U.S.

Ethanol Policy and Trade

Biofuels International Conference
Ghent
September 24, 2014
Doug Newman
International Trade Analyst
U.S. International Trade Commission
500 E St. SW
Washington, DC 20436
202-205-3328
douglas.newman@usitc.gov

Disclaimer
The analysis and views expressed in this presentation are solely
those of the author and do not necessarily reflect those of the
U.S. International Trade Commission or any other U.S.
government agency.

U.S. International Trade Commission

Independent, quasi-judicial federal agency
Investigates and studies trade issues
Section 332 (Probable effects; Competitiveness)
Title VII (AD, CVD)
Section 337 (IP)

Advisory
U.S. Trade Representative
Senate Finance; House Ways and Means

Publishes the Harmonized Tariff Schedules

Determined CBI ethanol dehydration quota

Major Points
Global policies affect trade flows
Major U.S. policy changes occurred in recent years
U.S. policy is under review
Uncertainty and risk continue
Exports have increased in importance to U.S. producers

Topics
Global overview
U.S. market
Policy elements and changes
Implications for U.S. trade

Global Overview

Global ethanol production growth, driven by fuel use, levels off in 2011

Billion gallons

30
25
20
15
10
5
0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Fuel

Other (beverage, industrial)

Source: Estimated based on data from LMC International.

Note: Data for 2014 are projected.

US and Brazil dominate global ethanol production, but others emerge

25,000

Million gallons

20,000

15,000

10,000

5,000

0
2006

2007

2008

US

2009

Brazil

Source: BEA; EIA; FAS; MAPA; Eurostat; LMC International.

Note: Data for 2014 are projected.

2010

EU

China

2011

2012

All other

2013

2014

Growth in global fuel ethanol consumption slows: major markets mature and face
constraints, new markets relatively small
25,000

Million gallons

20,000

15,000

10,000

5,000

0
2006

2007

2008

US

2009

2010

Brazil

EU

Source: BEA; EIA; FAS; MAPA; Eurostat; LMC International.

Note: Data for 2014 are projected.

2011

China

2012

All other

2013

2014

Global ethanol imports generally rise and diversify during 2003-2013

3,000

Million gallons

2,500

2,000

1,500

1,000

500

0
2003

2004

USA

2005
EU

2006
Canada

2007
Japan

2008

2009

2010

Central America

2011
Brazil

2012

2013

All other

Source: GTIS; LMC International.

Note: Includes all ethanol in HS heading 2207. Quantities include denaturants. EU imports understated during 2010-2012, as the bulk of
imports were classified in HS heading 3824.

Ethanol import penetration is greatest in EU market

Import share of consumption (percent)

35.0

30.0

25.0

20.0

15.0

10.0

5.0

0.0

US
2003

EU
2004

2005

2006

Source: Calculated based on data from GTIS; LMC International.

Brazil
2007

2008

2009

2010

World
2011

2012

2013

Global ethanol exports remain dominated by Brazil and the United States
2,500

Million gallons

2,000

1,500

1,000

500

0
2003

2004

2005

2006

United States

2007

Brazil

Source: GTIS; LMC International.

Note: Includes all ethanol in HS heading 2207. Quantities may include
denaturants.

2008

2009

2010

Central America

2011

2012

All other

2013

Ethanol export share of production typically greatest for Brazil; increasing in US

Export share of production (percent)

25.0

20.0

15.0

10.0

5.0

0.0

US

2003

EU

2004

2005

2006

Source: Calculated based on data from GTIS; LMC International.

Brazil

2007

2008

2009

2010

World

2011

2012

2013

U.S. Market

Major U.S. Policy Elements

Domestic policy

Renewable Fuel Standard (RFS)

California Low Carbon Fuel Standard (LCFS)
EPA E15 waiver
R&D grants and loan programs (BRDI, BCAP, REAP)

Trade policy
Duties
Duty drawbacks
Export promotion

Major U.S. Policy Changes

Expiration of the Volumetric Ethanol Excise Tax Credit (VEETC)
Expiration of the Other Duty or Charge (ODC)
Expiration of CBI dehydration quota
Expiration of Cellulosic Producer Tax Credit
Expiration of Biodiesel Blenders Tax Credit
Lowering of RFS RVO for 2014
California Low Carbon Fuel Standard on pause while being revamped

The Renewable Fuel Standard drives the U.S. market

40
35
30

Billion gallons

25
20
15
10
5
0
2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022
Undifferentiated renewable

Cellulosic

Undifferentiated advanced

Biomass-based diesel

Source: Energy Policy Act; EISA.

Note: Data for 2006 and 2007 represent the Renewable Fuel Program. Areas represent original ethanol-equivalent volume requirements.

The RFS resulted in dramatic ethanol market growth in the mid-2000s; growth slows in 2011
16,000
14,000
12,000

Million gallons

10,000
8,000
6,000
4,000
2,000

1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013

Production
Source: U.S. Department of Energy, Energy Information Administration.

Consumption

California Low Carbon Fuel Standard

Not part of the RFS
Goal is to lower carbon intensity of transport fuel by 10% by 2020
Carbon credit system with carbon intensity premiums
Sugarcane ethanol generally lower than corn ethanol
However, U.S. corn ethanol producers react with adjustments
Effectiveness constrained by blend percentages
Compliance schedule on hold as regime is amended
Urgency for imports of sugarcane ethanol postponed

U.S. Fuel Ethanol Duties

HTS subheading

Duties/Other duty or charge

Column 1

Trade preference programs

Preferential

2207.10.6010
(undenatured)

2.5 % ad
valorem

Free

AGOA, ATPA, Australia, Bahrain, CAFTADR , Canada, CBERA, Chile, Colombia,

GSP+ (least-developed), Israel, Jordan, Korea,
Mexico, Morocco, Oman, Panama, Peru,
Singapore

2207.20.0010
(denatured)

1.9 % ad
valorem

Free

AGOA, ATPA, Australia, Bahrain, CAFTADR, Canada, CBERA, Chile, Colombia, GSP+
(least-developed), Israel, Jordan, Korea,
Mexico, Morocco, Oman, Panama, Peru,
Singapore

14.27 cents per

liter
(54 cents per
gallon)

Free

GSP+ (least-developed), ATPA, CAFTA-DR,

Canada, CBERA, Colombia, Insular
Possessions, Israel, Mexico, Panama, Peru

9901.00.5000 (fuel use)

In addition to ch. 22 duties.
EXPIRED AT THE END
OF 2011. INACTIVE;
COULD BE
REINSTATED.
Source: HTSUSA.

CBI Dehydration Quota

Conferred origin for ethanol dehydrated from imported hydrous
feedstocks
7% of U.S. consumption=>No local feedstock required
Additional 35 million gallons=>30% local feedstock blend
required
Unlimited amount=>50% local feedstock blend
Applied to CBERA, DR/CAFTA, U.S. Insular Possessions
First-come, first-served
DR/CAFTA reservations for El Salvador (phase in to 25 mgy+)
and Costa Rica (31 mgy+)Does not increase the quota;
unfilled amount not reassigned
Expired at the end of 2011 along with the ODC. Would be
reactivated if the ODC is reimposed.

Duty Drawbacks
Jet fuel duty drawbacks facilitated direct imports of
anhydrous ethanol from Brazil during 2004-2008 and
likely mitigated the bulk of import duties.
Drawback provisions were amended to require ethanol in
the exported product after Oct. 1, 2008 in order to receive
drawbacks on the additional duty in HTS chapter 99; jet
fuel can still be used for drawbacks on HTS chapter 22
duties.
Consistent fuel ethanol exports since 2009 have
generated substitution drawbacks that mitigated import
duties.

How U.S. duty drawback regulations linked ethanol to jet fuel

Supplies, including jet fuel , used by U.S. carriers for overseas flights = deemed exports
19 U.S.C. 1309

Petroleum derivative products sharing 8-digit HTS subheading are commercially

interchangeable
19 U.S.C. 1313(p)

Jet fuel = HTS 2710.12.1520

Gasoline /ethanol blends (>70% gasoline by weight) = HTS 2710.12.1550
Abstracts (proprietary rulings) held that fuel ethanol imports that are blended with gasoline
are eligible for substitution manufacturing drawbacks, as they are considered to be an input
and a substitute for domestic ethanol that is used for the same purpose
19 U.S.C. 1313(b)

Result

Thus, imports of fuel ethanol can claim duty drawbacks against sales of jet fuel used by
U.S. carriers for overseas flights, even though jet fuel contains no ethanol
Only valid for HTS chapter 22 duties

U.S. ethanol imports, dominated by fuel use, responded to the RFS

800,000

700,000

1,000 gallons

600,000

500,000

400,000

300,000

200,000

100,000

2000

2001

2002

2003

2004

2005

2006

Fuel

2007

2008

Other

Source: Estimated by the USITC based on official statistics of the U.S. Department of Commerce.

