Thank you for the opportunity to comment on significant foreign trade barriers for the 2026
National Trade Estimate report.
We appreciate the support and assistance of the U.S. Trade Representative (USTR) on these
important and often longstanding issues 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 low-carbon, renewable fuel; 129 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 two billion
gallons of ethanol exports to over 60 countries around the world.
Expanding market access for U.S. ethanol is very different than other agricultural commodities
and requires different levels of support that accompany changing a country’s energy supply
chains and fuel specifications. These positive, mutually beneficial exchanges with countries have
already led to significant policy advancements, including with Japan and the United Kingdom.
We request a continuation of those supportive efforts in collaboration with industry both
bilaterally, regionally, and as a part of U.S. government engagement in international bodies (such
as the G7, G20, International Maritime Organization, and International Civil Aviation
Organization). USTR’s continued assistance will help to expand U.S. ethanol’s significant 2024
trade surplus of 1.79 billion gallons, or $3.97 billion.
Brazil
In 2024, the U.S. had a $150 million ethanol trade deficit with Brazil—in 2023 that deficit was
$212 million. This was in stark contrast with a $197 million U.S. ethanol trade surplus with
Brazil in 2018. This recent ethanol trade deficit with Brazil tracks with Brazil’s movement away
from reciprocal, tariff-free ethanol trade between our two countries. Furthermore, Brazil was
once the top export market for U.S. ethanol, valued at $736 million in 2017, but has fallen
significantly. While Brazil may have inched back to the 13th largest export market in 2024 ($54
million), it was the 41st largest market in 2023 ($140,000).
The Brazilian market has been the epitome of unfairness for U.S. ethanol. While we have
continued to push Brazil to remove its unfair tariff and to address other issues limiting U.S.
ethanol exports, they have been unwilling to do so. A reciprocal tariff on Brazil would help to
address grossly inequitable tariffs/trade, unfairness in U.S. ethanol’s lack of eligibility under
Brazil’s low carbon fuel policy, and Brazilian efforts to supersede U.S. leadership in biofuels and
as a supplier of choice.
We applaud USTR’s initiation of a Section 301 investigation into Brazil’s unfair trade action and
hope our earlier provided comments and testimony on this will help guide USTR in the next
steps of its investigation.
U.S. Tariffs Compared to Brazil
The U.S. levies 1.9 percent and 2.5 percent tariffs for denatured and undenatured non-beverage
ethanol, respectively. Today, Brazil’s applied tariff for imports of ethanol from non-Mercosur
countries is 18 percent, but this was not always the case.
Prior to 2012, Brazil lobbied the United States to remove its “other duty or charge” on ethanol
imports, with Brazilian industry calling for “free and fair trade” between the two largest ethanol
producing and consuming counties. Brazil sought to improve its access to the U.S. ethanol
market given the expanding volumetric requirements under the U.S. Renewable Fuels Standard
(RFS). However, as U.S. ethanol exports to Brazil expanded into 2017, Brazil went backward on
the desire for free and fair trade by establishing a tariff rate quote (TRQ). When the original TRQ
was expiring in 2019, Brazil increased the TRQ but added quarterly allocations. These
allocations limited exports given the seasonal nature of ethanol production in Brazil. Once that
TRQ expired in December 2020, U.S. ethanol exports to Brazil were assessed a 20 percent tariff.
The tariff fluctuated until it settled at the current 18 percent tariff in February 2023.
Brazil’s Low Carbon Fuel Policy (RenovaBio)
Brazil only recently decided to certify one U.S. ethanol producer under RenovaBio, the country’s
low carbon fuel policy. However, because of the issues surrounding the structure of RenovaBio’s
compliance verification, only a very small portion of that biorefinery’s production is deemed
eligible to participate. Brazil is seeking to apply this same methodology for all U.S. ethanol
producers, despite this extremely limited eligible. By comparison, RenovaBio certifies most, if
not all, of the output of Brazilian ethanol producers, allowing them to benefit from the program.
This further disadvantages U.S. ethanol while Brazil continues to peddle a misleading narrative
that falsely suggests any American producer can fairly participate in the program or that it allows
sustainably produced ethanol to be eligible.
RenovaBio also disadvantages U.S. corn ethanol by assigning it an unnecessarily punitive carbon
intensity score for the using default values. Given RenovaBio was established to meet the needs
of Brazil’s sugarcane growers and it was structured around that supply chain, Brazil’s producers
do not receive a similarly punitive default score as they do not need to rely on default values.
