In a post on the SugarCane.org site (a joint project of UNICA and the Brazilian Trade and Investment Promotion Agency (Apex-Brasil) to serve as a global information hub on sugarcane products), Leticia Phillips, UNICA’s Representative in North America, suggests that:

… we are seriously concerned the proposal as currently written would upend nearly a decade of established practice and effectively prevent Americans from importing and using Brazilian sugarcane ethanol, one of the cleanest and most available advanced biofuels on the market, by changing how “biointermediates” are treated.

The issue is that the proposal characterizes undenatured imported ethanol—e.g., sugarcane ethanol from Brazil—as a biointermediate product. Denaturing is the addition of chemicals to ethanol to ensure the alcohol is both not suitable for human consumption and is clearly “marked” for fuel use. Currently, the sugarcane ethanol is denatured in the US.

Categorizing undenatured imported ethanol as a biointermediate will impose significant and costly new obligations that may be infeasible and unfair for Brazilian sugarcane producers to meet. The unintended consequence may be blocking American access to this important source of advanced biofuel, and would treat foreign products differently from domestic biofuel supplies.

—Leticia Phillips

Brazilian sugarcane producers are urging clarification that the biointermediate definition does not apply to sugarcane ethanol.