2009

2010

2011

2012

2013

U.S. fuel ethanol imports are dominated by Brazil (including CBI pathway)
700,000

600,000

1,000 gallons

500,000

400,000

300,000

200,000

100,000

0
2003

2004

2005

2006

2007
CBI

2008
Brazil

2009
Canada

Source: Estimated by the USITC based on official statistics of the U.S. Department of Commerce.

2010
All other

2011

2012

2013

U.S. fuel ethanol imports are substantially lower YTD 2014--Brazil, CBI
300,000

250,000

1,000 gallons

200,000

150,000

100,000

50,000

January-July 2013

January-July 2014

Brazil

Guatemala

Netherlands

Spain

Paraguay

Nicaragua

France

Costa Rica

El Salvador

Jamaica

Sweden

United Kingdom

Source: Calculated based on data from GTIS; LMC International.

U.S. fuel ethanol imports enter mainly through ports in Florida and California
160,000

140,000

1,000 gallons

120,000

100,000

80,000

60,000

40,000

20,000

0
2009
Miami, FL

Source: USITC Dataweb.

Tampa, FL

2010
San Francisco, CA

2011
Los Angeles, CA

2012
Providence, RI

2013
New York, NY

Jan-July 2014
All other

U.S. CBI dehydration quota never filled

900,000
800,000
700,000

1,000 gallons

600,000
500,000
400,000
300,000
200,000
100,000

Filled

Unfilled

Source: Estimated by the USITC based on official statistics of the U.S. Department of Commerce; CBP.

2011

2010

2009

2008

2007

2006

2005

2004

2003

2002

2001

2000

1999

1998

1997

1996

1995

1994

1993

1992

1991

1990

CBI dehydration quota stimulated investment to expand capacity

400,000
350,000
300,000

1,000 gallons

250,000
200,000
150,000
100,000
50,000
0
2000

2001

2002

2003

2004

Trinidad & Tobago

2005

Jamaica

2006

2007

El Salvador

2008

Costa Rica

2009

2010

USVI

Source: Estimated by the USITC based on official statistics of the U.S. Department of Commerce; CBP.

2011

Export Promotion
Relatively new initiative
Ethanol now eligible for funding under the USDA Market Access
Program
RFA, ABFA trade mission to Brazil in Sept-Oct 2013 sponsored by
the Brazil-U.S. Business Council
RFA, Growth Energy, U.S. Grains Council and USDA trade mission
to China in May 2014; Japan and Korea in September 2014
Future missions planned to Latin American and Southeast Asia

Major Foreign Policy Issues Affecting Exports

EU RED and FQD: Changing circumstances
EU tariffs: E70 customs ruling and AD duty
Canada: RFS; Structural market
Brazil gasoline policy: Prices, taxes, and blend rate
Brazil transportation costs: ICMS; ship internally by truck
Emerging markets establishing ethanol programs
Market access in potential markets: India; China

U.S. exports of nonbeverage ethanol increased dramatically in 2011 as Canada

implements RFS and arbitrage opens in the EU and Brazil
1,200

1,000

Million gallons

800

600

400

200

0
2003

2004

2005
Canada

2006
EU-27

2007

2008

Brazil

Source: Compiled from official statistics of the U.S. Department of Commerce.

2009

All other

2010

2011

2012

2013

U.S. exports of nonbeverage ethanol to the EU expanded in 2010-12 but

returned to nominal levels in 2013 largely in response to EU policy changes
300

Million gallons

250

200

150

100

50

0
2005

2006

2007
Netherlands

2008

2009

United Kingdom

Source: Compiled from official statistics of the U.S. Department of Commerce.

Note: Schedule B subheadings 2207.1060 and 2207.20.

