Thank you for the opportunity to comment as part of a Section 301 investigation into China’s
implementation of the Economic and Trade Agreement Between the Government of the United
States of America and the Government of the People’s Republic of China (“Phase One
Agreement”).
We appreciate the support and assistance of the Office of the U.S. Trade Representative (USTR)
on this important issue as well as the agency’s continued engagement with foreign governments
to expand market access for U.S. ethanol. Growth Energy is the nation’s largest association of
ethanol producers, representing 97 U.S. plants that each year produce 9.5 billion gallons of lowcarbon, renewable fuel; 130 businesses associated with the production process; and tens of
thousands of ethanol supporters around the country. Growth Energy represents the leading
exporters in the ethanol industry, helping to support nearly 2 billion gallons of ethanol exports to
over 60 countries around the world.
In January 2020, China committed to substantial purchases under the Phase One Agreement,
including for agricultural commodities. These commitments have not been fulfilled. We
welcome USTR initiating this investigation.
The 2017 baseline for U.S. agricultural exports to China amounted to $19.6 billion1
. The Phase
One Agreement does not specify how the additional agricultural purchases would be
proportioned per commodity, although ethanol is specifically included in the “other” category.
China agreed to $32 billion in additional agricultural purchases over two years ($12.5 billion in
2020 and $19.5 billion in 2021) above the 2017 baseline and agreed to strive for a further $5
billion in additional imports per year of agricultural products. Thus, China’s minimal purchase
commitment of $32.1 billion in 2020 and $39.1 billion in 2021 not including the strived-for $5
billion.
However, the actual U.S. agricultural exports to China in 2020 ($26.4 billion) and in 2021 ($32.8
billion) were far below these commitments and the added annual $5 billion also never
materialized. Actual exports only amounted to 82 percent of minimal commitments in 2020 and
84 percent of minimal commitments in 2021.
1 Trade data compiled from the U.S. Department of Agriculture’s Global Agricultural Trade System.
The 2017 baseline for U.S. ethanol was 55 million gallons valued at $83 million. However, this
baseline is well below U.S. ethanol exports to China in 2016, which amounted to 198 million
gallons valued at $313 million. In 2020, U.S. ethanol exports were valued at $50.9 million (32
million gallons) and in 2021 were valued at $162.4 (100 million gallons). Since then, no
meaningful volumes have been exported, including in 2022 while other agricultural commodities
were still generally increasing in export value to China.
$0
$50,000
$100,000
$150,000
$200,000
$250,000
$300,000
$350,000
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
U.S. Ethanol Exports to China
(in thousands of dollars)
0.00
100,000,000.00
200,000,000.00
300,000,000.00
400,000,000.00
500,000,000.00
600,000,000.00
700,000,000.00
800,000,000.00
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
U.S. Ethanol Exports to China (liters)
China committed to a 64 percent increase over the 2017 baseline for 2020 and a 99 percent
increase over the 2017 baseline for 2021 in its agricultural purchase commitments under the
Phase One Agreement. No specific dollar or volumes were noted for ethanol purchases.
However, using these percentages, an estimate of ethanol purchases can be extrapolated had
China adhered to its commitments. Accordingly, ethanol purchases fell below what was expected
considering the overall percentage increase of commitments over the 2017 baseline.
In 2021, U.S. ethanol exports experienced a 95 percent increase over the 2017 ethanol baseline,
which is aligned with the agreement’s overall commitment percentage increase applied to
ethanol purchases. However, in 2020, U.S. ethanol exports of $50.9 million was 39 percent lower
than the 2017 ethanol baseline of $83.2 million. The actual amount of U.S. ethanol exports in
2020 was below the anticipated $136.3 million in ethanol purchases if considering the
agreement’s overall 2020 purchase commitment percentage increase of 64 percent over the 2017
baseline.
Under this approach, there was an $85 million purchase deficit of U.S. ethanol by China in 2020
and a $3.2 million purchase deficit in 2021, for a combined total of $88.6 million in nonmartialized purchases of U.S. ethanol by China.
A second way to consider if China fulfilled its purchase commitments related to U.S. ethanol is
comparing the overall share of U.S. ethanol to other agricultural purchases. In 2017, U.S. ethanol
accounted for 0.4 percent of U.S. agricultural exports to China. Of the additional $32 billion in
additional agricultural purchases China committed to, 0.4 percent would mean $135.5 million of
the additional purchase commitments would be of U.S. ethanol. Factoring in the 2017 ethanol
baseline and actual exports, this method shows an $88.6 million U.S. ethanol purchase deficit by
China under the Phase One Agreement.
Both assumptions show deficits higher than the value of U.S. ethanol exports to China in 2017.
The above assumptions also did not include the additional $5 billion in agricultural purchases
China agreed to strive for.
2017
Baseline
Additional
Purchase
Commitments
Total
Purchase
Commitment
Percentage
Increase Over
Baseline
(Commitment)
Actual
Exports
Percentage
Increase
Over
Baseline
(Actual)
Difference in
Commitment
vs. Actual
Agriculture (billions)
2020 $19.6 $12.5 $32.1 64% $26.4 35% -$5.7
2021 $19.6 $19.5 $39.1 99% $32.8 67% -$6.3
Total $32.0 $71.2 $59.2 -$12.0
Ethanol (millions)
2020 $83.2 $53.1 $136.3 64% $50.9 -39% -$85.4
2021 $83.2 $82.4 $165.6 99% $162.4 95% -$3.2
Total $135.5 $301.9 $213.3 -$88.6
Thank you for your consideration of these comments related to our concerns that China has not
followed through on its agricultural purchases under the Phase One Agreement, neither generally
nor on ethanol specifically. Growth Energy looks forward to working further with USTR to
resolve unfairness issues facing U.S. ethanol.
Sincerely,
Chris Bliley
Senior Vice President of Regulatory Affairs
Growth Energy
December 1, 2025
Ms. Jennifer Thornton
General Counsel
Office of the U.S. Trade Representative
600 17th Street NW
Washington, DC 20508
Docket ID: USTR-2025-0007
Dear Ms. Thornton: