 

bodies during that time period and characterized several of those 

chairs as competent, active, and experienced.

These topics are ones where Africans sought 

and ultimately secured concessions from the United States and other 

WTO members.

50

With a number of events relating to WTO and bilateral negotiations 

coming up that will focus on issues of interest to African countries, there 

is a window of opportunity for the United States to engage with SSA 

countries to ensure that U.S. interests are preserved. For example, 

according to the WTO, Kenya’s foreign minister has played a role in 

setting the multilateral negotiation agenda by prioritizing the ratification of 

the Trade Facilitation Agreement. According to WTO officials, while there 

is no official deadline for achieving the necessary acceptance, the foreign 

minister has set a goal of having this process completed by the time of 

the WTO’s 10th ministerial conference, in Nairobi, Kenya, in December 

2015. Two-thirds of the WTO’s 160 members will need to ratify the Trade 

Facilitation Agreement before the protocol of amendment to the WTO can 

go into effect, according to the WTO. Although Botswana and Mauritius 

are among the eight WTO members that had, as of June 18, 2015, 

 49The Doha Round is the latest round of trade negotiations among the WTO membership. 

Its aim is to achieve major reform of the international trading system through the 

introduction of lower trade barriers and revised trade rules. The work program covers 

about 20 areas of trade.

50For example, 44 percent of the chairs of the Import Licensing Committee, 25 percent of 

the chairs of the Committee on Market Access, 56 percent of the chairs of the Committee 

on Trade and Development, and 25 percent of the chairs of the Committee on Trade and 

Environment between 1995 and 2010 were African. See Apecu Laker, African 

Participation.

Upcoming Trade Events 

Involving SSA Countries 

May Provide Window of 

Opportunity for U.S. 

Engagement with SSA 

Countries
Page 36 GAO-15-701 African Growth and Opportunity Act

secured domestic acceptance, several African delegations, including 

AGOA recipients Nigeria and South Africa, have highlighted challenges 

they face in ratifying the Trade Facilitation Agreement. The Senate report 

accompanying the AGOA reauthorization legislation stated that the United 

States should seek opportunities to expand its ties with SSA countries 

through the negotiation of trade agreements that involve SSA countries.

Recent LDC priorities are evidence that progress in multilateral 

negotiations is possible, but they raise some concerns for the United 

States and, in some cases, AGOA countries. The LDC group has drafted 

a series of negotiation priorities in conjunction with the Doha round of 

global trade talks, which was to achieve improvements in agricultural 

disciplines and market access for both agricultural and non-agricultural 

goods. The December 2015 WTO ministerial conference is slated to 

revisit several topics of importance to Africa, including a potential LDC 

package and a decision on whether and how to proceed with the overall 

Doha round. Among the LDC priorities are for countries to further facilitate 

market access for LDC products. Both the United States and AGOA 

countries may face competing interests in committing to the requests of 

LDC negotiators. For example, available research suggests that AGOA 

countries would lose out to other suppliers if the textiles and apparel 

access presently provided to them were given to other LDCs such as 

Bangladesh and Cambodia. According to several African officials we met 

with from AGOA countries, competing with other LDCs without additional 

preferences is a major concern. This additional competition could also 

minimize the effectiveness of AGOA in increasing and diversifying exports 

from AGOA countries, which would run counter to U.S. interests. The 

legislation reauthorizing AGOA states that, among other things, it is in the 

interest of the United States to boost trade between the United States and 

SSA countries and that it is a U.S. goal to stimulate economic 

development in Africa and diversify sources of growth in sub-Saharan 

Africa. It is unclear whether LDC countries will insist upon some or all of 

these changes before they support continued Doha round negotiations.

