Analysis in Support of Certification that the Rule will not 

have a Significant Economic Impact on a Substantial 

Number of Small Entities

Proposed Rule

Importation of Fresh Unshu Oranges from Korea to the 

Continental United States, 7 CFR 319.28

10-022-1

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

April 2010
2

Summary

The Republic of Korea has requested USDA authorization to resume commercial 

shipments of fresh Unshu oranges into the continental United States. An administrative 

suspension of Korean imports of the fruit into the United States was imposed in 2002 

after interceptions of the causal agent of citrus canker. A systems approach would be 

used to mitigate pest risks. APHIS has determined that there would be a low risk of pest 

introduction into the United States under the proposed rule. 

The impact of Unshu orange imports from Korea is expected to be minimal for 

domestic producers. The United States does not commercially produce Unshu oranges, 

and price differences suggest that they are not a close substitute for U.S.-grown mandarin 

varieties, such as tangerines. Effects of the proposed rule in terms of product 

displacement may be borne by Japanese exporters, since Japan is currently the other 

major supplier of Unshu oranges to the United States.

Even if all Unshu orange imports from Korea were to directly replace a portion of

U.S.-grown tangerine consumption, the effect on U.S. producers would be still 

insignificant. Under such a scenario, annual imports of Unshu oranges from Korea of 

2,000 metric tons (the upper limit of the projected range of imports, which would well 

surpass the peak import volume of 1,611 metric tons recorded in 2002) would displace 

only 0.6 percent of fresh tangerines produced by U.S. operations in 2008-09. Even a 

small impact such as this for U.S. producers is highly unlikely.

The rule would not entail reporting, recordkeeping, or other compliance 

requirements beyond those set forth in existing regulations, such as in 7 CFR 319.56-6, 

which requires that all imported fruits or vegetables be subject to inspection at the port of 

first arrival. All costs associated with the proposed field pest control program, labeling, 

inspection and certification, and packinghouse procedures, would be incurred by the 

owner or the agent of the owner of the fruit prior to importation. 

Under these circumstances, the Administrator of the Animal and Plant Health 

Inspection Service has determined that this action will not have a significant economic 

impact on a substantial number of small entities.
3

Introduction

This analysis provides the basis, as required by the Regulatory Flexibility Act, for 

certification by the APHIS Administrator that the proposed rule, if promulgated, will not 

have a significant economic impact on a substantial number of small entities.

APHIS has received a request from the national plant protection organization 

(NPPO) of the Republic of Korea (South Korea) to allow the importation of Unshu 

oranges (Citrus reticulata Blanco var. unshu Swingle) from Cheju Island into the 

continental United States.1In 1994, APHIS approved the importation of Unshu oranges 

produced in Cheju Island into any area of the United States except several citrusproducing States. In 2002, the importation of Unshu oranges from Korea was suspended 

due to interceptions of citrus canker during pre-clearance inspections and subsequent 

detections of citrus canker at U.S. ports of entry.2 In 2007, in response to a request from

Korea, APHIS allowed the importation of Unshu oranges produced in Cheju Island to 

resume, but only to the State of Alaska.

3

 Currently, the regulations (7 CFR 319.28) allow 

the importation of Unshu oranges from certain areas in Japan and from Cheju Island in 

Korea into the United States under a permit and after the specified safeguards of a 

preclearance program are satisfied. 

In 2009, in response to Korea’s request to allow the importation of Unshu oranges 

from Cheju Island to the continental United States, APHIS developed a pest risk analysis

(PRA) using the previous PRA for imports into Alaska as a baseline for pest listing. The 

PRA incorporates new evidence that citrus canker bacteria (Xanthomonas citri subsp. 

citri) and sweet orange scab fungus (Elsinoë australis) are pests of quarantine 

significance associated with Unshu oranges.4 The two pests are rated as having a 

medium pest risk potential. Pests receiving a rating within the medium range may 

 

1

In this analysis, we refer to South Korea simply as Korea.

2 Citrus canker is a bacterial disease that affects citrus and is caused by the infectious bacterium 

Xanthomonas axonopodis pv. citri (also known as Xanthomonas campestris pv. citri and 

Xanthomonas citri). While not harmful to humans, the disease affects the health and marketability of 

infected fruit. http://www.aphis.usda.gov/plant_health/plant_pest_info/citruscanker/index.shtml.

3

Federal Register (FR 72, 60537-60541), Docket No. APHIS-2006-0133, Final Rule: Importation of fresh 

Unshu oranges from Korea to Alaska (7 CFR 319.28).

4

“Importation of Unshu Orange Fruit, Citrus reticulata that Blanco var. unshu Swingle, from Korea into 

the Continental United States, A qualitative, pathway-initiated risk analysis” December 23, 2009 Rev 003, 

USDA, APHIS, Center for Plant Health Science and Technology
4

require specific phytosanitary measures in addition to standard port-of-entry inspection. 

The PRA included a risk management document outlining the conditions under which 

Unshu oranges from Cheju Island could safely be imported into the continental United 

States and Alaska.

APHIS is proposing to include these conditions and requirements in § 319.28 for

the importation of Unshu oranges from Korea. APHIS is taking this action based on the 

determination that there is a low risk of introduction of citrus canker and sweet orange 

scab into the United States via imports of fresh Unshu oranges from Cheju Island, Korea. 

The proposed rule is consistent with World Trade Organization agreements that sanitary 

and phytosanitary regulatory restrictions should be based on scientific evidence and 

applied only to the extent necessary to protect human, animal, and plant health. 

Specifically, the proposed rule would amend the regulations concerning the 

importation of citrus fruit to remove certain requirements for the importation of Unshu 

oranges from Korea that are no longer necessary and make those regulations consistent 

with our domestic regulations for citrus canker. We propose to remove requirements for 

the fruit to be grown in specified canker-free export areas and for joint inspection in the 

groves and packinghouses by the Government of Korea and APHIS. We would also

clarify that surface sterilization of the fruit must be conducted using one of the approved 

phytosanitary treatments listed in 7 CFR part 305, and we would extend the area in the 

United States where Unshu oranges from Korea may be distributed to include the entire 

continental United States, as well as Alaska. Finally, we would require that each 

shipment be accompanied by a phytosanitary certificate containing an additional 

declaration stating that the fruit was given the required surface sterilization and inspected 

and found free of sweet orange scab.

Potential Impact on Small Entities

This proposed rule may affect domestic mandarin variety growers, especially 

those who engage in the production of tangerines, as well as the importers, wholesalers 

and distributors of mandarin varieties. The United States is not a commercial producer of 

Unshu oranges (Citrus reticulata var. unshu). The United States produces other 

mandarin varieties of Citrus reticulata, such as tangerines and Satsuma mandarins. 

Nonetheless, the action is expected to have minimal economic effect on U.S. entities, 
5

small or large, given the relatively small impact of current Unshu orange imports from 

Japan and Korea. Any increase in the quantity of Unshu oranges from Korea is expected 

to be insignificant. 

According to the Small Business Administration (SBA) standard, a business 

engaged in orange production is considered to be a small entity if its annual receipts are 

not more than $750,000.5 Table 1 summarizes 2007 Census of Agriculture data for 

tangerine growers, and table 2 summarizes 2007 Census of Agriculture data classified 

under “other-orange” growers which include all orange varieties other than Valencia 

oranges. “Other orange” varieties include: navels, tangerines, tangelos, temples, Satsuma

and other mandarin varieties. Of the “other orange” varieties, tangerines are considered 

to be most like Unshu oranges, although they are not close substitutes. 

In 2007, there were a total of 1,976 tangerine growers. By far, Florida and 

California are the two largest producers of tangerines, with tangerine growers in Florida 

and California accounting for 78 percent of the U.S. total and the tangerine acreage in

these two States accounting for 98 percent of the U.S. total. These percentages are 

similar for the 9,659 “other orange” growers overall, with growers in Florida and 

California accounting for 89 percent of the U.S. total and the Florida and California

acreage accounting for 98 percent of the U.S. total. Average annual sales per “other

orange” grower are estimated to have been about $102,347 in 2007.6 Clearly, “other

orange” growers are predominantly small entities according to the SBA standard of 

$750,000.

Table 1. Number of tangerine growers and acres, by State, 2007

State

Number of Tangerine Growers 

and Percentage Share of U.S. 

Total

Tangerine Acres and Percentage 

Share of U.S. Total

Florida 839 (42%) 14,604 (39.5%)

California 706 (36%) 21,528 (58.2%)

Hawaii 300 (15%) 87 (0.2%)

 

5

 U.S. Small Business Administration, Table of Small Business Size Standards. 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf

6 Average sales per entity is based on the number of non-Valencia orange growers recorded in the 2007 

Agricultural Census, i.e., 9,659 operations, and the total value of fresh and processed non-Valencia oranges 

reported in the 2009 USDA-NASS Citrus fruits 2009 Summary, i.e., $1.2 billion. 

http://usda.mannlib.cornell.edu/usda/current/CitrFrui/CitrFrui-09-24-2009.pdf
6

State

Number of Tangerine Growers 

and Percentage Share of U.S. 

