the Committee of European Sugar Users
CIUS
CIUS represents the European sugar-using food and beverage industries with more than 15, 000 companies across Europe.
ID: 860265952576-17
Lobbying Activity
Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
30 Apr 2025
The Committee of European Sugar Users (CIUS), representing major sugar-using food and drink companies in the European Union, welcomes the opportunity to provide feedback on the draft delegated act revising Annex I of the EU Deforestation Regulation (EUDR). We welcome the fact that sugarcane remains outside the scope of the Regulation in the proposed amendment. We believe there is no evidence-based justification to include sugarcane at this stage, as it is not a driver of deforestation linked to EU supply chains. Sugarcane cultivation generally occurs in areas far removed from high-risk forested ecosystems and is governed by national-level sustainability and traceability frameworks. In Brazil, the worlds largest sugarcane producerproduction is concentrated thousands of kilometres away from the Amazon biome, with under 0.2% of national output coming from that region. Future expansion is expected to continue on degraded pastureland, in line with agro-ecological zoning and national sustainability commitments. This reinforces that sugarcane production does not represent a deforestation risk relevant to the EUs objectives. In other markets our members are active in various initiatives related to sugarcane and its role in their broader business operations, including supporting farmers, improving supply chains and investing in sustainable practices. Moreover, many sugar producers supplying the EU are already subject to sustainability certifications and land-use controls. The absence of significant linkages between sugarcane production and deforestation or ecosystem conversion supports a continued exclusion from the EUDR. From a policy perspective, CIUS urges the Commission to uphold the Regulations risk-based, proportionate, and evidence-driven approach. Adding new commodities without clear environmental benefit risks undermining the credibility and effectiveness of the Regulation while imposing disproportionate burdens on compliant supply chains. We thank the Commission for the opportunity to contribute and remain available for further dialogue.
Read full responseResponse to Further reciprocal tariff liberalisation under Art. 29 of the EU-Ukraine Association Agreement
30 Sept 2024
CIUS, representing over 15,000 European sugar-using companies, acknowledges the significant progress achieved in EU-Ukraine trade relations since the DCFTAs provisional application in 2016, and notably the benefits to both Ukraine and the EU of the ATMs in 2022 and 2023. We fully support the deepening of trade ties through reciprocal tariff liberalization, especially as Ukraine moves toward integration into the EU single market. We think that it was neither necessary nor appropriate to introduce an automatic safeguard mechanism for sugar in 2024. Free trade in sugar between the EU and Ukraine proved to be beneficial to both economies and should be reinstated. The EUs sugar supply has consistently fallen short of demand over recent years, with a deficit ranging from 2 to 3 million tonnes annually. The EU has to import to fill this gap. However access to imports is restricted by prohibitive tariffs with the exception of a total of 1.4 million tonnes of TRQs, plus duty free quota free access to sugar from EPA/EBA countries. (600 000 tonnes imported in 2022/23) EPA/EBA countries dont produce enough for their own regional demands, let alone having sufficient sugar available to fill the gap in years such as 2022/2023 when the shortfall was far more at 2.8 million tonnes. In such years, some CIUS members are faced with the choice of cutting back production due to unavailability of sugar supply, a critical raw material for them, or selling at a loss due to much higher raw material costs and complexity than competitors producing outside of the EU. (see CIUS site for more detailed explanations) This is economically counterproductive for Europe. Measures need to be taken to ensure free access to more sugar when needed. While EU sugar producers are free to produce and export as much or as little as they like, imports are restricted. This results in distortion of the EU sugar market when EU production levels are low. In order to prevent such market distortion, the EU needs to provide for more access to supply sources, and Ukraine, as a future member, is an ideal source. Reciprocal tariff liberalization presents an opportunity to ensure both the EU and Ukraine benefit from free trade under the DCFTA. The continued liberalization of Ukrainian sugar imports, will enable access to the raw materials European industries need while supporting Ukraines economic recovery. Both parties can benefit from a mutually beneficial trade relationship that contributes to better functioning markets and stability. Given the war, Ukraine is unable to export to their traditional export markets like Kazakstan and their main export route via the Black sea was cut completely and is now very hazardous. Exporting to and via the EU is therefore a lifeline for Ukraine. The current system of blanket restrictions on sugar imports does not respond adequately to the reality of the EUs chronic fluctuating sugar supply deficit. And it would be simply unacceptable to restrict imports from Ukraine any more than the already excessively harsh restriction of 260 000 tonnes. As the DCFTA is reviewed, our preference would be duty free quota free trade, however if the safeguard were to be transformed into a TRQ, then we would recommend a starting TRQ of the average amount of imports over the last 2 years ie 500 000 tonnes. This should be increased each year as Ukraine integrates into the Single market. This would provide greater market security and transparency to both the EU and Ukraine. Free trade between the EU and Ukraine will provide some much needed flexibility to import more when needed and secure prospects of expanding combined agrifood export surplus and the economic benefits that brings to both Ukraine and the EU. Full contribution with facts and figures available attached.
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