Some AGOA countries are showing interest in WTO membership. Liberia 

and Ethiopia, two AGOA countries that are not yet members of the WTO, 

are in the process of acceding to the WTO. This process typically involves 

acceptance of existing WTO rules as well as negotiated market access 

commitments, demonstrating that they are declaring themselves ready to 

work toward fuller integration into the global economy. The Senate report 

accompanying the legislation reauthorizing AGOA stated that the United 

States should seek all opportunities to deepen and expand its ties with 

SSA countries through accession by SSA countries to the WTO.
Page 37 GAO-15-701 African Growth and Opportunity Act

The United States government has also proposed and begun to pursue 

plans to enhance bilateral trade with SSA countries. The recently-passed 

AGOA extension legislation includes plans to evaluate which AGOA 

countries are ready for and interested in pursuing reciprocal free trade 

agreements. In the immediate term, the United States is working with the 

Eastern African Community, reaching a cooperative agreement in 

February 2015 on non-tariff barriers in the Sanitary and Phytosanitary 

Measures and Technical Barriers to Trade areas with a goal of easing 

non-tariff barriers to trade. The United States government has also 

indicated it would like to build on the recently signed Trade and 

Investment Framework Agreement with the Economic Community of 

Western African States and that it hopes to advance negotiations with 

countries such as Nigeria, South Africa, and Angola.

We are not making any recommendations in this report. We sent a draft 

of this report to the Secretaries of Agriculture and State, the Chairman of 

USITC, and the U.S. Trade Representative for comment. State provided 

no comments and the others provided technical comments, which we 

incorporated in this report, as appropriate.

We are sending copies of this report to the appropriate congressional 

committees, the Secretaries of Agriculture, Commerce, State, and the 

Treasury; the Administrator of USAID; the Chairman of USITC; the U.S. 

Trade Representative; and other interested parties. In addition, the report 

is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-8612 or GianopoulosK@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VI.

Kimberly Gianopoulos

Director, International Affairs and Trade

Agency Comments
Page 38 GAO-15-701 African Growth and Opportunity Act

List of Requesters

The Honorable Orrin G. Hatch

Chairman

The Honorable Ron Wyden

Ranking Member

Committee on Finance

United States Senate

The Honorable Bob Corker

Chairman

Committee on Foreign Relations

United States Senate

The Honorable Jeff Flake

Chairman

Subcommittee on Africa and Global Health Policy

Committee on Foreign Relations

United States Senate

The Honorable Edward R. Royce

Chairman

The Honorable Eliot L. Engel

Ranking Member

Committee on Foreign Affairs

House of Representatives

The Honorable Sander M. Levin

Ranking Member

Committee on Ways and Means

House of Representatives

The Honorable Christopher H. Smith

Chairman

The Honorable Karen Bass

Ranking Member

Subcommittee on Africa, Global Health, Global Human Rights, and 

International Organizations

Committee on Foreign Affairs

House of Representatives
Page 39 GAO-15-701 African Growth and Opportunity Act

The Honorable Charles B. Rangel

Ranking Member

Subcommittee on Trade

Committee on Ways and Means

House of Representatives

The Honorable Robert Menendez

United States Senate

The Honorable Chris Coons

United States Senate

The Honorable Johnny Isakson 

United States Senate 

The Honorable Devin Nunes 

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-15-701 African Growth and Opportunity Act

In conducting our work, we identified and reviewed documents, data, and 

literature on the African Growth and Opportunity Act (AGOA) and other 

countries’ trade preference programs, trade agreements with AGOA 

countries, and sub-Saharan African (SSA) countries’ participation in 

multilateral trade negotiations. In addition, we interviewed officials from 

the Departments of Agriculture, Commerce, State, and the Treasury; the 

Office of the U.S. Trade Representative (USTR); the U.S. International 

Trade Commission (USITC); and the U.S. Agency for International 

Development (USAID). We conducted fieldwork in Geneva, Switzerland,

and Brussels, Belgium. We selected those locations for fieldwork based 

on the availability of officials for interviews, including multiple U.S. agency 

officials, African government officials,1 government officials from countries 

with trade preference programs,2

To examine how selected countries’ trade preference programs compare 

with AGOA in terms of key characteristics and performance, we focused 

on those countries that had the highest levels of trade in dollardenominated nominal terms—not adjusted for inflation—with AGOA 

countries and for which trade preference program information was 

available from official sources including the WTO, the United Nations 

Conference on Trade and Development (UNCTAD), and country provider 

government documents. Specifically, to identify the major country and 

and representatives from think tanks 

and multilateral organizations with pertinent expertise. We selected 

countries and regions for comparison that are major export markets for 

sub-Saharan Africa, including the European Union (EU), China, and India.