Total

Tangerine Acres and Percentage 

Share of U.S. Total

Texas 59 (3%) 174 (0.5%)

Arizona 36 (2%) 544 (1.5%)

Louisiana 36 (2%) 28 (<0.1%)

United States 1,976 (100%) 36,965 (100%)

Source: USDA NASS, 2007 Census of Agriculture, Table 32, Fruits and nuts.

Table 2. Number of non-Valencia (“other orange”) growers and acres, by State. 2007

State Number of non-Valencia (“Other 

Orange”) Growers and Percentage 

Share of U.S. Total

Non-Valencia (“Other Orange”) 

Acres and Percentage Share of 

U.S. total

Florida 4,575 (47%) 264,751 (61.3%)

California 4,052 (42%) 158,263 (36.7%)

Hawaii 407 (4%) 186 (0.4%)

Texas 384 (4%) 6,141 (1.4%)

Arizona 118 (1%) 1,718 (0.4%)

Louisiana 116 (1%) 503 (0.1%)

Alabama 7 (<0.1%) 6 (<0.1%)

United States 9,659 (100%) 431,568 (100%)

Source: USDA NASS, 2007 Census of Agriculture, Table 32, Fruits and nuts.

Table 3 shows the percentages of tangerine growers and tangerine acreage relative 

to the total number of “other orange” growers and acreage in 2007. In Florida and 

California, the two dominant tangerine-producing States, tangerine growers comprised 17 

to 18 percent of “other orange” operations. However, the tangerine acreage in Florida 

was much smaller than in California, i.e., 5.5 percent compared to 13.6 percent, 

indicating smaller operations in Florida, on average. The number of tangerine growers 

and the total tangerine acreage in Hawaii comprised large shares of that State’s “other 

orange” operations and acreage, 73.7 percent and 46.8 percent respectively.

Table 3. Tangerine growers and acres as percentages of non-Valencia (“other orange”) 

growers and acres, by State, 2007

State Percentage of Tangerine Growers Percentage of Tangerine Acres

Florida 18.3% 5.5%
7

State Percentage of Tangerine Growers Percentage of Tangerine Acres

California 17.4% 13.6%

Hawaii 73.7% 46.8%

Texas 15.4% 2.8%

Arizona 30.5% 31.7%

Louisiana 31.0% 5.6%

Alabama 0.0% 0.0%

United States 20.5% 8.6%

Source: USDA NASS, 2007Census of Agriculture.

Table 4 summarizes 2007 Census of Agriculture data for “other orange” growers

by acreage. According to the data, 16 percent of growers had less than 1 acre of “other 

orange” varieties, and the vast majority of growers, 93 percent, had less than 100 acres of 

“other orange” varieties.

Table 4. Size distribution of non-Valencia (“other orange”) operations, by number of farms 

and acreage, 2007

Acres

Number 

of farms 

Percentage 

share

Cumulative 

percentage Acres 

Percentage 

share 

Cumulative 

percentage 

0.1 to 0.9 acres 1,540 16% 16% 463 0% 0%

1.0 to 4.9 acres 2,378 25% 41% 5,575 1% 1%

5.0 to 14.9 acres 2,391 25% 65% 20,056 5% 6%

15.0 to 24.9 acres 987 10% 76% 18,618 4% 10%

25.0 to 49.9 acres 1,038 11% 86% 36,111 8% 19%

50.0 to 99.9 acres 620 6% 93% 42,829 10% 29%

100.0 to 249.9 acres 422 4% 97% 63,930 15% 43%

250.0 to 499.9 acres 153 2% 99% 50,699 12% 55%

500.0 to 749.9 acres 50 1% 99% 29,718 7% 62%

750.0 to 999.9 acres 26 0% 99% 22,400 5% 67%

1,000.0 to 1,499.9 

acres 23 0% 100% 27,322 6% 74%

1,500.0 acres or more 31 0% 100% 113,847 26% 100%

United States 9,659 100% 431,568 100%

Source: USDA NASS, 2007 Census of Agriculture, Table 35, Specified fruits and nuts by acres.
8

Tables 5 and 6 summarize data on certain categories of tangerine growers

enumerated in the 2007 Census of Agriculture. These categories are small family farms, 

limited resource farms, and farms having operators who belong to socially disadvantaged 

groups.7 A tangerine grower may qualify as a small family farm (or as a limited resource 

farm) and also be counted among those for which one or more of the operators belong to 

a socially disadvantaged group.

Table 5 shows that among the 1,976 farms that grew tangerines, 1,415 (over 70

percent) were limited resource or small family farms. It is notable that the combined 

number of retirement farms (399 farms) and residential/lifestyle farms (527 farms) 

accounted for almost half of all tangerine farms.

