**November 22, 2007.**

**Docket Clerk**

**Marketing Order Administration Branch**

**Fruit and Vegetable Programs**

**Agricultural Marketing Service**

**U.S. Department of Agriculture**

1400 Independence Avenue, S.W.

STOP 0237

Washington, DC 20250-0237

Re: Comments Regarding Proposed Changes in Regulatory Periods for Table
Grapes, Marketing Order No. 925 (**Docket No. AMS-FV-06-0184; FV
03-925-1 PR; 72 *Fed. Reg.* 60588 (October 25, 2007)**)

To Whom It May Concern:

On behalf of the Secretariat of Agriculture, Livestock, Rural
Development, Fisheries and Foods of Mexico (SAGARPA), we are submitting
these comments in response to the notice appearing in the October 25,
2007 *Federal Register*, requesting public comment on a proposed rule to
modify the regulatory period for table grapes, grown in designated areas
of Southern California or imported into the United States, subject to
Marketing Order No. 925 . The rule proposes to move forward the
regulatory period starting date from April 20 to April 1. One of the
purposes of this proposed change is to prevent the marketing or
importation of substandard grapes that do not meet the requirements of
Marketing Order No. 925 during the April 1 - April 19 period.

The Ministry of Agriculture of Mexico SAGARPA wishes to express, that
although we consider US Marketing Orders as inconsistent with
international trade rules, as an issue of fairness the regulatory period
should be moved forward as proposed by these changes, in order to avoid
saturation and dumping in the market of low quality grapes at a time
when Mexican grapes have cleared the marketing standards and are being
sold. Import data clearly show that Chilean table grapes are being
entered into the United States during this three week period, and that
these grapes do not meet the standards set forth in the Marketing Order.
Being of lesser quality, they sell for lower prices than grapes which
must meet the requirements of Marketing Order No. 925.

Moving the regulatory period forward to April 1 will limit the
introduction and sale of lower quality grapes to the market, which
depress both prices and demand, during the period immediately before the
arrival of higher quality grapes subject to the Marketing Order would
benefit growers selling these better grapes and consumers.

Additionally, portions of the Chilean table grapes being imported during
the April 1 - 19 periods are not released immediately to the market
during this period, but are released to the market subsequent to April
20, and directly compete and distort the market for Mexican table grapes
that are subject to the requirements of the Marketing Order. Given the
inferior quality of grapes entering before the Marketing Order period,
they are able to be sold at much lower prices than the Mexican grapes.
They can also cause consumers to stop buying grapes, as a consumer who
purchased an inferior grape may not realize that better quality grapes
are available, and simply cease purchasing grapes.

For these reasons, we respectfully urge AMS to adopt and finalize this
proposed rule modifying the regulatory period for Marketing Order No.
925.

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height="1.1069444444444445in"}

**Respectfully submitted,**

**Carlos Vázquez**

**Minister for Agriculutral Affairs**

**Embassy of Mexico**

C.c.p. - Lloyd Day -- Administrator - AMS / USDA

Lic. Graciela Aguilar A. -- Directora en Jefe -- ASERCA

Lic. Adriana Herrera -- Coordinación de Estudios y Negociaciones
Internacionales - ASERCA