How to import a custom action group from a file

It looks to me as though you simply add the contents of COMMENT to GENRE
For that procedure, there is even a post in the FAQs:

In your case, I would create an action group with 3 actions:

  1. Format tag field for GENRE
    Format string: %genre%\\%comment%
  2. Merge duplicat tag fields for GENRE
    Separator: ;
  3. Replace for GENRE
    Search: &
    Replace with: ;

That should lead to the same result as your list. No ELSE required.