United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Risk Management Document

Importation of Apples (Malus pumila) from China into the 

continental United States

January 15, 2015

Plant Health Programs (PHP)

Regulations, Permits and Manuals (RPM)

Contact Person: David B. Lamb
This document describes the risk management measures for the importation of fresh apple fruit, 

Malus pumila Mill., from China into the continental United States. A qualitative, pathwayinitiated pest risk assessment (PRA), “Importation of Apples (Malus pumila) from China into the 

continental United States” (USDA, 2013a) was developed in support of a request from China to 

export apples into the continental United States. The PRA was prepared based on pest 

interception data, the scientific literature, and information provided by the Government of China.

Entry of apples from China into the United States presents a risk of introduction of exotic plant 

pests. The PRA reported 21 (19 arthropods and 2 fungi) quarantine pests that may follow the 

pathway of commercial shipments of apples from China into the continental United States. 

The PRA determined that the following pests are candidates for risk management, because they

met the threshold to likely cause unacceptable consequences of introduction, and they

received an overall likelihood of introduction risk rating above Negligible:

Pest type Taxonomy Scientific name Likelihood of Introduction 

overall rating

Arthropod Acari: Tenuipalpidae Cenopalpus pulcher (Canestrini 

& Fanzago)

Medium

Coleoptera: Curculionidae Rhynchites auratus (Scopoli) Medium

Rhynchites bacchus (L.) Medium

Rhynchites giganteus Krynicky Medium

Rhynchites heros Roelofs Medium

Diptera: Tephritidae Bactrocera dorsalis (Hendel) High

Lepidoptera: Carposinidae Carposina sasakii Matsumura Medium

Lepidoptera: Lyonetiidae Leucoptera malifoliella (Costa) High

Lepidoptera: Pyralidae Cryptoblabes gnidiella 

(Millière)

Medium

Euzophera bigella (Zeller) Medium

Euzophera pyriella Yang Medium

Lepidoptera: Tortricidae Adoxophyes orana (Fischer von 

Röslerstamm)

Medium

Archips micaceana (Walker) Medium

Argyrotaenia ljungiana

(Thunberg)

Medium

Cydia funebrana (Treitschke) Medium

Grapholita inopinata Heinrich Medium

Spilonota albicana

(Motschulsky)

Medium

Spilonota prognathana Snellen Medium

Ulodemis trigrapha Meyrick Medium

Fungi Ascomycetes: Helotiales Monilia polystroma van 

Leeuwen

High

Monilinia fructigena Honey High

The PRA identified these pests as candidates for risk management and rated them Medium or 

High for probability of introduction. Low rated pests normally only require standard port–of-
entry inspection as a mitigation. Pests rated Medium and High for probability of introduction 

that have been identified in the PRA as candidates for risk management may require mitigations 

beyond standard port-of-entry inspection based on the biology of the pests.

Risk Management Measures:

APHIS proposes that fresh apples from China may be imported into the United States under the 

following systems approach:

1. An operational workplan detailing the systems approach will be developed by AQSIQ, the 

national plant protection organization (NPPO) of China subject to approval by APHIS. All 

oversight of the program will be done by AQSIQ or their designate. AQSIQ is expected to 

maintain program records for at least one year and provide them to APHIS upon request. 

APHIS reserves the right to require APHIS oversight visits in the event of pest interceptions 

or other problems.

2. Commercial consignments only may be exported.

3. Apples must be grown at production sites (orchards) registered with AQSIQ. The 

growers with registered production sites will be responsible for following the phytosanitary

measures agreed upon by APHIS and AQSIQ, including applying control measures that are 

authorized for use in China and the United States of America to reduce pest populations.

4. AQSIQ is responsible for ensuring that registered places of production are inspected 

every season in accordance with the workplan, with special emphasis on the control of 

quarantine pests listed above.

5. All apples must be bagged individually by the time they reach 2.5 cm in diameter.

6. Fallen fruit must be removed from orchards weekly.

7. Packinghouses must be registered with AQSIQ and must have a system of box markings 

allowing traceback to registered production sites.

