These comments are submitted on behalf of the Sweetener Users Association (SUA), whose members use sugar and other nutritive sweeteners in manufacturing foods and beverages. Companies in the industries represented by SUA account for some 600,000 jobs in the United States.  SUA appreciates the opportunity to provide our views on a request for comments entitled “Definition of Specialty Sugar in the Rules Concerning Allocation of the U.S. Refined Sugar Tariff-Rate Quota.”

In what follows, we respond directly to the six questions posed by the Office of the U.S. Trade Representative (USTR) with respect to whether the definition of specialty sugar should be amended to “[r]equire no further refining, processing, or other preparation prior to consumption, other than incorporation as an ingredient in human food.”  SUA believes the definition should be so amended, and we explain why in response to USTR’s questions.

Read more below.