Summary of responses: review of the UK’s raw cane sugar ATQ and related considerations

Question 1

1.  Introduction

Accepted Answer

Background

In 2020, the UK put in place a raw cane sugar Autonomous Tariff Quota (ATQ) which took effect on 1 January 2021. The ATQ allows a yearly volume of 260,000 tonnes of raw cane sugar to enter the UK market at a 0% rate of duty. The ATQ applies in addition to any volumes entering under preferential tariff arrangements, such as a Free Trade Agreement (FTA) or under the Developing Countries Trading Scheme. The previous government committed to reviewing the volume of the ATQ prior to the end of 2024.
The ATQ volume was determined to balance multiple objectives, including promoting domestic production and competition, promote consumer choice, preserving preferential access for developing countries, promoting the UK’s external trade agenda, and with consideration of impacts on public health. The raw cane sugar ATQ has been filled, or almost filled, in each of the last 3 years.
In addition to UK domestic sugar beet production and the raw cane sugar ATQ, importers in the UK can import sugar through its preferential agreements with other countries, for example, the Developing Country Trading Scheme (DCTS) and Economic Partnership Agreements (EPAs), and ultimately from any country by paying the UK Global Tariff (UKGT) rate.
The UK is a net importer of sugar, meaning it is a deficit market for sugar and therefore the UK sugar price is a function of import parity; the cost of importing sugar from the most competitive origins, after accounting for factors such as transport costs and the size of any relevant import duties. UK prices are therefore affected by European Union (EU) and global sugar prices. The ATQ was not anticipated to have major price impacts as its volume was not considered large enough to have a meaningful effect on the level and price of imports across the whole UK and EU market.
There is tariff-free trade in sugar between the EU and the UK which causes the price across this region to equalise as producers search for the best return on their product. The UK and EU can be considered as one sugar market and wholesale sugar price impacts would be expected to affect both the UK and EU market.
In the most recent sugar marketing year (2022 to 2023), net imports of sugar to the EU from the rest of the world were higher than usual. As imports from some producers are subject to volume restrictions through quotas and tariffs in the UK and EU market, once those quotas have been exhausted, the source of the marginal import pays the applied a Most Favoured Nation (MFN) tariff on top of world prices. When more imports are required therefore, the source of the marginal import has a higher price compared to world prices, resulting in European (and therefore UK) prices to be higher than world prices from autumn of 2022.
The UK sugar market has evolved since 2020 due to long term trends and global factors alongside the introduction of the raw cane sugar ATQ. This includes changes in supply sources for UK raw cane sugar. Imports from Brazil have increased while those from some other countries have decreased (for example, raw cane sugar from Belize, Guyana and Fiji, and refined sugar from the EU). The UK domestic beet sector has been affected by supply shocks in recent years including from virus yellows in 2020 and unfavourable weather in 2022.

Policy objectives

8. In setting the ATQ volume, the previous government sought to uphold the following principles:

the interests of consumers in the United Kingdom
the interests of producers in the United Kingdom of the goods concerned
the desirability of maintaining and promoting the external trade of the United Kingdom
the desirability of maintaining and promoting productivity in the United Kingdom
the extent to which the goods concerned are subject to competition

9. The previous government also sought to balance strategic trade objectives, such as the delivery of the UK’s trade ambitions and FTA trade agenda, whilst maintaining their commitment to international development work and to reduce global poverty.

10. Following the election, the new government has sought to uphold the above principles set out by the previous government. In coming to a decision, it has taken into account the responses received through the consultation as well as its own internal analysis.

What we asked

11. This consultation sought views on the raw cane sugar ATQ from relevant UK and international stakeholders.

12. It was launched at 4pm on 26 March 2024 and was open to submissions for 8 weeks. It closed at 11:59pm on 21 May 2024.

13. The consultation questionnaire was divided into 7 sections: Privacy and Confidentiality, Domestic Sugar Production, Importing Sugar into the UK, Exporting Sugar to the UK, The UK Sugar Market, Options and Stakeholder Information.

14. As well as inviting responses to specific questions on the main raw cane sugar ATQ options for 2024, the consultation set out other relevant tariff and quota options for raw cane sugar, including the UKGT rate, available for implementation from 1 January 2025. The consultation welcomed views on whether maintaining the UKGT rate would be appropriate and any other information on wider import routes for raw cane sugar that might be relevant.

15. The consultation also asked whether changes to the raw cane sugar ATQ would be appropriate in 2024.

16. A comprehensive list of all the questions asked as a part of this public consultation is available in Annex A.

This report

17. This report provides a summary of the responses received throughout the public consultation on the raw cane sugar ATQ. The views provided in these responses have been carefully considered and analysed. This report does not set out government policy with respect to future trade policy, but provides a summary of the responses received.

18. Some points raised fell outside the scope of this consultation. However, they have still been included in the statistical analysis where appropriate.

19. Respondents were not required to answer every question that was posed in the consultation response form. The number of responses for each question does not always equal the total number of consultation submissions.

