Dear Madame Ambassador:
On behalf of the Sweetener Users Association (SUA), I respectfully request that the Office of the U.S. Trade Representative move expeditiously to reallocate the fiscal year (FY) 2022 raw sugar tariff-rate quota (TRQ) to put additional supplies into the U.S. market, which remains unduly elevated at historically high prices that are not justified by supply-demand fundamentals. The need for reallocation is twofold. First, as explained further below, 10 quota-holding countries never fill their quotas because they have ceased to produce or export sugar. Not one of these countries has shipped a single ton of sugar to the United States since 2008. There is no reason to wait on reallocating the quota shares of these countries.
Second, the Philippines sugar authority has stated that it will not ship any sugar against its sizeable quota due to domestic production shortfalls. This being the case, the entirety of that nation’s quota should also be reallocated. Again, if a quota-holding country has stated on the record that it will not sell the United States any sugar, there is no reason to wait before reallocating its quota.
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