United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

March 2011

Analysis in Support of Certification that the 

Rule will not have a Significant Economic 

Impact on a Substantial Number of Small 

Entities

Proposed Rule 

APHIS-2011-0012

RIN 0579-AD48

Importation of Tomatoes from the 15 

Countries that comprise the Economic 

Community of West African States 

(ECOWAS)

Policy & Program Development

Policy Analysis & Development
1

Summary

This analysis examines impacts for U.S. small entities of a rule that would allow fresh 

tomato imports from member countries of the Economic Community of West African States 

(ECOWAS). The United States has no history of importing tomatoes from these countries. We 

model three levels of tomato exports to the United States from ECOWAS member States: (i) 5 

percent of ECOWAS average annual world exports, 2003-2008 (484 metric tons (MT)); (ii) 10 

percent of ECOWAS average annual world exports, 2003-2008 (967 MT); and (iii) 20 percent of 

ECOWAS average annual world exports, 2003-2008 (1,934 MT). Even when assuming the 

largest import quantity and no displacement of tomato imports from other countries, the welfare 

loss for U.S. small-entity producers would be equivalent to about 0.05 percent of their average 

annual revenue, that is, about $4.00. While U.S. tomato producers are predominantly small, this 

proposed rule will not have a significant economic impact on a substantial number of small 

entities. 
2

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, would not have 

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

We examine impacts for U.S. small entities of a rule that would allow the importation of 

fresh tomatoes (Solanum lycopersicum) from the 15 countries that comprise the Economic 

Community of West African States (ECOWAS). This action would provide market access into 

the continental United States for tomatoes without stems and calyxes from ECOWAS member 

States under conditions that would prevent the introduction of plant pests. The rule would

amend 7 CFR 319.56, and is part of a continuing program to allow the importation of foreign 

agricultural products that APHIS has determined are without significant risk of introducing 

exotic plant pests into the United States.

The rule is in response to a request from the Government of Senegal to allow fresh 

tomato imports from Senegal. In responding to this request, APHIS produced a regional pest 

risk analysis and risk management document. The latter document identifies the risk mitigation 

measures that would prevent the plant pests associated with tomatoes in commercial shipments 

from ECOWAS member States from being introduced into the continental United States. These 

measures include production in specified regions and in pest-free growing structures such as 

greenhouses, trapping requirements, shipping date restrictions, and safeguarding of the 

packinghouse. Also, the proposed rule would require that the tomatoes be accompanied by a 

phytosanitary certificate with an additional declaration to ensure that all measures of the systems 

approach have been followed.
3

The Regulatory Flexibility Act requires agencies to evaluate the potential effects of their 

proposed and final rules on small businesses, small organizations and small governmental 

jurisdictions. Section 603 of the Act requires an agency to prepare an initial regulatory 

flexibility analysis (IRFA) that describes the expected impact of the rule on small entities and the 

steps the agency has taken to minimize significant economic impacts on small entities. In place 

of the IRFA, the head of the agency may certify that a rule will not have a significant economic 

impact on a substantial number of small entities. This analysis provides the factual basis for 

certification of this rule. 

As background, we provide a brief overview of tomato production and trade by the 

United States and ECOWAS. This is followed with an estimate of price and welfare effects of 

the rule based on assumed levels of tomato imports from ECOWAS. We then describe the 

expected impact on small entities.

U.S. Tomato Production and Trade

The United States is a major tomato producer and importer. The U.S. produced 

1,670,643 metric tons (MT) of fresh tomatoes valued at $1.3 billion in 2009, while imports that 

year totaled 1,189,604 MT. Tomato production occurs in many States. The top ten States (FL, 

CA, VA, GA, OH, TN, NC, AL, NJ, and MI) accounted for 95 percent of total cash receipts in 

2009.1

 

As shown in table 1, both U.S. tomato production and consumption have fluctuated over 

recent years. The most recent data show production was 1,891,318 MT in 2004 and declined to 

1,670,643 MT in 2009, an annual decline of about 1.2 percent. Consumption increased over this 

same period, from 2,655,584 MT to 2,689,876 MT, and U.S. imports increased from 

 1 USDA/NASS, Vegetables 2010 Summary, January 2011.

931,779 
4

MT to 1,189,604 MT. Mexico is the source of the largest share of imports (88 percent in 2009), 

followed distantly by Canada (11 percent). Other minor suppliers include the Netherlands, 

Spain, Dominican Republic, Belgium, Israel, Costa Rica, and Guatemala. The U.S. was a net 

importer throughout the period with average annual imports (1,042,101 MT) dwarfing exports 

(160,052 

Year

MT). Imports provide for 39 percent of consumption. 

