To Whom It May Concern,
On behalf of the U.S. ethanol industry, we appreciate the opportunity to comment on the
draft resolution issued by the Ministry of Mines and Energy of Colombia “outlining
requirements and guidelines for authorizing and registering fuel alcohol producers and
importers”.
The U.S. Grains & Bioproducts Council (USGBC), Growth Energy, and the Renewable Fuels
Association (RFA), representing the U.S. ethanol industry and collectively accounting for
over 90% of national ethanol production capacity, respectfully submit these comments on
the proposed regulation.
The United States has consistently supplied high-quality ethanol to Colombia, supporting
the E10 mandate and contributing to stable supply, affordability, and environmental
performance. Maintaining a transparent, predictable, and cost-efficient regulatory
framework for imports and production is essential.
We acknowledge that the draft resolution aims to clarify and consolidate technical,
environmental, and quality requirements for ethanol producers and importers in Colombia.
This approach may enhance regulatory clarity and supply-chain traceability. To promote
market stability and fair competition, these requirements should be applied consistently to
all stakeholders (domestic producers and importers), ensuring a level playing field and
supporting reliable supply, regulatory certainty, and long-term market confidence.
We respectfully believe the regulation’s impact on ethanol imports and supply will depend
on how the new procedures are implemented, particularly regarding administrative
timelines, consistency in approvals, and coordination with customs and trade processes.For U.S. ethanol exporters, the final resolution should avoid unnecessary administrative
burdens, ensure clear and efficient procedures, allow sufficient time for compliance, and
accept internationally recognized certifications and standards. These measures will help
maintain market openness and support supply continuity and energy security.
We appreciate the Ministry’s openness to stakeholder input and value the opportunity for
continued dialogue, and we remain committed to working constructively with Colombia to
support a balanced, competitive, and sustainable ethanol market.
Comment No. 1
Subject: Equal Application of Requirements and Market Stability
Reference: Articles 1, 2, and 6 – Object, Scope, and Authorization Process
Comment:
The draft resolution aims to consolidate and clarify the regulatory framework applicable to fuel
ethanol producers and importers. To support market stability, supply continuity, and fair
competition, it is essential that the requirements and procedures apply equally to all, including
domestic producers and importers. When authorization, registration, and compliance
obligations are uniform, a level playing field is ensured. This avoids distortions between domestic
and imported supply and offers regulatory certainty for all participants in Colombia’s ethanol
blending program.
Comment No. 2
Subject: Transparency and Predictability of Administrative Procedures
Reference: Article 6 – Authorization and Registration Process
Comment:
While Article 6 establishes defined stages and timelines for the authorization and registration
process, the practical effectiveness of these provisions will depend on implementation and
consistent application. From our perspective, predictable administrative timelines and clear
communication during document review and technical evaluation are critical to avoid
uncertainty and potential supply disruptions. We encourage the Ministry to ensure that review
periods are strictly applied and that any requests for additional information are limited to clearly
defined, objective criteria.
Comment No. 3
Subject: Shipment-by-Shipment “Visto Bueno” Requirement
Reference: Article 7, numeral 11 – Prior Approval for Imports
Comment:
The requirement for a shipment-specific “visto bueno” issued by an administrative act may
introduce an additional procedural step prior to each import operation. This measure may affect
operational flexibility if approvals are delayed or applied inconsistently. In this context, it is
important to clearly define the specific administrative act being referenced, its legal nature, and
how it differs from or interacts with existing authorizations and import procedures. To mitigate
potential impacts on supply, we recommend clarifying that this approval process is fully
coordinated with existing customs and trade procedures (including DIAN and VUCE) and does
not duplicate documentation already required under current import regimes. Clear guidance and
consistent timelines will be essential to preserve predictability for import planning and logistics.
Comment No. 4
Subject: Administrative Burden and Operational Flexibility
Reference: Articles 5, 6, and 7 – Importer Requirements and Obligations
Comment:
Many technical and documentary requirements for importers are based on Colombia’s existing
fuel, environmental, and infrastructure rules. However, combined with shipment-specific approvals, these can increase paperwork. We recommend the Ministry to keep compliance
processes simple and proportionate. And avoid asking for information already in SICOM or other
official systems. Keeping operational flexibility is crucial.
Comment No. 5
Subject: Acceptance of International Certifications and Standards
Reference: Articles 7, 8, and 9 – Quality, Certification, and Technical Requirements
Comment:
The draft resolution rightly refers to recognized international standards and accreditation
schemes. For imported ethanol, clear acceptance of equivalent international certifications is
key, and mutual recognition should be explicit. This helps prevent redundant testing or
certification and supports timely supply while meeting Colombia’s quality and environmental
goals.
Comment No. 6
Subject: Implementation Timeline and Transition Period
Reference: Article 13 – Entry into Force
Comment:
Given the broad scope and new procedures, enough transition time is needed. Importers and
producers must adjust their processes, as adequate timelines help ensure compliance and
avoid disrupting supply chains. These also support ongoing ethanol availability for blending
mandates. In urgent/emergency cases requiring quick imports, the framework should clarify how
it operates to ensure supply shortages or compliance needs are addressed.
Comment No. 7
Subject: Ongoing Review and Stakeholder Engagement
Reference: General
Comment:
As the resolution seeks to harmonize and strengthen the regulatory framework for fuel ethanol,
its effectiveness will depend on continued dialogue between the Ministry and stakeholders. We
encourage the establishment of mechanisms for ongoing technical engagement and postimplementation review to identify and address any unintended operational challenges,
particularly those affecting import timelines, administrative consistency, and supply continuity