RenovaBio is a lucrative program for Brazilian biofuel producers and is modeled on the U.S.
RFS and California’s Low Carbon Fuel Standard (LCFS). In the U.S., Brazilian producers are
able to participate in both the RFS and the LCFS and can reap the financial benefits of those
programs. Brazilian sugarcane ethanol is eligible to create advanced Renewable Identification
Numbers (RINs) under the RFS as well as carbon credits under California’s LCFS. Conversely,
U.S. ethanol cannot participate in RenovaBio and is not eligible to generate similarly lucrative
carbon credits (known as CBios) under RenovaBio. In 2023 (the last full year of data available
from the U.S. Department of Agriculture’s (USDA’s) Foreign Agricultural Service), Brazilian
fuel distributors met 81 percent of RenovaBio’s reduction targets by retiring 33.1 million CBios.
CBio trading results in an estimated average price of $16.61 per CBio, resulting in a total of
$548 million in lost opportunity for U.S. ethanol producers under RenovaBio. Over time, the
amount of CBios are projected to increase incrementally, ultimately reaching nearly 96 million
CBios annually by 2031. Brazil hopes the CBios will reach values like California’s LCFS.
Third-Party Markets
Brazilian ethanol exports entering the United States via the Gulf are typically destined to be
processed into ethyl tert-butyl ether (ETBE) for export, including to Japan. While U.S. ethanol
can be used to meet up to 100 percent Japan’s on-road demand for ethanol and ETBE, it is
estimated that 40 percent of U.S. ETBE exports to Japan, or 85 million gallons (with an
estimated value of $153 million) are produced from Brazilian ethanol. A reciprocal tariff or
Section 301 remedies on Brazilian ethanol could result in higher costs for ETBE produced from
Brazilian ethanol and not U.S. ethanol. Improved economics of U.S. ethanol vis-à-vis Brazilian
could allow for a greater proportion of ETBE exported to Japan to come from U.S. ethanol.
Brazil continues to seek preferential recognition for its multi-cropped corn as being more
sustainable and a better alternative to U.S. corn. Not only do we disagree with this assessment
but as Brazil continues to push this false narrative, we have become increasingly concerned that
Brazil is affecting our potential to compete in certain markets, like Japan, that put a premium on
lifecycle emissions reductions. Assistance by the U.S. government would be welcome to reset
the discussion on sustainable corn production in the United States.
Canada
Canada has been our largest and most reliable export market, setting record volumes of 675
million gallons in 2024, valued at $1.5 billion. This represents approximately 35 percent of all
U.S. ethanol exports. Increases in provincial blending mandates have helped U.S. ethanol exports
grow to meet these higher mandates and represent continued growth potential. However, we are
concerned with “domestic content” requirements that have been announced at the provincial
level and proposed federally.
On August 8, Ontario’s Ministry of Environment, Conservation, and Parks adopted a domestic
content requirement for its gasoline, which was effective immediately. Ontario currently requires
a renewable content requirement of 11 percent in its gasoline (i.e., E11), which is set to increase
to E13 in 2028 and E15 in 2030. Of that renewable gasoline requirement, 27 percent of that will
need to have been produced in Canada for the remainder of 2025. For 2026 and 2027, that
percentage will increase to 64 percent; for 2028 and 2029 it will decrease to 54 percent and then
further decrease to 47 percent in 2030. The release notes that this requirement is aimed at being
time-limited and temporary in nature. However, no additional details were provided other than
that the ministry will continue to monitor factors impacting its producers. Ontario accounts for
approximately 37 percent of Canada’s gasoline sales.
In February 2025, British Colombia’s (BC’s) Minister of Energy and Climate Solutions issued
Ministerial Order No. M41. This order notes that effective January 1, 2026, the minimum five
percent renewable fuel requirement for gasoline must be met with eligible renewable fuels (i.e.,
ethanol) produced in Canada. BC’s low carbon fuel policy provides economic incentives for
ethanol producers who have made significant financial investments to lower their carbon
intensity level. This market, estimated to be 64 million gallons and valued at $115 million, will
be unfairly closed to U.S. ethanol, and could result in the loss of financial investments by U.S.
ethanol facilities who updated facilities to better perform in BC’s low carbon fuel policy.