 Table 1: U.S. Tomato Production, Consumption, Price, Exports and Imports, 2004-2009

Production 

in Metric 

Tons

Consumption 

in Metric 

Tons

Price per 

Metric 

Ton

Exports in 

Metric 

Tons

Imports in 

Metric 

Tons

2004 1,891,318 2,655,584 $825 167,513 931,779

2005 1,903,701 2,707,294 $917 148,099 951,692

2006 1,833,031 2,681,348 $963 144,108 992,425

2007 1,721,673 2,631,316 $767 161,344 1,070,988

2008 1,612,356 2,559,603 $1,003 168,874 1,116,121

2009 1,670,643 2,689,876 $895 170,371 1,189,604

6-Year Average 

(2004-2009) 1,772,120 2,654,170 $895 160,052 1,042,101

Source: USDA/ERS, Vegetables and Melons Situation Outlook Yearbook Data/#89011//May 

20, 2010. 

Production of tomatoes in the ECOWAS countries increased from 1,527,120 MT in 2003, 

to 2,463,608 MT in 2008 (the most recent data available).

ECOWAS Tomato Production and Trade

2

 2 UN/FAO, FAO stat, 2011. While the U.S. and ECOWAS data sets differ by one year (2004-2009 vs. 2003-2008), 

the two 6-year periods are comparable and support the conclusions of the analysis. 

The majority of tomatoes are openfield produced and would not qualify for export to the United States; the tomatoes imported must 

be produced in pest-exclusionary structures such as greenhouses. With the exception of Senegal, 

ECOWAS member countries export very small amounts of tomatoes, and most of these exports 

go to neighboring countries. Senegal’s tomato exports are greenhouse-produced and are 

supplied to EU countries with which Senegal has a well-established market. Over 99 percent of
5

Senegal’s tomato exports were sent to France, Germany, the United Kingdom, the Netherlands, 

Italy and Belgium. 

The average quantity of tomatoes exported by the ECOWAS member States during the 

period 2003-2008 was 9,670 MT. Of this total, Senegal exported an average of 7,449 MT, or 77 

percent. 

Impact of Potential Fresh Tomato Imports

We estimate the impact of tomato imports from ECOWAS on U.S. production, 

consumption, and prices using a net trade welfare model. The data used were obtained from 

FAO, ERS, and the U.S. Census Bureau (as reported in the Global Trade Atlas).3 The demand 

and supply elasticities used are -0.77 (average of 5 estimates) and 0.37, respectively.

4

Table 2 presents the changes we estimate could result from the assumed levels of U.S. 

tomato imports from ECOWAS. These include annual changes in U.S. consumption, 

production, wholesale price, consumer welfare, producer welfare, and net welfare. The largest 

assumed level of tomato exports to the United States from ECOWAS member States, 1,934 MT, 

We model three levels of tomato exports to the United States from ECOWAS: (i) 5

percent of ECOWAS average annual world tomato exports, 2003-2008 (484 MT); (ii) 10 percent 

of ECOWAS average annual world tomato exports, 2003-2008 (967 MT); and (iii) 20 percent of 

ECOWAS average annual world tomatoes exports, 2003-2008 (1,934 MT). The largest assumed 

level of exports is equivalent to less than 0.2 percent of average annual tomato imports by the 

United States during this same period. 

 3 UN/FAO, FAO stat data (http://faostat.fao.org) ; USDA/ERS, Vegetables and Melons Yearbook Data/#89011/ 

May 20, 2010; and Global Trade Atlas, Global Trade Information Services, Inc., country edition, March 2011. 4 The demand elasticity is from K. Huang, “A complete system of U.S. demand for food,” Technical Bulletin No. 

182, 1993, USDA/ERS, Washington DC; and the supply elasticity is from S.R. Hammig and R.C. Mettelhammer, 

“An evaluation of import tariffs in the Canada-U.S. fresh tomato market,” Canadian Journal of Agricultural 

Economics, Vol. 30 (1982): 133-152; S.T. Yen, B. Lin, J.M. Harris, and N. Ballinger, “Demand for differentiated 

vegetables,” paper presented at American Agricultural Economic Association economic meeting, Denver Colorado, 

August 1-4, 2004.
6

would result in a decline of $0.66 per MT in the wholesale price of tomatoes and a fall in U.S. 

production of 437 MT. Consumption could increase by 1,497 MT. Producer welfare could 

decline by $1.06 million and consumer welfare could increase by $1.74 million, yielding an 

annual net benefit of about $0.68 million.

