Dear Mr. Lewis:

The Sweetener Users Association (SUA) appreciates the opportunity to comment on the Agricultural Marketing Service’s (AMS) July 22 proposed rule to update the List of Bioengineered Foods. SUA’s members are U.S. food and beverage companies that use caloric sweeteners in manufacturing their products, as well as trade associations representing those companies. The segments of the U.S. food industry that use sugar in their business operations employ some 600,000 Americans.

SUA believes it is inappropriate to add sugarcane to the List of Bioengineered Foods. Our understanding is that the single variety of insect-resistant sugarcane approved by Brazil is only being raised in test trials and in only one region of the country, and not the region from which Brazilian sugar imported under tariff-rate quotas is typically sourced. Brazil is one of 40 different countries from which the United States imports sugar, in addition to our domestic cane supply, which is not bioengineered. Thus, the chance that BE sugarcane was used to produce refined sugar consumed anywhere in the United States appears to be minuscule.

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