Given the size and importance of the Canadian market for U.S. ethanol, and the inclusion of
ethanol on the second proposed list of commodities targeted by Canada for tariff retaliation, we
ask that any trade dispute be resolved as soon as possible so U.S. ethanol can enter Canada tarifffree and without provincial origin restrictions. Additionally, we are concerned about the
economic situation for inputs that are necessary for the U.S. ethanol production process, such as
yeasts. Some yeasts are produced in Canada and imported into the United States. An import tariff
on these products could undermine the price competitiveness of ethanol in the United States,
affecting U.S. consumers.
We are concerned that continued efforts to limit imports and utilization of U.S. ethanol could
result in market loss for U.S. ethanol and a loss of investments geared toward complying with
provincial low carbon fuel policies. Changes to Canada’s Clean Fuel Regulation may compound
these issues by making it more difficult for U.S. ethanol to comply and participate.
China
In January 2020, China committed to substantial purchases under the Phase One trade
agreement, including for agricultural commodities with a reference to ethanol. These
commitments have not been fulfilled. While ethanol is just one of many agricultural commodities
under the Phase One agreement, China agreed to $32 billion in additional purchases and agreed
to strive for a further $5 billion in additional imports per year of agricultural products. In 2017,
which serves as the baseline to determine purchases, U.S. ethanol exports to China were valued
at $83 million. In 2020, U.S. ethanol exports were valued at $51 million and $162 million. Since
then, no meaningful volumes have been exported. While tariffs are levied, endorsement by the
government is necessary for purchases and seems to be the main reason for the lack of U.S.
ethanol exports.
Colombia
On February 24, 2024, Colombia returned to its E10 mandate after almost three years of
instituting lower and fluctuating blend levels that caused U.S. ethanol exports to Colombia to
plummet. With this new market certainty, Colombia returned as the fifth-largest export market
for U.S. ethanol in 2024, valued at $377 million. Despite its return as a significant ethanol export
market, U.S. ethanol continues to face unfair trade practices despite the free trade agreement
between the United States and Colombia. Since May 2020, Colombia has levied a countervailing
duty (CVD) of $0.06646 per kilogram (or $0.20 per gallon) on imports of U.S. ethanol. During
the March 2023 expiry review, Colombia determined it would extend its CVD for an additional
five years at the same rate, but with an option to review after three years.
The process for the expiry review occurred during these blend rate fluctuations, which Colombia
noted were due to limited domestic supply and high import prices. However, the CVD results in
higher import prices of U.S. ethanol and its removal would have negated the need for continued
blend fluctuations by stabilizing both prices and imported supply. Additionally, while Colombia
did experience a drop in their domestic production, the country’s geographical limitations mean
that imports and domestic ethanol supply different regions, meaning a nationwide fluctuation
was not necessary to address domestic supply concerns, since they only affected a fraction of
Colombian jurisdictions. While this is no longer an issue given the return to E10 blending, it is
illustrative of the protectionist mentality on ethanol that is governing Colombia’s decisions on
the CVD.
Colombia continues to seek alternative options to its pricing formula for its domestically
produced ethanol, as well as additional means to restrict ethanol. Both proposals have the
potential to reduce U.S. ethanol exports and create policy uncertainty for Colombia’s ethanol
program. Colombia initiated a public comment period on October 1, 2025, for revisions to
pricing1 and a comment period on July 22, 2025, for potential restrictions on imports depending
on Colombian production.
2 USTR’s continued engagement to ensure fair and equal treatment in
this market is critical to continue strong U.S. ethanol exports to Colombia.
European Union (EU)
The EU imposes an import duty on U.S. ethanol of 19.2 EUR/hl and 10.2 EUR/hl (for
undenatured and denatured, respectively). In 2024, the EU was the fourth-largest export market
for U.S. ethanol with exports amounting to nearly 197 million gallons valued at $428 million.
Removing the EU’s import duty could help expand U.S. ethanol exports to the bloc, generally,
and make U.S. ethanol competitive with Brazil in the EU.
Currently, Brazilian ethanol is assessed the same import duty as the United States. However, that
could change if the pending EU/Mercosur trade agreement is approved following the December
2024 final negotiations. The agreement would phase in a TRQ that would give Brazilian ethanol
access to the EU market at a significantly reduced rate compared to U.S. ethanol, culminating
with up to almost 218 million gallons being assessed a 6.4 EUR/hl for undenatured ethanol and a
rate of 3.4 EUR/hl for denatured. Of that amount, up to almost 151 million gallons for specific
chemical uses can enter without any duty assessed. This will further hurt U.S. ethanol exports to
the EU as Brazil will be given a significant economic advantage.