Table 5. Number and percentage of limited resource and small family tangerine farms, 2007

Limited 

resource 

farms

Retirement 

farms

Residential/ 

lifestyle 

farms

Farming 

occupation/ 

lower sales

Farming 

occupation/ 

higher sales

All 

small 

family 

farms

Limited 

resource 

farms plus 

small family 

farms

All tangerine 

Farms

US 192 399 527 221 76 1,223 1,415 1,976

Percentage 

in total 

tangerine 

growers

10% 20% 27% 11% 4% 62% 72% 100%

Source: USDA NASS, 2007 Census of Agriculture.

 

7

USDA ERS. Structure and Finances of U.S. Family Farms: Family Farm Report, 2007 edition, EIB-24.

Any farm where the operator and persons related to the operator own a majority of the business is 

considered a family farm. Small family farms have annual gross sales of less than $250,000. This category 

of farms is further divided into retirement farms (operators reporting they are retired), residential/ lifestyle 

farms (operators reporting a major occupation other than farming), and farming-occupation farms 

(operators reporting farming as their major occupation). Farming-occupation farms are further classified as 

low-sales small family farms (gross sales less than $100,000) and high-sales small family farms (gross 

sales between $100,000 and $249,999).

Limited resource farms have (a) direct or indirect gross farm sales of not more than $100,000 and (b) a total 

household income at or below the national poverty level for a family of four, or less than 50 percent of 

county median household income. By definition, limited resource farms qualify as small family farms, but 

they are identified as a separate category in the 2007 Census of Agriculture and are excluded from the 

enumeration of small family farms.

Socially disadvantaged operators are members of groups that historically have been subjected to bias and 

prejudice. The categories are women; persons of Spanish, Hispanic, or Latino origin; American Indian or 

Alaska Native; Asian; Black or African American; and Native Hawaiian or other Pacific Islander. These 

farm operators, themselves, may not have experienced bias or prejudice, but identify with one or more of 

these gender, ethnic, and racial groups.
9

Table 6 shows the number and percentage of tangerine farms having operators

belonging to socially disadvantaged groups. There were 321 tangerine farms (16 percent)

for which the principal operator was a woman. In terms of ethnicity, 178 tangerine farms

(9 percent) were operated by Hispanics and 185 tangerine farms (9 percent) were 

operated by Asians. One percent of tangerine farms were operated by African 

Americans.

Table 6. Number and percentage of tangerine farms with operators belonging to socially 

disadvantaged group, 2007

Farms where 

the principal 

operator is 

female

Farms where 

an operator 

is of 

Spanish, 

Hispanic, or 

Latino origin

Farms where 

an operator 

reports race 

as American 

Indian or 

Alaska 

Native

Farms where 

an operator 

reports race 

as Asian

Farms where 

an operator 

reports race 

as Black or 

African

American

Farms where 

an operator 

reports race 

as Native 

Hawaiian or 

Other Pacific 

Islander

All 

Tangerine 

Farms

Number of 

farms 321 178 59 185 19 58 1,976

Percentage 

in total 

tangerine 

farms

16% 9% 3% 9% 1% 3% 100%

Source: USDA NASS, 2007 Census of Agriculture.

Although most tangerine operations are small family farms and significant

percentages of tangerine farm operators belong to socially disadvantaged groups, 

economic effects of the rule for these farms are not expected to differ from the effects for 

tangerine growers generally. We do not expect the proposed rule to have any appreciable 

impact on U.S. tangerine growers regardless of the size of operation or operator 

classification. 

In the case of fresh fruit merchant wholesalers (NAICS 424480), establishments 

with no more than 100 employees are considered small by the SBA standard. In 2002, 

there were 5,376 fresh fruit and vegetable merchant wholesalers in the United States with 

a total of 110,578 paid employees, or on average, 21 paid employees per establishment. 

It is likely that domestic fruit merchant wholesalers that may be affected by the rule are 

predominantly, if not entirely, small entities.

Prior to the administrative suspension in 2002, Korea and Japan were principal 

suppliers of Unshu oranges to the United States. Quantities of Unshu oranges imported 
10

from Korea and Japan, 1995 to 2009, are shown in table 7. Unshu orange imports from 

Japan between 1995 and 2009 averaged 206 metric tons per year.8 Average imports of 

Unshu oranges from Korea between 1995 and 2002 were 646 metric tons per year, with 

significant year-to-year fluctuations. The average for 2001 and 2002 jumped to 1,611

metric tons. Imports from Korea became marginal after 2002. Imports of Unshu oranges 

from Japan have been also declining, even in the recent years during which Unshu 

oranges from Korea have been prohibited.

