United States International Trade Commission

Investigation No. 332-537

USITC Publication 4419

August 2013

Olive Oil: Conditions 

of Competition 

between U.S. and 

Major Foreign 

Supplier Industries
Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

U.S. International Trade Commission

Robert B. Koopman

Director, Office of Operations

Karen Laney

Director, Office of Industries

COMMISSIONERS 

 

Irving A. Williamson, Chairman 

Daniel R. Pearson 

Shara L. Aranoff 

Dean A. Pinkert 

David S. Johanson 

Meredith M. Broadbent
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

USITC Publication 4419 August 2013

Olive Oil: Conditions of Competition 

between U.S. and Major Foreign Supplier 

Industries

Investigation No. 332-537
This report was prepared principally by

Project Leader

 Brendan Lynch 

brendan.lynch@usitc.gov 

Deputy Project Leader 

Alison Rozema 

alison.rozema@usitc.gov 

Office of Industries

 Katherine Baldwin, Renee Berry, Caitlin Blair, Joanna Bonarriva, 

John Fry, John Giamalva, and Michael McConnell 

Office of Economics 

Jose Signoret 

Office of the General Counsel

William Gearhart

Content Reviewers 

William Powers and Alan Treat 

Office of Analysis and Research Services 

Peg Hausman and Jeremy Wise

Administrative Support

Phyllis Boone, Monica Reed, and Wanda Tolson 

Help Desk and Customer Service Division

Sonya Wilson 

Under the direction of: 

Jonathan Coleman, Chief 

Agriculture and Fisheries Division 
Correction 

For the U.S. International Trade Commission, Olive Oil: Conditions of Competition between U.S. and 

Major Foreign Supplier Industries, Investigation No. 332-537, USITC Publication 4419 (August 2013). 

Five times throughout the report, the Australian Olive Association was inaccurately referred to as the 

Australian Olive Oil Association. These two entities are different, and the work of the Australian Olive 

Association was wrongly attributed to the Australian Olive Oil Association. This error has been corrected 

in the following places: on the acronyms list (page ix), in the executive summary (page xiv), in box 3.5 in 

chapter 3 (page 3-12), in the chapter 3 bibliography (page 3-21), and in chapter 4 (page 4-12). 

The Commission regrets the error. 

October 21, 2013 

i

Abstract

This report describes and analyzes the factors affecting competition between the United 

States and major olive oil producing countries. It provides: (a) an overview of global 

production, consumption, exports, and imports during 2008–12 and 2013 where 

available; (b) an analysis of the factors impacting consumption in the U.S. market; (c) 

profiles of the olive oil industries in the United States and other major producing 

countries; and (d) an examination of competition between firms and countries in both the 

global and U.S. market. 

Global demand for and consumption of olive oil have increased significantly since the 

1990s. While the United States and other “New World” players, such as Australia, 

Argentina, and Chile, have emerged as both producers and consumers, countries in the 

European Union (EU) and North Africa still dominate global production, consumption, 

and trade. Almost 60 percent of global exports by volume were intra-EU trade flows 

during 2008–12. The largest bilateral trade flows during this period were Spanish exports 

of olive oil to Italy, where large multinational companies source oil from around the 

world, blend and bottle it, and then re-export the final product to third-country markets, 

including the United States. 

The benchmark for international standards for determining the grade of an olive oil are 

set by the International Olive Council. Our findings suggest that the current standards for 

extra virgin olive oil are widely unenforced and allow a wide range of olive oil qualities 

to be marketed as extra virgin. Broad and unenforced standards can lead to adulterated 

and mislabeled product, weakening the competitiveness of high-quality U.S.-produced 

olive oil in the U.S. market. In addition, many U.S. consumers are unable to distinguish 

quality differences and, as a result, gravitate toward less costly oils, giving an advantage 

to large bottlers that sell low-cost imported product. 

iii

CONTENTS 

Page

Abstract ................................................................................................................................... i

Acronyms ............................................................................................................................... ix

Executive Summary ....................................................................................................... xi

Chapter 1 Introduction ............................................................................................. 1-1

 Overview ............................................................................................................................. 1-1

 Scope of the report .............................................................................................................. 1-4

 Approach ............................................................................................................................. 1-4

 Olive oil grading and standards ........................................................................................... 1-5

 Olive oil production process and supply chain ................................................................... 1-7

 Olive production ............................................................................................................. 1-7

 Milling ............................................................................................................................ 1-10

 Refining .......................................................................................................................... 1-11

 Bottling and marketing ................................................................................................... 1-11

 Bibliography ........................................................................................................................ 1-13

Chapter 2 Global Overview ................................................................................... 2-1

 Overview ............................................................................................................................. 2-1

 Global production of olive oil ............................................................................................. 2-4

 Global production trends ................................................................................................ 2-4

 Comparison of oil production costs ................................................................................ 2-5

 Global consumption of olive oil .......................................................................................... 2-7

 Trends in global trade .......................................................................................................... 2-9

 Global imports ................................................................................................................ 2-9

 Global exports ................................................................................................................. 2-20

 International tariff treatment for olive oil ....................................................................... 2-21

 Bibliography ........................................................................................................................ 2-23

Chapter 3 Olive Oil Standards and Enforcement ............................... 3-1

 Overview ............................................................................................................................. 3-1

 The importance of standards and enforcement for olive oil competitiveness ..................... 3-1

 Olive oil standards ............................................................................................................... 3-3

 Chemical and sensory testing criteria ............................................................................. 3-3

 International standard setting ......................................................................................... 3-7

 Debate over international standards .................................................................................... 3-7

 IOC membership ............................................................................................................ 3-9

 Evolution of IOC standards ............................................................................................ 3-10

 Effectiveness of standards................................................................................................... 3-14

 Internal testing by private companies ............................................................................. 3-14

 Official testing ................................................................................................................ 3-15

 Efforts to strengthen standards and enforcement in the U.S. market .................................. 3-16
iv

CONTENTS―Continued

Page

Chapter 3 Olive Oil Standards and Enforcement—Continued

 Potential U.S. federal marking order .............................................................................. 3-17

 Potential FDA standard of identity ................................................................................. 3-19

 Bibliography ....................................................................................................................... 3-21

Chapter 4 The U.S. Market for Olive Oil ................................................. 4-1

 Overview ............................................................................................................................. 4-1

 U.S. market characteristics .................................................................................................. 4-2

 Factors driving increased U.S. consumption ................................................................... 4-2

 Sources of supply in the U.S. market .................................................................................. 4-3

 Consumption characteristics in the U.S. market ................................................................. 4-3

 Consumption by market segment .................................................................................... 4-3

 Factors affecting consumption in the U.S. retail market ..................................................... 4-9

 Overview ......................................................................................................................... 4-9

 Consumer awareness and flavor preferences ................................................................... 4-10

 Branding and marketing .................................................................................................. 4-11

 Pricing ............................................................................................................................. 4-13

 Econometric analysis of demand ......................................................................................... 4-18

 Bibliography ........................................................................................................................ 4-21

Chapter 5 U.S. Olive Oil Production .............................................................. 5-1

 Overview ............................................................................................................................. 5-1

 Production profile ................................................................................................................ 5-2

 Production overview ...................................................................................................... 5-2

 Olive-growing sector ...................................................................................................... 5-3

 Olive oil-processing sector ............................................................................................. 5-9

 Factors affecting competitiveness ....................................................................................... 5-13

 Product differentiation .................................................................................................... 5-13

 Government policies and support mechanisms .............................................................. 5-14

 Cost structure at the farm level ....................................................................................... 5-17

 Industry size ................................................................................................................... 5-19

 Cropping alternatives and long-term availability of supply ........................................... 5-19

 Bibliography ........................................................................................................................ 5-21

Chapter 6 European Union .................................................................................... 6-1

 Overview ............................................................................................................................. 6-1

 Production and consumption trends ............................................................................... 6-3

 European Union policy ................................................................................................... 6-4

 Spain .................................................................................................................................... 6-10

 Overview ........................................................................................................................ 6-10

 Production profile ........................................................................................................... 6-11

 Consumption .................................................................................................................. 6-15
v

CONTENTS―Continued

Page

Chapter 6 European Union—Continued

 Trade .............................................................................................................................. 6-16

 Factors affecting competitiveness .................................................................................. 6-17

 Italy...................................................................................................................................... 6-23

 Overview ........................................................................................................................ 6-23

 Production profile ........................................................................................................... 6-24

 Consumption ................................................................................................................... 6-28

 Trade ............................................................................................................................... 6-29

 Factors affecting competitiveness .................................................................................. 6-30

 Greece .................................................................................................................................. 6-34

 Overview ........................................................................................................................ 6-34

 Production profile ........................................................................................................... 6-35

 Consumption ................................................................................................................... 6-38

 Trade ............................................................................................................................... 6-38

 Factors affecting competitiveness ................................................................................. 6-40

 Bibliography ........................................................................................................................ 6-43

Chapter 7 North Africa ............................................................................................. 7-1

 Overview ............................................................................................................................. 7-1

 Tunisia ................................................................................................................................. 7-2

 Overview ......................................................................................................................... 7-2

 Production profile ............................................................................................................ 7-3

 Consumption ................................................................................................................... 7-7

 Trade ................................................................................................................................ 7-8

 Factors affecting competitiveness ................................................................................. 7-9

 Morocco .............................................................................................................................. 7-15

 Overview ......................................................................................................................... 7-15

 Production profile ............................................................................................................ 7-15

 Consumption ................................................................................................................... 7-18

 Trade ................................................................................................................................ 7-19

 Factors affecting competitiveness ................................................................................. 7-19

 Bibliography ........................................................................................................................ 7-25

Chapter 8 New World and Middle East ...................................................... 8-1

 Overview ............................................................................................................................. 8-1

 New world producers .......................................................................................................... 8-1

 Overview .......................................................................................................................... 8-1

 Chile ................................................................................................................................. 8-2

 Australia ........................................................................................................................... 8-7

 Argentina ......................................................................................................................... 8-12

 Middle Eastern producers ................................................................................................... 8-17

 Overview ......................................................................................................................... 8-17

 Turkey ............................................................................................................................. 8-17
vi

CONTENTS―Continued

Page

Chapter 8 New World and Middle East—Continued

 Syria ............................................................................................................................... 8-19

 Bibliography ........................................................................................................................ 8-21

Appendixes 

A. Request letter ............................................................................................................................ A-1

B. Federal Register notice ............................................................................................................ B-1

C. Calendar of hearing .................................................................................................................. C-1

D. Summary of positions of interested parties .............................................................................. D-1

E. Consumer demand for olive oil: Econometric results from retail scanning data ...................... E-1

Boxes 

1.1. Olive milling technology ........................................................................................................ 1-10

2.1. International Olive Council .................................................................................................... 2-3

2.2. International olive oil prices ................................................................................................... 2-11

2.3. Trade preference between the EU and Mediterranean countries ............................................ 2-15

3.1. Olive oil perishability and quality .......................................................................................... 3-4

3.2. Olive oil chemistry ................................................................................................................. 3-4

3.3. Olive oil sensory testing ......................................................................................................... 3-5

3.4. U.S. participation in the IOC .................................................................................................. 3-8

3.5. Australian standards ............................................................................................................... 3-12

3.6. Quality Monitoring Program .................................................................................................. 3-17

3.7. Costs for hypothetical testing regime in the U.S. market ....................................................... 3-19

5.1. Development of the olive oil industry in California ............................................................... 5-4

5.2. The U.S. olive oil industry outside of California ................................................................... 5-7

6.1. CAP reforms for 2013–14 ...................................................................................................... 6-5

Figures 

ES.1. Olive oil: Share of global production and exports, 2008–12 average ................................. xiii

1.1. Production and marketing system for olive oil .................................................................. 1-8

2.1. Olive oil: Share of global production, consumption, exports and imports, 2008–12 

 average ............................................................................................................................. 2-2

2.2. Olive oil: Annual per capita consumption for selected countries, average MY 2007/08– 

 11/12 ................................................................................................................................ 2-9

2.3. Olive oil: Major trade flows in the EU and Mediterranean region, 2008–12 ..................... 2-14

2.4. Olive oil: Major global trade flows, 2008–12 ..................................................................... 2-16

4.1. Sources of U.S. olive oil supply and market channels ........................................................ 4-4

4.2. Average annual U.S. per capita sales, by region, February 2010–February 2013 .............. 4-8

5.1. U.S. olive fruit crushed for oil, 2000–2012 ........................................................................ 5-2

5.2. California olive production regions .................................................................................... 5-5

6.1. Spain: Share of olive hectarage and production by region ................................................. 6-12

6.2. Italy: Share of olive hectarage and production by region .................................................. 6-26

7.1. Tunisia: Share of olive oil milling by region ...................................................................... 7-6

E.1. Expenditure shares for product group 1 (branded, extra virgin, foreign) ............................ E-4
vii

CONTENTS―Continued

Page

Figures—Continued

E.2. Expenditure shares for product group 2 (unbranded, extra virgin, foreign) ........................ E-4

E.3. Expenditure shares for product group 3 (branded, extra virgin, domestic) ......................... E-5

E.4. Expenditure shares for product group 4 (flavored olive oil) ............................................... E-5

E.5. Expenditure shares for product group 5 (other refined olive oil) ........................................ E-6

Tables 

ES.1. Olive oil production characteristics of selected countries ................................................... xviii

1.1. Olive oil grade descriptions ................................................................................................ 1-6

1.2. Olive grove planting densities ............................................................................................. 1-9

2.1. Olive oil: World production, marketing years 1990/91, 2000/01, 2007/08–12/13 ............. 2-5

2.2. Olive oil: Farm-level cost of production by country and production method ..................... 2-7

2.3. Olive oil: World consumption, marketing years 1990/91, 2000/01, 2007/08–12/13 .......... 2-8

2.4. Olive oil: World imports, 2000, 2008–12 ........................................................................... 2-10

2.5. World: Imports of olive oil (HS 1509), 2000, 2008–12 ...................................................... 2-13

2.6. Olive oil: U.S. imports by country (HS 1509), 1990, 2000, and 2008–12 .......................... 2-18

2.7. Olive oil: U.S. imports by product, 1990, 2000, and 2008–12 ........................................... 2-19

2.8. World: Exports of olive oil (HS 1509), 2000, 2008–12 ...................................................... 2-21

2.9. Olive oil: MFN applied and bound tariffs for major importing countries/regions, 

 2011 ................................................................................................................................ 2-22

3.1. Primary biochemical parameters for extra virgin grade olive oil in international 

 standards ........................................................................................................................ 3-6

4.1. U.S. olive oil consumption, by market segment, selected years ......................................... 4-4

4.2. Average extra virgin olive oil price per ounce by brand, February 2010– 

 February 2013 ................................................................................................................. 4-17

4.3. Price elasticities for major olive oil categories ................................................................... 4-19

5.1. United States: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ........... 5-3

6.1. EU: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ........................... 6-1

6.2. Comparison of key production and consumption characteristics in Spain, Italy, and 

 Greece ............................................................................................................................. 6-2

6.3. 2012 EU CAP funding ........................................................................................................ 6-6

6.4. Spain: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ....................... 6-11

6.5. Spain: Exports of olive oil (HS 1509), 2008–12 ................................................................. 6-16

6.6. Constructed comparative costs by production method in Spain ......................................... 6-19

6.7. Italy: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ......................... 6-24

6.8. Italy: Imports of olive oil (HS 1509), 2008–12 ................................................................... 6-29

6.9. Italy: Exports of olive oil (HS 1509), 2008–12 ................................................................... 6-30

6.10. Italian government and EU rural development funds, 2007–13 totals, major olive 

 growing regions and national totals ................................................................................ 6-34

6.11. Greece: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 .................... 6-35

6.12. Greece: Exports of olive oil (HS 1509), 2008–12 ............................................................... 6-39
viii

 

CONTENTS―Continued

Page

Tables—Continued

7.1. Tunisia: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ..................... 7-3

7.2. Tunisia: Exports of olive oil (HS1509), 2008–12 ................................................................ 7-9

7.3. Morocco: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ................... 7-16

7.4. Morocco: Exports of olive oil (HS1509), 2008–12 .............................................................. 7-20

8.1. Chile: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ......................... 8-3

8.2. Australia: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ................... 8-9

8.3. Argentina: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ................. 8-13

8.4. Turkey: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 ..................... 8-18

E.1. Defined product groups and market shares .......................................................................... E-3

E.2. Estimated parameters for 5 product group model ................................................................ E-8

E.3. Estimated price and expenditure elasticities (all olive oil) ................................................... E-9

E.4. Estimated price and expenditure elasticities (all nonflavored olive oil) .............................. E-10

E.5. Price and expenditure elasticities (all nonflavored olive oil), national and Pacific ............. E-11

E.6. Extra virgin elasticities from a nested model ....................................................................... E-12
ix

ACRONYMS 

ADA Morocco Agence pour le Developement Agricole 

AEMO Asociación Española de Municipios del Olivo (Spanish 

Association of Olive Municipalities) 

Agence du Partenariat pour le Proges Agency of Partnership for Progress, or MCA-Morocco 

AOA Australian Olive Association 

AOOPA American Olive Oil Producers Association 

APIA Agriculture Investments Promotion Agency 

CAP Common Agricultural Policy 

CFIA Canadian Food Inspection Agency 

CHILEOLIVA Chilean Association of Olive Oil Producers 

COOC California Olive Oil Council 

COP Code of Practice (Australia) 

COR California Olive Ranch 

CREA Regional Agricultural Experimentation Consortium of 

Argentina 

DAGs 1,2-diacylglycerol 

EC European Commission 

EU European Union 

EVOO Extra virgin olive oil 

FAMEX Export Market Access Fund 

FAS Foreign Agricultural Service (USDA) 

FCIC Federal Crop Insurance Corporation 

FDA Food and Drug Administration 

FFA free fatty acid 

FOPRODEX Export Promotion Fund (Tunisia) 

FOPROHOC Fund for the Promotion of Packed Olive Oil (Tunisia) 

FSDO Special Fund for the Development of Olive Growing Tunisia) 

FY fiscal year 

GFSI Global Food Safety Initiative 

GTIS Global Trade Information System 

ha hectare 

HACCP Hazard Analysis and Critical Control Points 

HD high-density 

HS Harmonized System (global tariff system) 

INTA National Institute of Agricultural Technology (Argentina) 

IOC International Olive Council 

IPA Inward Processing Agreement 

kg kilogram 

MCC Millennium Challenge Corporation 

MFN most-favored nation 

MY Marketing Year 

mt metric ton 

NAOOA North American Olive Oil Association 

NASS National Agricultural Statistics Service 

OECD Organization for Economic Cooperation and Development 

ONH Office National de l'Huile (Tunisian National Olive Board) 

OOPC Promotional Committee for Olive and Olive Oil (Turkey) 
x

 

ACRONYMS—Continued

PDO protected designation of origin 

PET Polyethylene terephthalate 

PGI protected geographical indication 

PPP pyropheophytins 

PSA Private Storage Aid 

PSE Production Support Estimate 

PV peroxide value 

QMP Quality Monitoring Program (USDA) 

SCBGP Specialty Crop Block Grant Program 

SHD super high-density 

SOIVRE Servicio Oficial de Inspección, Vigilancia y Regulación de Las 

Exportaciones (Spanish Office of Export Surveillance, 

Certification, and Regulation) 

SPS Single Payment Scheme 

TL Turkish lira 

TRQ tariff-rate quota 

TurkStat Turkish Statistical Institute 

UAE United Arab Emirates 

UC Davis University of California at Davis 

UF-IFAS University of Florida Institute of Food and Agricultural 

Sciences 

UNAPROL Italian olive growers association 

UNIDO United Nations Industrial Development Organization 

USDA U.S. Department of Agriculture 

UV ultraviolet 

WTO World Trade Organization 

 
xi 

Executive Summary

Introduction 

Starting in the early 1990s, global consumption of olive oil began to increase as the 

product’s appeal spread beyond the Mediterranean region to nontraditional markets. 

Growth in olive oil demand has led to an expansion in global production beyond the 

Mediterranean, and while the region continues to supply almost 97 percent of the world’s 

olive oil, an increasing share is accounted for by so-called “New World” producing 

countries, specifically the United States, Australia, Argentina, and Chile. 

Although U.S. production of olive oil remains small on a global scale, the United States 

is among the nontraditional producing countries that are responding to higher global 

demand, and output has risen quickly in recent years. Between marketing years (MY) 

2007/08 and MY 2012/13,1

 U.S. production increased by 50 percent annually on average, 

albeit from a small base, as producers responded to rising domestic demand and the 

potential profitability of investing in olive groves. But recent investment in U.S. olive oil 

production has slowed in reaction to lower global prices following a succession of 

bumper crops in Spain, and because of concern among U.S. producers that their 

competitive position in the domestic market is threatened by a lack of regulatory 

oversight. 

U.S. and global consumption of olive oil has risen in spite of increased scrutiny from the 

media, government regulators, and policy makers following allegations of fraudulent 

practices in the sector. These practices mislead consumers through either mislabeling or 

adulteration. Mislabeling occurs when olive oil does not meet the standards for the grade 

(usually “extra virgin”) that appears on the label, while adulteration occurs when olive oil 

is blended with other oils, yet is labeled as 100 percent olive oil. Certain widely 

publicized reports concluded that many top-selling brands labeled as extra virgin failed to 

meet the standards established by the International Olive Council (IOC) for this grade. 

According to U.S. producers, mislabeled and adulterated olive oil enters the U.S. market, 

in part, because of a lack of mandatory enforceable product standards and testing in the 

United States. However, a debate has arisen about the correct standards for defining extra 

virgin olive oil and the appropriate mechanisms for enforcing the standards. 

The Committee on Ways and Means (Committee) of the House of Representatives asked 

the United States International Trade Commission (USITC) to examine and report on the 

conditions of competition between U.S. and major foreign olive oil supplier industries.2

The Committee requested that the report cover the period 2008 through 2012. 

Specifically, the Committee asked that the USITC’s report include the following: 

 an overview of the commercial olive oil industry in the United States and 

major supplier countries, including production of olives for olive oil 

 1

 A marketing year spans October 1 to September 30 the following year. Production and consumption 

data are reported by marketing year throughout the report, while trade data is generally provided on a 

calendar year basis. 2

 The request letter is appendix A and Federal Register notice is appendix B of this report. 
xii 

processing, planted acreage and new plantings, processing volumes, 

processing capacity, carryover inventory, and consumption; 

 information on the international market for olive oil, including U.S. and 

foreign supplier imports and exports of olive oil in its various forms, olive 

oil trade between the European Union (EU) and North African countries, 

and a history of the tariff treatment and classification of olive oil in the 

United States and major supplier countries; 

 a qualitative and, to the extent possible, quantitative assessment of the role 

of imports, standards and grading, prices, and other factors on olive oil 

consumption in the U.S. market; and 

 a comparison of the competitive strengths and weaknesses of the 

commercial olive production and olive oil-processing industries in the major 

producing countries and the United States, including factors such as 

industry structure, input production costs and availability, processing 

technology, product innovation, government support and other government 

intervention, exchange rates, and pricing and marketing regimes, plus the 

steps each respective industry is taking to increase its competitiveness. 

Major Findings and Observations 

Global Overview 

World olive oil production, consumption, and trade is highly concentrated in the 

Mediterranean region, primarily in southern EU countries. 

During MY 2007/08–12/13, about 97 percent of the world’s olive oil production and 

80 percent of global olive oil consumption was centered in countries bordering the 

Mediterranean. Within the Mediterranean region, both production and consumption was 

highly concentrated in the EU, with the bulk produced and consumed in Spain, Italy, and 

Greece. During 2008–12, the EU accounted for 87 percent of global olive oil exports by 

volume, made up largely of exports from Spain (52 percent) and Italy (23 percent) (figure 

ES.1). However, intra-EU trade flows comprise the majority of global exports, 

accounting for 57 percent of global export volume during 2008–12. The largest bilateral 

trade flows during this period were Spanish exports to Italy, which accounted for roughly 

one-quarter of global olive oil exports. 

Most of the recent growth in olive oil consumption occurred outside the traditional 

Mediterranean producing and consuming countries. 

A substantial and increasing share of global consumption is by countries that are not 

traditional olive oil producers. In particular, the United States, which accounted for about 

9 percent of world olive oil consumption during MY 2007/08–11/12, is now the world’s 

third-largest olive oil-consuming country, behind Italy and Spain. U.S. consumption has 

risen by more than 50 percent since MY 2000/01 and continues to grow at 4–5 percent 

annually. A key driver of growth is promotional campaigns directed toward healthconscious, high-income consumers highlighting the nutritional benefits of olive oil. 

Australia, Canada, China, and Japan have experienced strong consumption growth as 

well. 
xiii 

FIGURE ES.1 Olive oil: Share of global production and exports, 2008–12 average

 aData covers marketing years 2007/08 through 2011/12. A marketing year spans October 1 to September 30 the 

following year. bTrade data is presented on a calendar year basis, and includes intra-EU trade. 

Major Findings 

International standards for extra virgin olive oil allow a wide range of olive oil 

qualities to be marketed as extra virgin. 

Standards are necessary to guarantee the authenticity, quality, freshness, and safety of 

olive oil. Commercial grades for olive oil established by the IOC have traditionally been 

the benchmark throughout the world. However, in recent years considerable attention has 

been paid to international standards for grading, with the debate focused on the 

appropriate standards for the extra virgin category. The challenge is that the standards 

need to be broad enough to accommodate oil from diverse local olive varieties, but 

narrow enough to protect against fraud and adulteration. Although the term “extra virgin” 

is generally understood to denote the highest quality of olive oil, industry representatives 

report that the current standards are easily met by producers and allow olive oil marketed 

as “extra virgin” to represent a wide range of qualities. 