The EU also uses “crop caps” that significantly restrict the amount of U.S. corn ethanol that can
contribute to the EU’s on-road emissions reductions targets under its 2024 revisions to its
Renewable Energy Directive (RED). Revisions to RED were a part of the EU’s “Fit for 55”
package of proposals to implement the European Green Deal, which aims to reduce emissions by
at least 55 percent by 2030 and reach climate neutrality by 2050.
The “Fit for 55” package also included new policies that set emissions reductions standards for
aviation and marine fuels, called ReFuelEU Aviation and ReFuelEU Marine. Unlike for on-road
applications, crop-based biofuels (such as U.S. corn ethanol) are prohibited from meeting the
1 https://www.minenergia.gov.co/es/servicio-al-ciudadano/foros/establecer-metodologia-para-calculo-del-valoringreso-productor-alcohol-carburante-etanol/ 2 https://www.minenergia.gov.co/es/servicio-al-ciudadano/foros/establecer-un-mecanismo-para-medir-el-deficit-enla-oferta-nacional-de-alcohol-carburante-para-garantizar-el-abastecimiento-interno/
emissions reductions targets for both aviation and marine end uses. Both the U.S. and European
biofuels industries sought to rectify this injustice through the European courts, but these suits
were dismissed on February 25, 2025.
The European Union bioenergy policies and regulations support inaccurate and outdated
viewpoints that agriculture-based biofuels threaten global food security and cannot be
sustainably produced. As a result, U.S. ethanol is severely restricted.
India
India has become a significant global producer of ethanol, largely to meet their E20 blend goal
by 2025. India has also become a significant export market for U.S. ethanol. In 2024, India was
the third-largest export market for U.S. ethanol, amounting to nearly 187 million gallons valued
at $441 million. Despite the strength of this market, India prohibits the importation of ethanol for
fuel uses, so all U.S. ethanol exports to India were for industrial purposes. This restriction is
based solely on India’s protectionist policy to support their domestic industry. As India seeks to
establish itself as a global leader in biofuels, restricting access to their market sets a dangerous
precedent to other countries seeking to establish a biofuels program. We have recognized India’s
interest to grow their biofuels industry and how doing so can be economically precarious. We
supported past efforts to work around the full opening of the market. However, India has
repeatedly denied these motives and reinforced their interest to only put up barriers to entry and
unfairly close off competition.
Even if India can meet its ambitious E20 goal by relying only on domestic production, this
restriction undermines market access for U.S. ethanol for fuel purposes and underpins an
unfairtrade environment and practice by hindering fair competition.
Indonesia
Ethanol imports are assessed a 30-percent tariff rate by Indonesia, which is economically
uncompetitive for the market compared to other octane enhancers (which can face zero or fivepercent tariffs). To avoid this tariff, Indonesia is importing gasoline pre-blended with ethanol
that can enter the country duty-free and often comes from Singapore. While imports of preblended gasoline seem to be growing, it is difficult to measure. Indonesia is poised to begin
significant ethanol blending, with five-percent blending scheduled to start in 2025 for nonsubsidized gasoline, and 10-percent blending starting in 2029. Despite being a leading user of
biodiesel, ethanol blending has lagged due to limited domestic feedstocks. While there may be
some effort to prioritize domestic production, this shouldn’t be considered a barrier at this time,
given the potential flexibility for imports. If Indonesia implemented a nationwide E10 mandate,
removed the tariff, and removed other barriers to utilizing imported ethanol, it could result in a
potential export market of over 900 million gallons.
Japan
USTR has been a good partner for the U.S. ethanol industry when it comes to encouraging Japan
to expand their use of U.S. ethanol for both on-road and other applications. Because of this
engagement, U.S. ethanol had been able to meet 100 percent of Japan’s on-road ethanol demand,
which is primarily met through ETBE (a fuel additive produced with ethanol). While Japan
recently proposed increasing the greenhouse gas (GHG) emissions value of gasoline, this
increase will also correspond with increasing the emissions reduction target from 55 percent to
60 percent. This increased threshold would lower the maximum market share for U.S. ethanol
from 100 percent to approximately 90 percent. As part of the comment period for this change,
the U.S. ethanol industry requested Japan revise the score for U.S. ethanol so we could once
again access 10 percent of the market with an updated score. Additionally, Japan will be seeking
to set the GHG emissions profile for new feedstocks, such as Brazilian corn as well as cassava
and sugarcane from Thailand. While we appreciate the interest by Japan to expand feedstock
options as they seek to implement an E10 goal by 2030, we are concerned that U.S. ethanol may
not be a prioritized feedstock.