We identified three key characteristics for comparison because studies of 

preference programs generally show that these characteristics can affect 

program performance in increasing and diversifying trade. However, we 

did not independently assess the other countries’ trade preference 

programs and agreements with SSA countries. The information on those 

programs and agreements is based on interviews and both World Trade 

Organization (WTO) and other official sources. Insights discussed herein 

reflect our conclusions based on the views of those we interviewed as 

well as selected academic literature.

 1

We interviewed African government officials from Ethiopia, Lesotho, Mauritius, Nigeria, 

South Africa, and Uganda—countries we selected because they represent a range of 

sizes, face a range of trade challenges, and actively use AGOA benefits.

2

We interviewed government officials from Australia, Brazil, Canada, China, and the 

European Union (EU)—countries and regions we selected based on the amount of trade 

they conducted with SSA countries and congressional interest in their trade programs.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-15-701 African Growth and Opportunity Act

regional markets for AGOA-country exports, we used the WTO, 

UNCTAD, and World Bank integrated trade data, which we accessed 

through the International Trade Centre’s Trade Map portal. We organized 

the nominal import data in descending order by major AGOA-country 

exporters and then graphed the top eleven export markets from 2010 

through 2014. These exports of AGOA countries are for total exports, 

whether or not under a preference program. These countries include the 

United States, those in the EU, Canada, South Korea, Japan, Taiwan, 

Indonesia, India, Australia, and China. We also reviewed official WTO, 

UNCTAD, and government documents on these countries’ programs.

To examine the differences in preference programs of countries that are 

major importers from AGOA countries, we (1) analyzed recent AGOAcountry exports to major importing countries/regions and (2) analyzed 

cross-country differences in preference and non-preference import 

programs from AGOA countries. To analyze trade-weighted coverage 

across preference programs in major AGOA-country export markets, we 

used import data from the WTO’s Integrated Data Base (IDB) accessed 

through the World Integrated Trade Solution of the World Bank 

(http://wits.worldbank.org/). We summed imports by preference and nonpreference programs (such as Generalized System of Preferences, Least 

Developed Country programs, Everything but Arms, Most Favored Nation 

arrangements, etc.), and by dutiable and non-dutiable categories. For this 

analysis, we were not able to estimate utilization rates, as there were no 

publically available data on the amount of imports actually entering under 

the preference programs for certain major country importers. However, as 

a first approximation of program performance, we assumed that if imports 

were eligible to be imported under a preference program, they actually 

came in under the program. Another limitation to our analysis was that we 

were not able to obtain import and preference program data on a tariffline basis from some other major AGOA-country importers, notably China. 

Therefore, we were not able to compare U.S. programs’ trade-weighted 

coverage with that of China.

For each of the data sets that we used, we examined the data and found 

them sufficiently reliable for the purposes of our report. Specifically, we 

obtained and assessed official documentation such as users’ guides, 

frequently asked questions, and disclaimers; met with officials to discuss 

our planned use of the data and any limitations; and conducted spot 

checks against other authoritative sources.

Country eligibility. To determine country eligibility, we used the WTO 

Preferential Trade Arrangements database which identifies and compiles 
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-15-701 African Growth and Opportunity Act

information to identify all preferential trade agreements implemented by 

WTO members. Information includes required submissions by WTO 

members. We used the most up-to-date information available in the 

database, which varied by country. We also used UNCTAD data to 

determine selected trade preference programs’ country eligibility. We 

cross-checked the information found in the WTO database with the 

UNCTAD data for eligibility as of January 1, 2015. We also used other 

countries’ government websites, as available, to determine SSA country 

participation within its preference program. Furthermore, World Bank and

United Nations information was used to identify income classification and 

some procedural and policy requirements.