According to the PRA which was prepared in 2006 to allow the importation of 

Unshu oranges from Cheju Island to Alaska, the quantity of Unshu oranges that would be 

imported was estimated to be between 200 and 2,000 metric tons (440,925 and 4,409,245 

pounds).

9

 The actual volumes exported from Korea during 2007-2009 were much less 

than the original prediction. The historical import data suggest that Korea’s supply of 

Unshu oranges to the United States would not be significant under the proposed rule and

would have little effect on U.S. producers of mandarin varieties such as tangerine and 

Satsuma. This expectation is strengthened by the fact that the various mandarin varieties 

grown in the United States do not appear to be close substitutes for Unshu oranges.

Table 7. Unshu orange exports to the United States from Korea and 

Japan, 1995-2009

Calendar year Korea Japan Total

metric tons

1995 50 231 281

1996 214 160 374

1997 1,183 143 1326

1998 31 224 255

1999 377 342 719

2000 242 106 348

2001 1,461 291 1752

2002 1,611 - 1,611

2003 - 275 285

2004 - 272 282

2005 - 256 265

 

8 This average does not include 2002, since it is likely that Japan would have exported Unshu oranges to 

the United States in that year had the United States not required fumigation for all of Japan. 

9 USDA APHIS PPQ CHPST, “A Qualitative Pest Risk Analysis for the Importation of Fresh Unshu 

Orange Fruit (Citrus reticulate Blanco var. unshu Swingle) from the Republic of Korea,” May 25, 2006, pg 

33.
11

Calendar year Korea Japan Total

2006 - 156 165

2007 10 218 228

2008 39 109 148

2009 10 103 113

Source: Global Trade Atlas; HTS 080520, Mandarins (including tangerines and Satsumas); 

clementines, wilkings and similar citrus hybrids.

Note 1: The export data reported by Korea and Japan differ from the import data compiled by the U.S. 

Department of Commerce.

Note 2: Prior to 2002, Unshu oranges imported from Japan did not require fumigation. Imports were

allowed from certain areas in Japan, but not from Kyushu. In 2002, the United States allowed 

importation of Unshu oranges also from Kyushu, but required fumigation of all imports from Japan. 

That year, Japan did not export Unshu oranges to the United States. In 2003, the U.S. regulations were 

amended to only require fumigation of Unshu oranges imported from Kyushu.

U.S. tangerine production, imports, exports and domestic consumption are shown 

in table 8. Except 1995/1996, the United States was a net importer of mandarins 

(including Satsumas and tangerines). Imports were below 20 percent of supply in the

1990’s (table 9). During the past ten years, except for the 2001/2002 season, imports 

increased to the range of 20 to 30 percent of supply. Exports have been relatively stable 

since 1995/1996, at around 4 to 8 percent of total utilization.

Between 1995-1996 and 2008-2009, domestic fresh tangerine production 

increased by 16 percent, while imports increased more than five-fold. The level of 

supply were relatively stable at around 380,000 tons between 2000/01 and 2007/08, but 

showed a sharp increase in 2007/08 to 458,402 tons. The United States has become more 

dependent on imports of mandarin varieties to supplement increased demand. U.S. 

grower revenue from fresh tangerine and other mandarin variety production in 2006-07

was $141 million.10

 

Table 8. U.S. fresh tangerineasupply and utilization, 1995/96 through 2008/09 (excludes

processed fruit)

Supply Utilization

Seasonb U.S. Domestic 

Production Imports Total Export U.S. Domestic Consumption

metric tons (‘000)

1995/1996 293 20 312 22 290

1996/97 299 35 335 23 312

 

10 USDA NASS, “Citrus fruits final estimates 2003-2007 – December 2008”.

http://usda.mannlib.cornell.edu/usda/nass/SB997/sb1009.pdf
12

Supply Utilization

Seasonb U.S. Domestic 

Production Imports Total Export U.S. Domestic Consumption

1997/98 258 39 296 25 271

1998/99 249 57 306 14 291

1999/2000 298 96 395 28 367

2000/01 267 100 367 14 352

2001/02 297 53 349 15 334

2002/03 289 86 376 17 359

2003/04 296 92 388 20 368

2004/05 258 97 355 20 335

2005/06 282 103 385 21 364

2006/07 245 122 367 16 350

2007/08 361 97 458 32 427

2008/09c338 129 467 29 438

Source: USDA ERS Briefing Room, Fruit and Tree Nut Yearbook, 2009.

a

Includes all tangerine varieties, such as Fallglo, Sunburst, Honey, clementine, mandarin, and Satsuma.

b

Season begins in October of first year shown. 

c

Preliminary.

