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Looming Changes to the US Sugar Re-Export Program

The USDA recently published a Request For Information (RFI) related to the sugar re-export program. While the RFI may seem harmless, it is the prelude to proposed changes in the Sugar re-export program that will certainly cause harm to your company. Whether or not your company participates in the re-export program, if you care about fair and open competition, it is in your company’s interest to respond to the RFI.

The USDA is being pushed by certain large refining companies to amend the regulations with the goal of reducing competition in the sugar refining industry. Their approach is that by changing the definition of who qualifies as a recognized sugar refiner, they will prevent companies like CSC from importing raw sugar under the re-export program.

The responses to the RFI will be used by the USDA to shape proposed rule changes that we expect to be published in the coming months, further restricting access to supply and competition. We fully expect that certain large refining companies and domestic sugar interests will submit comments to the USDA that will outline new refiner qualifications that are blatantly and intentionally designed to stifle competition from innovation companies like CSC/Sugaright to keep prices high into perpetuity.

These include the following:

  • Sugar refiners must produce granulated sugar (designed to exclude companies like CSC/Sugaright

  • Sugar refiners must increase the polarization (granular sugar purity) during the refining process (designed to exclude companies like CSC/Sugar - as polarization is not a factor in liquid sugar refining)

  • ·Sugar refiners must pack product in a bag (designed to exclude CSC as liquid sugar is shipped in bulk liquid tankers)

Big sugar is once again trying to tell you, the customer, what to do and how much you should pay. CSC’s participation in the re-export program is one of the tools that we use to stay competitive, and the very reason that our competition wants to exclude us from the program.

CSC Sugar/Sugaright entered the refined liquid sugar market to challenge the legacy refining industry by focusing on innovation, excellent customer service and more environmentally friendly sourcing options. We value free and fair competition, and we know you do too.

We respectfully request your support in this matter by responding to the RFI.

The following link directs you to CSC’s response to the RFI:

CSC Sugar Response to the FAS RFI on the Sugar Re-Export Program
Download PDF • 173KB


Responses to the RFI are due on Monday November 7th. We have also included a form letter that your company could use in response to the RFI (assuming that your company agrees with our position of keeping the market competitive).

Suggested Response to FAS RFI on the Sugar Re-Export Program
Download DOCX • 15KB

USDA invites submission of comments through one of the following methods:

•Federal eRulemaking Portal: Go to Follow the online instructions for submitting comments.

• Email: FAS will accept electronic comments emailed to FAS.Sugars@ The email should contain the subject line, ‘‘Response to RFI: Inviting Input on the Sugar Re-Export Programs’’.

We thank you for your support.


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