Product coverage and exclusions. To compare product coverage we 

utilized WTO information including a 2014 WTO Secretariat report to 

identify tariff and trade data used to assess the extent of duty-free access 

available to AGOA countries’ exports under various other countries’

preference programs. We used tariff-line trade data presented in the 

database, which are based on member notifications. We also used 

government and non-government sources to gather information on 

product coverage offered by other countries’ preference programs.

Rules of origin. To report generally on rules of origin and specifically on 

rules of origin percentage levels, calculation methods, and cumulation, we 

used information from the WTO along with government and nongovernment sources. We also conducted a semi-structured interview with 

a sample of United States and foreign government officials, including 

African officials, along with trade experts. We discussed their knowledge 

of other countries’ trade preference programs, including varying rules of 

origin and the impact of rules of origin on preference program utilization.

Performance. To determine performance among AGOA and other 

preference programs we used a 2014 USITC report on AGOA that

includes a comprehensive economic literature review on selected

countries’ trade preference programs. The study identified 48 economic 

studies of preference programs, published from 2001 to 2013; of that 

number, 11 compared the performance of programs, and 7 of the 11 

compared the performance of the United States’ and the EU’s 

programs—in part because the United States and the EU are two of the 

few preference providers that provide data on actual imports under their 

preference programs.

To examine AGOA countries’ participation in trade negotiations, we used 

WTO data to determine the bilateral and multilateral trade agreements to 
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-15-701 African Growth and Opportunity Act

which AGOA countries are party. To identify insights from AGOA country 

trade negotiations, we chose to focus on AGOA countries’ Economic 

Partnership Agreements with the EU because (1) congressional 

requesters specifically asked about the impact of these agreements, (2) 

negotiations for the regional agreements were all concluded recently—in 

2014, (3) the EU is the largest recipient of SSA exports, and (4) the 

agreements replace a unilateral trade preference arrangement with a 

reciprocal trade arrangement. We reported insights based on our 

literature review on the negotiations leading up to (and the terms of) the 

agreements as well as interviews with trade experts from AGOA 

countries, U.S. government agencies, other key trade partners with 

AGOA countries, multilateral trade organizations (including the WTO), 

and think tanks.3

To determine impediments to SSA countries’ participation in trade 

negotiations, we reviewed the USITC report on AGOA and other relevant 

literature. We also developed a semi-structured interview tool. We 

selected a sample of officials and experts who would participate in semistructured interviews on the basis of (1) GAO selective sampling based 

on literature review, (2) recommendations from U.S. government officials 

knowledgeable about other countries’ trade negotiations with Africa, and, 

where applicable, (3) availability during our fieldwork in Geneva and 

Brussels. We implemented the semi-structured instrument in interviews 

with trade experts from AGOA countries, U.S. government agencies, 

other key trade partners with AGOA countries, multilateral trade 

organizations (including the WTO), and think tanks. From the literature 

and semi-structured interviews, we also examined efforts to address 

impediments to SSA countries’ participation in trade negotiations and the 

impact of those efforts. Our observations about upcoming trade 

negotiations involving AGOA countries are based on WTO documents 

and official government documents.

 3

We met with officials at the WTO, UNCTAD, the International Trade Centre, the World 

Bank, the International Centre for Trade and Sustainable Development, and the European 

Centre for Development Policy Management. 
Appendix II: Additional Information about 

Trade Preference Programs of Countries That 

Are Major Importers of Products from SubSaharan African Countries

Page 44 GAO-15-701 African Growth and Opportunity Act

Table 3 provides a comparison of key characteristics of selected

countries’ trade preference programs with sub-Saharan African (SSA) 

countries. The countries or groups of countries included in the table are 

the major destinations for SSA exports.

