Below are copies of the comments that were submitted on the Commerce Department’s draft 2019 sugar suspension agreements by CSC Sugar, the American Sugar Coalition, Imperial Sugar and on behalf of the Mexican Government.
Excerpts from the comments include:
- CSC Sugar asks “why do the agreements have both a requirement of shipments in bulk and a change in the polarity requirements? …There is no legitimate reason for the polarity change. The only reason for the polarity change is to stifle U.S. competition from CSC.”
- “Imperial Sugar supports Commerce’s 2019 draft amendment in their current form.” The 2019 amendments “will ensure that the cane refiners, including Imperial, have access to an adequate supply of imported raw sugar.” “Imperial Sugar already has demonstrated that the terms of the unamended 2014 agreements that are now reinstated failed to provide for an adequate supply of raw sugar to refiners and caused cane refining margins to collapse, resulting in cane refiners operating at low levels of capacity utilization.”
- The American Sugar Coalition argues that “It is no surprise…that CSC has never explained how the Draft Amendments would cause any injury other to it other than the economic disadvantage of not being able to source dumped and subsidized sugar, which the U.S. Court of International Trade has ruled is not harm under the statute.” “Commerce should implement the Draft Amendments without change as soon as possible.”