Table 9. U.S. fresh tangerineaproduction and imports as percent of supply, and exports

and consumption as percent of utilization, seasons 1995/96 through 2008/09 (excludes 

processed fruit)

SeasonbProduction Imports Exports Consumption

1995/1996 94% 6% 7% 93%

1996/97 89% 11% 7% 93%

1997/98 87% 13% 8% 92%

1998/99 81% 19% 5% 95%

1999/2000 76% 24% 7% 93%

2000/01 73% 27% 4% 96%

2001/02 85% 15% 4% 96%

2002/03 77% 23% 5% 95%

2003/04 76% 24% 5% 95%

2004/05 73% 27% 5% 95%

2005/06 73% 27% 5% 95%

2006/07 67% 33% 4% 96%

2007/08 79% 21% 7% 93%

2008/09c72% 28% 6% 94%

Source: USDA ERS Briefing Room, Fruit and Tree Nut Yearbook, 2009.

a

Includes all tangerine varieties, such as Fallglo, Sunburst, Honey, clementine, mandarin, and Satsuma.

b

Season begins in October of first year shown. 

c

Preliminary.

As shown in table 7, Korea’s Unshu orange exports to the United States peaked in 

2002, with a total volume of 1,611 metric tons. This quantity was 2 percent (3 percent)
13

of total U.S. tangerine imports in the 2001/02 (2002/03) season (table 8). Between the 

2002/03 and 2008-09 seasons, U.S. imports of mandarin oranges increased by 42,504 

tons, or 49 percent. However, imports from Korea failed to increase even after the import 

prohibition was lifted in 2007 to allow imports into Alaska.

Table 10 shows the value of recent U.S. imports of mandarin varieties. In 2009,

U.S. imports were valued at $156 million, of which approximately 46 percent was 

supplied by Spain ($72 million). The second and third largest exporters were Chile ($29 

million) and Morocco ($23 million), with a combined share of 33 percent. These three 

countries supplied almost 80 percent of U.S. imports of mandarin varieties in 2009. 

Japan, which supplied the majority of Unshu oranges to the United States, had a share of

only 0.1 percent.

Table 10. U.S. imports of mandarin varieties by partner country, 2007-2009 (HTS: 

080520, Mandarins (including tangerines and Satsumas); clementines, wilkings and 

similar citrus hybrids, fresh/dried)

Partner Country 2007 2008 2009 2009 % 

Share

million dollars

World $159.7 $157.6 $156.1 100.0%

Spain 100.5 87.9 72.4 46.4%

Chile 13.5 17.4 28.9 18.5%

Morocco 14.4 26.1 23.0 14.7%

Peru 11.8 8.6 11.4 7.3%

Australia 8.6 6.3 7.5 4.8%

South Africa 6.2 6.0 7.1 4.5%

Mexico 3.0 3.8 2.9 1.9%

Israel 0.3 0.7 1.9 1.2%

Jamaica 0.4 0.2 0.4 0.3%

Dominican Republic 0.0 0.2 0.2 0.1%

Japan 0.3 0.1 0.1 0.1%

China - - 0.1 0.1%

Italy 0.1 0.3 0.0 0.0%

Switzerland - - 0.0 0.0%

Source: Global Trade Atlas.
14

Table 11 shows yearly domestic production of Unshu oranges in Korea. Cheju 

Island is the primary production area for Unshu oranges and other mandarin varieties. 

Production capacity is constrained by the limited availability of cultivable land on the 

island. Harvest time for Korean Unshu oranges is from early September to early 

December, and the period of exports lasts about 40 days, from November 1 to December 

10. Korea’s average production for the last 10 years was 637,451 metric tons.

Table 11. Production of Unshu oranges in Korea, 2000-2009, metric tons

Year Production

metric tons (‘000)

2000 553

2001 635

2002 776

2003 631

2004 574

2005 638

2006 604

2007 718

2008 561

2009 686

Average 637

Source: National Agricultural Cooperative Federation/Jeju Regional HQ/Orange Team.

Table 12 summarizes Korean mandarin variety exports for 2001-2009. Russia 

and Canada are by far the largest importers. In 2009, Russia imported 1,475 tons (53

percent of Korea’s mandarin variety exports) and Canada imported 878 tons (30 percent). 

The U.S. share was less than 0.4 percent in 2009, although it was Korea’s third largest

customer in 2002 and second largest in 2001.

