3820-001b Guidelines for The Sampling and Testing of Raw Sugar Importations

Published CBP guidance; operative status and applicability must be assessed from the retained publisher edition.

U.S. DEPARTMENT OF HOMELAND SECURITY
U.S. Customs and Border Protection
CBP DIRECTIVE NO. 3820-00lC
EFFECTIVE DATE:
July 2026
ORIGINATING OFFICE: OS:LSS
SUPERSEDES: CD 3820-00lB
REVIEW DATE: July 2029
Guideliues for Sampling Raw Sugar Importations for Laboratory Testing
1. PURPOSE.
This Directive provides the guidelines to U.S. Customs and Border Protection (CBP) Officers
and Import Specialists on the sampling process of raw sugar importations. Timely and accurate
information is needed for raw sugar quota quantity calculations and allocations. This Directive
updates the sampling requirements for bulk raw sugar, raw sugar received in bags, and sampling
retail and non-centrifugal cane sugar (NCS) products.
2. BACKGROUND.
Sugar is the largest imported agricultural commodity subject to quota. Sugar, in the Sucrose
form, is the only sugar subject to quota by the "Certificate of Quota." The United States
Department of Agriculture (USDA) establishes the annual Eligibility and Specialty quota limits;
the United States Trade Representative (USTR) allocates the country Certificate quantitative
limits; and CBP, through the Office of Trade's Quota Branch, enforces the sugar quotas.
3. SCOPE.
This Directive covers raw sugar sampling guidance for the CBP Sugar Quota Import Program
and for Harmonized Tariff Schedule of the United States (HTSUS) classification after quota is
met. Raw sugar falls under the HTSUS: 1701.13.1000, I 701.14.1020 and 1701.14.1040 and
requires a Certificate of Quota Eligibility (CQE) for the in-quota tariff rate. The in-quota tariff
rate on raw sugar is lower than specialty or refined sugar. Therefore, all raw sugar entries are
sampled and polarity tested to ensure the sugar qualifies as raw sugar, i.e., having a polarity of
less than 99.5 degrees Z (
0
Z).
4. POLICY.
The Directive establishes the policy on sampling rate of bulk raw sugar, sugar in bags, and for
retail and NCS products. CBP Operations Support, Laboratories and Scientific Services (LSS)
serves as the technical authority for CBP on the testing and test results of these sugar products.
. . . . .
5. AUTHORITIES/REFERENCES.
5.1 Presidential Proclamation 6179 - Modification of Tariffs and Quota on Certain Sugars,
Symps, and Molasses
(I 990)

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5.2 19 United States Code (U.S.C.) § 1499 - Examination of merchandise
5.3 19 U .S.C. § 1202 - Hatmonized Tariff Schedule (HTS)
5.4 19 Code of Federal Regulations (C.F.R.) § 132.17 - Export certificate for sugar-
containing products subject to tariff-rate quota
5.5 19 C.F.R. § 151.12-Accreditation of commercial laboratories
5.6 19 C.F.R. § 151.13 - Approval of commercial gaugers
5.7 19 C.F.R. § 151.21 - Definitions
5.8 19 C.F.R. § 151.22 - Estimated duties on raw sugar
5.9 Harmonized Tai·iffSchedule of the United States (HTSUS) Chapter 17 - SUGARS AND
SUGAR CONFECTIONERY
6. DEFINITIONS.
6.1 Bag of sugar:
An intermediate bulk bag containing at least 110 pounds (50 kilograms).
This includes "super sacks" that typically contain 2,000 to 2,500 pounds (900 to 1,150
kilograms) of raw sugar.
6.2 CBP Accredited Laboratory: A commercial laboratory, within the United States, that
has demonstrated its capability to perform analysis of certain commodities to determine elements
related to the admissibility, quantity, composition, or characteristics of imported merchandise, as
described in 19 C.F.R. § 151.12.
6.3 Non-centrifugal cane sugar (NCS): Panela, jaggery, and other panela-type sugars are
cane sugars obtained without centrifugation, whose content of sucrose by weight, in the dry state,
corresponds to a polarimeter reading of 69°Z or more but less than 93°Z. The product contains
only natural anhedral microcrystals, of irregular shape, not visible to the naked eye, which are
surrounded by residues of molasses and other constituents of sugar cane.
6.4 Out-turn quantity: The actual landed weight of raw sugar. This value is determined by
commercial sugar weighers.
6.5 Polarimetric testing: The use of optical means (i.e., a polarimeter/polariscope) to
determine the percentage of sucrose in a product.
6.6 Qualified sugar gauger: A company specializing in sugar commodity transfers in
. weighing and sampling. To be qualified, the company must have experience as a sugar gauger
and certification from an outside accreditation or ce1tification body.
6.7 Raw sugar: Sugar whose content of sucrose by weight, in the dry state, corresponds to a
polarimeter reading of less than 99.5 °Z. The "degree", "sugar degree", or polarization degree"
unit of measure means an International Sugar Degree as determined by polarimetric test

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performed in accordance with procedures recognized by the International Commission for
Uniform Methods of Sugar Analysis (JCUMSA). This test discloses the percentage of sucrose
contained in the sugar.
6.8 Raw value (herein "raw sngar valne"): The equivalent of such articles in tenns of
ordinary commercial raw sugar testing value of 96°Z by the polariscope as determined in
accordance with regulations or instructions issued by the Secretary of the Treasury.
6.9 Retail packaging: Raw sugar put up in packaging of less than l 10 pounds ( 50
kilograms), whether or not labeled for retail sale.
7. RESPONSIBILITIES.
7.1 Office of Field Operations (OFO)
7.1.1
Directors, Field Operations, Port Directors, and the CBP Agriculture and Prepared
Products Center of Excellence and Expertise Director are responsible for implementing this
Directive, disseminating this information to the public, and ensuring Port compliance.
7.1.2 The Port Directors are responsible for implementing procedures to ensure Section 8 is
followed for the timely delivery of raw sugar samples to the servicing laboratory.
7.1.3 CBP Import Specialists and CBP Officers (CBPOs) shall adhere to Section 8 for
completion and submission of the CBP Form 6479, CBP Sample Label, with the sample.
7.2 Operations Support (OS): Laboratories and Scientific Services Laboratory Directors are
responsible for providing technical guidance in implementing this Directive for sample integrity
for accurate testing results.
8. PROCEDURES.
8.1
CBP Import Specialists and/or CBP Officers should check the Document Imaging
System (DIS) to determine whether the importer/broker has uploaded a certified letter, stating
they have contracted with a qualified sugar gauger for weighing and sampling purposes. If
present, CBPOs may override the shipment to general and release without examination. If the
DIS does not show the importer/broker has provided this letter, then the shipment must be
examined at the po1t of entry.
8.2 Sampling Instructions
8.2.1
If an examination is required, the examining CBPO will sample the raw sugar by
completely and compactly filling the special raw sugar container(s). This ensures the moisture
composition of the sample remains constant between the time of sampling to testing. Loss of
sample moisture affects sugar quantity calculations.
8.2.2 The minimum weight quantity for each raw sugar sample submitted to a laboratory shall
be approximately one pound (or450 grams) compactly placed in a container with a tight-fitting