20. Any percentages (%) present in this document have been rounded to the nearest 1% where appropriate, for presentational convenience. As a result, some percentage totals may not add up to 100%.

21. This document does not contain a list of the respondents or any personal or organisational details. Views have been summarised and are not attributable to any individual respondent or business. The responses are considered equally in the summary results to each question.

22. The government does not intend to publish any individual consultation response to ensure confidentiality. Organisations may publish their own responses independently.

Question 2

2.  Consultation submissions

Accepted Answer

Overview of the responses

23. The government received 12 responses to the consultation, 10 submitted via the consultation response form and 2 via email.

Table 1: breakdown of consultation responses received

Type of response	Number of responses
Consultation response form	10
Email Submissions	2
Total number of responses	12

Summary of respondent groups

24. The public consultation was launched on GOV.UK. Respondents were self-categorised into the following 5 groups:

an individual – responding with personal views rather than as an official representative of a business, business association or other organisation
non-governmental organisation – in an official capacity as the representative of a non-governmental organisation, academic institution or other organisation
public sector body – in an official capacity as a representative of a devolved administration, local government organisation, public service provider, other public sector body in the UK or elsewhere, or other international government
business – in an official capacity with the views of an individual business
business association – in an official capacity representing the views of a business organisation

25. Two thirds of responses were from businesses associations and public sector bodies (4 each). Each individual submission from a respondent is weighted equally in the tables presented throughout this document.

Table 2: total number of public consultation responses per group (self identified)

Respondent group	Number of responses	Responses as a percentage
Individual	0	0%
Non-governmental organisation (NGO)	1	8%
Public sector body	4	33%
Business	2	17%
Business association	4	33%
Other/left blank	1	8%
Total number of responses	12	100%

26. Respondents were also asked about how they interacted with the UK sugar market by indicating if they produced sugar domestically, imported sugar into the UK or exported sugar from the UK.

27. Within the category ‘produces sugar domestically’, we have included those that said yes to growing sugar beet domestically, as well as those that said that they produce and/or refine the sugar itself.

Table 3: summary of public consultation responses by type of interaction with the UK sugar market

Type of Respondent	Number of responses	Responses as a percentage
Produces sugar domestically	3	25%
Imports sugar into the UK	2	17%
Exports sugar into the UK	7	58%
Total number of responses	10	100%

28. Respondents who import sugar into the UK were asked to identify which trade arrangements they used for these imports, which is detailed in Table 4 below. Respondents could select multiple answers for this question, and they included imports of both raw cane sugar and other forms of sugar (for example, direct consumption cane sugar or refined white sugar).

Table 4: breakdown of trade arrangements used for importing sugar into the UK

Method of importing	Number of responses
FTAs – including the EU – Trade and Cooperation Agreement and Economic Partnership Agreements	2
Developing Country Trading Schemes (formerly the Generalised Scheme of Preferences)	1

29. Respondents who export sugar into the UK were also asked which trade arrangements they used, which is detailed in Table 5 below. All 6 respondents who export sugar into the UK answered this question. Respondents could select multiple answers for this question.

Table 5: breakdown of trade arrangements used for exporting sugar into the UK

Method of exporting	Number of responses
Economic Partnership Agreements	5
Developing Country Trading Schemes (formerly the Generalised Scheme of Preferences)	2

Question 3

3.  Responses to consultation

Accepted Answer

30. This section outlines an aggregated overview of how respondents answered each consultation question. For each question, a tick box option was provided to select either: agree, disagree, don’t know or prefer not to say, as well as a free text box to provide further information.

General sentiment on the ATQ

Consultation question: Are you in favour of continuing the ATQ on raw cane sugar beyond the end of 2024? Please explain your answer and provide any further comments and evidence to support this view.

31. All 12 consultation respondents answered this question. Eight (67%) indicated that they are not in favour of the ATQ on raw cane sugar continuing. Four (33%) indicated they are in favour of continuation.

Not in favour

32. Respondents who were not in favour of the raw cane sugar ATQ continuing cited reasons including that, in their view, the ATQ:

has disadvantaged UK growers of sugar beet, due to the regulations UK growers of sugar beet must adhere to that producers of sugar cane in other countries are not necessarily subject to
has displaced developing country exports of raw cane sugar to the UK, eroding the value of UK trade preferences, and having knock-on development impacts
failed to incentivise UK businesses to reduce sugar content from their products
has reduced the diversity of supply of raw cane sugar, which has had a negative environmental impact and raised food security concerns
has weakened the government’s negotiating capital in FTA negotiations.

33. Several respondents also stated that the UK can meet the raw cane sugar demands of the UK market through existing trade arrangements, and that the ATQ is not required.