Table 12. Korea’s mandarin variety exports, 2001-2009 (HTS: 080520, Mandarins (including 

tangerines and Satsumas); clementines, wilkings and similar citrus hybrids, fresh/dried)

Calendar year 2001 2002 2003 2004 2005 2006 2007 2008 2009

Partner country Metric tons

World 5,038 8,938 8,405 5,722 3,600 2,913 3,399 2,536 2,783

Russia 476 1,777 2,342 364 266 1,351 2,584 1,785 1,475

Canada 125 4,811 5,089 4,223 2,493 705 389 465 828

Indonesia 60 49 146 224 70 182 116 13 96
15

Calendar year 2001 2002 2003 2004 2005 2006 2007 2008 2009

China 11 - 516 4 - - - - 66

Singapore 111 33 0 111 9 141 67 45 55

Guam 33 46 36 172 83 75 58 62 51

Hong Kong 15 7 11 38 79 54 5 25 44

Mongolia - - 42 - 9 - - 66 40

Malaysia 94 171 - 147 112 80 43 - 24

Taiwan - 68 21 17 - 3 20 8 20

United Kingdom - - - - - - - 3 19

Japan 2,619 358 189 390 326 285 93 13 15

Vietnam 9 - - - 0 18 9 - 13

United States 1,461 1,611 - - - - 10 39 10

Northern Mariana Islands 3 6 4 22 17 11 6 7 9

United Arab Emirates - - - - - - - 6 8

Thailand - - - - - - - - 7

Guatemala - - - - - - - - 3

Kazakhstan - - - - - - - - 0

Philippines 12 - - - 127 - - - -

Sri Lanka 1 - - - - - - - -

Unidentified Country 8 - - - - - - - -

Source: Global Trade Atlas.

Note: Data as reported by the Republic of Korea.

Table 13 compares Korean production and exports of mandarin varieties. On 

average, only 0.7 percent of domestic production was exported. From 2005 to 2009, the 

export percentages averaged 0.5 percent.

Table 13. Korea’s mandarin variety production and exports, 2000-2009

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 Average

Metric tons

Production 552,724 634,892 775,633 631,242 573,939 637,696 603,737 718,129 560,616 685,901 637,451

Exports 2,572 5,038 8,938 8,405 5,722 3,600 2,913 3,399 2,536 2,783 4,590

Exports as a 

percentage of 

production

0.5% 0.8% 1.2% 1.3% 1.0% 0.6% 0.5% 0.5% 0.5% 0.4% 0.7%

Sources: National Agricultural Cooperative Federation/Jeju Regional HQ/Orange Team, Global Trade Atlas.

Table 14 shows the value, volume and unit price of Korea’s exports of mandarin

varieties. The total export values for 2007-2009 ranged between $2 million and $3 

million, and the average unit price ranged between $0.78/KG and $1.09/KG during this 

period. The value of exports to the United States was merely $13,000 in 2009, and the 

unit price was $1.30/KG.
16

Table 14. Value, volume and unit price of Korea’s exports of mandarin varieties, 2007-2009 

(HTS: 080520, Mandarins (including tangerines and Satsumas); clementines, wilkings and 

similar citrus hybrids, fresh/dried)

Calendar year 2007 2008 2009

Partner 

Country

US$ 

('000)

Quantity 

(MT)

Unit 

Price 

/KG

US$ 

('000)

Quantity 

(MT)

Unit 

Price 

/KG

US$ 

('000)

Quantity 

(MT)

Unit 

Price 

/KG

% share 

in total 

quantity

World 2,998 3,399 0.88 1,972 2,536 0.78 3,023 2,783 1.09 100.0%

Russia 1,736 2,584 0.67 1,085 1,785 0.61 1,383 1,475 0.94 53.0%

Canada 624 389 1.61 477 465 1.03 964 828 1.16 29.7%

Guam 149 58 2.56 91 62 1.47 117 51 2.31 1.8%

Indonesia 155 116 1.34 17 13 1.29 116 96 1.21 3.5%

Japan 133 93 1.42 98 13 7.65 98 15 6.65 0.5%

Singapore 88 67 1.32 55 45 1.23 77 55 1.39 2.0%

Hong Kong 9 5 1.68 34 25 1.36 53 44 1.19 1.6%

China - - - - - - 52 66 0.79 2.4%

Mongolia - - - 36 66 0.54 35 40 0.87 1.4%

Taiwan 23 20 1.11 10 8 1.35 31 20 1.57 0.7%

Malaysia 50 43 1.18 - - - 27 24 1.11 0.9%

Northern 

Mariana 

Islands

8 6 1.47 9 7 1.32 13 9 1.50 0.3%

United States 13 10 1.31 38 39 0.98 13 10 1.30 0.4%

United 

Kingdom - - - 15 3 5.93 12 19 0.65 0.7%

United Arab 

Emirates - - - 8 6 1.22 12 8 1.48 0.3%

Thailand - - - - - - 8 7 1.18 0.3%

Vietnam 11 9 1.30 - - - 8 13 0.63 0.5%

Guatemala - - - - - - 4 3 1.24 0.1%

Kazakhstan - - - - - - 0 0 1.00 0.0%

Source: Global Trade Atlas.

