United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

April 2014

Analysis in Support of Certification that the 

Rule will not have a Significant Economic 

Impact on a Substantial Number of Small 

Entities

Final Rule

APHIS 2013-0016

RIN 0579-AD81

Importation of Fresh Blueberry from Morocco

Policy & Program Development

Policy Analysis & Development
i

Summary

This analysis examines the expected economic impact for U.S small entities of a rule that 

will allow the importation of fresh blueberry from Morocco into the continental United States. 

The Small Business Administration’s small-entity standard for U.S. farms that produce fresh 

blueberry is annual receipts of not more than $750,000. As reported by the 2007 Census of 

Agriculture, the average value of sales by the 7,516 U.S. farms that produced fresh blueberry that 

year was about $53,000, well below the small-entity standard. 

Morocco expects to export 360,000 pounds of fresh blueberry to the continental United 

States annually. This quantity is equivalent to about one-tenth of one percent of the average 

annual supply (utilized production plus imports minus exports) of fresh blueberry in the United 

States, 2007-2012. Per capita consumption of fresh blueberry has increased from about 0.6 

pounds in 2007 to 1.3 pounds in 2012. The quantity imported from Morocco will result in a 

negligible addition to current supplies, and will marginally help meet the United States’ rapidly

increasing demand for fresh blueberry. While most blueberry farms are small, this rule will not 

have a significant economic impact on a substantial number of small entities. 
1

Introduction 

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

certification by the APHIS Administrator that the rule will not have a significant economic 

impact on a substantial number of small entities.

APHIS received a request from Morocco to authorize the importation of fresh blueberry

into the continental United States under a systems approach. In response to Morocco’s request, 

APHIS produced risk analysis and risk management documents. The latter identifies the risk 

mitigation measures expected to prevent the introduction of plant pests in the commercial 

shipments of fresh blueberry from Morocco. These measures include approved postharvest 

treatments, inspections for pests during growing seasons, and certification that consignments of 

blueberry meet phytosanitary requirements.

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

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

jurisdictions. Section 604 of the Act requires an agency to prepare a final regulatory flexibility

analysis (FRFA) that describes the expected impact of the rule on small entities and a description 

of the steps the agency has taken to minimize significant economic impacts on small entities 

consistent with the stated objectives of applicable statutes. In place of the FRFA, the head of the 

agency may certify that a rule will not have a significant economic impact on substantial number 

of small entities. 
2

 

U.S Blueberry Production and Trade 

The United States is the largest producer of blueberry, providing 55 percent of the 

world’s supply in 2011, followed by Canada at 32 percent.1 In the United States, most blueberry

fruit are picked between April and August.2Fresh blueberry production is a growing U.S. 

industry; utilized production expanded by 87 percent between 2007 (about 150 million pounds) 

and 2012 (about 281 million pounds) (table 1). 

Table 1. U.S fresh blueberry production, trade, and per capita consumption, 2007-2012

Year Utilized 

Production Imports Exports Domestic Supply

Per Capita 

Consumption

million pounds pounds

2007 150.28 77.37 50.60 177.05 0.59

2008 194.11 114.89 64.19 244.81 0.80

2009 225.65 133.28 64.28 294.65 0.96

2010 246.93 169.24 70.23 345.94 1.12

2011 287.90 192.53 78.50 401.93 1.29

2012p281.30 212.45 73.58 420.17 1.30

Six-year 

average

231.03 149.96 66.90 312.24 1.01

Source: USDA, Economic Research Service, 

http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1765

p

Preliminary. 

 

1 UN Food and Agriculture Organization, as reported by USDA Economic Research Service, 

http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1765

2 USDA Economic Research Service, 

http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1765
3

The United States is a net importer of fresh blueberry. As shown in table 1, between 2007 

and 2012, the United States imported 150 million pounds of blueberry per year on average, while 

exporting 67 million pounds. In 2012, the quantity of blueberry exported by the United States 

totaled about 73.6 million pounds, and imports totaled about 212.5 million pounds. While U.S. 

exports of fresh blueberry have been expanding, the growth in imports has been even greater 

despite increased U.S. production. Between 2007 and 2012, exports increased by more than 50 

percent; imports in 2012 were approaching three times their 2007 level. 

Canada received about 90 percent of U.S. fresh blueberry exports between 2007 and 2012

(table 2). Chile is the leading supplier of fresh blueberry imported by the United States (57 

percent, 2007-2012), followed by Canada (28 percent) (table 3). Fresh blueberry imports from 

both of these countries have boomed in recent years, given the rapid increase in U.S. demand. 