In favour

34. Respondents who were in favour of the raw cane sugar ATQ continuing stated that, in their view, the ATQ:

would provide parity or fair competition between sugar beet and sugar cane in the UK market and improve competition. The ATQ has led to more sugar processing in the UK, where value is added in the UK rather than overseas
has supported jobs and investment predominantly in Newham, London
could provide greater access to the world’s sugar market to improve consumer choice and offer a greater variety of supply of sugar for the UK’s food security
presents an opportunity for future investment and new business in the raw cane sugar refining industry in the UK
has not had any material impact on the UK’s ability to pursue new FTAs
has not had any material impact on public health, as sugar demand would have been met regardless of the ATQ

Table 6: summary of public consultation responses in favour or against continuing the ATQ on raw cane sugar

Responses	Number of responses	Responses as a percentage
In favour	4	33%
Against	8	67%
Total	12	100%

Suggestions on the ATQ volume

Consultation question: If you have a preferred ATQ volume in mind, please state the preferred volume you are proposing.

35. Eight of the consultation respondents answered this question, 6 of whom (75%) had already responded they did not want the ATQ to continue beyond the end of 2024.

36. Of those 6, 4 repeated their desire for removal and 2 said that in normal circumstances the amount should be zero, but in exceptional circumstances there could be an amount to meet a verifiable deficit in the UK market. Other comments suggested that the ATQ should be reduced in line with the increase in Australian raw cane sugar.

37. One respondent (13%) wanted the 260,000 tonnes volume to stay the same.

38. One respondent (13%) wanted the ATQ to be higher and proposed 800,000 tonnes.

Table 7: summary of public consultation responses in favour of the ATQ volume being higher, lower or the same

Responses	Number of responses	Responses as a percentage
Higher amount	1	13%
Removal	6	75%
Same amount	1	13%
Total	8	100%

Impacts of potential ATQ volumes

Consultation question: How might the following changes to the ATQ for raw cane sugar impact you:

A lower amount than 260,000 tonnes
A higher amount than 260,000 tonnes
An amount at 260,000 tonnes
No ATQ at all?

39. Seven respondents answered this question. Six (86%) of these respondents were in favour of either reducing or removing the ATQ.

Impact of lowering the ATQ volume

40. Positive impacts: the ATQ was argued to be identified as a threat to the economic viability of the beet industry in the UK and the jobs it supports. Respondents cited the potential for a lower ATQ amount to increase confidence in the future of the beet industry in the UK, which could lead to additional investment. Others suggested that a smaller ATQ would reduce its detrimental impact on African, Caribbean and Pacific (ACP) states and developing country sugar producers.

41. Negative impacts: respondents claimed that a lower ATQ amount would lead to a loss of confidence in the raw cane refining industry in the UK by both customers and investors. They stated would give the EU a significant competitive advantage in the UK market for white refined sugar, which could lead to predatory pricing pressure.

Impact of raising the ATQ volume

42. Positive impacts: respondents stated that, according to them, a higher volume would give raw cane sugar manufacturers the opportunity to fill the sugar supply deficit with sugar which would be processed in the UK. It would also enable businesses to always compete at global price levels and have confidence in investment decisions in UK infrastructure.

43. Negative impacts: respondents stated it would intensify the competition from major sugar cane producers, likely leading to lower prices and potentially squeezing profit margins. A larger quota would make it even harder for smaller cane sugar producers to compete against those with economies of scale or who are geographically closer to the UK and therefore it would have a proportionally negative effect on ACP and Least Developed Countries (LDC) sugar producers depending on the size of the quota. A larger ATQ would further damage the local beet industry by having a greater effect on the market price on top of the impact from concessions in recent trade agreements (for example, Australia). This would reduce confidence in the local beet industry and, it is claimed, expose domestic farmers to competition from producers with lower standards.

Impacts of maintaining the ATQ volume

44. Positive impacts: one respondent stated that maintaining the ATQ volume would give raw cane sugar manufacturers who are increasing their production capacity the possibility to explore UK as a potential export market.

45. Negative impacts: for those seeking a larger ATQ, they argued that maintaining the ATQ at the current volume would negatively impact the confidence in the raw cane refining industry in the UK as it would limit its ability to compete to its full potential against tariff-free EU beet sugar. However, those arguing for a smaller ATQ, or its removal altogether, stated that the current quota level already creates an unlevel playing field for domestic sugar beet growers or smaller cane producing countries.

Impact of removing the ATQ

46. Positive impact: respondents suggested that this could create a level playing field for smaller producers in ACP and LDC countries. It could boost confidence in the local UK beet sector supporting further investment.

47. Negative impact: one respondent argued that this would be catastrophic for the raw cane refining industry in the UK and the jobs it supports.

Mitigation

Consultation question: for any potential impact on you, what mitigations would you consider if the government was to:

Remove the raw cane sugar ATQ
Decrease the volume of the raw cane sugar ATQ
Maintain the same volume of the raw cane sugar ATQ
Increase the volume of the raw cane sugar ATQ

48․ Eight respondents answered this question, all outlining different proposals.