International standards for extra virgin olive oil are mostly unenforced. 

Despite a proliferation of olive oil standards for grading at the international and national 

level, there are few governmental bodies that enforce these standards along with 

sanctions for noncompliance. Mandatory official testing and sanctions occur in the EU 

and Canada; however, they test only a very small percentage of the oil exported from 

Italy and Spain, the leading global sources. The United States does not have mandatory 

testing, nor does it impose penalties for noncompliance. This lack of enforcement has 

resulted in a long history of fraudulent practices (adulteration and mislabeling) in the 

olive oil sector. 

Other

5.9%

Algeria

1.6%

Morocco

3.8%

Turkey

4.7%

Syria

5.1%

Tunisia

5.3%

Other EU 

3.1%

(2.3% of 

global)

Greece 

14.1%

(10.4% of 

global)

Italy 21.7% 

(16.0% of 

global)

Spain 61.1%

(45.0% of 

global)

Total EU

73.7%

Productiona

Source: International Olive Council (November 2012), 

accessed February 8, 2013.

Total: 3.0 million metric tons

Other

2.5%

Morocco

0.9%

Argentina

1.1%

Turkey

1.4%

Tunisia

7.0%

Other EU 

6.8%

(5.9% of 

global)

Greece 7.1%

(6.2% of 

global)

Italy 26.2%

(22.8% of 

global)

Spain 60%

(52.1% of 

global)

Total EU

87.0%

Exportsb

Total: 1.5 million metric tons

Source: GTIS, Global Trade Atlas database (accessed March 

26, 2013).
xiv 

Broad and mostly unenforced standards lead to adulterated and mislabeled 

products, weakening the competitiveness of U.S.-produced olive oil in the U.S. 

market. 

Broad and unenforced global standards have made it easier to label and sell olive oil as 

“extra virgin” even when it does not meet the quality criteria for that grade, or when it is 

a mix of extra virgin oil and refined olive oil. The lack of enforcement of standards has 

also made it easier to label and sell olive oil blended with other oils (such as sunflower or 

canola) as 100 percent olive oil. Moreover, a wide range of olive oil qualities can be 

marketed as extra virgin, which dilutes the extra virgin category and lowers the value of 

all oils with that label. Because of the wide differences in quality and price among olive 

oils marketed as “extra virgin” in the United States, consumers’ have mixed perceptions 

of extra virgin olive oil. Tighter standards for extra virgin oil would allow high-quality 

producers in the United States and other countries to differentiate their products more 

effectively. 

Efforts to change standards and strengthen enforcement have created tension 

between major supplying countries. 

There are differences of opinion between New World and Old World Mediterranean 

producers, as well as between premium and lower-quality olive oil producers, over what 

the appropriate standards are for oils to meet the extra virgin grade. For example, there is 

disagreement over strengthening the extra virgin standard by using new testing methods 

(e.g. pyropheophytins (PPPs) and 1,2-diacylglycerol (DAGs)) that may detect adulterated 

or degraded olive oil. 

Maintaining existing IOC standards is typically advocated by those who believe that the 

extra virgin category should be more, rather than less, inclusive. Proponents of this view 

include mass-market sellers of extra virgin oil that compete primarily on price, rather 

than on high quality. These producers claim that global trade in olive oil would be 

disrupted by standards that differ by country and that any changes to standards should be 

made through the IOC. More recently, efforts to strengthen standards have been made by 

Australia and the United States. The Australian Olive Association developed its own set 

of standards for domestic olive oil that include new chemical tests, testing of oil in retail 

outlets, and stricter labeling requirements. U.S. domestic olive oil producers are 

considering ways to strengthen official enforcement of olive oil standards in the United 

States, including advocating for a U.S. Department of Agriculture marketing order and a 

U.S. Food and Drug Administration standard of identity for olive oil. 

EU government support programs contribute to higher overall supplies of olive oil, 

reducing global olive oil prices. 

European producers receive significant financial support through a variety of Common 

Agricultural Policy (CAP) programs, including decoupled direct income payments to 

farmers, support for rural development programs, funding for quality improvement 

initiatives, and subsidized storage. Of these, direct payments provide most of the support. 

According to the European Commission’s Directorate-General for Agriculture, these 

payments generally account for between 25 and 50 percent of olive farm income, 

depending on the year and the type of farm. In Spain and Italy, direct payments typically 

range between €400 and €800 per hectare (ha) ($217 to $434 per acre).3

 Because global 

wholesale olive oil prices are determined by the interaction of global supply and demand 

 3

 One hectare is equivalent to 2.471 acres. 
xv 

factors, EU programs that maintain or increase olive oil production by supporting 

otherwise unprofitable farmers reduce prices for global bottlers and marketers. 

Olive oil marketers aim to differentiate their products by brand and level of quality, 

but price remains one of the most important factors in U.S. consumer purchasing 

decisions. This is due, in part, to a lack of consumer awareness of quality differences. 

Competition for sales of olive oil in the U.S. market is affected by a firm’s ability to 

differentiate its products and to market favorable characteristics of their oil. Many 

companies, including U.S. producers, use marketing strategies that highlight 

characteristics such as country of origin, health benefits, quality of the brand, and price. 

However, many U.S. consumers are unfamiliar with the product and unable to distinguish 

quality differences and, as a result, gravitate toward less costly oils. This gives an 

advantage to large olive oil bottlers that focus on “cost leadership” and capture market 

share by selling low-cost imported product. In contrast to the large importers, most U.S. 

producers sell smaller volumes of higher quality olive oil, which is more costly to 

produce and is sold at higher prices. 

U.S. farm-level production costs for olive oil match those of many of its competitors, 

but lack of scale and high capital costs result in higher delivered costs and prices at 

the retail level. 

The majority of U.S. olives for oil production are grown in efficient super-high-density 

(SHD) groves. As a result, at the grower level, the range of costs per kilogram (kg) of oil 

produced overlaps those of other countries. However, lack of scale hinders U.S. firms by 

increasing their unit costs at various stages throughout the supply chain, including 

bottling, transportation, distribution, and marketing. In addition, U.S. producers have 

high capital costs and focus exclusively on producing high-quality extra virgin oil, which 

requires early harvesting and increases costs in other ways. U.S. producers are also 

generally vertically integrated in growing and milling, which increases quality control but 

has typically been associated with smaller-scale production. 

At the retail level, U.S.-produced olive oil is not a significant substitute for foreign 

extra virgin olive oil or other grades of olive oil. 

Using weekly national retail sales data from February 2010 to February 2013, an 

econometric analysis estimated the relationships of demand in the retail market between 

branded foreign extra virgin olive oil, private label extra virgin, domestic branded extra 

virgin, and non-extra virgin olive oils. The results show that of all the categories 

examined, demand for domestically produced olive oil is the least responsive to increases 

in its own price. Moreover, there is little evidence that purchases of domestic branded 

extra virgin olive oil are significantly affected by price changes in the other oil 

categories. This suggests that consumer purchases of domestic olive oil are less 

motivated by price relationships than by other attributes of the product, such as the 

product’s domestic origin or its reputation for high quality. Additionally, demand for 

foreign, private label, and non-extra virgin oils is only minimally affected by changes in 

the price of U.S. domestic oil. This finding may be explained by the fact that domestic oil 

is not available at many retail establishments. 
xvi 

Other Industry Observations 

Sales of Olive Oil in the U.S. Market 

The United States is the world’s second-largest olive oil-importing country, and its 

domestic market is overwhelmingly supplied by imports. 

Imports accounted for 97 percent of U.S. consumption of olive oil in 2012, by volume. 

The United States is the world’s second leading olive oil-importing country behind Italy. 

U.S. olive oil imports have risen significantly since the early 1990s, although the pace of 

growth has dropped sharply during the past five years. Traditionally, Italy and Spain have 

been major suppliers of olive oil to the U.S. market. However, their shares of U.S. 

imports have fallen, mostly because of the emergence of Tunisia, Morocco, Argentina, 

and Chile as suppliers to the U.S. market, particularly at the expense of Italy. 

Approximately two-thirds of U.S. olive oil imports are in consumer-ready bottles, while 

one-third are in bulk. Imported bulk oil is destined for U.S. bottling plants that blend oils 

from other source countries and from diverse olive varieties into preset flavor profiles. 

Olive oil is sold in retail outlets (35–40 percent by volume), to the food service industry 

(e.g., restaurants and hotels) (40–45 percent by volume), and as an ingredient in 

processed foods (20 percent by volume).In the highly competitive U.S. olive oil market, 

many firms that rely on imported oil strive to be low-cost suppliers through economies of 

scale to gain market leadership, aiming to sell higher volumes of olive oil at lower prices. 

Per capita consumption of olive oil in the U.S. market is low but growing rapidly, 

largely due to greater awareness of the health benefits of olive oil. 

Olive oil consumption in the U.S. market has increased steadily over the past decade, 

although per capita consumption remains low in comparison to consumption in 

Mediterranean countries. Olive oil competes with other vegetable oils but, despite its 

higher price, has enjoyed strong growth rates in recent years. This growth is largely 

attributed to consumers’ greater awareness of the health benefits of olive oil. In 2011, 

only 40 percent of U.S. households purchased olive oil, and given the size of the U.S. 

market, even a small increase in this share would have a significant impact on the total 

volume of U.S. consumption. 

U.S. retail consumers are generally unfamiliar with the range of olive oil grades, 

although they tend to favor extra virgin olive oil. 

U.S. consumers generally prefer milder olive oils to strong, pungent, bitter, and flavorful 

ones. However, many consumers remain unfamiliar with the product and do not know 

what product attributes distinguish one quality level from the next. As a result, it is 

difficult for many U.S. consumers to judge what is good value for their money when 

making their olive oil purchases. Nonetheless, retail purchases are concentrated in the 

extra virgin category. There is also a smaller, but growing, consumer market segment for 

olive oil in the United States made up of consumers concerned with natural, organic, and 

gourmet foods. Consumer interest in food quality and sourcing has increased in recent 

years, as has interest in specialty or niche food products. Consumers in this segment are 

willing to pay premiums for higher-quality olive oil. 
xvii 

In the U.S. market, competition between firms and between producing countries 

occurs at different stages along the olive oil value chain.

 

In the U.S. market, competition among firms exists at the retail level where distinct 

business models are used to attract purchases by different types of consumers. Broadly, 

two types of business models are employed—cost leadership aimed at attracting 

consumers that base their purchasing decisions mostly on price, and product 

differentiation aimed at attracting consumers seeking high quality. Competition between 

producing countries primarily occurs further up the value chain—at the bottler level, 

rather than at the retail level. While each olive oil producing country has different 

competitive advantages and disadvantages (table ES. 1), industries in many countries 

(including Spain, Greece, and Tunisia) are oriented toward bulk oil sales to bottlers, 

mainly located in Italy, who blend and bottle oils from many sources. Therefore, 

competition between producing countries is primarily for sales to bottlers, and direct 

competition between countries in the U.S. retail market is minimal. 

Olive Oil Production in the United States 

The U.S. olive oil-producing industry encompasses two distinct business models that 

differ in production practices, scale, and marketing outlets. 

Olive oil is produced on a commercial scale in Texas and Georgia, but California 

accounts for the vast majority of U.S. production. In California, almost 90 percent of 

growers practice traditional low-density or medium-density olive production methods, 

but these account for only about 20 percent of total production. Their operations are 

typically small, with 20 acres or less, and they mostly use manual labor for harvesting. 

Olive oil from this segment typically enters niche marketing chains, such as boutique 

stores, farmers’ markets, roadside stands, and Internet sales. The remaining 80 percent of 

California’s olive oil production comes from SHD groves. These operations are large, 

typically about 100 acres or more; they rely entirely on mechanical harvesting and are 

intensively managed. These large producers typically market their product on retail 

shelves and are more likely to compete directly with imports. U.S. oil produced under 

this system is mainly directed toward the retail market, but smaller volumes are also 

marketed toward food service. 

The U.S. olive oil industry produces high-quality extra virgin olive oil. 

U.S. olive oil producers focus on quality and traceability. Large groves are intensively 

managed to ensure the production of high-quality fruit, and large U.S. olive mills 

mandate that olives delivered to them for milling meet extensive quality standards. Olives 

are harvested at the peak of ripeness, and nearly all olives are milled within 24 hours of 

harvest. These conditions help U.S. olive oils to have low free fatty acid levels (a 

measure of high quality) and positive taste attributes. 

Production in the European Union 

Global olive oil prices are driven by Spanish production. 

On average, Spain produces almost half of the world’s olive oil supply. As a result, 

Spanish production is a main determinant of global prices. Beginning in MY 2009/10, 

Spain experienced three consecutive bumper crops which resulted in a three-year period 
TABLE ES.1 Olive oil production characteristics of selected countries 

 Olive production 

characteristics 

Oil processing characteristics Oil characteristics Competitive advantages 

United States  Mix of artisanal and 

modern, mechanized production 

 Majority of production is 

from SHD groves 

 Modern and efficient 

 Only a few high-capacity mills 

 High-quality extra 

virgin 

 High quality  Growing domestic market  Highly efficient production 

systems 

Spain  Mostly semi-mechanized, 

traditional groves 

 Some large-scale 

intensive and SHD groves 

 Processing done mostly by 

grower-owned cooperatives 

 Large scale, efficient mills 

 35 percent extra 

virgin 

 Wide range of extra 

virgin and lowergrade oils 

 Market power and scale of 

production 

 Low cost of production  Supportive government 

programs 

Italy  Mostly small groves with 

traditional planting densities 

 Mostly hand harvested 

 Large number of small mills 

 Mix of traditional and modern 

mills 

 Hub of blending and bottling oil 

from around the world 

 Mostly extra virgin 

production 

 Wide range of 

grades, qualities, olive varieties, and flavor profiles 

 Reputation for high quality  Recognition of Italian brand  Supportive government 

programs 

Greece  Mostly small groves with 

traditional planting densities 

 Mostly hand harvested 

 Large number of small mills 

 Very few bottlers 

 Mostly flavorful 

extra virgin 

 High quality  Supportive government 

programs 

Morocco  Mostly traditional planting 

densities 

 Mostly hand harvested 

 Large number of small mills 

 Mostly traditional milling 

techniques 

 One-third extra 

virgin 

 Limited volume of 

flavorful and highquality oil 

 Proximity and trade 

preferences with the EU 

 Commercial relationship with 

U.S. bottler 

Tunisia  Mostly traditional planting 

densities 

 Mostly hand harvested 

 Many small mills using traditional 

techniques 

 Growth in modern, highercapacity mills 

 Mild flavor useful 

for blending 

 Proximity and trade 

preferences with the EU 

 Export-oriented government 

support programs 

 Low cost of production 

Chile  Mostly SHD production 

 Mostly mechanical 

harvesting 

 Small number of modern, efficient 

mills 

 Most mills have excess capacity 

that will accommodate growth 

 Mostly high-quality 

extra virgin 

 Reputation for high quality  Low cost of production  Southern hemisphere location 

Australia  Mostly intensive groves 

 Mostly mechanical 

harvesting 

 Modern and efficient 

 Only a few high-capacity mills 

 Mostly high-quality 

extra virgin 

 Reputation for high quality  Southern hemisphere location 

Argentina  Majority of production 

from SHD groves 

 Large number of 

traditional groves still remain 

 Mix of modern, highly efficient 

mills and some using older technologies 

 Concentrated among a handful of 

firms 

 Mostly extra virgin  Southern hemisphere location 

 Variety of microclimates  High number of olive varietals 

Source: Compiled by USITC staff. 

xviii 
xix 

of gradually declining global prices. However, a severe drought in Spain in MY 2012/13 

cut production by more than 60 percent. In response, between June 2012 and January 

2013 producer prices in Italy and Greece rose by approximately 30 percent, while prices 

in Spain increased by about 60 percent. 

Spain is focused on large-scale, low-cost production, most of which is a primary 

input for major international bottling companies. 

Spanish olive oil production encompasses a range of farm types and production methods. 

Generally, Spanish operations are larger than in other EU countries, and economies of 

scale translate into low-cost production. The industry is dominated by a large number of 

grower cooperatives that create scale economies and focus on producing large volumes, 

rather than high-quality oil. Because growers are paid largely on the basis of quantity 

supplied, they typically harvest later in the season in order to maximize the oil content of 

the fruit. However, late harvesting diminishes the quality of their oil due to olive 

degradation. Because much of the Spanish sector is focused on producing large volumes 

instead of quality, it primarily supplies oil in bulk to the large bottling companies in 

Spain and Italy. 

Many Italian growers focus on producing higher-quality oil using mostly traditional 

methods.

Growing and milling are highly fragmented in Italy, with small farms and a very large 

number of small mills. Production in Italy is expensive, but many producers emphasize 

and market the high quality of their oil. Many traditional producers in Italy argue that the 

market power of the large-scale blenders and bottlers drives down prices and makes 

traditional production unprofitable, while at the same time reducing the value of the 

“Italian” brand by marketing lower-quality imported product under Italian brand names. 

Italy plays a key role in the global olive oil supply chain as trader, blender, and 

bottler. 

Olive oil bottled in Italy has name recognition and cachet in export markets, especially in 

the United States. As a result, Italy is home to large companies (including some that are 

Spanish owned) that specialize in blending, marketing, and distribution. Most are not 

vertically integrated into oil production themselves, but instead source bulk oil from mills 

around the world (although mostly from Europe outside Italy), seeking the lowest price. 

These companies create a consistent, mild flavor profile for consumers around the world 

and compete in retail and food service markets on the basis of price, rather than 

competing in markets for higher-valued, more differentiated olive oils. 

Greece produces high-quality oil, though most of its exports are destined to Italy for 

blending and bottling. 

Greece plays an important role in global olive oil production, but little of its oil enters 

world markets as a bottled Greek product. Most Greek olive oil is consumed domestically 

(mostly sold directly by the mill to the final consumer), as Greece has the highest per 

capita olive oil consumption in the world. Of the remainder, most is exported to major 

bottlers in Italy for blending with other extra virgin olive oils from various sources. 

Greek extra virgin oil is recognized by blenders and bottlers as a component that raises 

the overall quality and flavor profile of a blend. Recent industry and government 

initiatives seek to increase Greek oil’s competitiveness by reducing the sector’s 
xx 

dependence on bulk exports to Italy and focusing more on selling differentiated Greek 

product. 

Production in North Africa 

North Africa is the largest olive oil-producing region outside the EU. 

The two largest producers and exporters of olive oil in the region are Tunisia and 

Morocco, which together accounted for 9 percent of global production and 20 percent of 

exports in MY 2011/12. The EU has traditionally provided a reliable export market for 

North African producers due to their close proximity to the EU’s large bottlers. 

Tunisia produces low-cost, neutral-flavored oil that is primarily exported to Italy 

for blending with other oils, then bottled and re-exported around the world under 

Italian brand names. 

Tunisian domestic consumption of olive oil is low in comparison with its production, 

leaving large supplies available for export. Tunisia has historically been an important 

supplier to the Italian market, due to its ability to supply neutral-flavored oil that is ideal 

for blending. Partly because of the olive varieties commonly grown in Tunisia, Tunisian 

olive oil—even oil that meets the IOC’s extra virgin standards—is generally bland, with 

neither a bitter nor a fruity flavor profile. These flavor characteristics are in demand by 

bottlers seeking oils to blend with more bitter and pungent oils from Italy and Greece, in 

order to create oil with a taste profile preferred by many consumers, including those in 

the United States. While this demand ensures a market for low-cost, lower-quality oil, it 

makes it difficult for the industry to move into potentially more profitable marketing 

outlets based on higher-quality, differentiated products. 

Morocco is only a major participant in global olive oil trade during bumper crops, 

since olive oil prices tend to be high in the Moroccan market. 

Despite relatively low per capita consumption levels, olive oil prices in Morocco are high 

relative to global olive oil prices, both at the retail and village level. Producers therefore 

target the domestic market before looking to export. As a result, the amount of product 

available for export is generally quite small, but varies annually because production in 

Morocco is highly dependent on sufficient and timely rainfall. Moroccan exports grew 

dramatically after production reached record levels during MY 2009/10 and MY 2010/11 

owing to ideal weather conditions, resulting in greater availability of supply for export. In 

addition, a commercial partnership established in 2009 between Pompeian Olive Oil 

Company, a U.S. blender, bottler, and marketer of olive oil, and Aïcha, a Moroccan olive 

oil producer, spurred the increase in exports to the United States. With the drop in 

Moroccan olive oil production in MY 2011/12 and 2012/13, supplies available for export 

fell. 

Production in New World and Middle Eastern Countries 

New World Countries produce mostly high-quality extra virgin olive oil, yet face 

challenges in differentiating their products on the global market. 

Over the past decade, olive oil production in Chile, Australia, and Argentina has 

increased dramatically. As in the United States, these countries use mostly modern 

growing and milling techniques, and produce mainly high-quality extra virgin olive oil. 
xxi 

Despite their recent production growth and a rise in their exports, New World producers 

face several challenges restricting their expansion. They must compete with established 

European producers that benefit from scale, government support, and low costs of 

production. They also view the international standards for grading extra virgin olive oil as 

weak, favoring EU producers, and lacking enforcement. According to these producers, 

their challenge is to differentiate their products based on quality when international 

standards allow large volumes of lower-quality oils to be labeled as extra virgin. 

Turkey and Syria are large olive oil producers, though not fully integrated into 

global markets, and prospects for export expansion are uncertain. 

Olive oil is produced throughout the Middle East, but Turkey and Syria are by far the 

largest producing countries. Both Turkey and Syria rely mostly on traditional production 

methods and lack modern equipment, resulting in variable olive oil production volumes 

and qualities. The main sales outlets for both Turkish and Syrian olive oil are their own 

domestic markets and exports to neighboring Middle East countries. The potential to 

expand exports is much greater for Turkey than Syria. In Turkey, planted acreage and 

production continue to expand, potentially providing surpluses for increased exports. In 

contrast, after years of expansion aided by government support, Syrian production and 

exports have declined as a result of the civil war that began in early 2011. For Syria, both 

future production volumes and integration into the global market will depend on ending 

the political unrest. 

1-1

CHAPTER 1 

Introduction 

Overview 

The olive tree is among the oldest cultivated trees in the world, and olive oil has been 

produced and consumed in the Mediterranean region for several millennia. Starting in the 

early 1990s, olive oil consumption began to increase as the product’s appeal spread 

beyond the Mediterranean region to nontraditional markets. Global demand has grown as 

the health benefits of olive oil consumption have become better known1

 and as disposable 

incomes, particularly in developing countries, have risen and allowed for greater 

expenditures on high-value food products. This growth in demand triggered an expansion 

in global production beyond the Mediterranean, and while the region continues to supply 

over 90 percent of the world’s olive oil, an increasing share is accounted for by so-called 

“New World” producing countries outside of the Mediterranean, including the United 

States. At the same time, Mediterranean producers have expanded their sales efforts 

beyond their home markets, where consumption has been stable or even declining. 

Although U.S. production of olive oil remains small on a global scale, the United States 

is among the nontraditional producing countries that are responding to higher global 

demand, and output has risen quickly in recent years, albeit from a small base. Between 

marketing year (MY) 2007/08 and MY 2012/13, U.S. production increased from only 

2,000 metric tons (mt) to 12,000 mt—equivalent to more than 50 percent growth each 

year—as producers responded to rising domestic demand and to incentives derived from 

the use of mechanical harvesting and the low water requirements of olive trees. But 

recently, investment in U.S. olive oil production has slowed because of declining global 

prices following bumper Spanish crops and because of the widespread view among U.S. 

producers that their competitive position in the domestic market is threatened by a lack of 

regulatory oversight. 

Olive oil is not part of the traditional American diet, and its consumption is not nearly as 

widespread as that of soybean or canola oil. It is estimated that only around 40 percent of 

U.S. households purchase olive oil.2

 In 2012, U.S. consumption per capita was just 1 

liter, significantly less than in European countries such as Greece (20 liters) and Spain 

(14 liters). Nonetheless, U.S. olive oil consumption is growing rapidly (5 percent 

annually between 2008 and 2012), while consumption of other vegetable oils is declining. 

In 2012, the United States was the world’s third-largest consuming market by volume 

behind Italy and Spain, and the second-largest importer, behind Italy. Because of recent 

demand growth and currently low levels of per capita consumption, the United States is 

widely viewed by producers and marketers as a market with tremendous growth 

potential. 

 1

 For example, olive oil features significantly in the “Mediterranean diet” that became popular in the 

1990s; this diet emphasizes weight loss and other elements promoting coronary health. 2

 Industry representative, interview by USITC staff, Tuscany, Italy, January 30, 2013; USITC, hearing 

transcript, 128, December 5, 2012 (testimony of Eryn Balch, North American Olive Oil Association). 
1-2

Numerous recent studies and reports have concluded that the olive oil sold both in the 

United States and abroad is often mislabeled or adulterated, resulting in misled 

consumers. Mislabeling occurs when olive oil does not meet the standards for the grade 

(usually “extra virgin”) that appears on the label, or when the oil’s country of origin is 

misrepresented. Adulteration occurs when olive oil is blended with seed oils, yet is 

labeled as 100 percent olive oil. In 2010, the U.S. Department of Agriculture (USDA) 

Foreign Agricultural Service (FAS) classified olive oil as one of the largest sources of 

agricultural fraud in the European Union (EU), based on the high frequency of 

mislabeling.3

 Similarly, a study appearing in the Journal of Food Science showed that 

olive oil was the most commonly referenced adulterated food in scholarly articles from 

1980 to 2010.4

 Reports by the University of California at Davis, Consumer Reports 

magazine, and the Spanish Organization of Consumers and Users, among many others, 

have concluded that when samples have been taken from retail shelves and tested, many 

top-selling brands labeled as extra virgin failed to meet at least one of the standards set 

out by the International Olive Council (IOC) for defining a product as extra virgin olive 

oil. In statements submitted to the U.S. International Trade Commission (Commission or 

USITC), both U.S. producers and importers of olive oil acknowledged that mislabeling 

and adulteration do occur, but they differ on the frequency of which these things are 

happening, the impact they are having on competition, and the proper methods for 

reducing their occurrence. 