Note: Data as reported by the Republic of Korea.

For comparison, Table 15 shows the value, volume and unit price of U.S. exports 

of mandarin varieties. Total export values for 2007-2009 ranged between $21 million 

and $40 million, and the average unit price ranged between $1.22/KG and $1.34/KG 

during this period. The value of exports to Korea in 2008 and 2009 was $760,000 and

$162,000, respectively, with unit prices of $1.04/KG and $0.98/KG.
17

Table 15. Value, volume and unit price of U.S. exports of mandarin varieties, 2007-2009 (HTS: 

080520, Mandarins (including tangerines and Satsumas); clementines, wilkings and similar citrus 

hybrids, fresh/dried)

Calendar year 2007 2008 2009

Partner 

country

US$ 

('000)

Quantity 

(MT)

Unit 

Price

US$ 

('000)

Quantity 

(MT)

Unit 

Price

US$ 

('000)

Quantity 

(MT)

Unit 

Price

% Share 

total 

quantity

World 21,032 17,234 1.22 39,381 30,810 1.28 40,214 30,112 1.34 100%

Canada 16,789 13,870 1.21 24,793 18,850 1.32 27,306 18,446 1.48 61.3%

Japan 2,156 1,791 1.20 5,836 4,442 1.31 7,014 6,778 1.03 22.5%

Australia 1,147 682 1.68 3,137 1,996 1.57 2,835 2,027 1.4 6.7%

Netherlands - - - 2,614 2,726 0.96 1,033 1,128 0.92 3.7%

New Zealand 428 415 1.03 964 785 1.23 668 474 1.41 1.6%

Barbados 203 169 1.21 74 75 0.98 311 258 1.2 0.9%

Korea - - - 760 732 1.04 162 166 0.98 0.6%

Mexico 43 62 0.70 250 340 0.74 150 193 0.78 0.6%

Russia - - - 19 13 1.44 144 182 0.8 0.6%

United 

Kingdom 45 49 0.91 324 299 1.08 82 79 1.03 0.3%

Source: Global Trade Atlas.

Note: Data as reported by the United States Department of Commerce.

If Unshu oranges and U.S.-grown mandarin varieties were close substitutes, then 

U.S. entities could be affected to the extent that Unshu orange imports from Korea would 

displace sales of the U.S.-grown mandarin varieties. Small entities would be affected, 

since they comprise a substantial number of the producers of mandarin varieties. 

However, even if all Unshu orange imports from Korea were to directly replace a portion 

of U.S.-grown tangerine consumption, the effect on U.S. producers would be very small. 

Under such a scenario, annual imports of Unshu oranges from Korea of 2,000 metric tons 

(the upper limit of the projected range of imports, which would well surpass the peak 

import volume of 1,611 tons recorded in 2002) would displace only 0.6 percent of fresh 

tangerines produced by U.S. operations in 2008-09. We emphasize that even a small 

impact such as this for U.S. producers is highly unlikely.

We expect that any product displacement that may occur because of the proposed 

rule would be borne by other foreign suppliers of Unshu oranges, in particular, Japan’s 

exporters. However, we do not expect any significant product displacement as a result of 

Korean supplies. Consumers may benefit, to the extent that the competition results in 

price declines and increased availability of Unshu oranges. We welcome public 
18

comment that would improve our understanding of possible effects of the proposed rule 

for U.S. small entities.

An alternative to this proposed rule would be to continue with the 2002 

administrative suspension of the importation of Unshu oranges from Korea into all parts 

of the United States except Alaska. Continuing the suspension of Korean Unshu orange 

imports into the continental United States is not a satisfactory alternative to the proposed 

rule. The proposed rule’s specified mitigation measures would ensure a low risk of 

introduction of citrus canker and sweet orange scab into the United States. Resumption 

of imports would reestablish import competition with Japanese suppliers, benefiting U.S. 

consumers but with little if any expected effect for U.S. producers.

The rule would not entail reporting, recordkeeping, or other compliance 

requirements beyond those set forth in existing regulations, such as in 7 CFR 319.56-6, 

which requires that all imported fruits or vegetables be subject to inspection at the port of 

first arrival. All costs associated with the proposed field pest control program, labeling, 

inspection and certification, and packinghouse procedures, would be incurred by the 

owner or the agent of the owner of the fruit prior to importation.

Under these circumstances, the Administrator of the Animal and Plant Health 

Inspection Service has determined that this action will not have a significant economic 

impact on a substantial number of small entities.