49. One suggestion was to improve the Rules of Origin that are negotiated in Economic Partnership Agreements if the ATQ was to remain or increase. In particular, this might involve increasing the value tolerance rule to 30%, for the government to look to provide appropriate support to improve productivity and competitiveness, and facilitating the transfer of technology.

50. Two respondents said that ACP industries would advocate financial mitigation measures if the ATQ was still in force.

51. One respondent, a country that produces raw cane sugar that is exported to the UK, stated they would consider diversification away from the UK market. Another respondent, representing domestic producers, said there are no clear mitigations available to them if the ATQ is maintained or increased and that businesses may need to leave the market. Two respondents said they did not expect any support or mitigations from the government.

52. One repeated their request for a rollback of the ATQ given its direct adverse impact on their market access to the UK but did not provide any specific proposals for mitigation.

Preferred ATQ volume

Consultation question: if you have a preferred ATQ volume in mind, please state the preferred volume you are proposing.

53. Eight respondents answered this question, with 6 (75%) suggesting that there should be no ATQ. Of those 6, 2 (25%) answered that the ATQ should only reflect any shortage after supply from ACP/LDC countries has been exhausted. One respondent stated the ATQ should be maintained at the current volume. One stated the UKGT rate for raw cane sugar should be set to zero, but if not, that the ATQ should be set at 800,000 tonnes.

Administration of the ATQ

Consultation question: if there is an ATQ for raw cane sugar beyond 2024, do you think the quota should be administered via license, first come first served or other (please specify)?

54. Nine respondents answered this question, with 6 (67%) suggesting that the quota should be administered through a licence. All 6 of these respondents had stated they wished for no ATQ at all. Two (22%) thought the quota should be administered through a first come first served basis, while one (11%) selected ‘other’, without providing further detail.

55. Those in favour of a licence said it would provide a more transparent and predictable quota allocation process, which would ensure fairness for smaller global sugar producers. It would also ensure regulatory standards. One response commented that a licensing approach could offer greater scope for the government to balance the needs of different exporting countries and provide greater certainty to sugar cane farming communities in least developed countries.

56. Respondents in favour of a first-come-first-served system highlighted that it would avoid a more complicated administrative system that a licence system would entail. It was also argued that a licencing system risked speculators artificially inflating the cost of raw sugar to secure ATQ import licences free of cost from the government, to then sell onto cane refiners at a profit.

Table 8: summary of public consultation responses by method of ATQ administration

Responses	Number of responses	Responses as a percentage
Licence	6	67%
First come first served	2	22%
Other	1	11%
Total	9	100%

Standards and regulations for the ATQ

Consultation question: Do you believe there should be standard-based restrictions (including for example, in respect to environmental or labour standards) on products any future raw cane sugar ATQ should apply to and if so why?

57. Nine respondents answered this question, with 5 (56%) stating that there should be standard-based restrictions that apply to the ATQ. The most common reason provided was that imported raw sugar cane should be produced to the same standard as domestic sugar beet, to prevent it from undercutting UK farmers. Further reasons cited included the environmental impact of raw cane sugar production, including deforestation and pollution. Responses argued that standard-based restrictions would encourage practices to mitigate these effects and promote improved environmental sustainability management in countries from which the UK imports raw cane sugar.

58. However, 2 respondents (22%) argued against introducing standard-based restrictions for environmental or labour practices. Reasons were that in their view it would provide a further non-tariff barrier to trade, which would benefit the larger producing countries; and that the differences in the climate and production environments for sugar cane and sugar beet means that the same regulations, such as use of pesticides, should not be applied in practice. Other responses stated that government-imposed standards may have no additional effect and that it may be difficult to ensure compliance.

59. Two respondents (22%) stated standard-based restrictions were complicated and faced challenges with implementation and compliance. They advocated for further engagement on this issue to understand the impact on ACP and LDC industries.

Table 9: summary of public consultation responses by support for standard-based restrictions on an ATQ

Responses	Number of responses	Responses as a percentage
There should be standard-based restrictions	5	56%
There should not be standard-based restrictions	2	22%
Other	2	22%
Total number of responses	9	100%

The UK’s sugar supply diversity and food security

Consultation question: Do you think imports from preferential sources trading with the UK tariff-free are important to UK sugar supply, and if so, why?

60. Seven respondents answered this question, with all 7 (100%) agreeing that imports from preferential sources are important to maintaining the UK’s sugar supply and ensure diversity of imports. This was noted as important to maintain food security, helping to mitigate against weather, energy and geopolitical shocks.

61. Other objectives for maintaining preferential trade access mentioned were commitment to driving forward socio-economic development in ACP and LDC countries and sustainability.

Views on the preliminary assessment of the UK sugar market set out in the consultation

Consultation question: what is your assessment of the analysis of the market presented in the section titled ‘The UK Sugar Market’ in the supplementary documents?

62. Eight respondents answered this question, with 6 (75%) stating that they agree with the assessment of the UK sugar market set out in the consultation. One response highlighted that it is important to differentiate between short-term and long-term effects of policies such as the ATQ on the UK sugar market, and the impact of other policies and regulations that affect beet growers.

