CRA Urges Strong, Rules-based Trade Action in Section 301 Testimony

May 6, 2026

WASHINGTON, D.C. - Today, Corn Refiners Association President and CEO John Bode offered testimony to the Office of the U.S. Trade Representative for its Section 301 Investigation into excess overseas production capacity.

In his remarks, Bode noted the importance of trade for American agriculture generally and corn refining specifically. He also welcomed the Trump Administration's thorough examination of important trade issues to ensure a rules-based trading environment.

"We support strong enforcement against unfair trade practices, while also urging a targeted, evidence-based approach that protects American competitiveness and preserves critical North American trade flows," said Bode.

Bode's testimony emphasized three key points: CRA's desire for the Trump Administration to carefully consider tariff exclusions on any duties that might result from the Section 301 Investigations; the importance of the integrated North American market for U.S. agricultural exports; and the overcapacity of manufacturing of certain refined corn products in China and other markets.

America's corn refiners directly employ more than 9,700 people and have an annual economic impact of $61 billion. The industry handles between 10-15% of the annual U.S. corn crop and typically exports between 15-20% of the shipments that leave 25 American facilities across 10 states.

Bode's remarks, as prepared for delivery, are below:

Thank you to the Office of the United States Trade Representative and others in the U.S. Government for the opportunity to present the views of the Corn Refiners Association.

My name is John Bode, President and CEO of the Corn Refiners Association. CRA represents one hundred percent of the U.S. corn refining, or wet milling, industry-an industry that plays a critical role in American manufacturing, agriculture, and food and industrial supply chains.

Our members employ nearly 9,700 people directly and support more than 166,000 direct and indirect jobs nationwide, with an annual economic impact exceeding $60 billion. Corn refiners manufacture essential inputs-starches, sweeteners, corn oil, advanced bio-products, and animal feed ingredients-that are used across the U.S. economy. Collectively, our industry uses 10-15% of the U.S. corn crop each year, delivering strong, ongoing demand for American farmers.

CRA appreciates the Administration's focus on structural excess capacity and non-market practices. These are serious issues, and we share the goal of ensuring a fair, rules-based trading system, and are eager to work with the Administration to ensure the tools used to address these challenges be carefully calibrated to avoid unintended harm to U.S. producers, workers, and consumers.

Today I will highlight the three key points made in our public comments.

First, we urge the Administration to carefully consider tariff exclusions if additional tariffs result from these investigations.

Corn refiners produce dozens of specialized products, each with distinct supply chains, demand patterns, and competitive dynamics. An oversimplified approach to tariffs and tariff exclusions risks capturing products where imports are not the problem and where domestic alternatives are limited or unavailable. We therefore strongly encourage USTR to formalize a transparent process for public input and product-specific analysis, and we stand ready to assist with data and expertise to ensure that any tariff actions align with the Administration's objectives.

We specifically note that several refined corn products were excluded from certain tariffs to account for the Section 232 investigation into pharmaceuticals. The President has now taken action related to that investigation and has not added tariffs on any refined corn products that were within the scope of the investigation. Our industry is awaiting clarification on if and how tariff exclusions will now be considered related to this subset of products.

Second, CRA underscores the critical importance of the North American market.

Canada and Mexico are not only our closest trading partners; they are also essential to the success and resilience of U.S. agriculture and food manufacturing. Mexico and Canada are consistently the top export destinations for U.S. refined corn products, accounting for approximately half of total U.S. exports in this sector in 2025.

Duty-free access under USMCA has enabled deeply integrated North American supply chains that support American jobs, enhance regional food security, and strengthen our global competitiveness. In many cases, refined corn products cross borders multiple times as inputs into further manufacturing. Disrupting this balance through new trade barriers with Canada or Mexico would have severe and immediate consequences for U.S. producers and workers.

As these Section 301 investigations proceed-and as the Administration undertakes the USMCA review-we urge careful consideration of these longstanding, mutually beneficial trade relationships.

Third, CRA highlights persistent overcapacity and unfair trade practices in certain foreign markets, particularly China.

U.S. imports of refined corn products from China have grown significantly over the past decade. Chinese producers operate in a system characterized by heavy state and provincial subsidies and capacity expansion that does not reflect normal market principles.

The U.S. government has repeatedly found that Chinese producers of refined corn products have engaged in dumping and subsidization, causing material injury to U.S. manufacturers. These findings-by both the Department of Commerce and the International Trade Commission-underscore the scale and persistence of the problem.

While existing trade remedy tools have provided important relief, challenges remain, including transshipment and the spread of non-market practices into third-country production. Addressing these distortions is essential to restoring fair competition.

In closing, the Corn Refiners Association appreciates USTR's leadership and the opportunity to contribute to these investigations. We support strong enforcement against unfair trade practices, while also urging a targeted, evidence-based approach that protects American competitiveness and preserves critical North American trade flows

We look forward to continued engagement and are eager to support your efforts moving forward.

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About the Corn Refiners Association (CRA)
The Corn Refiners Association (CRA) is the national trade association representing the corn refining industry of the United States. CRA and its predecessors have served this important segment of American agribusiness since 1913. Corn refiners manufacture sweeteners, starch, advanced bioproducts, corn oil and feed products from corn components such as starch, oil, protein, and fiber.