Appendix II: Additional Information about 

Trade Preference Programs of Countries 

That Are Major Importers of Products from 

Sub-Saharan African Countries
Appendix II: Additional Information about 

Trade Preference Programs of Countries That 

Are Major Importers of Products from SubSaharan African Countries

Page 45 GAO-15-701 African Growth and Opportunity Act

Table 3: Key Characteristics of Trade Preference Programs of Countries That Are Major Importers of Products from SubSaharan African (SSA) Countries

Notes: Taiwan, among the leading AGOA export markets, also has a preference program for LDCs 

that, as of 2014, provided duty-free coverage of 136 out of its total 8,928 tariff lines. Further 
Appendix II: Additional Information about 

Trade Preference Programs of Countries That 

Are Major Importers of Products from SubSaharan African Countries

Page 46 GAO-15-701 African Growth and Opportunity Act

information on its program may be found at the WTO Preferential Trade Arrangements database, 

accessed July 8, 2015, http://ptadb.wto.org/ptaList.aspx.

The product coverage for AGOA is separated into an LDC coverage rate and a non-LDC coverage 

rate. AGOA's non-LDC product coverage rate, at 85.1%, only applies to three countries - South 

Africa, Gabon, and Seychelles, since all other non-LDCs, such as Ghana and Kenya, are considered 

least-developed beneficiary countries for the purposes of AGOA. This data from the WTO Secretariat 

was confirmed by USTR.
Appendix III: Selected Trade Preference 

Programs’ Sub-Saharan African Country 

Eligibility

Page 47 GAO-15-701 African Growth and Opportunity Act

Sub-Saharan African countries are eligible for preferences under multiple 

countries’ preference programs (see table 4). Most of the programs are 

generalized (available to all developing countries, and known as 

Generalized System of Preferences (GSP) schemes,) but some programs 

focus exclusively on least-developed countries (LDCs). Some countries 

that had been eligible for preferences offered by the European Union

(EU) have transitioned from the EU’s preference programs to Economic 

Partnership Agreements.

Table 4: Sub-Saharan African Countries Eligible for Trade Preference Programs Offered by Major Sub-Saharan African 

Trading Partners 

Beneficiaries LDC

Preference Provider and Program

Australia Canada China European Union India Japan

South

Korea

Russian 

Federation United States

GSP GSP LDC GSP EBA GSP+ LDC GSP LDC GSP GSP AGOA

Angola LDC          

Benin LDC            

Botswana     

Burkina Faso LDC          

Burundi LDC           

Cameroon      

Cape Verde        

Central 

African 

Republic

LDC          

Chad LDC          

Comoros LDC           

Congo        

Côte d’Ivoire LDC      

Democratic 

Republic of 

the Congo

LDC         

Djibouti LDC          

Equatorial 

Guineaa LDC        

Eritrea LDC          

Ethiopia LDC           

Gabon     

Gambia LDC         

Ghana      

Appendix III: Selected Trade Preference 

Programs’ Sub-Saharan African Country 

Eligibility
Appendix III: Selected Trade Preference 

Programs’ Sub-Saharan African Country 

Eligibility

Page 48 GAO-15-701 African Growth and Opportunity Act

Beneficiaries LDC

Preference Provider and Program

Australia Canada China European Union India Japan

South

Korea

Russian 

Federation United States

GSP GSP LDC GSP EBA GSP+ LDC GSP LDC GSP GSP AGOA

Guinea LDC          

GuineaBissauLDC          

Kenya      

Lesotho LDC           

Liberia LDC           

Madagascar LDC           

Malawi LDC           

Mali LDC           

Mauritania LDC          

Mauritius     

Mozambique LDC           

Namibia     

Niger LDC          

Nigeria        

Rwanda LDC           

São Tomé

and Principe

       

Senegal LDC           

Seychelles    

Sierra Leone LDC          

Somalia LDC          

South Africa    

South Sudan LDC    

Sudan LDC         

Swaziland     

Tanzania

(United 

Republic of)

LDC           

Togo LDC          

Uganda LDC           

Zambia LDC           

Zimbabwe     

Legend: LDC = Least Developed Country; GSP = Generalized System of Preferences; EBA = Everything but Arms; AGOA = African Growth and 

Opportunity Act.