63. Four of the respondents (50%) questioned whether the assessment showcased the full picture in terms of quality and consumer prices or the latest data on imports. One response (13%) highlighted a lack of sufficient information to understand the significance of different import routes and geographies, and the contribution of the British beet sugar industry to the economy. Others mentioned the lack of public health policies being considered in the analysis.

64. In conducting this assessment, the government utilised the data available at the time of writing this response. We have continuously monitored the sugar market and used the latest available data to inform the outcome of this review.

ATQ impact on price

Consultation question: do you think the consumer price for sugar in the UK will change during 2024 or 2025, and if so, how? What factors do you think will be the cause of any price changes?

65. Six respondents answered this question. Three (50%) indicated it was difficult to answer conclusively, but that it would not be surprising to see lower prices in 2024 to 2025; one (17%) stated that consumers may see lower prices in 2025; one (17%) stated that bagged sugar makes up only a small fraction of the UK sugar consumption, so any changes in sugar prices would have negligible impacts on consumers; and one (17%) that retail prices are set by retailers but that they should at least be buying sugar more cheaply.

66. Of those who said they expected the price of sugar to fall in the UK, a common reason cited was favourable weather conditions in the autumn and summer in 2023 could lead to an increased harvest in 2024 for sugar beet farmers. Most respondents agreed that this will translate into a fall in wholesale sugar beet prices, which may equate to a fall in consumer prices during 2025.

Diversity in supply

Consultation question: What is your assessment of the main drivers of volatility within the UK sugar market particularly in regard to supply shocks and prices?

67. Eight respondents answered this question. All 8 (100%) mentioned weather conditions (in the UK and abroad) as being one of the main drivers of volatility. Global warming and the impact of pests and diseases were also mentioned. Two (25%) stakeholders stated that volatility is also driven by the EU price- as the UK’s largest trading partner, EU policies (such as capping any further imports of Ukrainian sugar from June 2024) has an impact on UK sugar prices.

68. Other respondents mentioned how the international sugar market can be driven by macro-economic and political factors. One example given was that the UK sugar market now relies heavily on exports of sugar from Brazil, which the respondent argued is a subsidised market. Changes to the Brazilian government, for example, could result in changes to its policy towards sugar production, impacting the UK market.

Risk to filling the sugar supply gap

Consultation question: What is your assessment of the main drivers of volatility within the UK sugar market particularly in regard to supply shocks and prices? What is your assessment of the probability of re-occurrences of the volatility seen in the 2022 / 2023 sugar marketing year within the UK sugar market particularly in regard to supply shocks and prices?

Do you think that there will be a shortfall in UK sugar supply from UK o4 EU sugar beet production during the 2023 to 2024 or 2024 to 2025 marketing years compared to average production. If so, what do you estimate the size of the shortfall to be (in tonnes)?

Has the raw cane sugar ATQ had any impact on the UK’s sugar supply since it has been in place?

69. Six respondents answered this question. One respondent (17%) stated there is an over-supply of sugar to the UK market and policies should be put in place to manage a decline for public health reasons. Two respondents (34%) stated there is likely to be an increase in sugar beet production in 2023 to 2024 and 2024 to 2025 marketing years compared to previous average production. Three respondents (50%) stated there is likely to be a shortfall, with 2 of the 3 respondents arguing this demand can be met through ACP and LDC producers.

70. One respondent (17%) argued that filling the sugar supply gap in the UK becomes harder to guarantee when uncertainty over the UK crop is higher. They also argued that the risk is amplified by EU beet sugar production facing the same heightened uncertainty as in the UK. This presents a risk to filling the sugar supply gap in the UK, as it is refined beet sugar from the EU that has in the past filled the largest proportion of the gap.

71. Three respondents (50%) also considered ACP or other FTA quotas to be able to comfortably fill any future shortfall. Three stakeholders agreed that the UK sugar market should be managed with a view to achieving other objectives, such as socio-economic development in ACP and LDC countries and sustainability.

Views on the impact of the ATQ on sugar prices

Consultation question: do you foresee any impacts on sugar prices during 2024, from the 260,000 tonne raw sugar cane ATQ for 2024?

72. Five respondents answered this question. Two respondents (40%) argued that sugar prices in 2024 to 2025 are likely to reduce because of increase in area planting in Europe and higher average yields experienced in 2023 to 2024 season and expected in 2024 to 2025.

73. One respondent (20%) did not foresee any impact on sugar prices as a result of the ATQ. Rather they stated that UK prices are a result of international sugar prices, exchange rates, beet sugar production volumes and other variables.

74. The remaining 2 respondents (40%) did not provide a direct answer to the question of impact on future price but did state the introduction of the ATQ correlated with a reduction in price in comparison with similar markets which do not have an ATQ in place.

