FAS: Segregate Sugar Data 09-28-04 - Organic Trade Association
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FAS: Segregate Sugar Data 09-28-04


Segregate Organically Produced Sugar (Produced Under 7 CFR 205) from Other Sugars

In All Information Collections for the Sugar Import Licensing Program:

Comments of the Organic Trade Association to “Notice and Request for Comments,”

Federal Register Vol. 69, No. 146, Friday, July 30, 2004, pp. 45669-45670.


Submitted by:

Tom Hutcheson

Associate Policy Director

 September 28, 2004



The Organic Trade Association (OTA) is the membership-based business association for organic businesses in North America, representing over 1500 members from all sectors of organic agriculture and the organic industry.


OTA believes that this and subsequent, similar information collections would be more useful if data for organic product were segregated.  Recent import limitations of specialty sugars as a class have occurred even though the demand for organic sugar was demonstrably increasing, and domestic supplies to help fill the gap were entirely lacking.


OTA further urges FAS to report this data separately, and to communicate to the public, including OTA, when this analysis is complete.


Thank you very much for your consideration.

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