According to many U.S. producers, incidences of mislabeled and adulterated olive oil 

entering the U.S. market are, in part, a consequence of a lack of mandatory enforceable 

product standards and testing in the United States.5

 However, the setting of standards and 

establishment of testing protocols is controversial, and an ongoing debate has arisen 

about what the standards for defining extra virgin olive oil should be and the appropriate 

mechanisms for enforcing the standards. The debate is being fueled primarily by the 

“New World” olive oil producing countries (including the United States, Chile, 

Argentina, and Australia), where production systems are characterized by intensive grove 

plantings, heavy use of mechanization, vertical integration, and a focus on producing 

high-quality extra virgin olive oil. New World producers argue, along with many 

premium olive oil producers in the Mediterranean, that mislabeled and adulterated olive 

oil puts premium olive oil producers at a disadvantage by depressing prices for all truly 

extra virgin olive oil and by limiting their ability to differentiate their product. Many New 

World producers also contend that the current IOC standards are weak, that they do not 

use the most modern technology, and that the lack of mandatory testing in the United 

States results in a wide range of qualities being marketed as extra virgin while allowing 

 3

 USDA, FAS, Italy: Olive Oil Update, July 6, 2010, 3. 4

 Moore, Spink, and Lipp, “Development and Application of a Database of Food Ingredient Fraud,” 

2012, 118–26. In April and May of 2007, more than 10,000 cases of containers labeled as extra virgin olive 

oil confiscated from storage facilities in New York and New Jersey by U.S. Food and Drug Administration 

(FDA) inspectors and U.S. marshals were found to contain soybean oil and low-quality olive pomace oil 

(described later in this chapter). FDA, “The Enforcement Story 2007,” 2008, 4–30; AOOPA, written 

submission to the USITC, December 12, 2012, 11. 5

 Industry representatives, interviews by USITC staff, California, November 13–15, 2012; USITC, 

hearing transcript, December 5, 2012 , 11 (testimony of Adam Englehardt, California Olive Ranch).
1-3

widespread mislabeling to occur.6 As a result, most premium olive oil producers favor 

stricter standards, enforced by mandatory and extensive testing.7

 

Opposing this view are certain importers and large-scale producers. Many of these firms

blend and bottle olive oils from all over the world and compete for customers primarily 

on the basis of price. They argue that tighter standards and stricter enforcement would 

increase their costs significantly, because extensive testing is expensive and because 

bottlenecks arising from testing would decrease the efficiency of their supply chains.8

According to the North American Olive Oil Association, such cost increases would 

translate into higher consumer prices, potentially pricing many consumers out of the olive 

oil segment in the United States.9

The Committee on Ways and Means (Committee) of the House of Representatives asked 

the USITC to conduct an investigation and provide a report on the conditions of 

competition between U.S. and major foreign olive oil supplier industries. 10 The 

Committee requested that the report primarily focus on the period 2008 through 2012. 

 The Committee asked for the USITC’s report to include the following: 

 An overview of the commercial olive oil industry in the United States and 

major supplier countries, including production of olives for olive oil 

processing, planted acreage and new plantings, processing volumes, 

processing capacity, carry-over inventory, and consumption; 

 Information on the international market for olive oil, including U.S. and 

foreign supplier imports and exports of olive oil in its various forms, olive oil 

trade between the European Union and North African countries, and a history 

of the tariff treatment and classification of olive oil in the United States and 

major supplier countries; 

 A qualitative and, to the extent possible, quantitative assessment of the role 

of imports, standards and grading, prices, and other factors on olive oil 

consumption in the U.S. market; and 

 A comparison of the competitive strengths and weaknesses of the 

commercial olive production and olive oil-processing industries in the major 

producing countries and the United States, including factors such as industry 

structure, input production costs and availability, processing technology, 

product innovation, government support and other government intervention, 

exchange rates, and pricing and marketing regimes, plus the steps each 

respective industry is taking to increase its competitiveness. 

 6

 Industry representatives, interviews by USITC staff, California, November 13–15, 2012; AOOPA, 

written submission to the USITC, November 28, 2012, 4; USITC, hearing transcript, December 5, 2012, 37 

(testimony of Dr. Selina Wang, University of California at Davis). 7

 Industry representatives, interviews by USITC staff, California, November 13–15, 2012; industry 

representatives, interview by USITC staff, Madrid, Spain, January 21, 2013; industry representatives, 

interviews by USITC staff, Tuscany, Italy, January 31, 2013. 8

 Industry representatives, interviews with USITC staff, Tuscany, Italy, January 30, 2013; North 

American Olive Oil Association (NAOOA), written submission to the USITC, December 17, 2012, 18–20. 9

 NAOOA, written submission to the USITC, December 17, 2012, 58. 10 The request letter is appendix A, and the Federal Register notice is appendix B. 
1-4

Scope of the Report 

In response to the Committee’s request, this report examines the conditions of 

competition among U.S. and major foreign olive oil supplier industries. This 

investigation focuses on olive oil, and consequently the product scope is mostly limited to 

olive oil classified within the Harmonized Tariff Schedule of the United States (HTS) 

heading 1509 (“Olive oil and its fractions, whether or not refined, but not chemically 

modified”). 11 As requested by the Committee, the report provides four types of 

information: (1) information on production, consumption, and trade, with an overview of 

the international market for olive oil; (2) overviews of the commercial olive oil industries 

in the United States and other major supplying countries; (3) analysis of the factors that 

affect the competitiveness of the major olive oil-producing countries; and (4) an 

assessment of the role of imports and other factors, such as standards and pricing, on 

consumption in the United States. 

The remainder of chapter 1 provides an overview of the grades and standards of olive oil, 

as well as the olive oil production process and supply chain. Chapter 2 provides 

information and analysis on production, consumption, and trade worldwide. Chapter 3 

describes the standards that exist globally for determining olive oil grades, as well as the 

effectiveness of the mechanisms used to enforce those standards. In addition, the chapter 

discusses how the current enforcement of standards impacts competition both in the U.S. 

and global olive oil market. The U.S. olive oil market and demand-side factors impacting 

competition in the U.S. market, such as consumer price sensitivity, branding, and 

consumer education, are discussed in chapter 4. Chapters 5 through 8 describe industries 

in the major producing countries, focusing on the supply-side factors, such as production 

methods and producers’ efficiency, that affect their competitive position in the global 

market. Because production methods, cost structures, and quality vary dramatically even 

within the large producing countries, the report attempts to assess competition by grade 

and market segment. Chapter 5 describes production in the United States. Production in 

the EU is covered in chapter 6, with a focus on the major producing countries Spain, 

Italy, and Greece. Chapter 7 describes production in North Africa, specifically Morocco 

and Tunisia. Chapter 8 provides an overview of production in the “New World” olive oilproducing countries whose role in the global market has increased over the last decade, 

specifically Chile, Argentina, and Australia. In addition, the chapter includes a brief 

description of the industries in Turkey and Syria, the two largest Middle Eastern 

producing countries. 

Approach 

As requested by the Committee, this report uses both qualitative and quantitative methods 

to evaluate the global olive oil market. Data were gathered for the report by reviewing 

existing literature and conducting extensive interviews with sources knowledgeable about 

the industry, including representatives from individual firms, trade associations, 

academia, and traders. USITC staff gathered information from individuals and companies 

with operations throughout the supply chain, from the grove to the mill and all the way to 

 11 Certain olive residue oils are classified under the HTS 4-digit code 1510, but these products were not 

critically analyzed because of their lack of importance both in global trade and the U.S. market. 
1-5

the retail shelves. Information was also provided to the Commission at a public hearing, 

where testimony was provided by representatives of the olive oil industry. USITC staff 

also held extensive meetings with both U.S. and foreign government officials. Staff 

traveled to California, Spain, Morocco, and Italy to meet government officials, 

researchers, farmers, cooperatives and trade associations, millers, and bottlers. They also 

interviewed officials at the European Commission (EC) in Brussels. 

USITC staff also used quantitative methods to analyze the global olive oil industry. Data 

on production, consumption, and trade were obtained from a variety of sources, including 

Global Trade Information Services; USITC’s DataWeb, which uses official statistics of 

the U.S. Department of Commerce (USDOC); the IOC; the EC; Italian, Spanish, and 

Moroccan government websites; and the U.S. Department of Agriculture. USITC staff 

analyzed dynamics in the U.S. market by using national and regional Nielsen retail 

point-of-sale data. The Nielsen data covered over 2,000 olive oil products sold in retail 

outlets on a weekly basis during 2010–12, across all regions of the United States. These 

data allowed staff to identify recent consumption trends and preferences in great depth, 

and were used as inputs into an econometric model that estimated how changes in three 

variables—the price of a given olive oil product, the price of competing products, and 

U.S. income—would affect demand for that product. 

Olive Oil Grading and Standards 

The quality of olive oil is an important factor contributing to a producer’s 

competitiveness in the global market, and as mentioned earlier, issues involving quality 

definition, standards, testing, and enforcement have become a considerable source of 

controversy within the sector. Olive oil is classified into distinct grades developed to 

indicate a level of quality depending on a variety of criteria, including method of 

production and oil characteristics, such as acidity, odor, flavor, and the absence of 

defects. Precise definitions and names of each grade of olive oil vary somewhat by 

standard-setting body, but the primary grades used are virgin olive oil, olive oil, refined 

olive oil, and olive pomace oil (table 1.1). Virgin olive oil, by definition, is produced only 

by mechanical processes (i.e., not refined by chemical means). The chemical standards 

also serve to denote purity; olive oil cannot contain other vegetable oils. 

Olive oil is graded using a set of chemical and sensory (e.g., taste and smell) parameters, 

such as levels of free fatty acids, peroxide value, and flavor and fruitiness, and specific 

standards have been established for these parameters.12 The most widely used standards 

for grading olive oil are issued by the IOC, though other standards have been established 

by other international bodies (such as the Codex Alimentarius Commission) and by 

certain national governments. Individual parameter levels and testing methods vary 

slightly depending on the country and standard-setting body. 

 12 For example, the level of free fatty acid in an olive oil is one parameter that determines its grade (the 

lower the level of free fatty acids, the higher the grade). The IOC standards for free fatty acids are less than 

0.8% for extra virgin and less than 2.0% for virgin olive oil. 
1-6

TABLE 1.1 Olive oil grade descriptions 

Grade Description and notes 

Virgin Oils obtained from olives that have not undergone any 

treatment other than washing, decanting, centrifugation, 

and filtration. Virgin oil is obtained during the first 

pressing of whole olives. 

 Extra virgin o The highest grade of virgin olive oil, which 

exhibits some fruitiness and is free of taste 

defects. 

 Virgin o Oil that is fit for human consumption, has 

reasonably good flavor, but may exhibit taste 

defects. 

 Lampante virgin o Virgin oil that is not fit for human consumption 

without further processing and contains flavor 

and odor defects. 

Olive oil Oil that is made from blending virgin and refined olive oil. 

This oil is fit for human consumption and makes up the 

majority of global olive oil sales. 

 

Refined olive oil Olive oil that has been refined into an edible product yet 

maintains the initial glyceridic structure of olive oil. The 

refining process heats the oil to rid it of flavor flaws such 

as rancidity. Refined oil does not contain the same 

beneficial nutrients as virgin oil. 

Olive pomace oil Olive pomace is the solid remains (skins, pulp, seeds, 

etc.) left over from the first press of olives for oil. Olive 

pomace oil is extracted from the pomace using chemical 

solvents and must be refined to be fit for human 

consumption. Once refined, it is typically mixed with 

virgin oils for consumption. 

Source: Compiled by USITC staff. 

Grades and standards have also become a source of controversy within the global 

industry, particularly regarding appropriate standards and testing procedures for the extra 

virgin category of olive oil. Throughout the olive oil industry, it is widely viewed that the 

IOC standards for extra virgin olive oil are broad and allow a wide range of olive oil 

qualities to meet the extra virgin standard.13 Thus, producers of high-quality extra virgin 

olive oil find it difficult to differentiate their product from low-end extra virgin olive oil, 

and this weakens their ability to command a price premium from consumers seeking 

high-quality oils. Certain premium extra virgin olive oils are considered to be the highest 

quality because they easily pass the chemical standards defined by the IOC for extra 

virgin and also have a very fruity and robust flavor profile. On the other hand, lowerquality extra virgin olive oils, many of which consist of blended oils from different 

producers around the world, have chemical traits that typically test at or close to the 

allowable parameters for the extra virgin category, and also have a more neutral, mild 

flavor. Many industry officials claim that by setting standards for extra virgin that are 

easily met, the IOC is favoring the interests of its Mediterranean members that are the 

 13 Industry representatives, interviews by USITC staff, California, November 13–15, 2012; industry 

representatives, interviews by USITC staff, Madrid and Andalucia, Spain, January 21–25, 2013; industry 

representatives, interviews by USITC staff, Meknes, Morocco, January 27–28, 2013; industry representatives, 

interviews by USITC staff, Tuscany and Puglia, Italy, January 30 and February 4, 2013. 
1-7

primary suppliers of lower-quality extra virgin olive oil in the global market instead of 

the interests of consumers.14

Testing, including how to test, what to test, and when to test, is another controversial 

factor complicating the effectiveness of global standards for olive oil. For example, it is 

generally recognized in the industry that no single chemical test can determine an oil 

grade, since olive oil quality depends on several criteria whose attributes change with 

time.15 Olive oil naturally begins degrading from the time of harvest until it is finally 

consumed, and the rate of degradation varies depending on the olive variety and handling 

conditions. As a result, there is also a debate as to the appropriate point in the supply 

chain at which testing should take place. 

Olive Oil Production Process and Supply Chain 

The olive oil supply chain consists of growers, millers, refiners, bottlers, and retailers 

(figure 1.1). Supply chains vary across countries and quality segments, based on different 

degrees of vertical integration and different business models for marketing olive oil to the 

final consumer. However, distinctions occur during the production process as well, 

especially at the farm level where the olives that are the primary driver of total olive oil 

cost and quality are grown. 

Olive Production 

Olive oil production begins in the groves where the olives are grown. The quality and the 

oil content of the olives produced during the growing season depend on several factors, 

including elevation, temperature, humidity, rainfall, soil quality, and slope of the land. 

Farm management practices, such as pruning and harvesting techniques, are also 

important. Proper pruning is required to achieve high yields by keeping the tree size 

manageable, maintaining the surface of the fruiting wood, and increasing light inside the 

canopy. Olive trees have a natural alternate bearing harvest cycle, and proper pruning and 

crop management help to mitigate these year-to-year swings in production. 

The olive variety also affects the flavor profile and perishability of the olive oil produced. 

Certain varieties, such as the Koroneiki commonly grown in Greece and the Coratina 

commonly grown in Italy, produce bitter and pungent oils, while others, such as the 

Picual and Arbequina varieties, produce fruitier oils that are sweeter and slightly less 

bitter. 16 However, it is difficult to generalize the flavor profile of a particular olive 

variety. For example, oil produced from an Arbequina olive in Catalonia, Spain, may 

taste different than an Arbequina oil produced in Andalusia, Spain, because of different 

soil qualities and weather conditions in each region during a particular year. The variety 

 14 USITC, hearing transcript, December 5, 2012, 148–149 (testimony of Leandro Ravetti, Boundary 

Bend Limited); USITC, hearing transcript, December 5, 2012, 157 (testimony of Dr. Rodney Mailer, New 

South Wales Department of Agriculture, Australia); industry representatives, interviews by USITC staff, 

California, November 13–15, 2012. 15 AOOPA, written submission to the USITC, February 12, 2013; USITC, hearing transcript, 

December 5, 2012, 28 (testimony of Bruce Golino, Santa Cruz Olive Tree Nursery and California Olive Oil 

Council). 16 Royal Spanish Academy of Gastronomy, “Olive Oils in 21st Century Gastronomy,” 2010, 77–79, 93. 
1-8 

FIGURE 1.1 Production and marketing system for olive oil

Source: Compiled by USITC staff.

Extra virgin 

and virgin 

olive oil Olive grove Bottler Virgin Mill olive oil Olives

Lampante and 

pomace oil

Refined olive oil

Olive oil 

refinery 

Olive oil

 (blends of refined and v

extra virgin) 

Extra virgin 

olive oil 
1-9 

of an olive also impacts an olive oil’s shelf life. For example, Arbequina oil tends to 

degrade faster than other olive oils even under ideal storage conditions.17

The planting density of the olive trees is a key factor determining the output of an olive 

grove because it affects the amount of olives and olive oil produced per hectare (ha), as 

well as the method used to harvest the olives. Planting densities can range from 50 to 

over 1,000 trees per ha (table 1.2). In traditional groves throughout southern Europe and 

Northern Africa, some of which were planted more than 100 years ago, the spacing 

between trees is vast, often between 30 and 60 feet. As a result, yields may be less than 

1 mt of olives per ha, compared with 13 mt in super high-density (SHD) groves. 

TABLE 1.2 Olive grove planting densities 

Traditional Intensive Super high-density 

Trees per hectare 40–200 200–600 1,000–1,200 

Tree spacing: meters (m) 

between trees 

7–20 m Within rows, 3–4 m; 

between rows, 6–8 m 

Within rows, 1–1.5 m; 

between rows, 3–4 m 

Harvesting method Hand harvested, 

sometimes assisted by 

the use of branch or 

trunk shakers 

Branch shakers or trunk 

shaker 

Over-row mechanical 

harvester 

Yield of olives (mt/ha) 0.5–5.0 6–8 10–13 

Source: Compiled by USITC staff. 

Traditional groves are often located on hillsides, typically are not irrigated, and use 

limited inputs, such as fertilizer. If traditional groves are located on flat land with enough 

rainfall, and proper farm management techniques are used, including pruning and 

fertilizing, yields can increase to 5 mt or higher, but this is rare. The method of 

harvesting, which for many growers is the largest component of their total cost of 

production, also varies depending on planting density. Most traditional and intensive 

groves are harvested by hand, although some use semi-mechanized harvesting methods, 

either with a machine that shakes the trunk of the olive tree or with a long pole with 

hooks and fingers at the end that vibrate and shake the tree foliage. Traditional and semiintensive, semi-mechanized groves account for the majority of global production. 

SHD groves, making up approximately only 2−3 percent of global production, are 

characterized by closer tree spacing, significant tree pruning and maintenance, and fully 

mechanized harvesting. SHD groves require flat terrain to allow harvesting by over-therow mechanical harvesters. SHD groves also need access to enough water for irrigation. 

One of the advantages of SHD production is that olives can be harvested at a specific 

maturity and milled within hours, before the olives start to degrade and ferment. In 

certain producing regions, this capital-intensive production method is especially attractive 

in that it does not rely on unpredictable manual labor for harvest. 

A key decision for growers is when to harvest their crop, because there is a tradeoff 

between oil quality and volume as the harvesting season progresses. Producers of 

premium extra virgin olive oil harvest their olives early in the season (October, 

November, and December in the Northern Hemisphere) before they are fully ripe and 

when the oil content of the fruit is lower. Olives harvested early have low acidity and a 

 17 Royal Spanish Academy of Gastronomy, “Olive Oils in 21st Century Gastronomy,” 2010, 79; 

industry representatives, interviews by USITC staff, Andalucia, Spain, January 23, 2013. 
1-10 

more fruity, or pungent, oil that contains more healthy nutrients, such as polyphenols. 

Olives that are harvested late in the season (January, February, or even March) produce 

lower-quality oil that has a milder flavor and contains fewer beneficial health attributes. 

However, olives harvested later in the season typically have a much higher oil content 

and so provide more output per hectare. This higher oil content translates into lower 

production costs per unit for millers, but at the expense of quality.18

Milling 

After harvesting, olives are delivered to a mill for processing into oil. On arrival, the 

olives are washed and the stray leaves and stems removed. Next, the olives are mashed 

into a paste. In most modern mills, the paste is then moved into a horizontal malaxer 

(mixer) for 20 to 60 minutes depending on olive variety and ripeness of the olives in 

order to allow the small olive oil droplets to combine into bigger ones. Longer 

malaxation times increase oil yields but result in more oxidation, which shortens the shelf 

life of the final product. After malaxation, the oil is separated from the other olive 

components. Historically this was done with large stone presses, but in modern mills, 

decanter centrifuges are used. This phase of the production process varies slightly 

between mills (see box 1.1). The oil coming out of the first decanter centrifuge is 

typically further processed to separate the remaining heavier water from the oil by using a 

second vertical centrifuge that rotates faster.19

BOX 1.1 Olive milling technology 

Olive milling technology has evolved over time. Oil is produced using either stone pressure mills, where olives are 

crushed with a traditional press, or continuous two- or three-phase mills that utilize decanter centrifuges to separate 

the oil from the mash. While stone pressure mills are still in use today, the bulk of global olive oil production is no 

longer produced in this way. Most modern mills use either two- or three-phase decanter centrifuges to separate the 

oil from the other olive components. Two-phase mills use the most recently developed equipment to separate the 

olive mash into oil and a wet pomace, or paste. Alternatively, in the three-phase system, the olive mash is first diluted 

with water in order to reduce the thickness. The decanter then separates the mash into the oil, wastewater containing 

coarse particles, and the olive pomace. While three-phase mills are still very common, many producers have shifted 

to two-phase production because it doesn’t require additional water, produces less waste, and has a smaller overall 

environmental impact.a 

_____________ 

a Intech, Olive Germplasm: The Olive Cultivation, Table Olive and Olive Oil Industry in Italy, December 5, 2012, 

174; Royal Spanish Academy of Gastronomy, “Olive Oils in 21st Century Gastronomy,” 2010, 222; industry 

representatives, interviews by USITC staff, Tuscany, Italy, January 31, 2013. 

 18 Industry representatives, interviews by USITC staff, California, November 13–15, 2012; industry 

representatives, interviews by USITC staff, Madrid and Andalusia, Spain, January 21–25, 2013; industry 

representatives, interviews by USITC staff, Meknes, Morocco, January 27–28, 2013; industry representatives, 

interviews by USITC staff, Tuscany and Puglia, Italy, January 30 and February 4, 2013. 19 Royal Spanish Academy of Gastronomy, “Olive Oils in 21st Century Gastronomy,” 2010, 216–221; 

industry representatives, interviews by USITC staff, Tuscany, Italy, January 31, 2013. 
1-11 

Refining 

Both olive pomace and lampante oils are low-grade oils that must be further processed to 

make them fit for human consumption.20 These oils go through a refining process that 

utilizes both heat and chemicals to neutralize acidity and remove flavor defects, as well 

as deodorize and decolor the oil. This process results in a flavorless, odorless oil that is fit 

for human consumption. Typically, refineries are managed and owned by the companies 

that specialize in bottling and marketing the product. This refined oil is blended by 

bottling companies with virgin oils to create what is commonly marketed as “olive oil.” 

Olive oil products of this type typically include anywhere from 3 percent to 12 percent 

virgin olive oil, with the remainder being refined olive oil.21

 

Bottling and Marketing 

After milling and, if necessary, refining, the oil moves to the bottling and marketing stage 

of the production process. Firms that bottle olive oil typically also market their products, 

targeting different sales outlets and types of consumers. Sales outlets for olive oil are 

retail and foodservice, with each outlet facing consumers with different preferences and 

knowledge about the product. The retail segment is made up of consumers buying olive 

oil that is bottled for home use and sold at grocery stores, farmers’ markets, and gourmet 

and boutique food stores, as well as discount retailers. The food service segment consists 

of restaurants and processed food producers that use olive oil as an ingredient. Olive oils 

distributed in the food service segment are typically of lower quality or grades, sold in 

larger volumes and at lower prices. 

Consumer preferences in the olive oil sector are often driven by knowledge of and 

exposure to the product. Bottlers have to consider these factors when determining how to 

market their product and which segments to target. Many consumers, especially retail 

customers in the United States, prefer milder oil that is neutral in flavor, partially because 

this is the flavor profile they are most commonly exposed to in the oils they use. In the 

United States, according to research conducted by sensory scientists at University of 

California at Davis, a high percentage of consumers see bitterness and pungency, which 

are actually attributes of high-quality, nutritionally beneficial oils, as negative features in 

olive oil. Many consumers prefer oils that are somewhat rancid and musty, even though 

these are defects associated with oils that are not classified as extra virgin.22 But even 

among experienced olive oil consumers, flavor profile preferences vary. Just as a wine 

drinker might prefer one wine varietal over another, many consumers prefer the milder 

taste of buttery and fruity oils over highly spicy, bitter, and pungent-tasting olive oils. As 

a result, bottlers have to determine what type of consumer will demand their product. 

