Dear Ms. Gannon:

These comments respond to your memorandum of December 8, 2021, with respect to the December calculation of the Export Limit under Section V.B of the Agreement Suspending the Countervailing Duty Investigation on Sugar from Mexico, as amended. The Sweetener Users Association (SUA) comprises companies that use sugar in food and beverage manufacturing. Our members are directly affected by government policy actions that affect the supply of sugar in the United States, including sugar imported from Mexico.

SUA Support Commerce’s Initial Determination

SUA appreciates the Commerce Department’s recent identification of additional U.S. needs and the accompanying increase in the Export Limit of 150,000 short tons, raw value (STRV), as requested by the U.S. Department of Agriculture. As explained further below, this action was both welcome and necessary. In the present case, SUA strongly agrees with Commerce’s initial determination that if the December Export Limit calculation results in a figure that is less than the September Export Limit or less than the revised November Export Limit, the December Export Limit should be maintained “at the level of the revised November Export Limit.”

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