Request for Comments on the Modernization of the African Growth and Opportunity Act (AGOA)

The Northwest Horticultural Council (NHC) submits the attached comments in response to USTR's "Request for Comments on the Modernization of the African Growth and Opportunity Act (AGOA)" published in the U.S. Federal Register on April 29, 2026. The NHC represents the growers, packers, and shippers of apples, pears, and cherries in Washington, Oregon, and Idaho on federal and international policy issues. Pacific Northwest pear growers produce 75 percent of all U.S. pears (both fresh market and for processing) and 46 percent (five-year average) of the processed pear crop produced in the United States. With the U.S. canned pear market matured and canned pear consumption declining, unfairly low-priced canned pear imports have increasingly led to lost sales and revenue for the U.S. growers, contributing significantly to U.S. canned pear tonnage declining by 23 percent between 2021 and 2025. As U.S. canned pear growers and processors continue to fight for their survival, imports from South Africa, China, and other countries are expected to continue to displace U.S. canned pears in the domestic market with unfairly subsidized, low-priced canned pears in 2026 and beyond. If those unfairly priced import volumes were not in the U.S. market, nearly 26,000 mt – including 4,100 mt from South Africa – of potential sales would be available to U.S. producers, providing growers and processors with product movement they desperately need. South Africa is the second largest importer of canned pears into the United States, importing more than 4,100 metric tons (mt) of canned pears valued at nearly $8 million in 2025. This represents 13 percent of canned pear imports. When combined with China (the largest importer of canned pears into the United States) that also employs unfair trade practices, this jumps to more than 80 percent of canned pear imports. Because South Africa continues to impose significant market access restrictions on U.S. agricultural producers while enjoying duty-free access to the U.S. market for most of its agricultural products, including processed pears (HTS 2008.40.00), the NHC requests that the President withdraw or suspend South Africa's AGOA benefits on HTS 2008.40.00 and reinstate the United States' most favored nation (MFN) tariff rate of 15.3 percent for all processed pears entering from that country. Furthermore, we request that USTR work with Congress to ensure that any reauthorization of AGOA withhold benefits for any product that is listed as import sensitive in the 2015 Trade Promotion Authority (TPA) law.