Broadly, bottlers must appeal to one of two consumer types, whether in retail or 

foodservice outlets. First, there are bottlers of premium oils that compete by targeting 

consumers with knowledge of the product, who make their purchasing decision more on 

 20 As noted earlier, pomace oil is produced by extracting oil from the solid olive remains that are left 

after the first press. Olive oil of the lampante grade is a virgin oil from the initial press of olives, but it is 

typically produced from overripe or degraded olives with a high degree of acidity. While these two grades of 

oil account for the majority of refined oils, virgin oils are also occasionally refined, primarily in Spain, when 

the demand and prices for refined oil are high and the market for virgin olive oil is limited. 21 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 24, 2013; industry 

representatives, interviews by USITC staff, Tuscany, Italy, January 30, 2013. 22 Industry representatives, interviews by USITC staff, California, November 14, 2012. 
1-12 

the basis of product attributes (such as fruitiness or bitterness) than price. Premium oils 

are often sold in gourmet food stores to consumers who are less price sensitive. Many of 

the producers targeting the premium extra virgin oil segment of the market are fully 

vertically integrated, owning the olive groves, mills, and bottling facilities. This allows 

them to maintain strict control of the product along the entire supply chain. As noted, the 

olives used for premium oils are harvested early in the season in order to maximize the 

quality and fruitiness of the oil. The olives are milled in smaller, fully traceable batches 

so that the producer can adjust the milling specifications, such as temperature, in order to 

fully highlight the flavor characteristics of the olives being milled. These production 

methods make premium olive oil expensive to produce. 

Second, there are large bottling companies that compete by selling a relatively low-cost 

product, marketed to price-conscious consumers, who typically prefer milder and blander 

oil. These large-scale bottlers, many located in northern Italy and accounting for a 

significant share of the olive oil traded internationally, employ a business model that 

involves less vertical integration. These bottlers neither own groves nor operate mills. 

Instead, they purchase olive oil in bulk from sources all over the world. Typically the 

bottlers receive samples of oils from prospective suppliers, and having tested the oil, 

negotiate a price based on volume, quality, and global market prices. Bottlers then blend 

the oils to create the desired flavor profile, bottle it in retail-ready containers, and market 

it either under their own brand names or private labels.23 By focusing on large-scale 

bottling, these operations benefit from economies of scale that result in lower unit costs 

and an ability to deliver highly price-competitive products to retail and foodservice 

outlets. While these two business models target different segments of the market, they do 

compete for a relatively small number of consumers who know enough about olive oil to 

look for quality and certain flavors, but at reasonable prices. 

 

 23 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 23–24, 2013; industry 

representatives, interviews by USITC staff, Meknes, Morocco, January 27–28, 2013; industry representatives, 

interviews by USITC staff, Tuscany, Italy, January 30, 2013. Not all olive oil producers choose to market 

branded olive oil in the United States. Several firms that produce large volumes of olive oil sell their products 

under a private label, often the retailer’s label and name (e.g., Safeway, Giant, and Publix). 
1-13 

Bibliography 

American Olive Oil Producers Association (AOOPA). Written submission to the U.S. International Trade 

Commission in connection with inv. no. 332-537, Olive Oil: Conditions of Competition between 

U.S. and Major Foreign Supplier Industries, November 28, 2012. 

———. Written submission to the U.S. International Trade Commission in connection with inv. no. 332-

537, Olive Oil: Conditions of Competition between U.S. and Major Foreign Supplier Industries,

December 12, 2012. 

———. Written submission to the U.S. International Trade Commission in connection with inv. no. 332-

537, Olive Oil: Conditions of Competition between U.S. and Major Foreign Supplier Industries,

February 12, 2012. 

Intech. Olive Germplasm: The Olive Cultivation, Table Olive and Olive Oil Industry in Italy, December 5, 

2012. http://cdn.intechopen.com/pdfs/41349/InTech-Olive_mill_by_products_management.pdf. 

Moore, Jeffrey C., John Spink, and Markus Lipp. “Development and Application of a Database of Food 

Ingredient Fraud and Economically Motivated Adulteration from 1980 to 2010.” Journal of Food 

Science 77, no. 4 (April 2012): R118–R126. 

North American Olive Oil Association (NAOOA). Written submission to U.S. International Trade 

Commission in connection with inv. no. 332-537, Olive Oil: Conditions of Competition between 

U.S. and Major Foreign Supplier Industries, December 17, 2012. 

Royal Spanish Academy of Gastronomy. “Olive Oils in 21st Century Gastronomy,” 2010. 

U.S. Department of Agriculture (USDA). Foreign Agricultural Service (FAS). Italy: Olive Oil Update, by 

Cyndi Barmore. GAIN Report no. IT1028, July 6, 2010. 

http://gain.fas.usda.gov/Recent%20GAIN%20Publications/Olive%20Oil%20Update_Rome_Italy

_7-6-2010.pdf. 

U.S. Food and Drug Administration (FDA). “Chapter 4: Center for Food Safety and Applied Nutrition.” 

In The Enforcement Story, Fiscal Year 2007. Washington, DC: FDA, 2008. 

http://www.fda.gov/downloads/iceci/enforcementactions/enforcementstory/enforcementstoryarchi

ve/ucm090298.pdf.

U.S. International Trade Commission (USITC). Hearing transcript in connection with inv. no. 332-537, 

Olive Oil: Conditions of Competition between U.S. and Major Foreign Supplier Industries, 

December 6, 2012. 

 2-1 

CHAPTER 2 

Global Overview

 

Overview 

Global olive oil production, consumption, and trade are centered in countries surrounding 

the Mediterranean Sea (figure 2.1). The Mediterranean climate, with its long, hot, dry 

summers and mild winters, provides ideal growing conditions for olive trees, which have 

been cultivated in the region for several millennia. During marketing years 

(MY) 2007/08–11/12,1

 about 97 percent of the world’s olive oil production came from 

countries bordering the Mediterranean. Within the Mediterranean region, production was 

highly concentrated in the European Union (EU),2

 which supplied close to three-quarters 

of global production—45 percent originating in Spain, 16 percent in Italy, and 10 percent 

in Greece—during this period. Almost one-quarter of global olive oil was produced in 

non-EU Mediterranean countries, led by Tunisia, Syria, Turkey, and Morocco. NonMediterranean countries, most notably Argentina, Australia, and Chile, accounted for a 

very small share of world production, albeit a growing one. The United States was not a 

major producing country, supplying less than one-fifth of 1 percent of world olive oil 

production during MY 2007/08–11/12. 

While global consumption of olive oil is also centered in the Mediterranean region, it is 

less concentrated than production (figure 2.1). Between MY 2007/08 and MY 2011/12, 

Mediterranean countries accounted for about 80 percent of global olive oil consumption, 

led by Italy (23 percent) and Spain (19 percent). Non-EU Mediterranean countries 

consumed about 17 percent of global consumption. An important and increasing share of 

global consumption is by countries that are not traditional olive oil producers, particularly 

the United States, which accounted for about 9 percent of world olive oil consumption 

during MY 2007/08–11/12. 

Like production and consumption, global trade in olive oil is concentrated among 

countries of the Mediterranean region, particularly countries within the EU (figure 2.1). 

During 2008–12, the EU accounted for 87 percent of global olive oil exports (including 

intra-EU exports) by volume, made up largely of exports from Spain (52 percent) and 

Italy (23 percent). However, the vast majority of global exports were intra-EU trade 

flows, which accounted for 57 percent of global export volume during 2008–12. The 

largest bilateral trade flows during this period were Spanish exports of olive oil to Italy, 

which amounted to 358,000 metric tons (mt) (more than $1 billion) annually, roughly 

one-quarter of global export volumes. Outside the EU, Tunisia is the only country with 

significant exports. 

 1

 A marketing year spans October 1 to September 30 the following year. 

2

 Prior to July 1, 2013, EU member states were Austria, Belgium, Bulgaria, Cyprus, the Czech 

Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, 

Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the 

United Kingdom. On July 1, 2013, Croatia became the 28th EU member, but Croatia is not included in the 

aggregated EU data in this report. For the remainder of the report the EU-27 will be referred to simply as the 

EU. 
2-2 

FIGURE 2.1 Olive oil: Share of global production, consumption, exports and imports, 2008–12 average

 aData covers marketing years 2007/08 through 2011/12. A marketing year spans October 1 to September 30 the following year. bIncludes intra–EU trade.

Other

14.0%

Australia

1.4%

Algeria

1.6%

Morocco

2.8%

Syria

3.9%

Turkey

4.0%

United States

9.0%

Other EU 

(9.5% of 

France 6.0%

(3.8% of globa

Greece 

(7.9% of 

Total EU

63.4%

Consumptiona

Source: IOC, “Table 4: [World] and [EU] Consumption,” Nov

Total: 3.0 million metric tons

Other

5.9%

Algeria

1.6%

Morocco

3.8%

Turkey

4.7%

Syria

5.1%

Tunisia

5.3%

Other EU 3.1%

(2.3% of global)

Greece 14.1%(10.4% of global)

Italy 21.7% 

(16.0% of global)

Spain 61.1%

(45.0% of global)

Total EU

73.7%

Productiona

Source: IOC, “Table 1: [World] and [EU] Production,” November 2012.

Total: 3.0 million metric tons

Other

11.1%

Australia

1.9%

Canada

2.2%

Japan

2.3%

Brazil

3.4%

United States

16.7%

Oth(9.4

Germany 6.1%(3.8% of global)

UK 6.3%

(3.9% of global)

Portugal 8.3%

(5.2% of globa

Total EU

62.4%

Importsb

Total: 1.6 million metric ton

Source: GTIS, Global Trade Atlas database (accessed Mar

Other

2.5%

Morocco

0.9%

Argentina

1.1%

Turkey

1.4%

Tunisia

7.0%

Other EU 6.8%(5.9% of global)

Greece 7.1 %

(6.2% of global)

Italy 26.2%

(22.8% of global)

Spain 60.0%

(52.1% of global)

Total EU

87.0%

Exportsb

Total: 1.5 million metric tons

Source: GTIS, Global Trade Atlas database (accessed March 26, 2013).
 2-3 

The EU’s share of global imports (including intra-EU imports) was 62 percent by volume 

during 2008–12, of which Italy accounted for 33 percent (figure 2.1). The United States 

was the second-largest olive oil-importing country during this period, with 17 percent of 

global imports. Other important global importers were Brazil, Japan, Canada, and 

Australia. Although these countries combined accounted for only about 10 percent of 

global imports between 2008 and 2012, imports by each grew dramatically during the 

period. 

The International Olive Council (IOC) is an intergovernmental organization that provides 

a forum for interaction and discussion among the world’s leading olive oil-producing and 

consuming countries. It plays a major role in setting standards for trade (box 2.1). 

Headquartered in Madrid, Spain, the IOC was established in 1959 under the auspices of 

the United Nations. Over time, IOC membership has grown to include the EU and 16 

olive oil-producing countries (Albania, Algeria, Argentina, Croatia, Egypt, Iran, Iraq, 

Israel, Jordan, Lebanon, Libya, Montenegro, Morocco, Syria, Tunisia, and Turkey) that 

account for 90–95 percent of global production. The United States is not a member of the 

IOC. 

BOX 2.1 International Olive Council 

IOC activities cover four major areas.a

 First, it provides economic analysis of the global market by collecting data and 

publishing annual reports on production, consumption, trade, stocks, and prices. Second, the IOC offers its members 

support in technical and chemical aspects of olive oil production. For example, it promotes technology to modernize 

olive growing; it sets standards for physical, chemical, and organoleptic (sensory) characteristics of olive oil; it trains 

and certifies sensory panels to evaluate olive oil from different sources; and it administers voluntary qualitymonitoring programs (such as the North American Olive Oil Association seal).b

 Third, the IOC undertakes product 

promotion, mostly in the form of market studies, promotional campaigns in both member and nonmember countries, 

and media relations. Fourth, the IOC funds and helps disseminate scientific research by multiple sources that 

demonstrates the health benefits of consuming olive oil. 

The IOC is governed by a Council of Members consisting of delegates from member countries (one delegate per 

member). The IOC allocates 1,000 participation shares among its members, with members receiving shares based 

on their average olive oil production and exports over the past six years. In 2013, the EU holds 684 shares, while no 

individual member can receive less than 5 shares. Because the United States is a small global producer of olive oil, it 

would likely receive the minimum 5 shares if it were to become an IOC member.c 

The Council of Members sets up committees and subcommittees that deal with specific aspects of olive oil production 

and trade. Current committees are the Economic Committee, the Technical Committee, the Promotion Committee, 

the Financial Committee, and the Advisory Committee, each composed of one delegate per member. The council 

meets twice a year, and proposals made by the Committees are adopted if more than half the members, accounting 

for 82 percent of the participation shares, approve. However, votes are often postponed until the next Council 

meeting if a consensus is not reached prior to a vote.d 

_____________ 

 a International Olive Council website, http://www.internationaloliveoil.org/ (accessed March 7, 2013). b More information on the NAOOA seal program is provided in chapter 3 and on the NAOOA website 

http://www.naooa.org/sealprogram. c IOC representative, interview by USITC staff, Madrid, Spain, January 21, 2013. d IOC representative, email to USITC staff, July 26, 2013. 

 
 2-4 

Global Production of Olive Oil 

Global Production Trends 

Since the early 1990s, global production of olive oil has more than doubled, exceeding 

3.4 million mt in MY 2011/12 (table 2.1). Production growth was consistent through 

MY 2011/12 until a drought in Spain dramatically reduced global production to 

2.5 million mt in MY 2012/13. Stronger growth occurred in the 1990s than in the 2000s, 

with production rising almost 6 percent annually between MY 1990/91 and 

MY 2000/01.3

 The vast majority of the growth in the 1990s came from the EU, especially 

Italy, Spain, and Greece, following an expansion in the area of productive olive trees, as 

well as improvements in yields.4 Between MY 2000/01 and MY 2011/12, the annual rate 

of global production growth fell to about 2.6 percent. During this period, 40 percent of 

the rise in production came from outside the EU. Growth was especially strong in nonEU Mediterranean countries, such as Syria, Tunisia, and Morocco, where production was 

spurred by domestic and foreign investment that both increased the area planted and 

improved yields through irrigation and modern harvesting methods. 5 During 

MY 2000/01–11/12, production in the EU grew about 2 percent annually, with strong 

growth in Spain and Portugal largely offset by lower production in Italy and Greece. 

According to industry experts, the introduction of decoupled income support under the 

2004 reform of the EU’s Common Agricultural Policy (CAP) led to lower support for 

producers and contributed to the drop in Italian and Greek production.6

 In addition, the 

so-called “New World” producing countries outside the Mediterranean region have 

emerged as important sources of olive oil in recent years, as production from these 

suppliers increased by 9.5 percent annually between MY 2007/08 and MY 2011/12. In 

particular, production in Southern Hemisphere countries Chile and Australia grew rapidly 

during this period. These countries benefit from intensive and efficient production 

methods, counterseasonal production to supply the world’s major markets in the Northern 

Hemisphere, and the ability of exporters to use previously established marketing channels 

for other products, such as wine, to get their olive oil into high-value gourmet food 

markets.7

 

Projections by the IOC for MY 2012/13 indicate a sharp drop in global production 

following a dramatic decline in Spanish production. According to the Spanish Olive Oil 

Agency, Spanish production in MY 2012/2013 fell to only 614,100 mt, a decline of 

62 percent compared with MY 2011/12, following unfavorable weather during much of 

 3 Global olive oil production trends are increasingly influenced by changes in the structure of the world 

market, characterized by increasing concentration of production in the hands of large, multinational bottling 

firms. Industry concentration is also increasing in the retail sector offering branded, private label products. 

Anania and Pupo D’Andrea, “Olive Oil in the Mediterranean,” Winter 2011, 5. 4 European Commission, Eurostat database (accessed March 26, 2013). 5 Mohammad, “Trade in Olive Oil in Syria,” December 2006, 5; Occhinegro, “The Global Market for 

Olive Oil,” June 17–18, 2008; industry representative, interview by USITC staff, Meknes, Morocco, 

January 26–29, 2013. For more information on production trends in these markets, see chapters 7 and 8. 6 Decoupled income support is assistance for producers that is not linked to prices or production. 

According to the WTO Agreement on Agriculture, such support is considered non-trade-distorting. Anania 

and Pupo D’Andrea, “Olive Oil in the Mediterranean,” Winter 2011, 6. More detail on EU policies can be 

found in chapter 6. 7 For more information on production trends and factors of competition in nontraditional markets, see 

chapter 8. 
 2-5 

TABLE 2.1 Olive oil: World production, marketing years 1990/91, 2000/01, 2007/08–12/13 (1,000 mt)

Country/region 1990/91 2000/01 2007/08 2008/09 2009/10 2010/11 a

2011/12 b2012/13

Spain 639.4 973.7 1,236.1 1,030.0 1,401.5 1,391.9 1,613.4 614.1

Italy 163.3 509.0 510.0 540.0 430.0 450.0 450.0 490.0

Greece 170.0 430.0 327.2 305.0 320.0 301.0 295.0 350.0

Tunisia 175.0 130.0 170.0 160.0 150.0 120.0 180.0 220.0

Syria 83.0 165.0 100.0 130.0 150.0 180.0 c

198.0 c198.0

Turkey 80.0 175.0 72.0 130.0 147.0 160.0 191.0 195.0

Morocco 36.0 35.0 85.0 85.0 140.0 130.0 120.0 100.0

Portugal 20.0 24.6 36.3 53.4 62.5 62.9 76.2 68.6

Algeria 6.0 26.5 24.0 61.5 26.5 67.0 54.5 56.5

Jordan 8.0 27.0 21.5 18.5 17.0 27.0 35.5 35.0

Chile (d

) (d) 6.5 8.5 12.0 16.0 21.5 21.5

Australia (d

) 1.0 12.0 15.0 18.0 18.0 19.0 19.0

Lebanon 6.0 6.0 10.5 12.0 9.0 32.0 18.0 18.0

Argentina 8.0 4.0 27.0 23.0 17.0 20.0 32.0 17.0

Libya 7.0 4.0 13.0 15.0 15.0 15.0 15.0 15.0

United States 0.3 0.4 1.4 1.8 2.9 4.1 4.5 8.3

All other 50.3 54.2 59.9 79.6 55.0 90.2 83.4 82.4

 Total 1,452.3 2,565.4 2,712.4 2,668.3 2,973.4 3,075.1 3,407.0 2,508.4

 EU 994.0 1,940.5 2,118.5 1,939.0 2,224.5 2,209.0 2,444.0 1,532.5

 Non-EU, Mediterranean 409.5 596.0 519.5 652.0 671.5 780.5 856.5 881.0

 New World suppliers 48.8 28.9 74.4 77.3 77.4 85.6 106.5 94.3

Source: IOC, “Table 1: [World] and [EU] Production,” November 2012; Government of Spain, Ministry of Agriculture, 

Food and the Environment, Olive Oil Agency website, 

http://aplicaciones.magrama.es/pwAgenciaAO/InfMercadosAceite_BalanCampa.aao?opcion_seleccionada=4000&c

ontrol_acceso=S&idioma=ING (accessed August 5, 2013); California Olive Oil Council representative, email to 

USITC staff, June 11, 2013. 

Note: A marketing year spans October 1 to September 30 the following year. 

 aProvisional. bProjected. 

c

IOC estimates for MY 2011/12 and 2012/13 Syrian production may not take into account the current conditions 

on the ground. Industry representatives reported that Syrian production has declined as a result of the political unrest 

and the outbreak of the civil war. 

 dNot available.

the growing season that significantly reduced yields.8

 As a result of reduced Spanish 

production, global olive production is expected to fall by more than 26 percent. 

Comparison of Oil Production Costs 

While factors such as bottling, distribution, marketing and promotions, and retail margins 

impact the price of olive oil, the oil itself accounts for over half of the final delivered cost 

of olive oil (for more information on the other factors impacting pricing, see chapter 4). 

As a result, the cost of producing oil is an important determinant of production trends and 

competitiveness in the global market. But making fair production cost comparisons is 

difficult because the elements of production systems at the grower level, such as the 

density of the grove, harvesting methods, and the timing of harvest, vary widely across 

global suppliers. In many cases, costs of oil production differ even within individual 

countries and growing regions. Meaningful cross-country comparisons require costs to be 

assessed on both a per hectare and per unit of oil produced basis. This is because growers 

operating intensively managed, highly productive groves typically have higher costs per 

 8

 Government of Spain, Ministry of Agriculture, Olive Oil Agency website, 

http://aplicaciones.magrama.es/pwAgenciaAO/InfMercadosAceite_BalanCampa.aao?opcion_seleccionada=4

000&control_acceso=S&idioma=ING (accessed June 19, 2013). 
 2-6 

hectare (because of high input use), but lower costs per unit of oil produced, compared 

with growers operating more traditional production systems. 

Costs on a per hectare basis vary widely depending on the type of farm and production 

method. Most olive growers in the Mediterranean region farm inherited small family 

plots and use traditional production methods, harvesting olives from trees that may be 

more than a century old. Such growers likely have never made significant investments to 

establish their operations, have minimal or no land costs, use little mechanization, and 

purchase few inputs. Traditional groves are typically labor-intensive operations, but 

because they rely mostly on family labor, labor costs are minimized. Therefore, per 

hectare production costs on traditional olive farms tend to be relatively low (see chapters 

6 and 7). 

In contrast to traditional production systems, newer super-high-density (SHD) 

plantations, such as those in California, and other recently planted intensive groves 

generally carry the burden of high initial investments needed to establish the groves and 

to buy harvest machinery (see chapters 5 and 6). SHD producers in the United States and 

around the world typically face higher fixed production costs than their main global 

competitors (those that account for the majority of traded olive oil).9

 On the other hand, 

while per hectare costs on a SHD farm are higher than on traditional farms, the costs per 

kilogram of oil produced tend to be lower because they have far higher tree densities and 

yields. For example, many SHD farms in California and Spain produce more than 10 mt 

of olives per hectare, compared to between only 1 and 4 mt on most traditional groves. 

Because of the range of cost structures and oil qualities, an itemized cost-of-production 

comparison between U.S. producers and their competitors may oversimplify market 

realities. While there is no single source of data that publishes comprehensive global 

costs of production using a consistent methodology, illustrative production costs on a per 

kilogram of oil produced basis for different production systems are shown in table 2.2. 

For SHD farms in Spain and California, per kilogram of oil production costs can be as 

low as €1.32 ($1.70) and €1.43 ($1.84), respectively, compared with traditional farms in 

Spain, where costs can be as high as €3.06 ($3.95), and in Italy, where they can be up to 

€5.80 ($7.48).10 It is important to note that the cost of production is also impacted by the 

quality of the oil produced. For example, the €5.80 ($7.48) cost represents production 

costs in Tuscany, Italy, where most growers use traditional production methods that 

increase costs in to order improve the quality of the oil produced.11 For more specific 

information on production costs by method and country, see chapters 5−8. The farm-level 

costs of production data given in table 2.2 represent averages and are useful for general 

 9

 Industry representatives, interviews by USITC staff, California, November 14, 2012. Less than 10 

percent of the imported extra virgin olive oil sold at retail in the U.S. market is produced under a strategy 

similar to that of most U.S. olive oils, namely high-quality, single-source oil. The remainder is produced by 

firms that bottle/blend a variety of oils under more of a cost leadership strategy. Nielsen, U.S. Retail Market 

Data, 2013. 10 The 2012 U.S. Federal Reserve annual average exchange rate of 1.29 U.S. dollars per euro was used 

for currency conversions. 11 Premium, artisanal, “estate” extra virgin olive oil producers are typically considered traditional 

because they largely cultivate olives by traditional methods on trees that have been owned for generations. 

They extract oil in small batches with the latest milling technology and market their branded oils both 

domestically (including through agritourism) and in export markets. These producers have a high cost 

structure not only because they harvest their olives early, when the olives have a low oil content, but also 

because they rely on well-trained, experienced labor for harvesting, pruning, and milling. While this highquality approach to the market is similar to that of California SHD producers, their cost structure differs 

because their tree variety and spacing require extensive labor. 
 2-7 

TABLE 2.2 Olive oil: Farm-level cost of production by country and production method 

Country and production method Production cost (€/kg) 

Spain (SHD) 1.32 

Spain (intensive) 1.29 (irrigated)–1.66 (non-irrigated) 

California (SHD) 1.43–2.02a 

Morocco 1.61–2.24 

Spain (traditional) 1.97 (semi-mechanized)– 3.06 (hand harvested) 

Italy 3.53– 5.80b

 

Source: Industry representative, telephone interview by USITC staff, May 6, 2013; industry representative, interview 

by USITC staff, California, November 15, 2012; UCCE, Sample Costs: Sacramento Valley, 2007, 19; AEMO, 

“Aproximación a los Costes del Cultivo del Olivo” [Approximating the costs of olive growing], June 2010; Bungaro, 

“Olio: le novità introdotte dalla nuova legge anti contraffazione” [Oil: new law combating counterfeiting], n.d. (accessed 

May 9, 2013); IOC, Morocco 2012, 8. 

Note: Californian and Italian costs are reported grower costs, while Spanish costs are constructed based on the 

average costs per hectare for each production method in 2009 and oil yields of between 18 and 19 percent per 

kilogram of olives. The Californian costs reflect the range of typical olive yields reported by industry representatives 

using a 16 percent oil content. However, the time of harvest and the corresponding oil content of the olives, which is 

an important determinant of per unit production costs, vary by year, country, and individual grower. 

 aU.S. costs were reported as $6.38 to $9.00 per gallon of oil produced. The 2012 U.S. Federal Reserve annual 

average exchange rate of 1.29 U.S. dollars per euro was used for currency conversions. bThe Italian costs are average costs from two olive oil-producing regions, specifically Puglia and Tuscany, that 

represent the range of costs in Italy. In Puglia, production is more intensive and represents the lower end of the range. 

Production in Tuscany, which represents the upper end of the range, relies heavily on traditional methods and tends to 

be much more expensive. 

comparisons. However, they do not fully account for varying oil yields, which often 

differ depending on the quality of the oil and market segment the producer is targeting. 

