Mr. Don Hill reports

SUCRO CALLS ON USDA'S AMS TO IMMEDIATELY RETRACT SERIOUSLY FLAWED MOLASSES REPORT

Sucro Ltd. has called upon the U.S. Department of Agriculture (USDA) and its Agricultural Marketing Service (AMS) to immediately retract its seriously flawed report on imported molasses under HTS 1703.10.30, which Sucro believes to include significant errors after information emerged showing glaring mathematical errors, scientific inconsistencies and unsupported allegations.

After Congress directed AMS to evaluate imported molasses, supported by $3-million in taxpayer financing inserted through the appropriations process, AMS released a report before the agency had properly addressed obvious methodological mistakes and mathematical errors.

AMS report contains basic mathematical errors

The report's central conclusion that imported molasses entering through Buffalo allegedly fails statutory requirements at a 78-per-cent rate appears to rely on calculations that cannot be independently replicated using AMS's own published methodology.

According to a technical review of the report:

• AMS explicitly states that soluble non-sugar solids (SNSS) were calculated as: SNSS equals (solids minus sugars) divided by solids.
• Applying AMS's own reported Table 5 data produces materially different results than those published in Table 6.

Examples include:

• Reported solids: 74.6;
• Reported sugars: 69.72;
• Actual calculated SNSS: approximately 6.5 per cent;
• AMS reported SNSS result: 3.72 per cent.

Those numbers do not reconcile and represent a material difference in the SNSS results. Sucro believes it is a fundamental mathematical failure at the core of the report and calls into question the integrity of the data being presented.

AMS report contains chemically impossible results

AMS also published a negative SNSS value of minus 4.26 per cent. That result implies that total measured sugar exceeded total measured solids, which is chemically impossible. This was immediately flagged to AMS as an obvious red flag that should have triggered further review.

However, when informed of the impossibility over its own results, AMS claimed "it essentially means 0 per cent." Sucro does not believe this statement supports good scientific analysis and is a retrospective rationalization of bad data.

Negative values should have triggered:

• Retesting;
• Chain-of-custody review;
• Sampling review;
• Methodology validation.

Instead, AMS simply published the data without qualification.

AMS has not provided raw data

When confronted with these inconsistencies and faults and correspondence showing repeated concerns, AMS declined to provide raw data and underlying sampling details, including;

• Missing raw data sets;
• Unclear protocols;
• Inability to validate calculations;
• Refusal to engage transparently with stakeholders.

No scientific body should publish conclusions that cannot be independently validated and certainly not after the report has been identified to have clear, fundamental and tangible errors.

AMS went beyond its technical mandate

Rather than staying within its scientific lane focused on product testing, AMS veered into trade policy recommendations. AMS:

• Made multiple references to domestic molasses as if that was a relevant profile; this has no bearing on verifying molasses imports under HTS 1703.10.30;
• Suggested changing tariff definitions;
• Recommended rewriting statutory thresholds;
• Proposed tightening import classifications;
• Inserted policy recommendations well outside AMS's technical role.

Sucro is disappointed that AMS made speculative, inflammatory and unsubstantiated claims that imports may involve blending or the use of additives despite providing no direct evidence proving such behaviour occurred.

The report was publicly marketed before its errors were addressed

Before AMS resolved obvious technical deficiencies, the report was allowed to be publicly shared with media outlets already amplifying sensationalized claims of tariff circumvention.

Immediate corrective action is required

AMS must:

1. Immediately withdraw and officially retract publication of its report;
2. Provide for an independent third party scientific review;
3. Ensure confidential disclosure of raw testing data with the specific importers in question;
4. Review AMS conduct that led to the leaking and media dissemination of a congressionally mandated report;
5. Invite congressional oversight into how this report was commissioned and released;
6. Suspend any policy action based on this report.

The company at Sucro has shown repeated openness and willingness to be transparent and forthcoming and historically maintained a good relationship with AMS as well as all other U.S. government entities. All Sucro is asking is for reciprocal treatment from the government -- a fair, open and honest exchange of information.

About Sucro Ltd.

Sucro is a growth-oriented sugar trader and refiner that operates throughout the Americas, with a primary focus on serving the North American sugar market. The company operates a highly integrated and interconnected sugar supply business, utilizing the entire sugar supply chain to service its customers. Sucro's integrated supply chain includes sourcing raw and refined sugar from countries throughout Latin America and refined sugar from its own refineries and delivering to customers in North America and the Caribbean. Since its inception in 2014, Sucro has achieved growth by creating value for customers through continuous process innovation and supply chain re-engineering. Sucro has established a broad production, sales and sourcing network throughout North America with two cane sugar refineries and an additional value-added processing facility and three cane sugar refineries, including two recently opened sugar cane refineries in Hamilton, Ont., and University Park, Ill. (a suburb of Chicago). The company has offices in Miami, Mexico City, Cali, Sao Paulo and Port of Spain.