As shown in table 1, per capita consumption of fresh blueberry has increased from about 0.6 

pounds in 2007 to 1.3 pounds in 2012. Chile’s exporters also benefit from a production cycle 

that is counter-seasonal to that of the United States. 
4

Table 2. U.S fresh blueberry exports, 2007-2012, million pounds

Destination 2007 2008 2009 2010 2011 2012 

Six-year 

Average

million pounds

World 50.60 64.19 64.28 70.23 78.50 73.58 66.90

Canada 47.03 59.88 58.90 63.65 69.98 63.92 60.56

Japan 0.97 2.06 3.26 3.71 5.74 5.24 3.50

Hong Kong 0.15 0.29 0.40 0.71 0.78 2.19 0.75

South Korea 0.15 0.33 0.29 0.53 0.42 0.24 0.33

United 

Kingdom 1.85 1.18 0.63 0.20 0.36 0.40 0.77

Rest of 

World 0.45 0.45 0.80 1.44 1.22 1.58 0.99

Source: USDA, Economic Research Service, 

http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=

1765

Table 3. U.S fresh blueberry imports, 2007-2012, million pounds

Source 2007 2008 2009 2010 2011 2012 

Six-year 

Average

million pounds

World 77.37 114.89 133.28 169.24 192.53 212.45 149.96

Chile 37.83 61.90 74.23 100.95 122.72 117.12 85.79

Canada 27.30 36.74 41.09 43.43 42.37 64.80 42.62

Argentina 11.50 14.38 15.88 20.56 20.96 21.02 17.38

Mexico 0.07 0.29 0.79 2.10 4.11 7.87 2.54

Uruguay 0.27 1.25 1.03 1.76 2.04 1.45 1.30

New Zealand 0.38 0.32 0.25 0.23 0.17 0.11 0.24

Rest of 

World 0.03 0.01 0.01 0.21 0.15 0.07 0.08

Source: USDA, Economic Research Service, 

http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=

1765
5

Potential Impact on Small Entities

Blueberry production is classified within the North American Industry Classification 

System under Berry (except Strawberry) Farming (NAICS 111334), for which the Small 

Business Administration’s small-entity standard is annual revenue of not more than $750,000.3 

The latest data on the number of farms that produce blueberry are found in the 2007 Census of 

Agriculture, which reports that the average value of blueberry sold per farm was about $53,000.4 

Clearly, most if not all blueberry producers are small entities. 

Table 4 shows that between 2002 and 2007, the number of farms that harvested blueberry

increased from 6,428 to 7,516, and the number of acres increased from about 52,000 to over 

60,000. 

Table 4. Number of blueberry farms and area harvested in leading States, 2007 and 2002

State 2007 2002 2007 2002

 7,516 6,428 60,353 52,002

Michigan 758 590 19,641 12,274

Oregon 713 659 5,185 3,887

Washington 475 289 3,926 289

Florida 442 343 2,376 1,646

New York 407 351 1,097 842

Georgia 343 408 4,802 4,451

Mississippi 317 249 2,209 1,289

North Carolina 297 267 5,323 5,009

New Jersey 268 240 7,605 7,468

Alabama 207 196 347 400

California 186 97 2,232 827

Arkansas 82 140 269 675

Others 3,779 3,189 24,982 25,219

Source: NASS, Census of Agriculture, 2007 and 2002.

Number of Farms Acres

U.S 

 

3

Small Business Administration Table of Small Business Size Standards 

http://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf

4

2007 U.S. Census of Agriculture and USDA Economic Research Service. 

 
6

Morocco expects to annually export 360,000 pounds of fresh blueberry to the continental 

United States. This quantity is equivalent to about one-tenth of one percent of U.S. domestic

supply (utilized production plus imports minus exports) between 2007 and 2012. We expect 

shipments to arrive in July and August, during the latter part of the U.S. season. Any impact on 

U.S. producers is expected to be negligible, given the relatively small quantity that Morocco 

intends to export to the United States.

No significant comments were received on our finding that the proposed rule would not 

result in a significant economic impact on a substantial number of small entities. One 

commenter suggested that the annual quantity of blueberry imported from Morocco be allowed 

to exceed 360,000 pounds only if approved by APHIS, and that the price not be allowed to be 

less than that of domestically produced blueberry. Even if these suggestions were in the public’s 

interest, APHIS has no authority to restrict import volumes or set market prices. Other 

commenters expressed satisfaction with the current availability and quality of fresh blueberry in 

the United States, and were concerned about the rule’s negative impact on U.S. blueberry

farmers’ businesses. As indicated, the quantity imported from Morocco will result in a

negligible addition to current supplies, and will marginally help meet the United States’ rapidly

increasing demand for fresh blueberry.

The APHIS Administrator has determined that this action will not have a significant 

economic impact on a substantial number of small entities.