General sentiment on the UKGT

Consultation question: please use this space to provide any views or evidence on the current raw cane sugar UKGT rate and whether you consider maintaining or changing this from January 2025 would be appropriate and what mitigations you would consider if the government was to change the UKGT rate

75. Six respondents answered this question and responses can be divided between those:

In favour of maintaining the raw cane sugar UKGT rate:

76. Five respondents (84%) were in favour of maintaining the current UKGT rate. Among the reasons cited were that reducing the UKGT rate would reduce the UK’s ability to negotiate in future trade deals and that the raw cane sugar UKGT rate must be closely aligned with the MFN rate applied by the EU. To do otherwise would misalign tariffs which could lead to the distortion of trade and create opportunities for fraud.

77. One respondent (17%) argued that any reduction to the UKGT would function as a further trade concession as with an ATQ, and that any further concessions should come through the development of sustainable and mutually beneficial FTAs, guided by thorough and wide-ranging consultation with sensitive agricultural sectors. One respondent suggested they would not be able to mitigate against negative effects if the UKGT was reduced or set at zero.

In favour of removing the raw cane sugar UKGT rate:

78. One respondent (17%) was in favour of setting the UKGT rate at zero. They argued that the current quota-based system leads to unpredictability and limits businesses’ ability to compete, grow and invest in the UK. They argued that the sugar policy that the UK inherited from the EU was discriminatory and benefitted EU sugar beets against sugar made from sugar cane.

Question 4

4.  Next steps

Accepted Answer

79. The government has carefully considered the responses to the consultation which have informed our approach to the raw cane sugar ATQ. Alongside this summary of responses document, the government has published its response to the consultation that sets out the decisions that were made following this consultation. Please refer to the response document for further information.

80. The sugar review team is grateful to those who took the time to respond to the consultation. The government will continue to engage and consider views from relevant stakeholders in the development of the UK’s trade policy on sugar.

Question 5

5.  Annex A: consultation questions

Accepted Answer

Section 1: privacy and confidentiality

By answering these questions, I give consent for the contents to be used for the purpose if this consultation.

This includes this data being shared with other UK government departments as necessary to complete this consultation.

Any details of this consultation response that are published will not include any personal identifiable details.

Please provide your name (This information is mandatory – please see the privacy notice for the reasons why this information is needed).
Please provide your email address (This information is mandatory – please see the privacy notice for reasons why this information is needed).
Do you consent for the Department for Business and Trade, or organisations working on their behalf, to contact you regarding the responses you have given? (for examples, to clarify any of your responses or to request additional information).
If you are happy for the Department for Business and Trade to contact you about relevant policy developments please select yes below.
Who are you responding on behalf of?
If you are content for your organisation to be identified in the government’s response to the consultation, please include your organisation’s name here
If you want the information you provide to be treated confidentially, please could you explain the reasons (please see the privacy notice for further information and an explanation of the requirements for public authorities).

Section 2: domestic sugar production

Do you produce sugar in the UK? (for example, through processing sugar beet or refining raw cane sugar)
In which region(s) in the UK do you produce sugar?
What is the approximate value and quantity of sugar that you produce annually?
What method of sugar production do you use?
What is the intended purpose of the sugar you produce?
How much sugar do you produce for retail contracts vs manufacturing for other goods?
What type of contracting do you use to procure the sugar you produce and what are the typical lead in times?
Please use this space to provide information on any contracting arrangements for selling or buying sugar or products containing sugar which you think is relevant to this consultation.
Please use this space to provide any information or evidence on UK sugar production that you feel may be relevant to this consultation and that you do not feel you have had the opportunity to express in any of your previous answers.

Section 3: importing sugar into the UK

Have you imported sugar in any form into the UK over the last 5 years?
Which of the following do you import into the UK?
From which countries(s) of the world do you import these products into the UK and under which trading agreements?
Please explain why you import from the countries you have noted with the trading agreements you have highlighted in question (3)
Please provide any further details as to whether the countries you import from, and/or the trading arrangements you use, have changed over the last 5 years, and if so, why.
What is the intended purpose of the products you import?
Please use this space to provide any information or evidence around sugar imports to the UK that you feel may be relevant to this consultation and that you do not feel you have had the opportunity to express in any of your previous answers.

Section 4: exporting sugar to the UK

Have you exported sugar in any form to the UK in the last 5 years?
Which of the following do you export to the UK?
From which region(s) of the world do you export these products into the UK, under which trading agreements?
Please explain why you export from the countries you have noted with the trading arrangements you have highlighted in question (3).
Please provide any further details of whether the countries you export from and/or the trading arrangements you use have changed over the last 5 years, and if so, why?
What is the intended purpose of the products you export?
Please use this space to provide any information or evidence around sugar exports to the UK that you feel may be relevant to this consultation and that you do not feel you have had the opportunity to express in any of your previous answers.