Source: GAO analysis of United Nations, World Trade Organization, and preference provider country official information. l GAO-15-701
Appendix III: Selected Trade Preference 

Programs’ Sub-Saharan African Country 

Eligibility

Page 49 GAO-15-701 African Growth and Opportunity Act

Notes: The Russian Federation’s GSP program is also offered by Belarus and Kazakhstan.

a

The UN General Assembly, in its resolution 68/L.20 adopted on December 4, 2013, decided that 

Equatorial Guinea will graduate from LDC status 3 and a half years after the adoption of the 

resolution and that Vanuatu will graduate 4 years after the adoption of the resolution.
Appendix IV: Margins of Preference

Page 50 GAO-15-701 African Growth and Opportunity Act

Although the extent of product coverage and duty-free versus reduced 

duties are important when evaluating the potential impact of programs, it 

is also important to consider the margin of preference for program 

beneficiaries. The margin of preference is defined as the difference 

between the tariffs all countries face—known as the most favored nation 

(MFN) rate—versus the tariff charged preference program beneficiaries.

Essentially it is the price advantage that the program accords 

beneficiaries over other competitors in their market.

• In the case of programs that provide duty-free treatment to covered 

products, the tariff charged is zero, and thus the margin of preference 

is the entire value of that difference. Thus, if a country had an average 

MFN tariff of 10 percent and accorded preference program 

beneficiaries duty-free treatment, the beneficiary would enjoy a 10 

percent margin of preference in that market.

• In the case of programs that provide reduced duties, the margin of 

preference would be a fraction of that. For example, if the preference 

program provider’s average MFN tariff was 10 percent and its

preference program involved a 50 percent reduction in duties, 

beneficiaries of its programs would face a 5 percent tariff and have a 

5 percentage point advantage over competitors.

As shown in table 5, according to WTO Secretariat calculations, many 

developing countries have substantially higher tariffs than developed 

countries on key products from LDCs.

Table 5: Average Tariffs Charged by Developed Countries and Select Developing 

Countries on Key Products from Least-Developed Countries

In percentage, ad valorem

Product Developed countries Select developing countries

Agriculture 0.9 22.3

Clothing 6.7 13.7

Textiles 3.1 7.3

Other 0.3 3.6

Source: WT/COMTD/LDC/W/59, Oct. 23, 2014, WTO Secretariat, Market Access for Products and Services of Export Interest to LeastDeveloped Countries, p. 39 and 43. | GAO-15-701

Note: The select developing countries are: Brazil, China, India, Indonesia, South Korea, Mexico, 

Philippines, South Africa, Sri Lanka, Chinese Taipei (Taiwan), Turkey, and Vietnam. For the purposes 

of this table, average Most Favored Nation tariffs are used.

For example, developing country tariffs on agriculture are more than 20 

times as high as those in developed countries, and tariffs on clothing and 

Appendix IV: Margins of Preference
Appendix IV: Margins of Preference

Page 51 GAO-15-701 African Growth and Opportunity Act

textiles are about twice as high. Several of these developing countries, 

such as China and India, have put preferences in place for LDCs. All 

other things being equal, a producer from a country that has access to 

both developed and developing countries’ programs may focus first on 

using the one with the highest margin of preference.
Appendix V: Rules of Origin for Select SubSaharan African Trading Partners

Page 52 GAO-15-701 African Growth and Opportunity Act

Table 6 shows the different factors considered by selected countries 

when determining whether a finished product qualifies to enter under its 

preference program.