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screw cap. LSS recommends a 16 oz., wide-mouthed plastic jar with a screw top cap, such as
Uline Model S-14510 or similar. Plastic insulating tape (e.g., electrical tape) must be placed
around the joint of the container and the screw cap to seal the container. Taping the screw cap
joint helps maintain the moisture content.
8.2.3 NCS and sugar in individual retail packages may be submitted to the laboratory in its
original packaging without further sampling, when possible. Total weight should be at least one
pound ( 450 g). Otherwise, Section 8.2.2 should be followed. A Ziplock bag with seal tape may
be used for shipment ofNCS that cannot fit in jars or is not in retail packaging.
8.3 Sampling Rate
8.3.l Sugar in Bulk:
The sampling rate for raw sugar conveyances in bulk shall be as follows:
one sample for each 2,800,000 pounds (1,270,059 kilograms), or part thereof, of raw sugar in the
shipment (see Chart l); a maximum of25 samples per entry line may be submitted for analysis.
The sampling and labeling instrnctions per Section 8.2 and Section 8.4 shall be followed.
Chart I· Samoling Rate for Raw Sugar in Bulk
#
Required
Bulk Conve ,ance Weie:hts
Samples
Kilograms (kg)
Pounds (lbs.)
1
1,270,059 and under
2,800,000 and under
2
1,270,060 to 2,540,117
2,800,00 I to 5,600,000
2,540,118 to 3,810,176 3
5,600,001 to 8,400,000
4
3,810,177 to 5,080,235
8,400,001 to 11,200,000
5
5,080,233 to 6,350,293
11,200,001 to 14,000,000
6
6,350,294 to 7,620,352
14,000,001 to 16,800,000
7
7,620,353 to 8,890,410
16,800,00 I to 19,600,000
8,890,411 to 10,160,465 8
19,600,001 to 22,400,000
10,160,466 to 11,430,528 9
22,400,001 to 25,200,000
10
11,430,529 to 12,700,586
25,200,00 I to 28,000,000
11
12,700,587 to 13,970,645
28,000,001 to 30,800,000
12
13,970,646 to 15,240,704
30,800,00 I to 33,600,000
15,240,705 to 16,510,762 13
33,600,00 I to 36,400,000
14
16,510,763 to 17,780,821
36,400,001 to 39,200,000
17,780,822 to 19,050,880 15
39,200,001 to 42,000,000
16
19,050,881 to 20,320,938
42,000,001 to 44,800,000
17
20,320,939 to 21,590,997
44,800,001 to 47,600,000
18
21,590,998 to 22,86 I ,055
47,600,001 to 50,400,000
19
22,861,056 to 24,131,114
50,400,001 to 53,200,000
20
24,131,115 to 25,401,173
53,200,001 to 56,000,000
21
25,401,174 to 26,671,231
56,000,00 I to 58,800,000
22
26,671,232 to 27,941,290
58,800,001 to 61,600,000
23
27,941,291 to 29,211,349
61,600,001 to 64,400,000
24
29,211,350 to 30,481,407
64,400,001 to 67,200,000
25
30,481,408 or more
67,200,001 to 70,000,000

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8.3.2 Sugar in Bags: A typical full shipping container containing sugar in bags weighs
approximately 55,115 pounds (25,000 kilograms) which equates to approximately 500 I IO-lb.
(50 kilograms) bags or 25 supersacks. Raw sugar conveyances in bags (i.e., "sugar in bags")
shall be sampled as follows: one randomly selected bag per 110,231 pounds (50,000 kilograms),
or part thereof, of raw sugar in the shipment (see Chart 2); a maximum of20 samples per entry
line may be submitted for analysis. Please note, do not take more than one sample from a single
container, regardless of weight. The sampling and labeling instructions per Section 8.2 and
Section 8.4 shall be followed.
Chart 2· Samoline: Rate for Sue:ar in Bags
Bulk Conveyance Weights # Required
Samples
Kilo11rams (k!!)
Pounds (lbs.)
I
50,000 and under
110,231 and under
2
50,00 I to I 00,000
110,232 to 220,462
I 00,00 I to 150,000 3
220,463 to 330,693
4
150,00 I to 200,000
330,694 to 440,925
5
200,00 I to 250,000
440,926 to 551,156
6
250,001 to 300,000
551,157 to 661,387
7
300,001 to 350,000
661,388 to 771,618
8
350,00 I to 400,000
771,619 to 881,850
400,00 I to 450,000 9
881,85 I to 992,080
10
450,00 I to 500,000
992,081 to 1,102,31 I
11
500,00 I to 550,000
1,102,312 to 1,212,542
12
550,00 I to 600,000
1,212,543 to 1,322,774
13
600,00 I to 650,000
1,322,775 to 1,433,005
14
650,00 I to 700,000
1,433,006 to 1,543,236
15
700,00 I to 750,000
1,543,237 to 1,653,467
16
750,001 to 800,000
1,653,468 to 1,763,698
17
800,00 I to 850,000
1,763,699 to 1,873,929
18
850,00 I to 900,000
1,873,930 to 1,984,160
19
900,00 l to 950,000
1,984,161 to 2,094,39 I
20
950,00 I or more
2,094,392 or more
8.3.3 NCS (Panela and panela-type sugars): and other raw sugar in retail packaging shall be
sampled as follows: one sample of product in retail packaging (e.g., a block, a disk, a cone, etc.)
per entry line for submission to the laboratory. The labeling requirements for NCS and other
retail packaged sugars are the same as those for bulk sugars (See Section 8.4).
8.4 Marking of sample containers: Each sample container shall be marked with the
appropriate entry number and line number and the entered out-turn weight of raw sugar, in
pounds or kilograms, of the conveyance that it represents (e.g., given 4 samples obtained: first
container - entry number, entered "out-turn" weight, "Sample I of 4"; second container - entry
number, entered "out-turn" weight, "Sample 2 of 4"; etc.). The last sample container for an entry
shall be identified by marking the container with the following infmmation:

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8.4.1 Entry number and line number: Laboratory case numbers will not be created, and lab
reports will not be issued, without an entry number and line number for reference.
8.4.2 Out-turn quantity: in pounds or kilograms, of the raw sugar for the entry.
8.4.3 Other shipment information: The entry date, vessel name, importer name, total number
of sample containers, and name of submitter and telephone number should there be questions.
8.4.4 Quantity of raw sugar: in the conveyance that each sample represents in pounds or
kilograms.
8.4.5 The words "LAST SAMPLE" on the last sample being submitted.
8.4.6 Whether the entry is for Quota or for Re-export.
8.5 Documentation:
A CBP Form 64 79 for each entry shall be completed and submitted
with the samples to the servicing laboratory. Samples submitted to LSS without a CBP Form
6479 completed will not be accepted and analyzed by the laboratory.
8.6 It is recommended that raw sugar samples be sent to the servicing laboratory by the next
business day after the shipment is off-loaded or examined to preserve the moisture content as
much as possible. As a general practice, the laboratory sample will be analyzed by the
laboratory within 30 calendar days of receipt of the sample
and the required documentation to
ensure the quality of the sample tested. The CBP Laboratory, in certain situations, may contract
the polarimetry testing ofNCS samples to a CBP Accredited Laboratory, that is accredited to test
raw sugar for polarity, to ensure timeliness of analysis.
8.7 The servicing laboratory tests the number of samples for each entry line as specified in
Section 8.3, regardless of how many samples are submitted. In cases where fewer samples are
submitted, LSS will test all samples received. This approach ensures testing is conducted in
accordance with this Directive. For transparency and documentation, LSS reports will state the
number of samples tested, for example:
• Ten jars (or bags, packages, etc.) of raw sugar are required as per Section 6.3 of Directive
3820-00IC; however, twelve samples were received. Ten jars (or bags, packages, etc.),
chosen at random, were tested.
• Twelve ( or bags, packages, etc.) of raw sugar were required as per Section 6.3 of Directive
3820-00 IC; however, only ten were received. All items received were tested.
8.8 Laboratmy reports will provide the out-tum quantity of raw sugar, polarimetric sucrose
content, calculated sugar factor, and calculated raw sugar value for the entry. If the out-tum
quantity is not provided, then only the polarization degree Z and calculated sugar factor will be
reported to the submitter. In these cases, the Import Specialists and the Office of Trade Quota
and Agriculture Branch will need to determine the final calculated raw sugar value based upon
the documented out-turn weight in the entry using the following formula:

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• calculated raw sugar value= out-turn weight x calculated sugar factor
8.9 The designated personnel in the CBP Agriculture and Prepared Products Center for
Excellence and Expertise, stated on the CBP Form 6479, will receive the servicing laboratory's
report electronically. Results for samples submitted directly to the LSS San Juan Laboratory in
San Juan, Puerto Rico will be reported to the Import Specialist responsible for the entry.
8.10 Field Import Specialists shall not send a calculated raw sugar value to the Office of Trade
Quota and Agriculture Branch. They will, however, continue the timely input of other quota
information into ACE.
8.11 LSS transmits to the Office of Trade Quota and Agriculture Branch the laboratory tests
results including the raw sugar value when the out-turn weight is supplied with the sample entry
documentation.
8.12 The Office of Trade Quota and Agriculture Branch updates the quota sugar records based
on laboratory results and in accordance with regulations.
9. RECORDKEEPING. Laboratory reports will be kept for 20 years in CBP Records and
lnfonnation complying with the Federal Records Act.
10. NO PRIVATE RIGHT CREATED. This Directive is an internal policy statement of
CBP and does not create or confer any rights, privileges, or benefits upon any person,
party, or entity.
11. APPROVAL AUTHORITY.
Digitally signed by CASEY 0
CASEYO
DURST
Date: 2026.08.03 20:42:06 ~04'00'
DURST
Casey Durst (Date)
Executive Assistant Commissioner
Operations Support
U.S. Customs and Border Protection