Section 5: the UK sugar market

What is your assessment of the analysis of the market presented in Chapter 3 of this consultation document?
What is your assessment of the main drivers of volatility within the UK sugar market particularly in regard to supply shocks and prices? (you may want to consider a range of drivers, including but not limited to the current tariff structure, likelihood of unfavourable weather conditions, use of pesticides, likelihood of crop disease).
What is your assessment of the probability of re-occurrences of the volatility seen in the 2022 to 2023 sugar marketing year within the UK sugar market particularly in regard to supply shocks and prices?
Do you think that there will be a shortfall in UK sugar supply from UK/EU sugar beet production during the 2023 to 2024 or 2024 to 2025 marketing years compared to average production. If so, what do you estimate the size of the shortfall to be (in tonnes)?
Do you think the consumer price for sugar in the UK will change during 2024 or 2025, and if so how? What factors do you think will be the cause of any price changes?
Looking beyond the 2023 to 2024 and 2024 to 2025 sugar marketing years, do you think that there will be future shortfalls in UK sugar beet production from UK/EU sources compared to average production?
Do you think imports from preferential sources trading with the UK tariff-free are important to UK sugar supply, and if so, why?
Please use this space to provide any information or evidence on the sugar market that you feel may be relevant to this consultation and that you do not feel you have had the opportunity to express in any of your previous answers in this section.
Please use this space to provide any views or evidence on sugar supply that you feel may be relevant to this consultation and that you do not feel you have had the opportunity to express in your previous answers.

Section 6: options

Current use of the Raw Cane Sugar ATQ

Has your organisation used the yearly raw cane sugar ATQ of 260,000 tonnes since 2021?
Please set out the years in which your organisation used the raw cane sugar ATQ and the volume used in each year where applicable.
With reference to the area that will inform our policy approach set out at the end of the ‘Public Consultation Information’ section at the beginning of the consultation, since 2021 what impact do you believe the raw cane sugar ATQ has had on:

the UK’s ability to pursue new trading arrangements
developing country trade
interest of consumers
interests of producers
the UK’s external trade
UK productivity
competition in the UK
public health
environmental issues

What has been the impact on you since the introduction of the ATQ for raw cane sugar at 260,000 tonnes in 2021? (Please answer this question based on the viewpoint of how you are responding to this consultation. For example, if you are responding as a business, the answer should focus on the impact it has had on your business).
Has the raw cane sugar ATQ has any price impact on the UK sugar beet processors since it has been in place?
Has the raw cane sugar ATQ had any price impact on the UK sugar beet refiners since it has been in place?
Has the raw cane sugar ATQ had any price impact on the UK raw sugar cane refiners since it has been in place?
Has the raw cane sugar ATQ had any impact on UK sugar beet farmers since it has been in place?
Has the raw cane sugar ATQ had any impact on the UK’s sugar supply since it has been in place?
Has the raw cane sugar ATQ had any impact on wider public interests since it has been in place? (For example, If you believe there are implications for the environment or public health or any other areas you this is relevant. Please provide justifications for your answer).

Questions on the Raw Cane Sugar ATQ in 2024

How is your organisation intending to utilise the raw cane sugar ATQ (if at all) in 2024? Please specify which Commodity Codes in particular.
Do you think the raw cane sugar ATQ is likely to be fully utilised in 2024?
Do you foresee any impacts on sugar prices during 2024, from the 260,000 tonne raw sugar cane ATQ for 2024? (please provide evidence set out what these impacts could be, when you might expect them to occur, and whether they might impact particular groups of consumers).
Do you foresee any other impacts, aside from on sugar prices, from the 260,000 tonne raw sugar cane ATQ for 2024?
Based upon current conditions and expectations in the UK and EU sugar market, do you think the government should make any changes to the ATQ in 2024?

Future of the Raw Cane Sugar ATQ from 1 January 2025

With reference to the areas that will inform our policy approach set out at the end of the ‘Public Consultation information’ section at the beginning of the consultation, what impact do you believe a raw can sugar ATQ will have beyond the end of 2024 on:

the UK’s ability to pursue new trading arrangement
developing country trade
interests of consumers
interests of producers
the UK’s external trade
UK productivity
competition in the UK
public health
environmental issues

What impact do you believe a raw cane sugar ATQ will have on you beyond the end of 2024? (please answer this question based on the viewpoint of how you are responding to this consultation. For example, if you are responding as a business, the answer should focus on the impact you think it will have on your business).
Are you in favour of continuing the ATQ on raw cane sugar beyond the end of 2024?
Please explain your answer and provide any further comments and evidence to support this view.
How might the following changes to the ATQ for raw cane sugar impact the areas that will inform our policy approach and that are set out at the start of this section:

a lower amount than 260,000 tonnes
a higher amount than 260,000 tonnes
an amount at 260,000 tonnes
no ATQ at all

How might the following changes to the ATQ for raw can sugar impact you?

a lower amount than 260,000 tonnes
a higher amount than 260,000 tonnes
an amount at 260,000 tonnes
no ATQ at all

If you have a preferred ATQ volume in mind, please state the preferred volume you are proposing.
If there is an ATQ for raw cane sugar beyond 2024, do you think the quota should be administered via:
Please provide any comments and evidence on your preference
Do you believe there should be standard-based restrictions (including for example, in respect to environmental or labour standards) on products any future raw cane sugar ATQ should apply to and if so, why?
Please use this space to provide any information or evidence on the raw cane ATQ that you feel may be relevant to this consultation and that you do not feel you have had the opportunity to express in any of your previous answers.