Table 2: Estimated Impact on the U.S. Economy of Tomato Imports from ECOWAS for Three 

Import Scenarios

Assumed annual tomato 

imports from ECOWAS, MT 4841 9672 1,9343

Change in U.S. consumption, 

MT

375 749 1,497

Change in U.S. production, 

MT

-109 -218 -437

Change in wholesale price of 

tomatoes, dollars per MT

-$0.16 -$0.33 -$0.66

Change in consumer welfare $435,507 $870,175 $1,740,595

Change in producer welfare -$264,487 -$528,410 -$1,056,748

Annual net benefit $171,020 $341,765 $683,847

Note: The baseline data used are five-year annual averages for production, consumption, prices, 

exports and imports, as reported in the last row of table 1. The demand and supply elasticities 

used are -0.77 and 0.37, respectively (see footnote 4). 

1 Five percent of ECOWAS average annual world exports, 2003-2008 (484 MT). 2 Ten percent of ECOWAS average annual world exports, 2003-2008 (967 MT). 3 Twenty percent of ECOWAS average annual world exports, 2003-2008 (1,934 MT).

In all three scenarios, consumer welfare gains outweigh producer welfare losses. Even in 

the third scenario, in which we assume imports would be 20 percent of ECOWAS’ average 

annual world tomato exports (2003-2008), the decline in producer welfare represents less than 

0.09 percent of cash receipts received from the sale of domestically produced fresh tomatoes.

5

 5 $1.06 million is less than 0.09 percent of $1.3 billion.

 

The price decline in this third scenario is less than 0.08 percent. The price and welfare effects 

would be even smaller than are indicated by the three scenarios, to the extent that tomato imports 

from ECOWAS displace tomato imports from other countries. 
7

Potential Impact on Small Entities

The Small Business Administration (SBA) has established guidelines for determining 

which firms are to be considered small under the Regulatory Flexibility Act. This rule could 

affect U.S. producers of fresh tomatoes (classified under Other Vegetable (except Potato) and 

Melon Farming, NAICS 111219) and importers of fresh tomatoes. Vegetable-producing 

establishments are classified as small if their annual receipts are not more than $750,000.6

Total change in producer welfare1

 

According to the 2007 Census of Agriculture (most recent data on farm sizes), there were 25,809 

farms producing tomatoes in the United States. About 68 percent of these farms had less than 

one acre in tomatoes. Overall, 25,128 farms (97.4 percent) had a total of 39,879 acres in 

tomatoes (about 9 percent of the total planted area) and are considered small, with an average of 

about 1.6 acres and an average annual income of about $8,000 in 2007. The remaining 2.6 

percent of the farms planted a total of 402,346 acres in tomatoes (91 percent of the planted area). 

They averaged 591 acres, with an average annual income of about $3 million. As shown in 

table 3, the impact of potential tomato imports on U.S. small-entity producers as a result of this 

rule would be small. The annual decrease in producer welfare per small entity is estimated to be

less than $4 or about 0.05 percent of average annual sales by small entities, when we assume that 

1,934 MT of tomatoes would be exported to the United States from ECOWAS because of this 

rule. The dollar decrease in welfare for most small tomato producers would be even smaller, 

given that the majority planted less than an acre in tomatoes.

Table 3: The Economic Impact of Potential Tomato Imports from ECOWAS on U.S. Small 

Entities, assuming Annual Exports of 1,934 Metric Tons to the United States, 2009 dollars 

-$1,056,748

 6 SBA, Small business size standards matched to the North American Industry Classification System 2007, Effective 

August 22, 2008(www.sba.gov/size/sizetable2002.html).
8

Change in welfare incurred by small entities2 -$95,107

Average change per acre, small entities3 -$2.38

Average change per small entity4 -$3.78

Average change as % of average sales, small entities5 -0.05%

1 From table 2. 

2 Change in producer welfare multiplied by 9 percent, the percentage of total acreage 

planted by producers with annual revenues of not more than $750,000, that is, small 

entities. We assume that the change in producer welfare would be proportional to 

acreage share. 