2010
Finland

2011
All other

2012

2013

A major data discrepancy regarding U.S.EU ethanol trade resulted from customs
classification and reporting differences and suggests need for harmonized standards
300

250

Million gallons

200

150

100

50

0
2005

2006

2007
US exports

2008

2009
EU-27 imports

2010

2011

2012

Difference

Source: EU: GTIS, Global Trade Atlas; U.S.: Compiled from official statistics of the U.S. Department of Commerce.
Note: Includes HS heading 2207. Most EU imports of fuel ethanol from the United States likely were classified in HS heading 3824.

2013

U.S.-EU ethanol trade classification issue

HS heading 2207 provides for ethyl alcohol, and other spirits, denatured, of any strength.

HS subheading 2710.11 specifically provides for fuel mixtures containing at least 70 percent petroleum
oils, by weight.

HS subheading 3824.90 could provide for ethanol fuel mixtures between E30 and E93?

HSC (WCO) meetingno consensus. Some informal consensus that less than 93% ethanol is the dividing
line between chapter 22 and chapter 38.

ASTM specifies maximum of 2.5% denaturant, minimum of about 92% ethanol for denatured fuel ethanol
standard (D4806).

IRS VEETC denaturant level limited to about 2% (up to 2.5% for rounding). (VEETC expired)

IRS proposed regulation requires additional 0.1% gasoline to qualify for VEETC. (VEETC expired)

EPA allows 2% (2.44% for rounding) denaturant to count toward RFS mandate.

EU Binding Tariff Informations (BTIs)Chapter 38 classification for mixtures as low as E93. UK,
Netherlands, Sweden, Finland.

EU specificationsdiffer by member state, end use.

EU customs ruling that E70 is denatured ethanol classified in HS chapter 22.

Substantial data discrepancy between U.S. exports and EU imports.

When does denatured fuel ethanol change tariff classification?

Denatured
Ethanol

Chemical
Mixtures

70%
petrol

Gasoline
Mixtures

HS subheading 2207.20
HS heading text specifies of any strength--ambiguous
No explanatory notes at WCO level
EU duty: 0.102 euros/liter (about 13% ad valorem)

[denatured fuel ethanol usually 2-5% denaturant in US; WCO recommended 7%

denaturant as dividing line; no international consensus]

HS subheading 3824.90
Basket category, contains numerous products
EU duty: 6.5 percent ad valorem
EU E70 customs ruling effectively eliminates this category

HS subheading 2710.12
Mixtures containing at least 70% petroleum products, by
weight
Not a trade issue

New statistical category for U.S. fuel ethanol exports in 2012 clarified market data
100
90
80
70

Million gallons

60
50
40
30
20
10

Canada

Brazil

EU28

Mexico

Peru

All other

Source: Compiled from official statistics of the U.S. Department of Commerce. January-March 2012 estimated by USITC.

Jul-14

Jun-14

May-14

Apr-14

Mar-14

Feb-14

Jan-14

Dec-13

Nov-13

Oct-13

Sept-13

Aug-13

Jul-13

Jun-13

May-13

Apr-13

Mar-13

Feb-13

Jan-13

Dec-12

Nov-12

Oct-12

Sep-12

Aug-12

Jul-12

Jun-12

May-12

Apr-12

Mar-12

Feb-12

Jan-12

U.S. fuel ethanol exports to established markets are substantially higher in 2014
500,000
450,000
400,000

1,000 gallons

350,000
300,000
250,000
200,000
150,000
100,000
50,000
0

January-July 2013

Canada

Brazil

Source: Calculated based on data from GTIS; LMC International.

January-July 2014

United Arab Em

All others

U.S. fuel exports to newer markets have also increased substantially in 2014
100,000
90,000
80,000

1,000 gallons

70,000
60,000
50,000
40,000
30,000
20,000
10,000
0

January-July 2013

Philippines

Mexico

Korea

Peru

Source: Calculated based on data from GTIS; LMC International.

January-July 2014

India

Singapore

Colombia

Tunisia

Panama

U.S. fuel ethanol is exported mainly through ports in Texas, upper Midwest, New York
350,000

300,000

1,000 gallons

250,000

200,000

150,000

100,000

50,000

0
2012
Houston-Galveston, TX

Source: USITC Dataweb.