Table 6: Rules of Origin for Select Countries

Calculation method

Country or 

region

Preference 

program Percentage level Numerator Denominator Cumulation

United States AGOA Minimum of 35 percent

Additional rules: (a) The cost or 

value of materials produced in the 

customs territory of the United 

States may be counted toward the 

35 percent requirement up to a 

maximum amount not to exceed15 

percent of the article’s appraised 

value; (b) the cost or value of the 

materials used that are produced 

in one or more beneficiary subSaharan African countries shall be 

counted toward the 35 percent 

requirement; and (c) the direct 

costs of processing operations 

performed in one or more such 

beneficiary sub-Saharan African 

countries or former beneficiary 

sub-Saharan African countries 

shall be applied in determining 

such percentage. 

Sum of the cost 

of value of 

material 

produced in the 

beneficiary 

developing 

country and the 

direct cost of 

processing

Appraised value of 

the article at the 

time of entry into 

the United States

Cumulation among AGOAdesignated

countries

GSP-LDC Same Same Same Regional cumulation for 

GSP-eligible members of 

Andean Group, ASEAN 

(with exclusions), 

CARICOM, SADC, and 

WAEMU

Canada GSP-LDC Equal or greater than 40 percent Originating 

contents

Ex-factory price All General Preferential 

Tariff beneficiary countries 

are regarded as one single 

area. All LDCT beneficiary 

countries are regarded as 

one single area

Appendix V: Rules of Origin for Select SubSaharan African Trading Partners
Appendix V: Rules of Origin for Select SubSaharan African Trading Partners

Page 53 GAO-15-701 African Growth and Opportunity Act

Calculation method

Country or 

region

Preference 

program Percentage level Numerator Denominator Cumulation

European Union EBA Maximum amount of nonoriginating material 70 percent 

with exceptions

Value of nonoriginating 

material 

Ex-works price (a) Cumulation with the EU, 

Norway, Switzerland, and 

Turkey; 

(b) Regional cumulation 

with ASEAN, Andean 

Community, SAARC, 

Mercosur; 

(c) Cumulation between 

ASEAN and SAARC

(d) Extended cumulation
Appendix V: Rules of Origin for Select SubSaharan African Trading Partners

Page 54 GAO-15-701 African Growth and Opportunity Act

Calculation method

Country or 

region

Preference 

program Percentage level Numerator Denominator Cumulation

Japan GSP-LDC Maximum amount of nonoriginating material 40 or 50 

percent where used in the single 

list

Value of nonoriginating 

materials

Value of the FOB 

price

Cumulation of Indonesia, 

Malaysia, the Philippines, 

Thailand, and Vietnam

Legend: AGOA = African Growth and Opportunity Act; GSP = Generalized System of Preferences; LDC = Least Developed Country; ASEAN = 

Association of Southeast Asian Nations; CARICOM = Caribbean Community; SADC = Southern African Development Community; WAEMU = West 

African Economic and Monetary Union; LDCT = Least Developed Country Tariff; SAARC = South Asian Association for Regional Cooperation.

Source: World Trade Organization data. l GAO-15-701

Notes:

Cumulation allows beneficiary countries to combine inputs from multiple sources to meet the local 

sourcing requirements.

Ex factory price is the price of a product at the moment that it leaves the factory.

Ex-works price is the price paid for the product ex works to the manufacturer in whose undertaking 

the last working or processing is carried out, provided the price includes the value of all the materials 

used minus any internal taxes that are, or may be, repaid when the product obtained is exported. 

Free on Board (FOB) price is the price, excluding insurance and freight.
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 55 GAO-15-701 African Growth and Opportunity Act

Kimberly Gianopoulos, (202) 512-8612 or GianopoulosK@gao.gov

In addition to the contact listed above, Kim Frankena (Assistant Director), 

Jeffrey Baldwin-Bott (analyst in charge), Ashley Alley, Kenneth Bombara, 

Debbie Chung, Barbara El Osta, Jill Lacey, and Shakira O’Neil made key 

contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(321030)
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