The raw cane sugar UKGT rate

Please use this space to provide any views or evidence on the current raw cane sugar UKGT rate and whether you consider maintaining or changing this from January 2025 would be appropriate (please refer to the areas set out at the end of the ‘Public Consultation Information’ section at the beginning of the consultation and please provide any evidence to support your view).
With reference to Table 2 in Chapter 3, which sets out the current import routes for raw cane sugar, please use this space to provide any views or evidence on those import routes and how their future use might impact government decisions in regard to this consultation.
Are there any points you want to make in respect to the Public Sector Equality Duty and/or the Environmental Principles Duty that are relevant to this consultation?

Section 7: stakeholder information

If responding Individual to Section 1(d):

Where do you currently live (your main address)?
How old are you?

If responding Non-governmental organisation to section 1(d):

What is the name of the organisation you are responding on behalf of? (for example, trade union, interest group, charity or academic institution)
What is your company number with Companies House?
Which area(s) does your organisation represent? (this information is mandatory)
How many members does your organisation represent in total?

If responding Public Sector Body to section 1(d):

What is the name of the public sector body you are responding on behalf of?
Which area(s) does your public sector body represent? (this information is mandatory)

If responding Business to Section 1(d):

What is the name of your business?
What is your company number with Companies House?
Approximately how many employees are currently on your businesses’ payroll in the UK across all sites?
Where is your business located? (this information is mandatory)
In what sector(s) does your business predominately operate in the UK? (This information is mandatory)

If responding to Business Association to Section 1(d):

What is the name of the trade association or business representative organisation you are responding on behalf of?
Please specify (this is mandatory)

number of businesses represented
average size of business represented

Which business area(s) does your organisation represent? (this information is mandatory)
How did you find out about this consultation?

Question 6

6.  Annex B: demographics

Accepted Answer

The demographic questions in the consultation form were tailored based on the respondent groups that the consultation responses were submitted on behalf of. This means there is variation in the demographic questions asked for each of the Individual, Business, NGO, Public Sector Bodies and Business Association groups.

2. The results of each question have been separated into each of these groups and presented through graphs below.

3. Seven out of 12 responded to the public consultation and answered this demographic question relevant to them.

Graph 1: showing the location of the individuals who responded to the public consultation

Graph 1 shows that 7 out of 12 responded showing their location as follows:

West Midlands: 2
East of England: 1
Other Country: 3
South East England: 1
Did not answer: 5

4. Seven out of 12 responded to the public consultation answered this demographic question relevant to them.

Graph 2: showing the age of the individuals who responded to the public consultation.

Graph 2 shows 8 out of 12 responded to the following age brackets:

25 to 34: 2
35 to 44: 2
45 to 54: 1
prefer not to say: 2
did not answer: 5

5. Eight out of 12 who responded to the public consultation answered this demographic question relevant to them.

Graph 3: showing how many members does your organisation represent in total.

Responded with the following responses:

10 to 100: 2
101 to 250: 1
251 to 1,000: 1
1,001 to 5,000: 1
more than 10,000: 1
prefer not to say: 1
do not know: 1
not answered: 4

6. Six out of 12 who responded to the public consultation answered this demographic question relevant to them.

Graph 4: which areas does your organisation represent?

Graph 4 had 4 out of 12 responses with the following:

prefer not to say: 1
Environment: 1
Manufacturing: 1
International development food, farmers, manufacturing : 1
Food, farmers, manufacturing: 1
Farmers: 1
did not answer: 6

7. Four out of 12 who responded to the public consultation answered this demographic question relevant to them.

Graph 5: what is the number of businesses represented?

Graph 5 shows 4 out of 12 responded with the following:

10 to 100: 1
101 to 250: 2
1,001 to 5,000: 1
did not answer: 8

8. Four out of 12 who responded to the public consultation answered this demographic question relevant to them.

Graph 6: what is the average size of businesses represented?

Graph 6 shows 3 out of 12 responded with the following:

Micro (0 to 9 employees): 1
Small (10 to 49 employees): 1
Large (250+ employees): 2
did not answer: 8

9. 3 out of 12 who responded to the public consultation answered this demographic question relevant to them.

Graph 7: which business area(s) does your organisation represent?

Graph 7 shows 3 out of 12 responded with the following:

Agriculture, forestry, fishing, food, beverages and tobacco: 2
Agriculture, forestry and fishing: 1
did not answer: 9

10. Three out of 12 who responded to the public consultation answered this demographic question relevant to them.

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1. Introduction