3 Decrease in producer welfare for small entities divided by 39,879, the number of 

acres planted by small entities.

4 Average decrease per acre multiplied by 1.59, the average number of acres per small 

entity.

5 Average decrease per small entity divided by $7,990, the average annual revenue per 

small entity.

The 2007 Census of Agriculture also contains data on certain sub-categories of tomato 

producers, namely, small family farms including limited resource farms, and farms having 

operators who belong to socially disadvantaged groups.7

 7 For definitions and information, see: USDA ERS. Structure and Finances of U.S. Farms: Family Farm Report, 

2010 edition, EIB-66, July 2010. http://www.ers.usda.gov/Publications/EIB66/EIB66.pdf

 Most farms that produce tomatoes

qualify as small family farms (gross farm sales of less than $250,000), and many of the small 

family farms also qualify as limited resource farms (gross farm sales of not more than $100,000 

and low household income). Categories of socially disadvantaged operators are women, persons 

of Hispanic origin, American Indian or Alaska Native, Asian, African American, and Native 

Hawaiian or other Pacific. As described above for small tomato farms generally, any economic 

impacts of the rule for operations categorized as small family farms or farms having operators 

who belong to socially disadvantaged groups would be insignificant, given the small quantity of 

tomatoes expected to be imported from ECOWAS compared to domestic production and current 

imports.
9

Table 4 shows that among the 25,809 farms that produced tomatoes in 2007, 22,522 (over 

87 percent) were small family farms. It is notable that the combined number of retirement farms 

(5,017 farms) and residential/lifestyle farms (6,996 farms) accounted for over 46 percent of all 

tomato farms.

Table 5 shows the number and percentage of tomato farms that had operators belonging 

to socially disadvantaged groups in 2007. There were 4,311 tomato farms (16.7 percent) for 

which the principal operator was a woman. In terms of ethnicity, 958 tomato farms (3.7 percent) 

were operated by Hispanics and 820 tomato farms (3.2 percent) had an operator who was 

American Indian or Alaskan Native. The percentage of tomato farms operated by African 

Americans was 2.7 percent.

Although most tomato producers are small family farms and there are tomato growers 

who belong to socially disadvantaged groups, economic effects of the rule for these farms are not 

expected to differ from the effects for tomato producers generally. We do not expect the 

proposed rule to have any appreciable impact on U.S. tomato producers regardless of the size of 

operation or operator classification.

The quantity of tomatoes expected to be imported from ECOWAS is not significant; any 

effect on prices would be insignificant. Based on the above information and analysis, the 

proposed rule will not have a significant economic impact on a substantial number of small 

entities. 
10

Table 4. Number and percentage of small family tomato farms, 2007

Limited 

Resource Farms

Retirement 

Farms

Residential/ 

lifestyle Farms 

Farming 

Occupation/Lower 

Sales

Farming 

Occupation/ Higher 

Sales

All 

Small Family

Tomato Farms

All 

Tomato Farms

Number 4,443 5,017 6,996 4,850 1,216 22,522 25,809

Percentage 17.2 19.4 27.1 18.8 4.7 87.3 100%

Source: USDA NASS, 2007 Census of Agriculture.

Note: A limited resource farm is a small family farm that has gross sales of less than $100,000 (indexed after 2003), and a household income less than the poverty level 

for a family of four with two children or less than half the county median income. A retirement farm is a small family farm whose operators report they are retired 

(excludes limited resource farms operated by retired farmers). A residential/lifestyle farm is a small family farm whose operators report a major occupation other than 

farming (excludes limited resource farms whose operators report a major occupation other than farming). A farming occupation/lower-sales farm is a small family farm

with sales less than $100,000 whose operators report farming as their major occupation (excludes limited resource farms whose operators report farming as their major 

occupation). A farming occupation/higher-sales farm is a small family farm with sales between $100,000 and $249,000 whose operators report farming as their major 

occupation.

Table 5. Number and percentage of tomato farms with operators belonging to socially disadvantaged groups, 2007

Farms 

where the Principal 

Operator is Female

Farms where 

an Operator reports 

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 

Tomato Farms

Number 4,311 958 820 600 704 50 25,809

Percentage 16.7 3.7 3.2 2.3 2.7 0.2 100%

Source: USDA NASS, 2007 Census of Agriculture.

Note: For the ethnic/racial categories, farms reported for their top-three operators. An operator may report as belonging to more than one ethic/racial 

category, and a farm may report having operators belonging to more than one category.