2013
Detroit, MI

Pembina, ND

Jan-July 2014
Duluth, MN

New York, NY

All other

Major Domestic Market Issues

Surplus corn ethanol capacity
Blend wall
Higher-level blend infrastructure
Cellulosic shortfall
California amending LCFS

U.S. ethanol capacity nears final RFS obligation for undifferentiated renewable
fuel (corn ethanol)
16,000

14,000

Million gallons

12,000

10,000

8,000

6,000

4,000

2,000

0
1999

2000

2001

2002

2003

2004

Final undifferentiated renewable fuel RVO

Source: Renewable Fuels Association.

Note: Data are as of January 1 of the given year.

2005

2006

2007

Capacity

2008

2009

2010

2011

2012

2013

Capacity under construction/expansion

2014

Although the blend wall is approaching, timing is difficult to assess

40

35

Billion gallons

30

25

20

15

Including RIN carryover

And adding additional biomass-based diesel gallons and RIN credits

10

5
2009

2010

2011

RFS (EISA)

2012

2013
E10

2014

2015

2016

E10 (adjusted)

2017

2018

2019
E15

2020

2021
E25

Source: Calculated based on the RFS and EIA gasoline consumption forecasts.
Note: Data for comparative purposes regarding different blends. Actual date of blend wall constraint depends on several factors.

2022

Limited availability of higher-level blends

E15: 78 stations (80% of fleet can use)
Blender pumps: 308 pumps
E85: 3,387 stations (7% of fleet can use)
Total number of gas stations: 142,000
Source: Renewable Fuels Association; E85Prices.com.

Cellulosic ethanol commercial capacity coming

online but still well short of original RFS

Dupont: 30 mg, IA
Poet: 25 my, IA
Abengoa: 25 my, KS
Quad County: 2 my, IA

Scheduled 2014 cellulosic RVO: 1.75 bg

EPA 2014 projected range: 8-30 mg
EPA proposed 2014 cellulosic RVO: 17 mg

RFS cellulosic RVO shortfalls

EPA maintained the total advanced RVO
This effectively doubled the undifferentiated advanced
RVO
Availability of alternatives inform EPAs decision

Biomass-based diesel extra half RIN credits

Additional biomass-based diesel gallons
Sugarcane ethanol imports
Other domestic advanced

Biogas
Naptha
Renewable diesel
Ethanol (sorghum)

RIN carryover

Advanced biofuel
Year

Undifferentiated
renewable fuel

Biomass-based
diesel

Cellulosic

Total renewable fuel

Undifferentiated

Total, advanced
biofuel
Share of
gasoline/diesel
(percent)

Billions of gallons

2006

2.78

2007

4.7

4.7

4.02

2008

7.76

2009

10.5

0.5

0.1

0.6

11.1

10.21

2010

12

0.65

0.0065 (0.1)

0.2935 (0.2)

0.95

12.95

8.25

2011

12.6

0.8

0.0066 (0.25)

0.5434 (0.3)

1.35

13.95

8.01

2012

13.2

0.00865 (0.5 )

0.99135 (0.5)

15.2

9.23

2013

13.8

1.28 (1)

0.014 (1)

1.456 (0.75)

2.75

16.55

9.63

2014

14.4

1.75

3.75

18.15

2015

15

1.5

5.5

20.5

2016

15

4.25

7.25

22.25

2017

15

5.5

2.5

24

2018

15

11

26

2019

15

8.5

3.5

13

28

2020

15

10.5

3.5

15

30

2021

15

13.5

3.5

18

33

2022

15

16

21

36

50

GHG reduction

Percent
20

50

60

Source: Energy Policy Act; EISA; 75 Fed. Reg. 76790 (December 9, 2010); various EPA Regulatory Announcements.
Note: The cellulosic volume was lowered substantially 2010-2013 ; the biomass-based diesel standard was combined for 2009 and 2010.