8. Packinghouses must have a system of quality control of fruit, including culling to remove 

all leaves and any damaged or infested fruit.

9. All apples must undergo washing and brushing or air blasting.
10. AQSIQ must inspect a biometric sample of the packed-out apples for pests and disease. 

The sample size for this inspection will be specified in the workplan.

11. AQSIQ must issue a Phytosanitary Certificate indicating that the consignment produced 

in accordance with the workplan, was inspected and found free of pests of quarantine 

concern.

12. An APHIS approved treatment is required for fruit produced south of 33rd parallel, to 

mitigate Bactrocera dorsalis fruit flies. Currently the only APHIS approved treatment for 

Bactrocera dorsalis in apples is T108-a fumigation plus refrigeration of fruits, but any other 

treatment subsequently approved by APHIS may be used.

13. Upon detection of Monilinia fructigena or Monilia polystroma in a consignment for 

export, APHIS will reject the infected consignment and may reject the production site for 

importation to the United States for the remainder of that season. If Monilinia fructigena or 

Monilia polystroma are detected in a shipment from more than one registered production site

in a Province, APHIS may prohibit the importation into the United States of apples from the 

Province until an investigation is conducted and APHIS and AQSIQ agree that appropriate 

remedial actions have been taken. Procedures for disqualification of production sites based 

on pest detections in export consignments will be detailed in the workplan approved by 

APHIS and AQSIQ. 

14. The exportation to the United States of apples from the rejected production site may

resume in the next growing season if an investigation is conducted and APHIS and AQSIQ

agree that appropriate remedial actions have been taken.

15. The fruit will be inspected by U.S. Customs and Border Protection at the first U.S. port 

of entry for pests and disease. 

Efficacy of Risk Management Measures:

All production sites will have to be registered with AQSIQ , the NPPO of China. This will also 

ensure that only commercially produced fruit will be imported. Commercially produced fruit 

undergoes standard commercial practices which for apples include washing, brushing, air 

blasting and culling, which remove infested or damaged fruit from the pathway. APHIS pest 

interception data indicate that commercially produced fruit are far less likely than ‘dooryard’ 

fruit to carry pests. Washing, brushing and air blasting also remove surface pests such as scale 

insects, thrips and mites. The required operational workplan will ensure that AQSIQ will 

provide oversight to the production sites so that bagging of fruit will be applied consistently to 

all fruit. AQSIQ will also monitor the production sites at least twice per season so that effective 

control of quarantine pests will be maintained. The packinghouses must also maintain traceback 

through box markings, so that any problem consignments can be traced back to the production 

sites and remedial action may be taken. AQSIQ monitoring of pest populations will determine 
the need and timing of field controls and insure effective control of pests (Lewis, 1981). The 

operational details for monitoring and application of controls in the orchards, if needed, will be 

detailed in the workplan. 

Of the 21 quarantine pests listed in the PRA (USDA, 2013a), 19 are arthropods, of which 8 are 

Lepidoptera and 4 are weevils (Curculionidae). The required bagging of the individual fruit at 

2.5 cm in diameter will prevent these Lepidoptera and Coleoptera pests from infesting the apples. 

China has imported certain pear species using bagging as a mitigation for Lepidoptera since 

1998. In 15 years of importation there have been only 15 interceptions of Lepidoptera and 0 

interceptions of Curculionidae indicating that bagging is an effective mitigation for these pests 

(AQAS, 2013). In addition to the bagging, APHIS requires packing house culling and an 

inspection of apples by AQSIQ. Lepidoptera pests of apples leave obvious feeding damage, 

holes and frass in the fruit. Standard industry packinghouse procedures as culling and a 

phytosanitary inspection will remove these visible pests from the pathway. If pests are found 

upon port-of-entry inspection, traceback will allow removal of problem production sites from the 

program. The pear leaf miner, Leucoptera malifoliella, was intercepted in significant numbers 

in apples imported from France in 1985 (AQAS, 2013). This led to restrictions on imports of 

apples and the previous requirement for pre-clearance. The current systems approach will 

require removal of all leaves, packinghouse culling and packinghouse inspections, which 

together will effectively remove this leaf miner from the pathway of fresh fruit.