We appreciate the continued phase-down of U.S. ethanol’s tariff under the United States-Japan
Trade Agreement (USJTA) that entered into force on January 1, 2020. However, we understand
this is only for one specific tariff line,
3 which leaves both U.S. fuel ethanol as well as industrial
ethanol facing additional tariff lines. The tariff removal for non-beverage ethanol would not just
further position U.S. ethanol positively as Japan seeks to implement direct E10 blending but
could also improve the economic competitiveness of U.S. ethanol in the Japanese market
compared to other countries that supply ethanol to Japan.
4
We applaud the reference of ethanol as part of the $8 billion in purchases Japan committed to as
part of the September 4, 2025, executive order. We appreciate USTR and the U.S. government’s
continued efforts to include ethanol as part of the bilateral United States-Japan discussions,
including earlier statements and commitments stemming from leader meetings, such as Japan
doubling its ethanol demand for both on-road and for aviation. We encourage USTR to continue
the pressure and engagement with Japan on the positive role U.S. ethanol can play and to help
facilitate its mutually beneficial use in Japan.
In 2024, U.S. ethanol exports to Japan (again, primarily as ETBE) are estimated to be at least
129 million gallons, which would place it as the fifth-largest ethanol market. As Japan’s effective
blend rate with ETBE is less than 2 percent, moving to E10 direct blending would result in
significant ethanol export growth.
Mexico
Mexico has been a top, reliable export market for U.S. ethanol for both industrial and beverage
purposes. In 2024, U.S. ethanol exports to Mexico hit a record 84 million gallons, valued at over
$270 million. U.S. ethanol enjoys tariff-free access to Mexico. Given restrictions on blending
levels, Mexico currently does not blend ethanol into its gasoline despite some pilot projects for
higher-level blends, but the country is currently exploring new ways to develop their domestic
ethanol industry as well as to initiate fuel ethanol blending in the country. While Mexico is
seeking to develop domestic production, moving to allow E10 nationwide could result in a $1.9
billion ethanol market that could be met with U.S. imports.
Nigeria
3 2207.10.199
4 Specific codes where tariff removal for U.S. ethanol could be beneficial include: 2207.20.100, 2207.20.200,
2207.10.121, 2207.10.122, 2270.10.123, 2207.10.191
Despite having an E10 policy on the books since 2007, Nigeria does not currently blend fuel
ethanol. The U.S. ethanol industry has been working with Nigeria to start implementing a pilot
program to use fuel ethanol. These efforts have focused on developing fuel ethanol standards,
handling capacity, and integrating supply chains. While these efforts are progressing,
successfully moving from the pilot phase will require a reduction of the 20 percent import tariff
Nigeria levies on non-beverage ethanol. Removing this tariff, or at a minimum providing parity
between ethanol and other fuel additives, will help to make larger-scale ethanol blending
economically viable for U.S. ethanol exports, as well as to help support a domestic ethanol and
fuel industry. Improved economics for ethanol could assist in lowering prices paid by Nigerian
consumers following the May 2023 removal of its fuel subsidy on petroleum imports. Nigeria
has been a steady export market for U.S. ethanol for industrial purposes, valued at nearly $44
million in 2024. If Nigeria implemented a nationwide E10 mandate, it would generate 320
million gallons of ethanol demand, largely met with imports, with an estimated value of $576
million.
United Kingdom (UK)
We applaud the recent TRQ the Administration obtained for nearly 370 million gallons of U.S.
ethanol to enter the UK duty free, avoiding the £0.16/liter tariff on undenatured ethanol and a
£0.085/liter tariff on denatured ethanol. This volume is approximately 150 percent of the ethanol
volume exported in 2024.
Like the EU, the UK also limits the use of corn ethanol to meet its on-road emissions reduction
goals (i.e. a crop cap) and prohibits the use of food-based feedstocks to meet their emissions
reduction goals under their new aviation emissions policy. The UK is also putting together policy
recommendations for the maritime sector, which we ask USTR to engage on to avoid limitations
on U.S. corn ethanol.
