Comments Recommend Higher Polarity Threshold and Other Smart Fixes to Ensure Reliable Access to Sugar Needed for U.S. Food Manufacturing

Washington, D.C. (January 14, 2026) — In comments submitted to the U.S. Department of Agriculture (USDA) Foreign Agricultural Service (FAS) yesterday, the Sweetener Users Association (SUA) detailed seven recommendations for ensuring refined sugar imports are actually refined.

Currently, sugar with a polarity above 99.5 is considered “refined.” However, food manufacturers require sugar with a polarity of 99.8 or 99.9 to use in their products. This means that much of the sugar imported under refined tariff-rate quotas (TRQs) requires further processing, which adds to the time and cost of production, and crowds out refined sugar imports of higher quality that would be ready for direct use. Learn more here.

The recommendations, submitted in response to a Request for Information that USDA published pursuant to a One Big Beautiful Bill Act requirement, include:

1. Defining ‘‘refined sugar’’ as having a minimum polarization of 99.8 degrees or higher: For purposes of all increases to the [World Trade Organization (WTO)] minimum obligated refined [tariff-rate quota (TRQ)], we favor this definition because it will ensure access to sugar that meets industrial users’ quality needs and will maximize the efficiency of the refined TRQ.

 2. Establishing a standard for color- or reflectance-based units for refined sugar such as those utilized by the International Commission of Uniform Methods of Sugar Analysis: As a general matter, we would favor this option, in combination with others. We encourage USDA to explore the adequacy of resources for testing that might be necessary to enforce this requirement.

 3. Prescribing specifications for the packaging type for refined sugar: This option could prove useful since it is easily observable and verifiable. Genuine refined sugar will be shipped in packages rather than in bulk, so packaging offers a good way of distinguishing between sugar that does and does not require further processing in the United States.

 4. Prescribing specifications for transportation modes for refined sugar: Similar to option 3 above, this requirement could be helpful in readily distinguishing cargoes that do and do not require further processing.

5. Requiring affidavits or other evidence that sugar imported as refined sugar will not undergo further refining in the United States: If available enforcement resources are constrained, this requirement could be helpful. In general, we would recommend that this not be the sole additional requirement, but operate in tandem with one or more other stipulations. It is important that, if this option is chosen, required statements be legally binding on those making them.

6. Prescribing appropriate terms and conditions to avoid unlawful sugar imports: Additional information would be helpful in evaluating this option. SUA supports the prevention of unlawful sugar imports. However, as we have noted above, many of the problematic imports of intermediate polarity ‘refined’ sugar are perfectly legal under the current [Harmonized Tariff Schedule of the United States], so we would not suggest adopting this option alone. The problem is bigger than any unlawful imports that may occur.

7. Establishing other definitions, terms and conditions, or other requirements: Although we would certainly be open to requirements beyond those laid out in items 1-6, we do not have specific alternatives to suggest. We strongly encourage FAS to adopt one or a combination of items 1-6, even if additional options are identified under item 7.

SUA explained how the modifications would benefit the sugar industry:

[R]efined TRQ increases can contribute to maintaining domestic demand for sugar and discouraging both import substitution and food product reformulation toward non-sugar sweeteners, whether caloric or non-caloric. These impacts would operate to the benefit of U.S. sugar producers, processors and refiners.

 It is also the case that the current 99.5 degrees polarity point encourages imports of intermediate-polarity sugar that would not otherwise occur. When this sugar eventually enters the market, it increases the total supply of sugar that requires further processing, potentially competing with the output of cane sugar processors owned by U.S. producers.

SUA looks forward to working with policymakers on simple fixes to improve U.S. sugar policy for all stakeholders.

Media Contact:
Anna Miller
amiller@fratelli.com