Currently the only APHIS approved treatment for Bactrocera dorsalis in apples is T108-a,

fumigation plus refrigeration of fruits, but any other treatment subsequently approved by APHIS 

may be used. Cold treatment T-108-a is an approved APHIS treatment for Bactrocera dorsalis

(USDA, 2013b). This fumigation plus cold treatment has been used for many years on different 

fruit/country combinations and will ensure the mortality of all Bactrocera dorsalis larvae.

Monilinia fructigena is the most common cause of fruit rot in fruit orchards, causing 

characteristic brown rot symptoms with conidial pustules often in concentric circles (CABI, 

2013). Field inspections, packinghouse inspections, and the Phytosanitary Certificate stating 

disease freedom are considered sufficient mitigation measures for the fungal diseases. 

Field sanitation of removing fallen fruit is required under this systems approach, and this will 

remove fruit from the field which would otherwise provide host material for pests of concern. 

Culling at the packing house is a standard industry practice which removes all obviously

blemished, diseased and insect-infested fruits from the pathway. Registration of places of 

production and packinghouses will allow trace back and auditing. Any problem places of 

production and packinghouses can be removed from the export program unless they comply with 

mitigations.

Apples produced under this systems approach will also be subject to inspection by Department of 

Homeland Security, Customs and Border Protection (CBP) at the United States port of entry. 

Infected and/or infested fruit will be rejected, and trace back will be done by APHIS and AQSIQ

to identify and correct problems including removal of the packinghouse or place of production 

from the export program.
The requirements of a phytosanitary certificate issued by AQSIQ will document that the 

consignment is a product of the exporting country. A phytosanitary certificate will also provide 

phytosanitary security by requiring AQSIQ to conduct inspections for pests of quarantine 

concern.

Summary:

Most of the pests on the pest list have never been intercepted at ports of entry in commercial fruit 

shipments. Standard commercial practices are sufficient to mitigate many pests. The systems 

approach of field and packing house measures described above will remove all other pests from 

the pathway. Requiring bagging of fruit, removal of leaves, packinghouse culling and inspection 

will ensure that the Lepidoptera and Curculionidae pests will be removed from the pathway of 

fresh apples. APHIS has determined that the listed risk management measures, along with the 

requirement of a phytosanitary certificate and the port of entry inspection, will mitigate the risk 

of pest introductions on apples from China into the continental United States.

Authors:

José R. Hernández, Ph.D.

Senior Risk Manager - Plant Pathology

Walter P. Gould, Ph.D.

Senior Risk Manager – Entomology

Devaiah A. Muruvanda, Ph.D. 

Senior Risk Manager – Entomology

References:

AQAS. 2013. Pest Interception Database (PestID). United States Department of Agriculture, 

Animal and Plant Health Inspection Service, Plant Protection and Quarantine (PPQ). Accessed 

October, 2013.

CABI. 2013. Crop Protection Compendium. Commonwealth Agricultural Bureau International 

(CABI), Wallingford, UK.

Hadidi, A., M. Barba, T. Candresse, and W. Jelkmann. 2011. Virus and Virus-like Diseases of 

Pome and Stone Fruit. APS Press, St. Paul, MN. p. 341-359.

Lewis, T. 1981. Pest monitoring to aid insecticide use. Philosophical Transactions of the Royal 

Society, London. 295 (1076): 153-162.
USDA. 2013a. Importation of Apples (Malus pumila) from China into the continental United

States. Animal and Plant Health Inspection Service, Center for Plant Health Science and 

Technology, Plant Epidemiology and Risk Analysis Laboratory, Raleigh, NC. 311 pp.

USDA. 2013b. USDA Treatment Manual. 

http://www.aphis.usda.gov/import_export/plants/manuals/ports/downloads/treatment.pdf

Accessed December 2013.

Watson, A.J. 1971. Foreign bacterial and fungus diseases of food, forage, and fiber crops: An 

annotated list. United States Department of Agriculture, Agricultural Research Service. 111 pp.