Cellulosic shortfall combined with maintenance of advanced requirement effectively doubled

the undifferentiated advanced RVO; demand for imports of sugarcane ethanol depends on the
availability of alternatives

Advanced RFS (million gallons)

3,000

2,500

750

2,000

500
706
1,500

300
1,000

200
94

243

1,280

500

650

491

800

1,000

2010
Biomass-based diesel
Source: Calculated based on RFS.

2011
Cellulosic

2012
Cellulosic shortfall

2013
Undifferentiated

2013 undifferentiated advanced RVO fulfillment scenarios

(RVO = 1.464 bg; cellulosic shortfall = 994 mg)
3,000

2,544
2,500

Million gallons

580
2,000

549
1,500

666

295

580

1,000

320
150

245

640

640

EPA NPRM

EPA FR

500

800

0
Biomass-based diesel RINs

Extra biomass-based diesel gallons

Other advanced

MAX
2012 Carryover RINS (D4/D5)

Source: Calculated based on RFS; EPA, 2013 RFS proposal and final rule.
Note: MAX scenario assumes biomass-based diesel production of 1.6 bg and other EPA scenarios in the final rule.

Sugarcane ethanol

EPA 2014 RVO proposal

Initial proposal published November 29, 2013
Total RVO of 15.21 bg, down from 18.15 bg in RFS
Undifferentiated renewable RVO (corn) of 13.01 bg, down from 14.4 bg
in RFS
Advanced RVO of 2.20 bg, down from 3.75 bg in RFS
Cellulosic RVO of 17 mg, down from 1.75 bg in RFS
Biomass-based diesel RVO of 1.28 bg, unchanged
Undifferentiated advanced RVO of 903 mg, down from 1 bg in RFS
Could result in a need for less than 300 mg of imported sugarcane
ethanol (903 mg - 640 BBD RIN credits - ? carryover RINS)

Proposal revised and sent to OMB for interagency review

Can take up to 90 days for review; decision expected sooner
Some RVOs expected to increase from initial proposal
Approval expected sometime after late October 2014

Proposal to significantly relax the LCFS compliance schedule

Year

Gasoline and gasoline blends

Carbon intensity (gCO2e/MJ)

Baseline

(may change)

% Reduction
95.85

2011

95.61

0.25

2012

95.34

0.5

2013

97.96

94.89

1.0

2014

97.47

94.41

1.5

2015

96.48

93.45

2.5

2016

95.49

92.50

3.5

2017

94.00

91.06

5.0

2018

92.52

89.62

6.5

2019

91.03

88.18

8.0

2020+

89.06

86.27

10.0

Source: California Air Resources Board, draft Final Regulation Order, available at http://www.arb.ca.gov/fuels/lcfs/CleanFinalRegOrder112612.pdf (accessed
September 9, 2014).

CA LCFS carbon intensity values from applications show wide variation between and
among feedstockscorn ethanol improving carbon profile

Fuel

Carbon Intensity Values

(gCO2e/MJ)

Pathway

Direct Emissions

Land Use or Other

Effects

Total

Gasoline

CARBOB

99.18

99.18

Corn ethanol
(undenatured)

Lowest

43.21

30

73.21

Highest

62.44

30

92.44

Lowest

17.94

46

63.94

Highest

32.94

46

78.94

Sugarcane ethanol
(undenatured)

Note: As of December, 2012. Only includes values from facilities that filed applications.
Source: California Air Resources Board, available at http://www.arb.ca.gov/fuels/lcfs/lu_tables_11282012.pdf.

Summary of major policy implications for U.S. trade

RFS RVOs may be lowered for 2014 and beyond

Increases pressure to export corn ethanol
Reduces need for imported sugarcane/molasses ethanol

California LCFS amendment

Reduces urgency for imported sugarcane/molasses ethanol
Reduces pressure to export corn ethanol
But only about 12% of U.S. market

Expiration of ODC and CBI dehydration quota

Uncertain real effect because of duty drawbacks
Eliminates pressure by trade partners to lower duties

Biodiesel blenders tax credit reinstated retroactively

Reduces need for imported sugarcane/molasses ethanol
Reduces blend wall pressure on ethanol

Opportunities for trade

Growth in existing markets

Canada; Brazil
United States and EU less certain; niches?

Development of new markets

Proliferation of biofuel policies

Latin America; Asia; Africa
India and China market access?
New export promotion initiative

New technology/products

Improve carbon profile

Lower costs
2nd and 3rd generation

General trend towards lower trade barriers

WTO bound duty reductions

Environmental Goods Agreement
Free Trade Agreements

Thank You!