Removal of crop caps and crop prohibitions would help ensure growing export markets for U.S.
ethanol in what has become a significant market for U.S. ethanol since the UK initiated its E10
mandate in 2023. In 2024, the UK was the second largest export market for U.S. ethanol, with
243 million gallons valued at $535 million.
Vietnam
Vietnam has undergone several reductions in the tariff it levies on imports of U.S. ethanol over
the past few years including a tariffs reduction from 10 percent to five percent in March of this
year. This reduction followed a similar action in July 2023 when Vietnam lowered its tariff to 10
percent for both denatured and undenatured ethanol. Despite this reduction, the tariff continues
to position U.S. ethanol at an economic disadvantage particularly compared to tariffs imposed on
gasoline and other fuel additives, which are levied at either zero or three percent. A tariff
removal for U.S. ethanol would also assist competitiveness for U.S. ethanol compared with
ethanol from other origins, where they may have duty-free access to the Vietnam market.
With such a significant discrepancy between other fuel additives, it is even more difficult to
expand the use of ethanol blending in other grades of gasoline at higher blend rates. U.S. ethanol
exports to Vietnam in 2024 were valued at $15.7 million, but decreasing the tariff and increasing
blend rates to all grades of gasoline could result in significant export growth to Vietnam with
improved economic competitiveness.
We are encouraged to see E10 pilot efforts in Vietnam in anticipation of the announced E10
nationwide offering starting in 2026. Continued engagement by USTR on the benefits of ethanol
blending would help support E10 implementation. Nationwide E10 in Vietnam could result in
240 million gallons of export potential, which has an estimated value of $432 million. While this
would not negate the overall U.S. trade deficit of $123.5 billion with Vietnam, increasing ethanol
exports can play a role in reducing it.
International Bodies
Ethanol as a feedstock to produce sustainable aviation and maritime fuels is receiving increased
attention from other countries who are looking to meet their emissions reduction targets as
agreed to under the International Civil Aviation Organization’s (ICAO) Carbon Offsetting and
Reduction Scheme for International Aviation (CORSIA) and the International Maritime
Organization (IMO). Updated values from this year placed U.S. corn ethanol for alcohol-to-jet as
a “CORSIA Eligible Fuel”. Despite recent updates to the emissions profile of U.S. corn ethanol
under ICAO CORSIA, additional adjustments are needed to more scientifically and accurately
portray U.S. ethanol—specifically changes such as the removal of quantitative scoring for
indirect land use change, more accurate references to U.S. agricultural land use, and the
incorporation of practices undertaken by farmers that reduce carbon emissions, such as no-till
farming.
Without these changes, U.S. ethanol is inaccurately scored in such a way that could place it
outside the eligible emissions value countries, such as Japan, may seek to implement.
Conversely, there seems to be significant interest in ICAO to support Brazil in their efforts to
unscientifically get an improved score for their “second crop” corn, which would undermine
market demand for U.S. corn. While we appreciate the increased engagement by the U.S.
government on CORSIA, we urge you to incorporate the U.S. biofuels industry within the United
States expert nominations to ICAO. Otherwise, decisions and negotiations in ICAO are taking
place that could unduly harm U.S. ethanol without giving the industry any means to weigh in on
or ultimately shape the resulting policies.
Like ICAO for aviation, we are also eager to engage within the sustainable marine fuel sector,
particularly as IMO is adopting their own greenhouse gas emissions policies. A strong U.S.
government effort is needed to ensure that U.S. corn ethanol is accurately placed and well
positioned to be used as a feedstock for marine fuel for those countries participating in the IMO’s
Net Zero Framework, or any other subsequent IMO frameworks encouraging greater use of
lower emission fuels. We similarly ask for your support for strong U.S. industry representation
and engagement in future discussions at the IMO. Unlike aviation, we believe that ethanol could
be utilized within the maritime sector as a “drop-in” fuel to existing vessels that are already
configured to run on methanol. However, without a workable pathway for U.S. ethanol under the
IMO, countries would not have an incentive to utilize U.S. ethanol.
Thank you for your consideration of these comments. 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
October 30, 2025
Mr. Edward Marcus
Chair of the Trade Policy Staff Committee
Office of the U.S. Trade Representative
600 17th Street NW
Washington, DC 20508
Docket ID: USTR-2025-17782
Dear Mr. Marcus: