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European Sugar Refineries Association

ESRA

The European Sugar Refineries Association was formed in 2011 and represents the interests of the vast majority of Europe’s sugar refining industry.

Lobbying Activity

Meeting with Vanesa Hernandez Guerrero (Head of Unit Taxation and Customs Union)

13 Mar 2025 · Physical meeting - Discussion on the current functioning of the inward processing procedure in the sugar market and the future of that procedure if the reform on the UCC is adopted

Response to Enhancing Market transparency in the agri-food chain

19 Jun 2019

The European Sugar Refineries Association (ESRA), which represents the majority of the cane refining industry in the European Union, welcomes moves by the European Commission towards increased transparency. However, we agree with sentiments expressed by other respondents that the sugar sector is already subject to high standards of transparency, with producers obliged to report prices since 2006, and regional price reporting introduced in 2018. Players in the sugar sector therefore already enjoy some of the EU’s most ample information regarding prices. Furthermore, we wish to express some concerns regarding the Commission proposal at hand: 1) We are concerned that the reporting of post-production buying prices for sugar may distort competition in the sugar sector in favour of sugar users and retailers, exacerbating a situation whereby cane refiners already operate under very tight profit margins. It is essential that refiners’ negotiating position in these commercial relationships is not undermined any further. 2) This approach also risks the imposition of an unjustifiably heavy price reporting burden on refiners, as it is buying prices rather than selling prices that are to be registered. As refiners often supply thousands of customers, we recommend that the Commission alter the proposal to protect refiners from being forced to report the buying prices of each and every one of these customers. Rather, an effort should be made to ensure that sugar users and retailers also contribute to the reporting process. This would be required in order to avoid a repetition of the situation in the reporting of sugar stocks, for example, where users and retailers are not obliged to submit information. 3) Cane refiners are also concerned about the differentiation in the proposal between short- and long-term contracts. On the one hand, the proposal seems to lack clarity on how this differentiation is to be made. On the other, in a sector such as ours where contracts are often negotiated on the basis of futures, and prices may change at the time of invoicing, it is difficult to envisage what kind of accounting procedures could be put in place to distinguish between short- and long-term contracts – indeed, our commercial reality indicates that such as differentiation would not lead to any better representation of the market reality at a given time. Moreover, should such a differentiation be made, the risk of human error in reporting would increase significantly, undermining the veracity of statistics. 4) Lastly, we would appreciate further clarity from the Commission on how information reported through such a mechanism would be rendered anonymous. Therefore, while refiners are not in principle opposed to increased transparency, we strongly advise the Commission to take into account these operational and commercial challenges, which we believe would make the current proposal unworkable. Moreover, refiners would request that the Commission provide further information on what measures might be put in place to respond to any price anomalies which such a reporting mechanism would potentially reveal.
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Response to Legal act to apportion certain concessions between the EU and the United Kingdom (Brexit preparedness)

17 Jul 2018

ESRA represents the majority of the EU cane sugar refining sector, with members in Italy, Portugal, Romania, and the UK. EU sugar production is divided between refiners of sugar beet which is grown in the EU (~85%) and our cane refining sector (~15%) which is fully dependent on imports of raw cane sugar from outside the EU, from which we produce white sugar and other products. Our dependence on imports makes us well-placed to comment on the apportionment of WTO tariff-rate quotas (TRQs) on sugar. The global sugar market is volatile and competitive, meaning that the most essential element in our access to imports is choice. ESRA members require the ability to source raw sugar from as many different sources as possible in order to make commercial decisions based on the market conditions of the day. The recent reform of the EU sugar market–which has seen a massive increase in domestic production, leading to a collapse in the price of white sugar in the EU–has restricted our choice more than ever before. We are now dependent on access to raw sugar imports through zero-duty TRQs in EU free trade agreements (FTAs). In the past, a number of sugar TRQs under the EU’s WTO schedules have been of interest to EU cane refiners. They provide the only access to some of the world’s most important sugar markets – in particular the TRQs relating to Brazil, and the erga omnes TRQ, which can provide access to any market. In previous years, these have at times provided essential access to imports for ESRA members. But the recent changes to the EU sugar market have rendered them obsolete, because all but a tiny portion of raw sugar imports under these quotas are subject to a €98/tn duty. With the EU sugar market in significant surplus–which is likely to continue into the future–this duty means that these imports are uncompetitive, and will no longer supply the EU with raw sugar. However, cane refiners would like to express their opposition to the approach put forward in this regulation, whereby the WTO TRQs would be split between the UK and the EU based on past trade flows. EU cane refiners are opposed to the proposed approach because: (1) Splitting TRQs eliminates choice Under the Commission’s proposal, EU cane refiners – whether they be located in the UK or the EU-27 – would see a further limitation on their choice regarding access to raw sugar imports. Even if the calculation method proposed would see the majority of volumes allocated to EU refiners, it would still reduce overall access permanently, at a time when EU refiners are struggling to source sufficient raw material. This is especially relevant to the Australia TRQ of 10,000tn. This quota is already so small that it is only rarely useful to EU cane refiners. Splitting it in half would effectively eliminate all access for EU refiners to Australia raw sugar-volumes would be far too small. (2) The use of reference years is inherently flawed Changing market conditions make it difficult to justify using any particular reference years to decide how to apportion sugar tariffs. Each ESRA member approaches the market for raw sugar with as much flexibility as possible, leading to wide YOY differences e.g. Brazilian imports, where Portugal (with 2 ESRA Members) imported 88,000tn in 2012/13, but 78tn in 2013/14. The law of averages cannot produce a realistic depiction of EU and UK demand for raw sugar. (3) Creation of trade uncertainty Although the EC intends to renegotiate WTO schedules, this will not occur for many years. In the meantime, the EU will be left open to challenges from other WTO members, creating an unacceptable level of uncertainty in trade. Thus,WTO TRQs should not be split between UK and the EU. The status quo should be maintained, as the commitments in question adhere to the bloc, not to its individual member states. Our position is based on considerations of practicality, fairness, and certainty, and offers the best solution for both the EU-27 and the UK sugar markets
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and NOVE and

12 Apr 2018 · EU sugar sector

Meeting with Xavier Coget (Cabinet of Vice-President Jyrki Katainen)

21 Feb 2018 · EU-Mexico and EU-Mercosur negotiations

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

29 Oct 2015 · Business discussion