As mentioned earlier, overall per unit costs of production are generally higher for highquality olive oil, even without considering whether the olives are grown in traditional or 

intensive groves. This is due to the fact that high-quality oil is produced from just-ripe 

olives, which are harvested earlier and yield less oil than olives that are left on the trees 

longer.12 Correspondingly, growers can harvest olives later in the season in order to 

increase oil content and produce larger volumes of oil per hectare. This practice lowers 

per unit costs, but also reduces the quality of the oil. 

Global Consumption of Olive Oil 

Global olive oil production has risen in response to strong and consistent growth in global 

consumption over the past several decades. World consumption of olive oil grew at 

3 percent annually between MY 1990/91 and MY 2011/12, but the growth rate was much 

higher during the 1990s than the 2000s—4.5 percent annually compared with 2 percent 

annually. Historically the EU was the main driver of global consumption growth, and 

between MY 1990/91 and MY 2000/01, roughly two-thirds of all growth occurred in the 

EU (table 2.3). In part the rise in EU consumption was due to EU-financed promotion 

programs that highlighted the health and quality characteristics of olive oil, as well as 

historical and cultural ties with the product as a food staple. 13 However, since 

 12 Industry representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 13 Anania and Pupo D’Andrea, “Olive Oil in the Mediterranean,” Winter 2011, no. 16, 5. 
2-8 

TABLE 2.3 Olive oil: World consumption, marketing years 1990/91, 2000/01, 2007/08 –12/13 (1,000 mt)

Country/region 1990/91 2000/01 2007/08 2008/09 2009/10 2010/11 a

2011/12 b2012/13

Italy 540.0 729.0 705.0 710.0 675.7 660.0 724.5 695.0

Spain 394.1 580.8 546.3 533.06 539.4 554.2 582.1 550.0

United States 88.0 201.7 240.4 251.6 255.8 272.1 296.2 302.2

Greece 204.0 270.0 264.0 229.0 228.5 227.5 212.5 208.0

Turkey 55.0 72.5 85.0 108.0 110.0 131.0 150.0 160.0

Syria 62.0 110.0 80.0 110.0 120.5 130.5 135.5 135.5

France 28.0 92.0 101.6 113.5 114.8 112.8 111.2 112.5

Morocco 37.0 45.0 65.0 70.0 90.0 100.0 90.0 85.0

Portugal 27.0 60.5 75.8 87.5 87.8 82.0 73.8 73.8

Algeria 7.0 26.0 25.0 55.0 33.5 59.0 57.0 55.5

Australia 13.5 31.0 35.0 37.0 44.0 44.0 44.5 42.5

Japan 4.0 30.0 29.0 30.0 40.5 35.5 42.0 42.0

Tunisia 54.5 58.0 50.0 21.0 30.0 30.0 40.0 40.0

China (c

) (c) (c) 12.0 18.0 29.5 40.0 41.0

Canada 10.0 24.5 29.0 30.0 37.0 40.0 38.5 38.0

Russia 5.0 4.0 17.0 15.0 22.0 21.0 24.0 24.0

Mexico 4.0 6.5 10.0 9.5 9.0 10.0 11.0 11.0

All other 133.4 256.2 390.8 404.4 443.3 519.0 539.4 529.2

 Total 1,666.5 2,590.5 2,754.5 2,831.5 2,902.0 3,061.0 3,210.0 3,137.0

 EU 1,214.5 1,835.0 1,866.0 1,858.0 1,846.0 1,866.5 1,917.0 1,856.9

 Non-EU, Mediterranean 253.5 372.5 396.0 472.5 472.5 559.5 597.5 584.5

 New World suppliers 198.5 383.0 492.5 501.0 583.5 635.0 695.5 695.6

Source: IOC, “Table 4: [World] and [EU] Consumption,” November 2012; USITC staff calculations based on industry 

representatives, email to USITC staff, June 11, 2013.

Note: A marketing year spans October 1 to September 30 the following year. 

 aProvisional. bProjected. cNot available.

MY 2000/01, EU consumption growth has slowed as consumption in both Italy and 

Greece has declined, reflecting the persistent economic weakness in these two 

countries.14 Global consumption is projected to fall in MY 2012/13 to 3.1 million mt, 

about 2 percent lower than in MY 2011/12, mostly from lower consumption in Spain and 

Italy. 

Since MY 2000/01, the vast majority of consumption growth has occurred outside the 

EU, led by the United States, the world’s third-largest olive oil-consuming country 

behind Italy and Spain. U.S. consumption has increased by more than 50 percent since 

MY 2000/01 and continues to grow at 4–5 percent annually. Industry experts view 

promotional campaigns directed toward health-conscious, higher-income consumers that 

focus on the nutritional benefits of olive oil as key drivers of this expansion. Strong 

consumption growth is observed in other high-income countries as well, such as Canada, 

Japan, and Australia.15 Growth in nontraditional markets also has been driven by rising 

per capita income in developing countries, competitive prices for olive oil vis-à-vis other 

vegetable oils, increased availability, and strong promotional campaigns that have 

exposed consumers to olive oil in nontraditional markets, such as China and northern 

 14 Occhinegro, “The Global Market for Olive Oil,” June 17–18, 2008. 15 Bauer, “The U.S. Import Market,” 2011, 26. 
2-9 

Europe.16 Another recent driver of global olive oil consumption has been the trend toward 

more strongly differentiated products, such as organic olive oil and oils with certified 

geographic indications or certified denominations of origin.17

On a per capita basis, Greece is the world’s leading consumer of olive oil, exceeding 

20 liters per person per year, a level that has remained fairly stable over the past 20 years 

(figure 2.2). Spain and Italy are also leading per capita consumers of olive oil, ranging 

between about 12 and 14 liters during MY 2007/08–11/12. In comparison, U.S. per capita 

consumption is just one liter annually, although it has risen steadily over time and is more 

than double the world average. The low level of world per capita consumption, at only 

0.5 liters, implies significant potential for global consumption growth as per capita 

incomes rise and awareness of the product’s positive health attributes increases. 

TABLE 2.4 Olive oil: World imports (HS 1509.10 and 1509.90), 2000, 2008–12 

Product 2000 2008 2009 2010 2011 2012

 Quantity (1,000 mt) 

Virgina 753.5 1,159.2 1,166.5 1,327.1 1,399.5 1,401.0

Refinedb 296.3 315.3 304.5 328.0 329.8 370.9

 All 1,049.7 1,474.6 1,471.0 1,655.1 1,729.2 1,771.9

 Value (million $)

Virgina 1,536.0 4,913.1 4,066.1 4,354.6 4,735.1 4,403.9

Refinedb 634.5 1,251.0 1,008.4 1,017.1 1,025.1 1,028.9

 All 2,170.6 6,164.4 5,097.9 5,399.7 5,800.2 5,432.9

 Unit values ($ per mt) 

Virgina 2,038.6 4,238.3 3,485.7 3,281.4 3,383.4 3,143.5

Refinedb 2,141.7 3,967.1 3,311.9 3,100.5 3,108.7 2,773.8

 All 2,067.7 4,180.5 3,465.6 3,262.5 3,354.2 3,066.1

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

 aOlive oil and its fractions, virgin but chemically modified (HS1509.10). bOlive oil and its fractions, refined but not chemically modified (HS1509.90). 

14 percent annually; value growth fell by 3 percent annually between 2008 and 2012, 

Trends in Global Trade 

 Global Imports 

Global imports of olive oil rose over the past decade, expanding from $2.2 billion in 2000 

to $5.4 billion in 2012 (almost 8 percent average annual growth). This growth was the 

 16 Ibid. 17 Country or region of origin often implies product quality to the consumer. Anania and Pupo 

D’Andrea,“The Global Market for Olive Oil,” 2008. 

0

5

10

15

20

25

Greece Spain Italy Portugal Tunisia Morocco Australia France Canada United

States

World

FIGURE 2.2 Olive oil: Annual per capita consumption for selected countries, average 

MY 2007/08-11/12

Source: Consumption data were sourced from IOC, “Table 4: [World] and [EU] Consumption,” November 2012; 

population data were sourced from the Food and Agriculture Organization database. liters per person
2-10 

result of increases in both trade volumes and unit values (table 2.4). Trade volume grew 

about 5 percent annually throughout the period. The majority of the growth in trade value 

occurred in the first half of the period. Between 2000 and 2008, the value of trade grew 

14 percent on average annually before decreasing 3 percent annually between 2008 and 

2012 as a result of declining prices. Import unit values were generally consistent with 

trends in global olive oil prices, falling sharply during 2008–12; in 2012, they were 27 

percent lower than in 2008. World prices fell during this period largely in response to 

higher production and inventory levels (box 2.2). In addition to the drop in global prices, 

the weakening of the euro vis-à-vis the dollar between 2008 and 2012 pushed down the 

dollar-denominated import unit values even further. 18 

TABLE 2.4 Olive oil: World imports, 2000, 2008–12 

Product 2000 2008 2009 2010 2011 2012

 Quantity (1,000 mt) 

Virgina 753.5 1,159.2 1,166.5 1,327.1 1,399.5 1,401.0

Refinedb 296.3 315.3 304.5 328.0 329.8 370.9

 All 1,049.7 1,474.6 1,471.0 1,655.1 1,729.2 1,771.9

 Value (million $)

Virgina 1,536.0 4,913.1 4,066.1 4,354.6 4,735.1 4,403.9

Refinedb 634.5 1,251.0 1,008.4 1,017.1 1,025.1 1,028.9

 All 2,170.6 6,164.4 5,097.9 5,399.7 5,800.2 5,432.9

 Unit values ($ per mt) 

Virgina 2,038.6 4,238.3 3,485.7 3,281.4 3,383.4 3,143.5

Refinedb 2,141.7 3,967.1 3,311.9 3,100.5 3,108.7 2,773.8

 All 2,067.7 4,180.5 3,465.6 3,262.5 3,354.2 3,066.1

Source: GTIS, Global Trade Atlas database (accessed June 8, 2013). 

 aOlive oil and its fractions, virgin but chemically modified (HS1509.10). bOlive oil and its fractions, refined but not chemically modified (HS1509.90). 

 

 18 For example, between 2008 and 2012, the olive oil price reported for Jaén, Spain, fell from €2,474 to 

€1,891 per mt (a 6.5 percent average annual decline). Because the euro depreciated during this period from 

$1.464 to $1.285, the dollar-denominated Jaén price fell from $3,622 to $2,431 per mt (a 9.5 percent annual 

decline). 
2-11 

BOX 2.2 International olive oil prices 

Since the EU is the largest producer and exporter of olive oil, international prices are largely determined by demand 

and supply in the EU, particularly Spain (which accounted for almost one-half of global olive oil production in MY 

2011/12).a

 Prices paid to producers for extra virgin olive oil are reported for the regions of Bari (Italy), 

Heraklion/Chania (Greece), and Jaén (Spain) (see figure below). These prices not only directly reflect about threequarters of global olive oil supply, but also influence export prices in non-EU producing countries. Prices are largely 

determined by production, consumption, and stock levels in major markets. 

Between 2008 and 2012, prices quoted in all three regions declined, dropping by 6.5 percent annually in Jaén, 

3.7 percent in Heraklion/Chania, and 1.1 percent in Bari over this period. The overall drop in global price can be 

linked to the fact that world production growth outpaced consumption growth for most of this period. This trend was 

led by Spain, where between MY 2007/08 and MY 2011/12, production grew by an average of about 7 percent 

annually, while consumption rose just 1.5 percent annually. As a result, the ratio of inventories to consumption rose to 

almost 30 percent by MY 2011/12. The uptick in prices in the second half of 2012 was a response to the expectation 

of lower global production in MY 2012/13 following poor growing and harvesting conditions in Spain. 

While the Jaén and Heraklion/Chania price series track each other very closely, the Bari price is more volatile and 

tends to diverge from the others, especially during price spikes in mid-2008 and mid-2011. According to EU industry 

representatives, one reason for the divergence is that the Bari price tends to be slightly disconnected from global 

prices, reflecting local supply/demand conditions. Accordingly, the rise in the Bari price beginning in late 2010 was in 

part the result of speculation about a possible poor MY 2010/11 harvest in Puglia and potential shortages. Prices then 

fell sharply once the crop was sold the following summer. Price divergence may also reflect quality and cost 

differences between the oils represented by the Bari and Jaén prices.

_____________ 

a OLIVÆ, “The World Market in Figures,” no. 117, 2012, 30. b EC, DG Agriculture and Rural Development, “Commodity Price Monitoring” (accessed June 20, 2013). 

 1,500

 1,750

 2,000

 2,250

 2,500

 2,750

 3,000

 3,250

 3,500

 3,750

 4,000

2008 2009 2010 2011 2012 2013

Bari (Italy) Heraklion/Chania (Greece) Jaén (Spain)

Selected European extra virgin olive oil prices, 2008–13b

Euros per metric ton
2-12 

Over time there has been a shift in the composition of olive oil trade, with virgin olive oil 

accounting for a higher share of world trade at the expense of refined olive oil 

(table 2.4).19 Between 2000 and 2012, trade in virgin olive oil (HS 1509.10) increased by 

10 percent annually by value, while refined olive oil (HS 1509.90) imports rose by about 

4 percent. As a result, the share of world trade accounted for by virgin olive oil increased 

from roughly 70 percent to 80 percent. While trade data on extra virgin olive oil are not 

available because it is not broken out in the tariff schedule, growth in trade of virgin oils 

was driven largely by rapidly increasing consumer demand for high-quality extra virgin 

olive oils. 

Imports are dominated by the EU, with most trade occurring among EU countries 

(table 2.5, figure 2.3). During 2008–12, the EU accounted for about 60 percent of global 

olive oil trade, in terms of both value and volume. About one-half of global trade was 

accounted for by intra-EU trade flows; in fact, about 90 percent of the olive oil imported 

by EU countries is sourced from other EU countries. Most EU olive oil imports not 

sourced within the EU are from the Mediterranean region, mainly Tunisia and Morocco. 

In addition to proximity to the EU market, several non-EU Mediterranean countries 

receive preferential access to the EU market (box 2.3). 

Italy is by far the world’s leading importing country, accounting for about one-third of 

global trade in olive oil over the past decade, supplied mostly by Spain and Greece. 

Italy’s olive oil imports consist largely of bulk product, which is bottled in Italy and 

exported (see chapter 6). France, Germany, Portugal, and the United Kingdom were 

among the top 10 importing countries during 2008–12, supplied mostly by Italy and 

Spain. Imports by these countries have grown steadily over the past decade in response to 

increased domestic consumption, fueled by rising incomes and consumers’ greater 

awareness of the positive attributes of the product.20

The United States is the world’s second leading olive oil-importing country behind Italy 

(figure 2.4 and table 2.5). U.S. olive oil imports grew significantly starting in the early 

1990s, although the pace of growth fell sharply during 2008–2012. Beginning in 2008, 

the volume of imports rose by about 6 percent annually, while import values fell almost 

2 percent. This divergence can be explained by the 2008–12 drop in olive oil import unit 

values by an average of 7 percent annually for EU suppliers and 8 percent annually for 

non-EU suppliers, with unit values from all suppliers dropping by more than $1,000 per 

mt over the period.21 This follows the pattern of lower world prices discussed in box 2.2 

above. 

 19 International tariff nomenclature is harmonized at the 6-digit level. Olive oil falls under two 6-digit 

codes—HS 1509.10 (olive oil and its fractions, virgin but not chemically modified) and HS 1509.90 (olive oil 

and its fractions, refined but not chemically modified). Because there is no separate code for extra virgin 

olive oil, trade in extra virgin olive oil falls under 1509.10. 20 Datamonitor, Study on the Promotion of Consumption of Olive Oil, 2010. 21 Based on world import unit values for HS 1509. GTIS, Global Trade Atlas database (accessed 

June 19, 2013). 
2-13 

TABLE 2.5 World: Imports of olive oil (HS1509), 2000, 2008–12 (includes intra-EU trade) 

Country 2000 2008 2009 2010 2011 2012

Quantity (1,000 mt) 

Italy 415.7 492.8 470.0 569.0 584.2 559.5

United States 194.4 243.6 260.0 262.3 276.0 306.8

France 83.4 110.3 114.0 113.6 114.3 115.9

Portugal 38.8 76.3 70.5 83.8 87.9 100.6

Brazil 25.9 42.8 44.6 52.5 62.9 73.5

Spain 13.5 56.9 48.3 48.4 47.7 73.3

United Kingdom 43.7 61.0 58.0 62.5 64.7 66.1

Germany 34.4 53.6 60.1 62.1 65.8 65.2

Japan 27.3 29.6 33.1 39.7 36.3 46.4

China 0.2 10.2 12.5 21.3 32.8 41.3

Canada 24.2 32.8 31.0 38.1 39.7 40.1

Australia 27.0 23.7 30.7 36.2 29.5 33.4

All other 121.1 241.0 238.0 265.7 287.5 249.7

 Total 1,049.7 1,474.6 1,471.0 1,655.1 1,729.2 1,771.9

 Total EU 671.1 939.5 911.6 1,036.2 1,071.7 1,082.3

 EU internal trade 564.0 788.7 815.0 952.7 994.0 975.2

 EU external trade 107.8 150.8 96.6 83.5 77.7 107.1

Value (million $) 

Italy 735.1 1,861.7 1,369.6 1,542.0 1,622.0 1,430.0

United States 413.4 1,006.5 879.8 868.6 925.2 938.5

France 176.0 467.2 408.3 384.1 418.9 373.6

Portugal 65.1 279.0 208.1 211.5 227.6 253.8

Brazil 74.5 231.2 210.4 231.6 286.3 311.7

Spain 25.8 204.5 126.2 116.5 119.8 140.9

United Kingdom 87.0 268.3 213.6 208.6 216.0 201.7

Germany 87.8 293.8 273.4 250.8 279.1 253.3

Japan 91.1 176.7 170.6 197.8 185.8 210.3

China 0.4 48.6 50.2 84.0 140.1 158.1

Canada 58.5 155.7 133.1 148.5 156.4 148.2

Australia 62.7 102.9 123.8 140.7 118.3 116.8

All other 293.3 1,068.3 930.7 1,007.3 1,104.7 896.5

 Total 2,178.3 6,164.4 5,097.9 5,399.7 5,800.2 5,432.9

 Total EU 1,284.5 3,802.5 2,953.5 3,085.9 3,291.8 3,016.3

 EU internal trade 1,098.2 3,224.8 2,678.0 2,848.1 3,070.2 2,754.7

 EU external trade 186.3 577.7 275.5 237.8 221.6 261.6

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

 
FIGURE 2.3 Olive oil: Major trade flows in the EU and Mediterranean region, 2008–12 

Source: GTIS, Global Trade Atlas database (accessed June 10, 2013). Note: Trade amounts are shown in thousands of metric tons. 

2-14 
2-15 

BOX 2.3 Trade preferences between the EU and Mediterranean countries 

In 2011, 95 percent of olive oil imports in the EU were from countries surrounding the Mediterranean, both from other 

EU countries, such as Spain, and from non-EU countries, such as Tunisia and Morocco. Trade between EU countries 

(e.g., imports into Italy from Spain) was duty free under the EU customs union. Imports of olive oil into the EU from 

other countries surrounding the Mediterranean (e.g., Tunisia and Morocco) were generally subject to preferential 

rates of duty under tariff-rate quota systems and other arrangements. These systems and arrangements had the 

general effect of permitting most Mediterranean-area olive oil to enter the EU duty-free.a

 

Preferential tariff treatmentb 

Duty rates of “free” are applied to imports of olive oil from Albania, Bosnia and Herzegovina, Kosovo, Montenegro, 

Serbia, Andorra, Croatia, Macedonia, and San Marino. Egypt, Israel, Jordan, and Lebanon all receive quota-free, 

duty-free treatment on refined olive oil (HS 1509.90). The EU has a free trade agreement with Chile in which Chilean 

olive oil enters the EU market without a duty. Preferential rates are also extended to Algeria and Turkey. Imports from 

six countries are subject to tariff-rate quotas, under which the in-quota rate is “free” and the over-quota rate is the 

most-favored nation (MFN) rate. In 2011, the quota amounts were as follows: Algeria, 1,000 mt (HS 1509 and 1510); 

Jordan, 12,000 mt (HS 1509.10); Lebanon, 1,000 mt (HS 1509.10 and 1510); Occupied Territory of Palestine, 3,000 

mt (HS 1509.10); Tunisia, 56,700 mt (HS 1509.10); and Turkey, 100 mt (HS 1509.10). The quota administration 

varies by country. For example, the Tunisian quota is allocated on a monthly basis and the quantity also varies by the 

month. The quota for other countries, such as Jordan and Lebanon, is allocated on a first-come, first-served basis. 

The Inward Processing Arrangement 

Under the Inward Processing Arrangement (IPA), EU member countries may import olive oil from a non-EU source 

duty free, provided an equivalent amount, in terms of quantity and quality, of olive oil is re-exported after it has been 

processed in the EU.c

 Processing activities include blending with other oils and bottling. During 2009–11, about twothirds of EU imports (excluding intra-EU trade) were imported under the IPA, mainly from Tunisia and Morocco, with 

most of the remainder qualifying for duty-free access. 

_____________ 

a Anania and Pupo D’Andrea, “Olive Oil in the Mediterranean,” Winter 2011, 1–6. b EC, COMTEXT database (accessed February 15, 2013); TARIC database (accessed February 15, 2013). c Gil and Ben Kaabia, “Import Demand Analysis for Olive Oil,” 2004, 11.
FIGURE 2.4 Olive oil: Major global trade flows, 2008–12

Source: GTIS Global Trade Atlas database (accessed June 10, 2013). Note: Trade amounts are shown in thousands of metric tons. Intra-EU trade flows are not included. 

2-16 
2-17 

In a written submission to the USITC, the American Olive Oil Producers Association 

(AOOPA) highlighted the role of exchange rates in determining prices on the U.S. 

market. It noted that a few years ago, the high value of the euro (which peaked at 

$1.60 per euro in mid-2008) provided some limited protection for the domestic industry. 

Since then the euro has depreciated to around $1.30, thereby lowering the price of EU 

olive oil when denominated in U.S. dollars.22

Since the early 1990s, Italy and Spain have been major suppliers of olive oil to the U.S. 

market (table 2.6). However, their share of U.S. imports has fallen over time; from a high 

of about 95 percent in 1990, it stabilized at around 80 percent during 2008–12. This is 

mostly because of the emergence of Tunisia, Morocco, Argentina, and Chile as suppliers 

to the U.S. market at the expense of Italy. An important recent trend is the growth of U.S. 

imports from Morocco, which rose from $2 million in 2009 to $61 million in 2011, 

largely driven by bulk imports for bottling in the United States.23 The sharp drop in U.S. 

imports from Morocco in 2012 was a result of a weather-related drop in Moroccan 

production coupled with continued strong growth in domestic consumption in Morocco.24

Other trends can be observed in U.S. olive oil imports over time. For example, an 

increased share of U.S. imports is accounted for by virgin olive oil (table 2.7). In the 

early 1990s, the shares of virgin and refined olive oil imports were roughly 30 percent 

and 70 percent, respectively. By 2000, the shares were roughly even, and by 2012 

imports of virgin olive oil were double those of refined. The trend toward higher imports 

of virgin olive oil reflects increased consumer awareness and stronger demand for higherquality extra virgin olive oils in the U.S. market.25

There has also been a shift toward increasing quantities of U.S. imports of olive oil in 

bulk shipments instead of bottled. U.S. olive oil import data are broken out between 

bottled and bulk. 26 During the 1990s, less than 20 percent of imports were in bulk. 

However, starting in 2008, more and more imports consisted of bulk shipments, and by 

2012, bulk shipments accounted for 38 percent of U.S. import volumes (32 percent by 

value). This near-doubling of bulk imports reflects increased capacity for olive oil 

bottling within the United States as companies have invested in U.S. bottling to improve 

just-in-time delivery capabilities, move quality control systems closer to the final 

consumer, and reduce shipping costs.27

 

 22 American Olive Oil Producers Association, written submission to USITC, February 12, 2013, 26–27. 23 Industry representative, interview by USITC staff, Maryland, December 20, 2012. 24 Industry representative, interview by USITC staff, Meknes, Morocco, January 26–29, 2013. 25 See chapter 4 for a detailed description of recent U.S. market trends in olive oil. 26 The Harmonized Tariff Schedule of the United States (HTS) breaks out olive oil trade by size of 

container (specifically, whether the container holds more or less than 18 kilograms). Imports in containers 

less than 18 kg are considered to be in bottles ready for retail sale, while imports in containers over 18 kg are 

considered to be in bulk. Olive oil in bulk containers is either bottled for retail sale in the United States, or 

directly sold to the food service and ingredients sectors. In 2009, the food service and ingredients sectors 

reportedly accounted for about two-thirds of the olive oil consumed in North America. Datamonitor, Study on 

the Promotion of Consumption of Olive Oil, 2010, 23. 27 Datamonitor, Study on the Promotion of Consumption of Olive Oil, 2010; industry representative, 

telephone interview by USITC staff, July 2, 2013. 
2-18 

TABLE 2.6 Olive oil: U.S. imports by country (HS1509), 1990, 2000, and 2008–12 

Country 1990 2000 2008 2009 2010 2011 2012

Quantity (1,000 mt) 

Italy 75.7 148.4 145.2 145.6 138.1 140.9 155.0

Spain 16.6 28.6 48.6 50.3 66.0 61.5 81.6

Tunisia 1.2 4.7 25.4 34.8 26.5 24.1 39.6

Morocco 0.0 0.1 2.9 0.6 11.4 23.7 5.4

Argentina 0.0 0.5 6.2 9.6 3.4 11.6 5.4

Chile 0.0 0.0 0.3 0.4 1.1 2.4 5.4

Greece 1.3 4.3 4.2 4.7 4.3 4.2 4.8

All other 1.9 7.9 11.1 14.5 12.7 10.0 9.7

 Total 96.7 194.4 243.6 260.0 262.3 276.0 306.8

 EU 95.1 183.2 200.4 202.3 210.4 208.7 243.3

Value (million $) 

Italy 156.6 310.5 619.1 518.7 481.8 509.7 519.5

Spain 34.7 63.3 192.1 164.0 205.1 191.0 220.5

Tunisia 2.8 9.5 96.9 97.1 81.0 73.6 101.4

Morocco 0.1 0.1 9.6 2.0 27.9 61.0 14.7

Argentina 0.0 2.4 23.0 27.0 10.4 32.4 14.2

Chile 0.0 0.0 2.1 2.7 5.0 8.9 16.6

Greece 2.8 10.2 19.3 19.0 17.5 17.6 18.5

All other 4.1 17.4 46.4 52.0 45.0 39.9 32.9

 Total 201.1 413.4 1,006.5 879.8 868.6 925.2 938.3

 EU 197.7 388.8 840.2 707.9 712.1 726.0 766.0

 Unit value ($ per mt) 

Italy 2,069 2,092 4,264 3,563 3,489 3,617 3,352

Spain 2,090 2,213 3,953 3,260 3,108 3,106 2,703

Tunisia 2,333 2,021 3,815 2,790 3,057 3,054 2,561

Morocco (a

) 1,000 3,310 3,333 2,447 2,574 2,722

Argentina (a

) 4,800 3,710 2,813 3,059 2,793 2,630

Chile (a

) (a) 7,000 6,750 4,545 3,708 3,074

Greece 2,154 2,372 4,595 4,043 4,070 4,190 3,426

All other 2,158 2,203 4,180 3,586 3,543 3,990 3,392

 Total 2,080 2,127 4,132 3,384 3,311 3,352 3,059

 EU 2,079 2,122 4,193 3,499 3,385 3,479 3,148

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

 aNot available. 

 
2-19 

TABLE 2.7 Olive oil: U.S. imports by product, 1990, 2000, and 2008–12 

Product 1990 2000 2008 2009 2010 2011 2012

 Quantity (1,000 mt) 

Virgin 

 Bottleda 20.9 75.2 121.1 126.9 122.4 127.9 137.1

 Bulkb

 7.8 17.6 47.6 52.7 58.8 61.3 67.6

 Total 28.7 92.8 168.6 179.6 181.2 189.2 204.7

Other 

 Bottledc

 58.5 90.7 53.9 56.7 51.1 49.9 52.0

 Bulkd

 9.5 10.9 21.1 23.7 30.0 37.0 50.1

 Total 67.9 101.6 75.0 80.4 81.1 86.9 102.1

 Grand total 96.7 194.4 243.6 260.0 262.3 276.0 306.8

 Value (million $) 

Virgin 

 Bottleda 46.2 171.4 549.6 482.6 460.2 496.7 491.3

 Bulkb

 17.1 40.5 184.2 161.4 179.4 184.2 182.6

 Total 63.3 212.0 733.7 644.0 639.6 680.9 674.0

Other 

 Bottledc

 121.7 182.1 200.1 175.9 155.2 151.4 151.0

 Bulkd

 16.1 19.3 72.7 59.9 73.9 92.9 113.5

 Total 137.8 201.5 272.7 235.8 229.0 244.3 264.5

 Grand total 201.1 413.4 1,006.5 879.8 868.6 925.2 938.5

 Unit value ($ per mt) 

Virgin 

 Bottleda 2,209 2,278 4,539 3,803 3,760 3,884 3,583

 Bulkb

 2,192 2,304 3,871 3,062 3,052 3,007 2,703

 Total 2,205 2,283 4,351 3,586 3,530 3,600 3,292

Other 

 Bottledc

 2,081 2,008 3,715 3,101 3,037 3,037 2,901

 Bulkd

 1,701 1,779 3,441 2,525 2,458 2,511 2,268

 Total 2,028 1,983 3,638 2,931 2,823 2,813 2,590

 Grand total 2,081 2,127 4,131 3,383 3,311 3,352 3,059

Source: USITC, Dataweb (accessed June 19, 2013). 

Note: 18 kg of olive oil converts to about 1.4 U.S. gallons. 

 aVirgin olive oil, not chemically modified, in containers under 18 kg (1509.10.20). bVirgin olive oil, not chemically modified, in containers 18 kg or larger (1509.10.40). cNon-virgin olive oil, not chemically modified, in containers under 18 kg (1509.90.20). dNon-virgin olive oil, not chemically modified, in containers 18 kg or larger (1509.90.40). 

Apart from the EU and United States, other major olive oil-importing countries are 

Brazil, Japan, Canada, China, and Australia (figure 2.4 and table 2.5). Brazilian imports 

grew about 15 percent annually between 2008 and 2012, with most sourced from 

Portugal and Argentina. While imports by Japan and Canada grew steadily during 2008–

12, imports by China more than quadrupled over this time period, reaching $158 million 

in 2012. In China, growth in olive oil consumption for home use and by hotels and 

restaurants has been considerable, driven by rising per capita incomes and greater 

awareness of the nutritional and health benefits of olive oil.28

 28 Lazzeri, “The Chinese Olive Oil Sector,” Winter 2011, 9. 
2-20 

Global Exports 

As noted earlier, most global olive oil exports are from countries bordering the 

Mediterranean (table 2.8). Spain is by far the world’s leading exporting country, 

accounting for about half of global exports during 2008–12, with roughly three-quarters 

destined for the EU market (mostly Italy). Italy is the second leading global olive oilexporting country. It has accounted for about 23 percent of global exports since 2008, of 

which close to one-third were sent to the United States. Other EU countries, mainly 

Greece and Portugal, together accounted for about 12 percent of global exports between 

2008 and 2012.29 Major markets for Greece are within the EU, while about one-half of 

Portuguese olive oil is sent to Brazil. The United States is not a target market for either 

country. 

Outside the EU, Tunisia is by far the leading olive oil-exporting country, while Moroccan 

exports have been growing strongly from a low base. Tunisia accounted for as much as 

11 percent of world exports by value in 2008, most destined for Italy and the United 

States. However, its exports dropped sharply during 2009–11, largely because of a fall in 

production associated with poor weather conditions.30 Moroccan exports of olive oil rose 

more than 15-fold from 2008 to 2011, expanding from about 2,000 mt to 30,500 mt. 

Close to 60 percent of Moroccan exports are sent to the United States, with Italy and 

Spain as other important markets. 31 The growth in Moroccan exports resulted from 

increased production following three consecutive years of ideal weather conditions and 

government-supported private sector investment, including planting of high-yielding 

trees and wider use of advanced management practices (see chapter 7).32 In addition, a 

commercial partnership established in 2009 between Pompeian Olive Oil Company, a 

U.S. blender, bottler, and marketer of olive oil, and Aïcha, a Moroccan olive oil producer, 

spurred the increase in exports to the United States.

33 As noted, owing to a shortfall in 

production, Moroccan exports dropped in 2012 to 11,600 mt and are expected to fall 

further in 2013. 

The United States is a small exporter of olive oil. During 2008–12, U.S. olive oil exports 

averaged about $23 million annually (or 7,000 mt). U.S. exports include domestically 

produced oil, but the majority of export shipments are transshipments and imported oil 

that is bottled and then re-exported. 34 While certain U.S. producers have begun using 

trade shows and marketing campaigns to increase awareness in and shipments to 

countries like Japan and China, most U.S. exports consist of bottled virgin olive oil sold 

to Canada and Central America.35

 29 The EU has not used export refunds for olive oil surplus disposal since 1998. 30 AOOPA, written submission to USITC, November 26, 2013, 47. 31 GTIS, Global Trade Atlas database (June 19, 2013). 32 Industry representative, interview by USITC staff, Meknes, Morocco, January 26–29, 2013. 33 Industry representative, interview by USITC staff, Maryland, December 20, 2012; industry 

representative, interviews by USITC staff, Meknes, Morocco, January 26–28, 2013. 34 AOOPA, written submission to USITC, November 26, 2012, 19. 35 GTIS, Global Trade Atlas database (accessed June 19, 2013); industry representative, interviews by 

USITC staff, California, November 15, 2013. 
2-21 

TABLE 2.8 World: Exports of olive oil (HS1509), 2000, 2008–12 (includes intra-EU trade) 

Country 2000 2008 2009 2010 2011 2012

Quantity (1,000 mt) 

Spain 419.3 654.5 661.6 851.7 850.7 826.9

Italy 265.4 306.3 294.4 343.3 363.4 378.0

Tunisia 113.9 169.0 141.7 108.8 100.3 (a

)

Greece 113.4 86.8 92.0 79.7 112.1 128.4

Portugal 19.6 40.4 43.4 54.2 76.7 96.4

Turkey 14.6 17.2 29.7 18.3 12.7 23.5

Syria (a

) (a) 19.2 17.5 (a) (a)

Argentina 6.2 15.6 19.0 12.0 22.2 15.7

Morocco (a

) 2.0 3.1 20.8 30.5 11.6

United States 5.4 6.4 5.4 5.7 7.3 9.3

France 3.6 5.0 5.0 5.7 6.2 6.4

Germany 0.7 3.5 4.6 6.1 5.9 5.0

Australia 0.3 4.1 6.8 5.5 6.6 3.3

All other 9.3 23.9 43.6 25.4 35.0 40.2

 Total 971.7 1,334.8 1,369.3 1,554.7 1,629.7 1,542.9

 Total EU-27 827.8 1,107.5 1,113.6 1,353.3 1,432.4 1,456.7

 EU-27 internal trade 543.6 743.8 740.4 894.7 936.8 898.7

 EU-27 external trade 284.2 363.7 373.2 458.6 495.6 558.0

Value (million $) 

Spain 825.7 2,704.2 2,157.4 2,476.6 2,589.0 2,374.1

Italy 714.7 1,631.1 1,341.8 1,465.5 1,633.1 1,546.0

Tunisia 192.9 620.3 395.7 308.8 286.1 (a

)

Greece 231.6 385.5 324.5 283.1 378.9 416.4

Portugal 54.4 207.4 189.9 215.1 290.1 339.3

Turkey 29.1 71.0 96.2 63.8 49.5 76.5

Syria (a

) (a) 65.7 65.5 (a) (a)

Argentina 23.1 64.5 62.6 42.9 69.9 49.5

Morocco (a

) 7.8 10.0 55.0 75.0 30.3

United States 6.2 23.1 18.9 19.1 24.9 30.1

France 13.0 44.3 36.2 35.9 40.3 38.9

Germany 2.3 21.9 23.7 26.3 29.3 22.7

Australia 0.6 18.3 29.7 21.8 22.7 14.9

All other 22.4 99.6 136.2 106.2 140.0 147.4

 Total 2,115.9 5,898.8 4,888.6 5,183.3 5,628.9 5,085.7

 Total EU-27 1,857.2 5,046.9 4,127.5 4,554.5 5034.2 4,803.8

 EU-27 internal trade 1,097.1 3,120.6 2,484.7 2,655.1 2,910.1 2,638.0

 EU-27 external trade 759.6 1,926.2 1,642.7 1,899.4 2,124.1 2,165.8

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

 aNot available.

International Tariff Treatment for Olive Oil

With the exception of the EU, global tariffs on olive oil are generally low, as indicated in 

table 2.9. Although World Trade Organization (WTO) bound tariffs are as high as 

127.5 percent (Israel) among these countries, applied rates are 10 percent or less, with the 

exception of the EU. In 2011, duty rates of “free” were applied to imports into Australia, 

Canada, Japan, India, and Mexico. The United States imposes tariffs of $34 per mt for 

imports of olive oil in bulk and $50 per mt for bottled, translating into ad valorem 
2-22 

TABLE 2.9 Olive oil: MFN applied and bound tariffs for major importing countries/regions, 2011 (percent) 

 HS 1509.10 HS 1509.90 

Countrya Applied Bound Applied Bound

United Statesb 1 1 1 1

EU-27b 53–72 53–72 49 49

Australia 0 0 0 0

Brazil 10 35 10 35

Canada 0 0 0 0

China 10 10 10 10

Japan 0 0 0 0

India 7.5 45 7.5 40

Mexico 0 45 0 45

Israel 8 127.5 8 127.5

Russia 10 10 10 10

South Africa 10 81 10 81

Saudi Arabia 5 12 5 12

South Korea 8 27 8 27

Switzerland 0 0 0 0

United Arab Emirates 5 15 5 15

Source: WTO, Consolidated Tariff Schedules database (CTS). 

 aCountries listed accounted for more than 96 percent of global imports in 2011. b

Ad valorem equivalent of specific tariffs, calculated using 2011 import unit values. 

equivalent tariffs of about 1 percent. Only the EU imposes significant tariffs on olive oil, 

ranging between €1,226 per mt and €1,346 per mt (roughly $1,650–$1,800 per mt). 

While these tariffs represent ad valorem equivalent tariffs of close to 50 percent or more, 

the vast majority of EU imports are sourced either internally or under preferential trade 

arrangements with non-EU Mediterranean countries, such that only a negligible amount 

of imports are assessed the full MFN rates (see box 2.3). The United States does not 

receive preferential market access for olive oil and U.S. producers report that the high EU 

MFN tariff rates prohibit U.S. sales to the EU in years when supplies might be available 

for export.36 

 

 36 Industry representative, interview by USITC staff, Washington, DC, June 26, 2013. 
2-23 

Bibliography 

AEMO. See Spanish Association of Olive Municipalities. 

American Olive Oil Producers Association (AOOPA). Written submission to the U.S. International Trade 

Commission in connection with inv. no. 332-537, Olive Oil: Conditions of Competition between 

U.S. and Major Foreign Supplier Industries, November 26, 2013. 

Anania, Giovanni, and Maria Rosaria Pupo D’Andrea. “Olive Oil in the Mediterranean: Area, Production, 

Consumption, and Trade.” The CIHEAM Watch Letter no. 16 (winter 2011): 1–6. 

http://utagri.enea.it/sites/default/files/watch_letter_ndeg16.pdf. 

———. “The Global Market for Olive Oil: Actors, Trends, Policies, Prospects and Research Needs.” 

TRADEAG working paper 08/2, 2008. 

Bauer, Bob. “The U.S. Import Market: An Inside View.” OLIVÆ no. 116, 2011. 

Datamonitor. Study on the Promotion of Consumption of Olive Oil and Olives in the USA and Canada. 

Report code CYCM0372, January 20, 2010. 

Drogué, S. “The EU Olive Oil Policy, Recent Evolutions and Perspectives.” INRA and Agro ParisTech. 

Joint Research Unit Public Economics, Working Papers 2006/01, 2006. 

European Commission (EC). DG Agriculture and Rural Development, “Commodity Price Monitoring,” 

http://ec.europa.eu/agriculture/markets-and-prices/price-monitoring/index_en.htm (accessed June 

20, 2013). 

———. Eurostat database. 

http://epp.eurostat.ec.europa.eu/portal/page/portal/statistics/search_database (accessed various 

dates). 

Gil, José M., and Monia Ben Kaabia. “Import Demand Analysis for Olive Oil in the European Union.” 

MEDfrol. European Commission, 2004. 

Global Trade Information Service, Inc. (GTIS). Global Trade Atlas database (accessed various dates). 

http://www.gtis.com/english/GTIS_GTA.html (fee required). 

Gobierno de España. Ministerio de Medio Ambiente, y Medio Rural y Marino. “The Value Chain and 

Price Formation in the Spanish Olive Oil Industry,” January 2010. 

http://www.internationaloliveoil.org/estaticos/view/307-the-olive-oil-value-chain-in-spain. 

International Olive Council (IOC). “Table 1: [World] and [EU] Production.” World Olive Oil Figures, 

November 2012. http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures. 

———. “Table 4: [World] and [EU] Consumption.” World Olive Oil Figures, November 2012. 

http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures. 

Lazzeri, Yvette. “The Chinese Olive Oil Sector: An Emerging Market with High Potential.” CIHEAM 

Watch Letter no. 16 (winter 2011): 8–10. 

http://utagri.enea.it/sites/default/files/watch_letter_ndeg16.pdf. 
2-24 

Mili, Samir. “The Olive Oil Value Chain: International Prospects and Challenges.” Presentation to the 

International Olive Council Advisory Committee, Essaouira, Morocco, June 22, 2010. 

Mohammad, Mohammad Ali. “Trade in Olive Oil in Syria.” Commodity Brief no. 11. Ministry of 

Agriculture and Agrarian Reform, National Agricultural Policy Center, December 2006. 

http://napcsyr.net/dwnldfiles/divisions/tpd/pubs/comd_brf/en/09_cbrf_olive_oil_trade_mm_en.pdf. 

Occhinegro, Massimo. “The Global Market for Olive Oil: Issues and Prospects in the Mediterranean 

Basin.” Presentation for the Cal/Med Consortium workshop “Mediterranean Products in the 

Global Market,” Cetraro, Italy, June 17–18, 2008. 

http://aic.ucdavis.edu/calmed/calmed4/Occhinegro,%20Cetraro.pdf. 

OLIVÆ, “The World Market in Figures,” no. 117, 2012. 

Spanish Association of Olive Municipalities (AEMO). “Aproximación a los Costes del Cultivo del 

Olivo.” [Approximation of the costs of olive cultivation]. Presentation prepared for AEMO 

seminar, June 2010. 

United States International Trade Commission (USITC) Interactive Tariff and Trade Database (USITC 

DataWeb)/U.S. Department of Commerce (USDOC). http://dataweb.usitc.gov (accessed various 

dates). 
3-1 

CHAPTER 3 

Olive Oil Standards and Enforcement 

Overview

In the United States, quality standards are intended to ensure that only acceptable-quality 

products are in the U.S. marketplace, support consumer satisfaction, encourage repeat 

purchases, and thereby increase sales for the good covered by the standard.1

 For olive oil, 

the benchmark for standards internationally is set by the International Olive Council 

(IOC).2

 The IOC’s members account for the vast majority of global olive oil production, 

and its standards are intended to establish quality and purity levels for olive oil traded 

internationally. To do so, the standards provide classifications for distinct quality grades, 

prohibit olive oils containing other edible oils, and require that virgin olive oils be 

extracted only by mechanical processes (i.e., not by chemical means). 

In recent years, a growing segment of the global olive oil industry has expressed concerns 

about current IOC standards for olive oil, particularly those for extra virgin. A principal 

concern is that the standard for extra virgin olive oil is too broad, thereby allowing a wide 

range of olive oil qualities to be classified as extra virgin. With increasing amounts of 

olive oil being produced outside the traditional Mediterranean growing region, the 

challenge is for standards to be broad enough to accommodate olive oils extracted from 

the diverse olive varieties grown worldwide, but at the same time narrow enough to 

protect against fraud and adulteration.3

 Tighter extra virgin standards would allow highquality producers that can meet them, such as those in the United States, to further 

differentiate their product. At the same time, while official enforcement is necessary to 

guarantee compliance with standards, currently few governmental bodies provide such 

enforcement with sanctions for noncompliance. Many producers believe that broad and 

unenforced olive oil standards work to the advantage of unscrupulous producers and fail 

to benefit both high-quality producers and olive oil consumers. 

The Importance of Standards and Enforcement for Olive Oil 

Competitiveness 

For most agricultural products, grades and standards are important to producers because 

they provide a way to differentiate their products from those of competitors. Product 

differentiation involves highlighting product traits that consumers see as desirable and for 

which they are willing to pay extra. In the case of olive oil, standards include the “extra 

virgin” grade, which is generally understood by consumers to denote the highest-quality 

oil and thus allows them to differentiate among olive oil products. However, according to 

industry representatives, the current global standards for the extra virgin grade are so 

 1

 USDA, AMS, “International Marketing.” 

2

 The IOC, an intergovernmental organization created in 1959 under the auspices of the United Nations 

for the olive and olive oil sector is responsible for administering the International Agreement on Olive Oil 

and has established commercial grades for olive oil. 3

 IOC representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 
3-2 

broad that olive oil currently marketed as “extra virgin” contains a wide range of qualities 

and sells at a wide range of prices. 4 In the United States, because of these wide 

differences in quality and price, even within the extra virgin grade, consumers find it 

difficult to tell what is truly high quality and what is good value. If extra virgin standards 

were tighter, producers that could meet them, such as U.S. producers of high-quality 

extra virgin olive oil, could further differentiate their products. U.S. producers believe 

that the high quality of U.S. olive oil will drive consumption of their product, much as it 

has for other commodities produced in California, if the product can be differentiated 

with the help of tighter standards.5

In addition to product differentiation, the establishment and enforcement of standards for 

agricultural products can help ensure the integrity of the label and authenticity of the 

product. In the case of olive oil, there is a long history of fraud (adulteration and 

mislabeling) in the sector.6

 In part this stems from the lack of enforcement of olive oil 

standards, leading to sales of olive oil labeled as “extra virgin” that does not meet the 

standards for that grade. Lack of standards enforcement has also allowed extra virgin oil 

blended with refined (“soft deodorized”) olive oil to be sold as extra virgin, and has 

allowed olive oil blended with seed oils to be sold as 100 percent olive oil.7

 

Recent studies and press reports support U.S. producers’ claim that some “extra virgin” 

oils purchased by U.S. consumers do not, in fact, meet the extra virgin grade criteria.8

Such reports have been echoed in various other countries by both producer and consumer 

groups. U.S. producers and importers of olive oil both acknowledge the need for 

enforcement of standards in the United States. However, the two sides disagree on the 

extent to which noncompliant olive oils can be found in the market, the impact that those 

oils are having on competition in the U.S. market, and the type and frequency of testing 

that should be required to ensure compliance with standards.9

 The North American Olive 

Oil Association (NAOOA), an industry trade organization representing importers, 

maintains that random testing of supermarket samples shows that less than 2 percent of 

oils sold at retail have evidence of adulteration. Similarly, the IOC reports that less than 

10 percent of the 200 oils it samples annually show any chemical anomalies that suggest 

 4

 Industry representatives, interviews by USITC staff, California, November 13–15, 2012; industry 

representatives, interview by USITC staff, Madrid, Spain, January 21, 2013; industry representative, 

interview by USITC staff, Tuscany, Italy, February 4, 2013; industry representatives, telephone interview by 

USITC staff, February 15, 2013; Gustafson and Lybbert, “What’s Extra Virgin?” University of California, 

n.d. (accessed June 18, 2013). 5

 California olive oil producers specifically attributed the growth in U.S. pistachio production and 

consumption to the industry’s focus on high quality, which is enforced by U.S. mandatory grade standards. 

USITC hearing transcript, December 5, 2012, 116 (testimony of Gregg Kelley, California Olive Ranch). U.S. 

producers also mentioned grapes, almonds, walnuts, and tomatoes as specialty Mediterranean crops produced 

in California that have become globally competitive through a focus on high quality. USITC hearing 

transcript, December 5, 2012, 17 (testimony of Gregg Kelley, California Olive Ranch); USITC hearing 

transcript, December 5, 2012, 54 (testimony of Adam Englehardt, California Olive Ranch). 6

 USITC hearing transcript, December 5, 2012, 119 (testimony of Tom Mueller, Author); Moore, 

Spink, and Lipp, “Development and Application of a Database of Food Ingredient Fraud,” 2012, 118–26; 

Mueller, “Slippery Business,” August 13, 2007. 7

 Soft deodorized olive oil is produced through a process of “soft-column deodorization” which 

involves allowing the oil to react to steam at a temperature of 230–40 degrees Celsius to eliminate off flavors 

and odors. Olive oils treated with this process are considered refined and therefore do not meet the standard 

for the extra virgin and virgin grades. 8

 Chen, “Forget the IRS,” May 17, 2013; Aubrey, “U.S. Olive Oil Makers,” December 6, 2012; Frankel 

et al., “Report: Tests Indicate,” July 2010. 9

 NAOOA, written submission to the USITC, February 12, 2013, 3; AOOPA, written submission to the 

USITC, November 28, 2012, 4. 
3-3 

mislabeling of an oil’s appropriate grade. 10 On the other hand, an analysis by the 

University of California, Davis, concluded that 73 percent of samples from the top-selling 

brands failed sensory tests (e.g., taste and aroma) for extra virgin olive oil and that 

28 percent of samples failed at least one IOC chemical test for extra virgin olive oil.11 

Key to any discussion of olive oil standards and enforcement is identifying the reasons 

why extra virgin olive oils may fail chemical and sensory tests. While considerable work 

is ongoing, olive oil testing is not yet foolproof in this area.12 It is widely agreed that 

olive oil adulteration with seed oils has become a less significant problem globally and in 

the U.S. market, likely attributable to lower olive oil prices relative to prices of common 

adulterant seed oils.13 Mislabeling, however, is more of a problem, and U.S. industry 

representatives report that there are currently two main enforcement challenges in the 

U.S. market: detecting old and/or rancid oils that do not meet the extra virgin standard 

(an issue of quality), and detecting oils labeled extra virgin that are actually adulterated 

with soft deodorized oil (an issue of purity). 14 The quality issue is particularly 

problematic. According to U.S. industry representatives, it is not clear if the olive oils 

labeled extra virgin that fail IOC extra virgin tests were intentionally mislabeled at the 

time of production, or whether they met the chemical tests at the time of bottling but 

subsequently degraded in transit or on retail shelves (box 3.1).15 

Olive Oil Standards

Creating universal and internationally accepted grade standards for olive oil is difficult 

because the chemical composition of olive oil varies naturally, based on olive variety and 

country of origin. The challenge is to create standards that are broad enough to 

accommodate the naturally occurring chemical differences in regional olive varieties, yet 

are narrow enough to protect against fraud and adulteration. 

Chemical and Sensory Testing Criteria 

There are two methods of testing whether olive oil meets the standards for specific 

grades: chemical and sensory (“organoleptic”). It is generally recognized in the industry 

that no single chemical test can determine the grade of an olive oil. Rather, the levels of 

several chemical compounds must be measured and, for extra virgin and virgin, the 

results must be confirmed by sensory analysis. Testing is complicated by olive oil’s 

natural perishability, which results in changes in chemical composition over time. Some 

chemical tests measure levels of certain chemical compounds related to quality, while 

others measure purity (box 3.2). Sensory testing is deemed necessary to determine extra 

 10 NAOOA, “Frequently Asked Questions on Recent Olive Oil News,” February 2012; Olive Oil Times,

“IOC Weighs in on Davis Study,” n.d. (accessed June 18, 2013). 11 Frankel et al., Evaluation of Extra-Virgin Olive Oil, April 2011. 12 Industry representative, telephone interview by USITC staff, February 5, 2013. 13 Industry representative, interview by USITC staff, Puglia, Italy, February 4, 2013; USITC, hearing 

transcript, December 5, 2012, 171 (testimony of Dr. Rodney Mailer, Charles Sturt University); industry 

representative, interview by USITC staff, Rome, Italy, February 1, 2013; industry representative, telephone 

interview by USITC staff, February 5, 2013. Estimates are that less than 10 percent of olive oil is adulterated 

with other seed oils. Industry representative, telephone interview by USITC staff, February 5, 2013. 14 Industry representative, telephone interview by USITC staff, February 5, 2013. 15 Ibid. 
3-4 

BOX 3.1 Olive oil perishability and quality 

Many U.S. consumers, including distributors and marketers, fail to realize how perishable olive oil is. Olives and olive 

oil begin degrading from the time of the olive harvest as heat, light, and oxygen speed up the enzymatic breakdown 

of the olives and the oil, creating rancidity. Thus the shelf life and quality of olive oil depends on various factors 

throughout the production and distribution chain. The olive variety, method of harvest, condition of harvested olive, 

time from harvesting to milling, type of milling/extraction system, and length and type of olive oil storage all affect both 

the olive oil’s quality and its shelf life.a Because olive oil is so perishable, its quality is further determined by the 

methods used in the bottling, handling, and distribution stages. For example, millers and bottlers may top off olive oil 

storage tanks as well as individual bottles with nitrogen to slow oxidization.b Metal tins or tinted glass bottles also aid 

in shielding the oil from oxygen and light.c

 

The shelf life and freshness of an olive oil are typically signaled to consumers through a “best before” date on the 

label, although this is not mandatory for U.S. olive oil labels. From a producer’s perspective, an ideal shelf-life 

designation adequately reflects the freshness of the oil when bottled, but also is long enough to cover the time the oil 

spends in transit and sitting on a retail shelf. Until recently, shelf life for olive oil was generally accepted as 

approximately two years. However, some industry representatives now note that whether any extra virgin olive oil will 

remain fresh and continue to meet the extra virgin standard for two years depends on a number of factors, particularly 

the olive variety used, the quality of the oil at bottling, and storage and handling conditions throughout production and 

distribution. Some in the industry favor shorter time frames for “best before” dates to ensure that the consumer buys a 

quality product, or advocate including a harvest date on the label to give the consumer more information about 

freshness.d

 Some producers are conducting research on appropriate “best before” dates for specific oils, but most 

agree that more needs to be done.e

 

Most in the industry agree on the need for a “best before” date, even though this is difficult to mandate and there is 

disagreement about how to calculate it. Bottlers tend to favor a requirement for a “best before” date based on the 

bottling date, because they do not produce the oil and may not be able to vouch for a harvest date. Some large 

bottlers would also like to see the rest of the distribution chain be more responsible in handling their olive oil products 

and take responsibility for olive oil that has degraded throughout the distribution chain and on retail shelves.f 

_____________ 

a Industry representatives, interviews by USITC staff, Tuscany and Puglia, Italy, January–February 2013. b Industry representatives, interviews by USITC staff, Andalusia, Spain, January 23–24, 2013. c Polyethylene terephthalate (PET) plastic bottles, although popular for packaging in the United States, are more 

porous than glass and may be less effective at protecting olive oil from light and oxygen. Industry representative, 

interview by USITC staff, Andalusia, Spain, January 24, 2013. d Industry representative, interview by USITC staff, Madrid, Spain, January, 22, 2012. e Industry representative, interview by USITC staff, Andalusia, Spain, January 24, 2013. f Industry representative, interview by USITC staff, Madrid, Spain, January 22, 2013.

BOX 3.2 Olive oil chemistry 

Certain chemical criteria, such as levels of peroxide, free fatty acids (FFAs), and ultraviolet (UV) absorbency, have 

traditionally been recognized as crude indicators of olive oil quality by indicating the extent to which the oil has 

degraded at the time of testing.a

 FFA and peroxide levels rise when enzymes in the olive and olive oil break down 

from exposure to heat, light, and oxygen over three oxidation phases. Neither free fatty acids nor peroxide are 

discernible by human senses, but both are a prelude to rancidity. At the same time, these tests are not definitive 

indicators of age: both new and older oils can have high FFA levels, and peroxide levels can rise and then fall over 

time during the oil’s secondary oxidation phase. For this reason, UV absorbance values, which rise during secondary 

oxidation, are a better indicator of age. In addition, testing for levels of other chemical compounds, such as linoleic 

acid and campesterol, can indicate olive oil purity by detecting possible adulteration with refined olive oil or seed oils, 

which have different chemical structures than olive oil.b

_____________ 

a Olive Oil Times, “Olive Oil Analysis Discussed,” May 7, 2012. b Mailer, “Chemistry and Quality of Olive Oil,” August 2006. 
3-5 

virgin status, which requires the oil to have no sensory defects and to manifest at least 

some positive olive fruitiness, bitterness, or pungency. Trained tasters can sense defects 

in the oil that go undetected by chemical means, and which can be described by terms 

such as “winey-vinegary,” “musty,” “fusty,” and “rancid” (box 3.3). 

BOX 3.3 Olive oil sensory testing 

IOC grading standards require that extra virgin olive oil be free of sensory defects and have some positive sensory 

attributes, traits which, to date, can only be judged by a tasting panel. Therefore the IOC requires sensory, or panel, 

testing to assess oil as being virgin or extra virgin grade. With this method, a panel of human evaluators record their 

sensory responses to the products being tested. Statistical analysis is then employed to generate inferences and 

insights regarding the product.a

 An olive oil that meets all chemical standards for the extra virgin grade can still fail to 

make the grade if a certified sensory panel finds that the positive sensory attributes are absent and/or a defect is 

present. 

The IOC provides written sensory evaluation standards for olive oil, including definitions of sensory properties and 

defects and a point system for assigning grades or classifications; it also prescribes methods of panel training and 

certifies laboratories evaluating olive oil. In a panel test, a group of 8 to 12 trained panel testers taste and evaluate 

the olive oils in testing rooms. The IOC recommends that a maximum of four olive oil samples be evaluated in each 

session, with a maximum of three sessions per day, per tester, to avoid tasting fatigue. In addition, palates should be 

cleansed between samples and a minimum of 15 minutes should elapse between sessions. 

Given these time requirements and the time and cost needed to train a panel tester, sensory panel testing can be a 

bottleneck, especially in view of the vast amount of virgin and extra virgin olive oil that is globally traded and 

marketed. The Organizzazione Nazionale Assaggiatori Olio de Oliva (Italy’s national association of olive oil testers) 

reports that there currently are not enough trained olive oil panelists worldwide.b

 The number of active panels 

necessary to test the globally available volume of extra virgin olive oil has been estimated at 1,000,c

 yet in Spain, the 

largest single-country producer of olive oil, there were only 13 IOC-accredited sensory panels in 2013.d

 

While many premium producers argue that sensory testing is necessary in order to identify oils that are low quality 

but can still pass chemical tests, the NAOOA says that sensory panel testing brings with it problems of its own, 

including the subjectivity of panel testers and a potential lack of harmonization among panels.e In the EU, official 

testing allows for some subjectivity in panel testing in that if an extra virgin sample fails one panel test, it can be sent 

to a “referee panel” for a second opinion.f According to NAOOA, the Organizzazione Nazionale Assaggiatori Olio de 

Oliva reports that “in roughly 25 percent of the cases in Spain the panels do not agree.”g

 Because of these 

drawbacks, global industry is researching ways to identify chemical markers in extra virgin olive oil that match official 

sensory terms.h If such methods were found and accepted by all industry players, it would relieve the uncertainty 

surrounding sensory panel testing for extra virgin olive oil. 

_____________ 

 a ASTM, “Sensory Evaluation Methods.” (accessed June 18, 2013).

b Industry representative, interview by USITC staff, Tuscany, Italy, January 30, 2013. c Industry representative, telephone interview by USITC staff, February 5, 2013. d IOC, “List of Laboratories,” December 2012. 

e NAOOA, written submission to the USITC, February 12, 2013, 5; industry representatives, interviews by USITC 

staff, Puglia, Italy, February 4, 2013. f Industry representative, interview by USITC staff, Maryland, December 20, 2012. 

g NAOOA, written submission to the USITC, February 12, 2013, 4. 

h USITC, hearing transcript, December 5, 2012, 109–11 (testimony of Dr. Selina C. Wang, UC Davis). 

The parameters for key chemical compounds for extra virgin olive oil set by various 

standard-setting bodies are presented below (table 3.1). Differences in current standards 

tend to involve acceptable levels of free fatty acids (linolenic, linoleic, oleic acid, and 

others), which can indicate oil quality; of sterols (particularly campesterol), which can 

indicate the presence of seed oil; and of alkyl esters, pyropheophytins (PPP), and 1,2-

diacylglycerol (DAG), which may indicate that olive oil is old or has been produced 
3-6 

TABLE 3.1 Primary biochemical parameters for extra virgin grade olive oil in international standards 

 

IOC Codex EU USDA 

California 

Olive Oil 

Council 

North 

American 

Olive Oil 

Association 

Australian 

Olive 

Association 

Free fatty acid A crude indicator of 

quality based on the 

hydrolytic breakdown 

of fatty acid chains. 

≤ 0.8% ≤ 0.8% ≤ 0.8% ≤ 0.8% ≤ 0.5% ≤ 0.8% ≤ 0.8% 

Peroxide value 

(PV) 

A crude indicator of 

the amount of 

oxidation that has 

taken place in the oil. 

≤ 20 ≤ 20 ≤ 20 ≤ 20 ≤ 20 ≤ 20 < 20 

UV coefficients 

(K232) 

A more delicate 

indicator of oxidation, 

particularly of that 

caused by heat in the 

refining process. 

Measuring oil’s UV 

light absorbancy 

indicates the quantity 

of certain oxidized 

compounds that 

resonate at certain 

wavelengths. 

≤ 2.5 ≤ 2.5 ≤ 2.5 ≤ 2.5 ≤ 2.5 ≤ 2.5 ≤ 2.5 

Alkyl ester Elevated levels can 

indicate oil made from 

fermented olives or 

adulterated with 

refined olive oil. 

75 mga na 75 mg na na na na 

Linolenic acid Elevated levels can 

indicate adulteration 

with vegetable oil. 

≤ 1.0 na ≤ 1.0 ≤ 1.5 na na ≤ 1.5 

Campesterol Elevated levels can 

indicate adulteration 

with vegetable or 

refined olive oil. 

≤ 4.5b ≤ 4.0 ≤ 4.0 ≤ 4.5 na na ≤ 4.8 

Pyropheophytins 

(PPP) 

Elevated levels of 

PPP can indicate 

oxidation or 

adulteration with 

refined olive oil. 

na na na na na na ≤ 17 

Diacylglycerols 

(DAG) 

Reduced levels of 1,2 

DAG can indicate 

oxidation or 

adulteration with 

refined olive oil. 

na na na na na na ≥ 35 

Source: Devarenne and Vossen, Understanding the USDA Olive Oil Standards, September 2010; Codex Alimentarius, Standard for 

Olive Oils and Olive Pomace Oils, 2009; Mailer, A World Tour of Olive Oil Standards, n.d; California Olive Council, “The Certification 

Process.”; IOC, “Nota de Prensa,” May 27, 2013. 

 aIn May 2013, the IOC adopted new parameters for alkyl esters in the extra virgin standard. Beginning in October 2013, the 

current 75 mg/kg limit for alkyl esters will be replaced by a limit of 40 mg/kg for ethyl esters only in MY 2013/14, then to 35 mg/kg in 

MY 2014/15, and 30 mg/kg in MY 2015/16. 

 bIn May 2013, the IOC adopted a new upper limit for campesterol of 4.5 in the extra virgin standard. For oils that contain more 

than 4 percent but less than 4.5 campesterol, additional tests are required.
3-7 

from poor-quality olives, or that extra virgin oil has been blended with soft deodorized 

olive oil. 

International Standard Setting 

Several international bodies are involved with standards for olive oil. Some bodies set 

limits on biochemical compounds for various grades of olive oil, others approve scientific 

methods for determining their levels, and some do both. The IOC, the Codex 

Alimentarius Commission (Codex), 16 the European Commission, and many national 

governments set standards which specify limits on certain key biochemical compounds in 

olive oil for grading purposes. The American Oil Chemists Society, the IOC, the 

International Standards Organization (ISO), the Association of Analytical Communities 

International, and the European Committee for Standardization are involved in 

developing and setting methods for analyzing olive oil composition. 

The IOC, an intergovernmental organization created in 1959 under the auspices of the 

United Nations for the olive and olive oil sector (see chapter 2, box 2.1), is responsible 

for administering the International Agreement on Olive Oil and has established 

commercial grades for olive oil. IOC standards have traditionally been the benchmark for 

olive oil standards throughout the world, because until recently nearly all olive oil was 

produced in IOC-member countries. For example, the Codex olive oil standards are 

closely aligned with those of the IOC. In addition, some national olive oil standards are 

based on the IOC standards and/or the Codex standards with or without modifications 

(see table 3.1). These countries include the United States, where the U.S. Department of 

Agriculture (USDA) revised its standards for olive oil in 2010. USDA standards for olive 

oil closely match those of the IOC, even though the United States is not an IOC member 

(box 3.4). 17 Following the revision of the USDA standards, U.S. producers have 

advocated for certain other core tests for extra virgin. 18 Often in reaction to perceived 

shortcomings of national grading standards, olive oil producer industry organizations in 

various countries have devised their own (in some cases more stringent) industry 

standards, particularly for extra virgin olive oil (see table 3.1). 

Debate Over International Standards 

In recent years, considerable attention has been given to the standards used for grading 

olive oil, mostly focused on IOC standards for extra virgin olive oil. There appears to be 

an overall consensus within the global industry that the current IOC standards for extra 

 16 Codex is a United Nations organization through which member countries, including the United 

States, formulate and harmonize international food standards. 17 The revised USDA olive oil grade standards include the same requirements as the IOC standard 

except for slightly higher limits for linolenic acid and campesterol to account for domestic variation from the 

IOC limits. Also, the IOC definition for “ordinary olive oil” is not included in the U.S. standards because of 

its limited recognition and unpalatability. For this reason, the revised U.S grade standards involve eight 

grades instead of nine. 75 Fed. Reg. 22363 (April 28, 2010). 18 U.S. producers advocate for the core tests for extra virgin to be free fatty acids (FFA), peroxides 

value (PV), UV coefficients (UV), panel test (PAT), pyropheophytins (PPP), and diacylglycerols (DAGs). 

Except for the PPP and DAGs, all of these tests are currently required by the IOC standard. For refined olive 

oils and their blends, they would be free fatty acids, peroxides value, UV coefficients, fatty acid profile 

(FAP), sterols (STE), and erythrodiol and uvaol (E+U). AOOPA, written submission to the USITC, 

February 12, 2013, 15. 
3-8 

BOX 3.4 U.S. participation in the IOC 

 

Membership in the IOC requires official government participation because it obligates the member country to adopt 

and enforce the International Agreement on Olive Oil, an international treaty. Members must also fund the 

organization, provide it with statistical data, and incorporate its norms and standards into national laws. The United 

States is not a member of the IOC, but it has observer status, which allows it to follow the technical work undertaken 

in the IOC committees. The U.S. government states that for both policy and financial reasons it does not wish to 

become a member of the IOC.a

One issue is the standards developed by the IOC for grading olive oil. The United States views these standards as 

not representative of all global olive oil production due to the IOC’s weighted voting structure, which, according to 

U.S. government officials, keeps the IOC from currently being recognized as a standards-setting body by the World 

Trade Organization (WTO).b

 Instead, the U.S. government is working to adopt olive oil standards through Codex, 

which the WTO does recognize as an official standards-setting body. 

At the same time, the U.S. stance on membership in the IOC is related to broader U.S. government policy on U.S. 

membership in international commodity organizations. According to U.S. government officials, the U.S. government 

would like to curb U.S. membership in such groups; indeed, the trend over the last decade has been for the U.S. 

government to withdraw from them. The U.S. Congress has recently pressed the Department of State further, via 

legislation, in this regard. The joint explanatory statement (H. Rept. 112-331) accompanying the Department of State, 

Foreign Operations, and Related Programs Appropriations Act, 2012 (Div. I, Public Law 112–74) requests that the 

Department of State “conduct a review of United States membership in each international organization supported by 

the Contributions to International Organizations account and prioritize United States participation in, and funding for, 

each organization in accordance with United States policy goals.”c

 

_____________ 

 a U.S. Department of State and U.S. Department of Agriculture officials, email to USITC staff, May 1, 2013. b Ibid. 

c Ibid. 

 

virgin olive oil permit a wide range of oil qualities to qualify as extra virgin. For 

example, the IOC benchmark standard sets a limit on FFA of 0.8 percent and on PV of 20 

to qualify as extra virgin, even though many producers and purchasers (both in and 

outside the IOC) concede that, considering olive oil’s perishability, the threshold for both 

FFA and PV values should be lower. Producers point out that it is not difficult to produce 

olive oil with an FFA level lower than 0.5 percent, and many will not market a product 

with a PV higher than 12.19 Because the extra virgin standards are so broad, they are not 

useful for differentiating high-quality and low-quality extra virgin olive oils in the global 

market. As a result, consumers are not clear as to the characteristics of high-quality extra 

virgin olive oil, which undermines the competitiveness of high-quality producers, both 

globally and in the U.S. market.20

IOC extra virgin standards have led to a divide among producers, between those 

producing high-quality oils that surpass the IOC standards by large margins and therefore 

wish to see the IOC standards tightened, and those that market extra virgin olive oils 

whose chemical compound levels only mirror the current extra virgin thresholds and 

therefore view the IOC standards as satisfactory. Those favoring the status quo have 

developed production systems and pricing strategies in response to the current standards. 

 19 Industry representatives, interviews by USITC staff, California, November 13, 2012; industry 

representatives, interviews by USITC staff, Washington, DC, April 9, 2013; industry representative, 

interview by USITC staff, Madrid, Spain, January 21, 2013; industry representatives, interviews by USITC 

staff, Meknes, Morocco, January 27, 2013; industry representatives, interviews by USITC staff, Puglia, Italy, 

February 4, 2013. 20 Industry representative, interview by USITC staff, Puglia, Italy, February 5, 2013; industry 

representative, interview by USITC staff, Andalusia, Spain, January 23, 2013; USITC, hearing transcript, 

December 5, 2012, 28 (testimony of Bruce Golino, Santa Cruz Olive Tree Nursery). 
3-9 

Also, some large bottling companies that market mild-flavored extra virgin olive oil with 

chemical traits close to the threshold recognize that the current IOC extra virgin standard 

is broad,21 but insist that global trade in olive oil would be disrupted by unharmonized 

standards and argue that any changes to standards be done through the IOC. On the other 

hand, producers of higher-quality oils argue that tighter standards would increase 

consumption, particularly in the U.S. market, by reducing consumer confusion.22

There is also a debate within the industry over how to measure the quality and purity of 

extra virgin olive oil.23 The chemical tests included in the IOC standards that measure 

quality are not definitive in determining the age of an olive oil, which can be an indicator 

of freshness. Olive oil producers in the United States and Australia report frustration over 

the IOC’s reluctance to consider what they view as the most advanced chemical tests 

available for this purpose. 24 Regarding purity, there is currently no agreement about 

which chemical compounds best detect adulteration, such as the presence of soft 

deodorized oil in extra virgin olive oil.25 IOC representatives maintain that the tests and 

other methods proposed to date are inadequate for detecting olive oil impurities and that 

more research is needed.26

IOC Membership 

The standards debate is complicated by the fact that IOC standards impact trade 

worldwide, yet are established only by members of the IOC, which is largely made up of 

major olive oil-producing countries. 27 Thus nonmembers, including major olive oilconsuming countries and New World oil-producing countries, have little or no say in how 

standards are set. And, despite its 17-country membership, the IOC agenda is largely set 

by EU countries with large production and exports, particularly Spain and Italy. 28

Reportedly, large multinational olive oil blenders/bottlers in those countries have been 

particularly active in influencing the activities of the organization through their official 

EU representatives.29 Although in recent years the IOC has acknowledged the importance 

of balancing the needs of olive oil producers all over the world as well as the needs of 

olive oil-consuming countries, its institutional structure remains the same. 

 21 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 23, 2013. 22 USITC hearing transcript, December 5, 2012, 115 (testimony of Gregg Kelley, California Olive 

Ranch); industry representatives, interviews by USITC staff, California, November 13–15, 2012. 23 USITC, hearing transcript, December 5, 2012, 28–31 (testimony of Bruce Golino, Santa Cruz Olive 

Tree Nursery). 24 AOOPA, written submission to the USITC, December 12, 2012, 14; USITC, hearing transcript, 

December 5, 155–57 (testimony of Dr. Rodney Mailer, Charles Sturt University). 25 Industry representative, telephone interview by USITC staff, May 28, 2013. 26 IOC representative, interview by USITC staff, Madrid, Spain, January 21, 2013. As part of its 

continuing efforts in this regard, an international olive oil seminar jointly organized by the European 

Commission’s Directorate-General for Agriculture and the Joint Research Centre (located in Geel, Belgium) 

with the IOC was held in June 2013. Representatives from the U.S. Department of Agriculture, UC-Davis 

Olive Center, and American Oil Chemists’ Society participated in the workshop. The seminar focused on 

“the evaluation of the quality parameters of edible olive oils as well as their traceability and authentication” 

and resulted in the creation of “terms of reference” for an international research project, open to EU Member 

States and any international cooperation, on olive oil authentication to be launched by early 2014. EC, 

“Scientific Workshop on Olive Oil Authentication (Madrid, 10-11 June 2013),” n.d (accessed July 25, 2013). 27 EU countries are members of the IOC through EU membership. This EU membership comprises 

several producing countries (e.g., Spain, Italy, Greece, and France) but also nonproducing, primarily 

consuming countries (e.g., Germany and England). 28 Industry representative, phone interview by USITC staff, February 5, 2013; USITC, hearing 

transcript, December 5, 2012, 30 (testimony of Bruce Golino, Santa Cruz Olive Tree Nursery). 29 Vivante, “Tests Find Higher Alkyl Ester Levels in Supermarket Olive Oils,” n. d. (accessed June 18, 

2013). 
3-10 

The IOC institutional framework allows standards to evolve over time to reflect changing 

science and the needs of its members. However, because changes to standards are 

normally adopted by consensus, they evolve slowly.30 As noted in chapter 2, if consensus 

cannot be reached on an issue, IOC rules allow a vote to be taken through a system of 

shares allocated to members. In order to adopt new measures, both a majority of members 

and 82 percent of participation shares, which are divided among members based on a 

formula that takes into account average oil production and exports, must vote in favor. 

This structure gives the EU the vast majority of the shares for approvals. The IOC’s 

bureaucratic nature and the small voice allotted to non- or small-producing countries have 

driven the olive oil industries in other countries to develop their own olive oil standards, 

such as the recent Australian standards (see box 3.5 and chapter 8) and the efforts of U.S. 

producers, described below.31

Evolution of IOC Standards 

Several recent issues highlight the ongoing debate over chemical standards and methods 

of testing for olive oil. At the heart of several of these debates are producers’ strategies 

for differentiating their products in terms of quality to more effectively compete in the 

marketplace. Two debates over specific tests and testing procedures highlight the 

different views. For example, there have been differences of opinion between producers 

of premium and lower-quality extra virgin oil on new methods for detecting adulterated 

and/or rancid olive oil (DAG/PPP) and for strengthening the extra virgin standard (alkyl 

esters). Another issue, regarding the limit for campesterol, involves New World 

producers achieving recognition of regional differences in their extra virgin olive oil. 

Most recent changes to IOC standards in May 2013 included changes to the limits on 

alkyl esters and campesterol in extra virgin olive oil. 

DAG/PPP 

Two chemical tests for olive oil, one measuring levels of pyropheophytins (PPP) and the 

other measuring levels of 1,2-diacylglycerol (DAG), were recently developed as part of 

the ongoing effort to test for olive oil freshness, quality, and authenticity.32 Australian 

and U.S. industry representatives believe that, in addition to UV absorption, these tests 

are strong indicators of olive oil age, poor storage conditions, and adulteration with 

deodorized olive oil, as well as oil made from deteriorated fruit.33 For example, these 

tests have been endorsed by the American Oil Chemists’ Society, which reports that 

testing for PPP helps analysts detect thermally treated olive oils and estimate the age of 

 30 IOC representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 31 USITC, hearing transcript, December 5, 2012, 150–54 (testimony of Mr. Leandro Ravetti, Boundary 

Bend, Ltd.); USITC, hearing transcript, December 5, 2012, 49 (testimony of Bruce Golino, Santa Cruz Olive 

Tree Nursery); industry representative, telephone interview by USITC staff, February 5, 2013. 32 The PPP test measures the degree to which chlorophylls in the olive oil have degraded to 

pyropheophytin, which deteriorates at a predictable pace. Such degradation is sped up by even short periods 

at high temperatures—such as those present during the deodorizing or soft-column refining process—making 

it a useful indicator of the presence of deodorized olive oil as well as of the age of an oil, according to 

proponents. The DAG test measures the proportion of two forms of diacylglycerol (DAG): 1,2 and 1,3. In 

good-quality fresh oil, the prevalent form of DAG is the 1,2 form, where the fatty acids are bonded to a 

glycerol molecule in the 1 and 2 positions. However, the bond on the 2 position is weak and easily broken, 

leading to the migration of that 2-position fatty acid to the 3 position. This results in the much more stable 1,3 

DAG. According to proponents of the DAG test, the ratio of 1,2 DAG to the total DAG is a good indicator of 

the quality of the original olive fruit and the processing as well as an indicator of the age of an oil, since the 

migration from 1,2 to 1,3 DAG takes place naturally as oil ages. Devarenne, “Olive Oil Analysis,” May 7, 

2012. 33 Devarenne, “Olive Oil Analysis,” May 7, 2012. 
3-11 

the oil, while the DAG test indicates the presence of 1,2-diglycerides, a characteristic of 

fresh olive oil.34 In addition, researchers at the University of California, Davis, Olive 

Center showed a direct correlation between sensory findings and results for PPP and 

DAG in the supermarket oils they tested.35

In spite of these findings, DAG and PPP tests have not been adopted by the IOC in 

chemical standards for extra virgin olive oil,36 and Australia is the only country to require 

olive oil to undergo PPP and DAG tests to meet its national voluntary standards 

(box 3.5). DAG and PPP tests were initially proposed in the IOC chemical committee in 

2005/06 and again in 2008, but consideration of the tests never moved past the testing 

stage of the initial IOC chemical working group. The working group concluded that the 

PPP and DAG tests may be useful for measuring the freshness of an oil, but not its 

quality or purity. The group also stated that when the test was used to determine extra 

virgin status, it was found to contradict the results of the other chemical and sensory tests 

in the current standard.37 While the IOC debates the usefulness of these tests, U.S. olive 

oil producers are working with other like-minded global producers to institute DAG and 

PPP tests as acceptable testing methods for olive oil standards.38 

Alkyl Esters 

High levels of alkyl esters in extra virgin olive oil have been found to indicate poorquality olives or extra virgin oils blended with soft deodorized oils.39 In November 2009, 

the IOC recognized the usefulness of this criterion in finding fraud via an addition to its 

grading standards: a limit on total alkyl esters in virgin olive oils of 75 miligrams per 

kilogram (mg/kg). The EU followed in 2011 by adopting the IOC limit. This new EU 

limit sparked a debate within the EU over the appropriate level of alkyl esters in extra 

virgin olive oil.40 At the time, EU producers of high-quality extra virgin olive oil stated 

that the EU limit was far too high and should be lowered to 25 mg/kg or 50 mg/kg, while 

producers in Spain argued for a 100 mg/kg limit. 41 In response to Italian industry 

concerns about the global image of its olive oil quality, in 2012, the Italian government 

 34 Gertz, “Keynote Presentation,” May 18, 2008. 

35 Frankel et al., Report, July 2010. 36 According to the IOC, a “nonfresh” older oil can still be of high quality, while a brand-new oil may 

not be high quality, so using these tests would not be appropriate for a mandatory standard. In addition, any 

measurement of freshness (parameters on PPP and DAG levels) would vary by the olive variety. The IOC 

states that the alkyl esters test, which is part of the current IOC standard, serves a function similar to that of 

the DAG and PPP tests. The IOC chemical committee determined that the research presented did show that 

the DAG and PPP tests could be a measure of purity, not quality, if test results were presented as a ratio of 

triglycerides to diglycerides. In fact, global olive oil companies have begun to use these tests to measure the 

quality of olive oil for internal purposes, but do not support it at the IOC as part of a mandatory standard for 

final products. Industry representative, interview by USITC staff, Tuscany, Italy, January 2013; IOC 

representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 37 IOC representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 38 AOOPA, written submission to the USITC, December 12, 2012, 18. In addition to conventional 

methods for measuring DAG and PPP levels, research into the design of a simple and quick quality control 

system for detecting quality, authenticity, origin, and age based on near-infrared (NIR) technology is 

ongoing. Gertz, “Rapid Assessment of Quality Parameters,” June 2013. This method is currently being used 

in internal testing by some olive oil producing firms, including in the United States. Industry representatives, 

interview by USITC staff, Washington, DC, June 26, 2013. 39 Pérez-Camino et al., “Alkyl Esters,” August 13, 2008; Gómez-Coca, et al., “Fatty Acid,” 

December 2012. 40 IOC representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 41 Industry representatives, interviews by USITC staff, Puglia, Italy, February 4–5, 2013; Vivante, 

“Tests Find Higher Alkyl Ester Levels,” n.d. (accessed June 18, 2013). 
3-12 

BOX 3.5 Australian standards 

 

In an effort to address the elements of international olive oil grading standards that it felt were inadequate, the 

Australian Olive Association developed its own set of standards for domestic olive oil in 2005. The main purpose of 

these standards, known as the Code of Practice (COP), is to educate consumers and enhance the products and 

production processes of Australian-produced olive oil.a

 The essence of the COP standards was adopted in July 2011 

by Standards Australia, an independent, nongovernmental Australian standards organization, with the goal of 

providing a scientifically based, consumer-oriented Australian standard.b 

There are several key components that distinguish the Australian standards from other grading standards. They use 

many of the same chemical tests as the IOC standard to identify adulterated oil and test quality. However, Australian 

producers note that the IOC’s chemical limits were established using data from European oils and do not take into 

account variations that stem from the different varieties and growing conditions found outside of Europe and North 

Africa. The producers argue that this situation prevents many high-quality oils from New World producers from 

qualifying for IOC quality standards.c

 The chemical parameters of the Australian standard address these differences, 

allowing for natural variations in some areas and stricter standards in others, particularly campesterol and linolenic 

acid.d The standard also requires both the DAG and PPP chemical tests. The standard is also distinguished by its 

provision for randomly testing bottles of olive oil taken off retail shelves, rather than at production facilities, in order to

capture the degradation that naturally occurs over time. This deterioration is exacerbated by heat and UV exposure 

throughout the distribution chain. 

Other elements of the Australian standard are designed to give the consumer more information. A “best before” date 

on the bottle’s label is required and cannot exceed two years from the bottling date. The standard’s chemical limits 

are set at minimum levels, with the understanding that olive oil would be produced at a much higher quality but would 

still be able to meet these minimum standards near the end of its shelf life. Finally, the standard also bans the use of 

terms on labels which it deems misleading, such as “Premium,” “Super,” “Light,” or “Pure,” to provide consumers 

more clarity about the contents of the product.e

 

Currently the Australian standard is voluntary. However, Australian producer signatories that are found to be out of 

compliance may have action taken against them by the Australian Competition and Consumer Commission, another 

nongovernmental body.f There is currently no government regulation enforcing the standards, although there is 

support from Australian producers and some retailers to potentially codify a standard into Australian law in the future.g

_____________ 

 a AOA, “Code of Practice” (accessed March 14, 2013). b Industry representative, email to USITC staff, March 13, 2013. c USITC, hearing transcript, December 5, 2012, 148–54 (testimony of Leandro Ravetti, Boundary Bend Limited); 

Ravetti, written submission to the USITC, November 29, 2012. d Industry representative, email to USITC staff, February 4, 2013. e Standards Australia, “Olive Oils and Olive-Pomace Oils,” July 20, 2011, 16 f Industry representative, email to USITC staff, February 4, 2013; Standards Australia, “About us.” 

g USITC, hearing transcript, December 6, 2012, 202 (testimony of Leandro Ravetti, Boundary Bend Limited). 

 

mandated a national limit of 35 mg/kg of alkyl esters for olive oil produced in Italy.42 In 

May 2013, the members of the IOC agreed to replace the limit for total alkyl esters with a 

limit on ethyl esters only in a staged process. Alkyl esters in olive oil include fatty acid 

methyl esters as well as fatty acid ethyl esters. Beginning in October 2013, the maximum 

level for ethyl esters will fall from the current 75 mg/kg to 40 mg/kg in 2013/14, then to 

35 mg/kg in 2014/15, and finally to 30 mg/kg in 2015/16.43

 42 Butler, “Unaprol President Urges European Commission to Lower Alkyl Ester Limits,” January 8, 

2012. Italian government officials, interview by USITC staff, Rome, Italy, February 1, 2013. Bungaro, “Olio: 

le novità introdotte dalla nuova legge anti contraffazione” [Oil: new law combating counterfeiting], n.d. 43 IOC, “Nota de Prensa” [press release], May 27, 2013. The new limit on ethyl esters, along with 

several other changes to chemical limits for olive oil, was adopted by the IOC in May 2013 in an effort to 

combat fraud and adulteration in olive oil. IOC representative, email communication with USITC staff, July 

4, 2013. 
3-13 

Campesterol 

Campesterol is a naturally occurring plant sterol in olive oil. Efforts have been made by 

Australia and Argentina, with support from the United States, to change the current 

parameters in the Codex standards for extra virgin olive oil. The current Codex standards 

set an upper limit for campesterol in extra virgin olive oil of 4 percent. Proponents of this 

limit contend that a larger value can indicate the addition of seed oils or refined oils (like 

sunflower, soy, canola, or cottonseed). However, some global producers, including those 

in the United States and Australia, have found that extra virgin olive oil produced in 

certain countries, particularly those outside the Mediterranean, tend to have naturally 

occurring campesterol levels greater than 4 percent.44 Producers of extra virgin olive oils 

with elevated campesterol levels have also noted that owing to the sterol’s likely 

beneficial properties of balancing cholesterol levels in the human body, this type of extra 

virgin olive oil should not be disqualified from the extra virgin category by the restrictive 

parameters for campesterol in the current standard, and that the need for a way to detect 

adulterated oil can be met by adjusting several other chemical parameters in the 

standard.45 

In 2011, the Australian government proposed raising the campesterol limit for extra 

virgin olive oil in the Codex standards to 4.8 percent.46 The proposal was supported by 

the United States and other similarly affected, non-Mediterranean producers of olive oil, 

but was opposed by EU member countries and the IOC. 47 According to U.S. industry 

sources, at that time the IOC argued that raising the level would allow more fraudulent 

olive oil in the global market.48 Australia’s response to this concern was to propose 

lowering the standard on stigmasterol in olive oil from 3.9 percent to 1.9 percent, a 

change it believed would effectively protect against olive oil fraud. 

In May 2013, the IOC adopted a new upper limit for campesterol of 4.5 percent in its 

standards for extra virgin olive oil, with additional limits on other chemical tests for extra 

virgin olive oil with campesterol levels between 4 and 4.5 percent.49 The IOC rationale 

for this and other changes made to the standards at that time was “to intensify the fight 

against fraud and adulteration.”50 U.S. industry representatives called the change a step in 

the right direction, but noted that the new IOC campesterol standard still excludes a large 

share of olive oils produced outside the Mediterranean region from the extra virgin 

category.51

 44 In an examination of global olive oils by the Australian government with the assistance of the 

governments of the United States and New Zealand, over 800 samples from Australia, 60 samples from the 

Unites States, over 400 samples from Argentina, and some olive oils from the EU were found to have 

campesterol levels greater than 4 percent. Government of Australia, “Discussion Paper on the Revision of the 

Limit for Campesterol,” November 2012; AOOPA, written submission to the USITC, February 12, 2013, 30. 45 AOOPA, written submission to the USITC, February 12, 2013, 31. 46 USDA, FSIS, “Draft U.S. Positions for the 23rd Session,” n.d. 47 USDA, FSIS, “Report of the U.S. Delegate,” April 19, 2011. 

48 AOOPA, written submission to the USITC, February 12, 2013, 31. 49 The new campesterol limit allows any virgin or extra virgin olive oil which contains more than 4 

percent but less than 4.5 percent campesterol to be recognized as virgin or extra virgin olive oil as long as it 

has a stigmasterol content of less than 1.4 percent, a delta-7-stigmastastenol content of less than 0.3 percent, 

and complies with the other extra virgin or virgin parameters. IOC representative, email communication to 

USITC staff, July 4, 2013. 50 IOC representative, email communication to USITC staff, July 4, 2013. 51 Industry representatives, interview by USITC staff, Washington, DC, June 26, 2013. 
3-14 

Effectiveness of Standards 

Even well-crafted standards can lose their effectiveness without enforcement. However, 

despite the proliferation of olive oil standards at the international and national 

governmental levels, there are few governmental bodies that provide mandatory 

enforcement of grading standards with sanctions for noncompliance. As a result, a very 

small share of total global olive oil production is actually officially tested.52 While the 

IOC gives support to members and nonmembers for maintaining standards, such as 

providing expertise and certification and training programs for testing, it does not have 

enforcement powers. 53 Lack of enforced regulation may provide an opportunity and 

incentive for fraudulent behavior by some firms, as described above. The EU and Canada 

are two economies that do have official government enforcement regimes in place for 

olive oil. 

Standards enforcement involves olive oil testing, which can be done at production 

facilities, at points of consumption (e.g., retail outlets), or both. Olive oil testing at the 

point of production can be motivated by several factors: business contracts covering 

purchases of olive oil to be used as raw material for blending; official government 

requirements for compliance with standards (in limited cases); and the desire to use test 

results for marketing purposes (e.g., for quality seals). Enforcement of olive oil standards 

at the point of consumption is generally motivated by a desire to ensure that consumers 

purchase the grade and type of olive oil that is specified on the label. 

Internal Testing by Private Companies 

Olive oil producers test olive oil at various stages of the production process. Producers 

may test the fruit before olives are milled; often, if they employ contract growers, the 

purpose is to determine oil content and olive quality for payment to growers. In some 

cases, producers may test the olives to help mill operators fine-tune the milling process in 

order to enhance the quality attributes of the milled oil. Oil may again be tested after 

milling and before storing; after blending oils of separate milled batches; and at the point 

of bottling. Bottlers/blenders that contract for milled oil may test supplies of olive oil raw 

material at the point of entry into their bottling plant. Producers of bottled product, both 

large and small, generally test for the final time at the point of bottling.54 

Most large olive oil producers and bottlers maintain quality control systems to ensure 

authenticity and the desired grade in their products. 55 Contractual commercial 

arrangements motivate much olive oil testing, as growers and millers need to be sure of 

the quality of olives received before paying for them, and bottling/blending companies 

must ensure that olive oil deliveries meet the specifications contracted. Blending/bottling 

operations test their blended oils to ensure they meet internal benchmarks, including 

predetermined flavor profiles and overall consistency. Once bottled, olive oil is tested to 

ensure that food safety and minimum quality standards are met for proper labeling. In 

some cases, retail buyers require such tests as a condition of purchase, to ensure both 

 52 Industry representative, telephone interview by USITC staff, February 5, 2013; industry 

representative, interview by USITC staff, Puglia, Italy, February 4, 2013. 53 IOC representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 54 Industry representative, interview by USITC staff, Maryland, December 20, 2012. 55 NAOOA, written submission to the USITC, February 12, 2013, 2. 
3-15 

quality and traceability back to the original oil supplier.56 Some producers may further 

test to qualify their oil for a certification program which permits the use of a quality seal 

on the label. Some producers also conduct checks at the end of the distribution chain by 

contracting with independent auditors who pull shelf samples from retail stores for 

testing.57 

Official Testing 

As mentioned above, official government enforcement regimes for olive oil exist in only 

a few countries. In the EU, grading standards for olive oil are codified into law, and 

official testing of olive oil production is mandatory for both domestically marketed 

products and products for export.58 However, EU regulations require testing only for a 

very small share of EU production. Newly adopted regulations in the EU require one 

official chemical test per 1,000 mt, or 0.1 percent, of olive oil marketed in the EU.59 

Approaches for testing differ from country to country. The Spanish government’s system 

of inspection for exports is conducted by SOIVRE (the Spanish Office of Export 

Surveillance, Certification, and Regulation). Physical inspections are conducted through 

risk-based analysis; the Spanish government reported that about 11 percent of exports are 

chemically tested in this program. 60 In 2012 there were a total of 770 inspections 

conducted by Spanish regional governments and 23 percent were found to be 

noncompliant.61 In Italy, inspection is carried out by the law enforcement unit of the 

Carabinieri tasked with combating food fraud. The Carabinieri use traditional law 

enforcement techniques, sanitary inspections, and lab testing to uncover fraud in the olive 

oil sector.62 In Italy, the recently passed Mangiello law (October 2012) mandates tighter 

olive oil quality standards, more extensive testing, and significantly increased penalties 

for oil fraud (see page 6-33).63 

The Canadian Food and Inspection Agency (CFIA) has a program to detect and reduce 

the occurrence of adulterated olive oil in Canada. Through the CFIA’s Fair Labeling 

Practices program, product labels and industry controls are assessed to ensure that olive 

oil products meet labeling requirements, and product samples are analyzed to check for 

adulteration with other oils and to verify that CFIA’s standards for virgin and extra virgin 

olive oil are met. In this program, inspectors send 80–100 samples for analysis annually, 

and they often target products that are the subject of consumer or trade complaints of 

alleged adulteration. CFIA reports that the percentage of noncompliant samples fell from 

47 percent in 2006–07 to 11 percent in 2009–10.64 Since that time noncompliant samples 

rose to just over 30 percent in 2010–11 and 2012–13.65

 56 Industry representative, telephone interview by USITC staff, March 18, 2013. 57 Industry representative, interview by USITC staff, Maryland, December 20, 2012. 58 EC official, email to USITC staff, June 28, 2013. 59 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 60 Government of Spain, “Export of Olive Oil Inspection Type,” data sheet provided to USITC staff, 

Madrid, Spain, January 25, 2013. 61 Of the noncompliant samples, 47.5 percent related to quality and purity, 32.7 percent related to 

labeling, 4 percent related to traceability, and 15.7 were related to other violations. Izquierdo, “Frauds in 

Olive Oil Sector in Spain,” June 2013. 62 Italian government official, interview by USITC staff, Rome, Italy, February 1, 2013. 63 Industry representative, interview by USITC staff, Puglia, Italy, February 4, 2013. 64 Sheridan, “Surveillance and Analysis of Olive Oil in Canada,” 2007; Devarenne, “Olive Oil Analysis 

Discussed,” May 7, 2012. 65 Sheridan et al., “Olive Oil Authenticity: A Canadian Perspective,” June 2013. 
3-16 

When a product is found to be adulterated, inspectors may expand the sampling to other 

olive oil brands and products carried by the same importer, or to products coming from 

the same broker or country of origin as the adulterated sample. Inspectors may also target 

products because they are new in the marketplace, they seem unreasonably inexpensive, 

the importer or producer has a history of noncompliance, or a drought or other 

environmental factor may have affected products from certain countries. 66 When a 

company is found to be selling or distributing a misrepresented product, appropriate 

enforcement action, up to and including prosecution, may be taken. Under the CFIA 

program for olive oil, $250,000 in fines have been levied and more than $500,000 worth 

of olive oil has been ordered disposed since 2007.67 

Under the enforcement regimes in Spain and Italy, testing takes place at the point of 

bottling or export, while the Canadian regime involves testing retail bottles. Testing at 

bottling may guarantee that an oil qualifies for the extra virgin grade at that point, but 

does not ensure that the oil will remain extra virgin at the end of its shelf life. Bottlers 

question their role in ensuring the quality of the product once it has left their facilities. 

They prefer a scheme in which a bottle of olive oil found to be unsatisfactory by a 

customer is replaced by the manufacturer or its cost is refunded if proper proof of 

purchase is provided, a common practice for many grocery retailers.68 A more consumeroriented scheme, however, such as the official retail testing that occurs in Canada, 

involves testing oil from bottles on retail shelves. This type of testing scheme takes into 

account the perishability of olive oil and its vulnerability to deterioration while it is in 

storage, being distributed, and on retail shelves. 

Efforts to Strengthen Standards and Enforcement in the 

U.S. Market 

Mechanisms in the U.S. market to ensure olive oil quality are voluntary and not officially 

enforced. In the U.S. market, USDA standards define olive oil and olive pomace oil by 

delineating chemical and sensory parameters for each of the grades, but provide no 

mechanism for enforcement and no penalties for noncompliance. In addition, the USDA 

maintains a Quality Monitoring Program—a voluntary testing and quality seal program—

for a variety of commodities, including olive oil (box 3.6). Since 1989, NAOOA has 

carried out random testing of olive oil authenticity and chemical compliance with the 

grade level after it became a party to the IOC’s quality monitoring agreement.69 Through 

this program, NAOOA tests olive oil it buys in U.S. supermarkets and contacts individual 

manufacturers and often U.S. authorities when anomalies are found, but the organization 

itself has no enforcement authority.70

 66 Canadian government official, email to USITC staff, December 5, 2012. 67 Sheridan et al., “Olive Oil Authenticity: A Canadian Perspective,” June 2013. 68 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 23–24, 2013. 69 The IOC quality monitoring agreement was established in 1989 for industry trade organizations to 

participate in IOC activities, such as quality monitoring, without formal country membership. Current 

signatories to the IOC quality monitoring agreement include, among others, industry trade organizations in 

the United States, Australia, and Brazil. Industry representative, telephone interview by USITC staff, August 

5, 2013. NAOOA, “Quality” (accessed June 18, 2013). 70 The NAOOA has tested 900 samples in the past five years, representing more than 700 companies 

and 800 brands. The NAOOA will often alert the FDA when anomalies are found. NAOOA, written 

submission to the USITC, December 5, 2012. 
3-17 

BOX 3.6 Quality Monitoring Program 

The USDA Quality Monitoring Program (QMP), which evaluates a range of commodities including canned, frozen, 

and certain fresh fruits and vegetables, was expanded to include extra virgin and organic extra virgin olive oil in April 

2012. The program is a voluntary, user-fee-based service that gives firms objective third-party assessments of 

product quality. The QMP for olive oil is overseen by the USDA’s Agricultural Marketing Service (AMS) and verifies 

olive oil quality and purity on a monthly basis. For firms that join the QMP, the program uses criteria based on the 

U.S. grade standards and international standards for olive oil. The QMP assessment also includes unannounced 

plant visits to review production processes, quality assurance measures, and recordkeeping systems.a

 Once 

approved by the program, companies can market their products using an official USDA seal on product labels to 

indicate their participation.b

 

QMP verifies the quality and purity of olive oil through chemical and sensory testing of samples at a firm’s bottling 

plant for the product lines the firm has designated for the program. Samples are sent to the AMS lab in Blakely, GA, 

with results available in 10 days to 2 weeks. While chemical and sensory (panel) testing is done on the samples, no 

referee panel is available to give a second opinion on sensory test results.c

 The program’s costs of approximately 

$5,000 per month are covered entirely by the firm and include the AMS inspection and lab fees. Chemical and 

sensory test costs range from $2,000 to $2,500 per lot for four samples, although a firm could see lab costs per unit 

decrease if it places larger volumes of oil in the program.d

 The remainder of the cost covers inspectors’ time in and 

travel to the firm’s facility. In addition, program checks are performance driven; the frequency of checks is reduced as 

samples are found to comply, which could decrease the cost of the program over time. Pompeian, Inc.—

headquartered in Baltimore, Maryland—was the first manufacturer to participate in USDA’s QMP for olive oil.e

_____________ 

 a Parrott, “Quality Monitoring Program Expands to Olive Oil,” April 3, 2012. b USDA, AMS, “Grading, Certification and Verification,” (accessed June 18, 2013). 

c U.S. government official, interview by USITC staff, Washington, DC, November 8, 2012. d U.S. government official, interview by USITC staff, Washington, DC, November 8, 2012. It is estimated that a 

full battery of 22 chemical and sensory tests might cost as much as $7,000 per lot, and since this cost is prohibitive, 

the QMP does not do the full battery. NAOOA, written submission to the USITC, December 17, 2013, 57. e Parrott, “Quality Monitoring Program Expands to Olive Oil,” April 3, 2012; industry representative, interview by 

USITC staff, Maryland, December 20, 2012. 

 

In recent years, efforts have been underway to strengthen olive oil standards in the United 

States and to address the lack of enforcement. The states of California, Oregon, New 

York, and Connecticut have legal standards in place defining “extra virgin” olive oil 

which match those of the IOC, but without formal mechanisms to enforce them.71 U.S. 

olive oil producers and importers have pursued separate strategies to make olive oil 

standards enforcement a reality in the United States. Most notably, U.S. producers are 

considering a U.S. marketing order from the USDA for olive oil, while importers are 

proposing a U.S. Food and Drug Administration (FDA) standard of identity for olive oil, 

each with the potential for official U.S. government enforcement authority (see 

discussion below). Most recently, the NAOOA brought legal action against a firm it 

found to be noncompliant with standards for olive oil.72

Potential U.S. Federal Marketing Order 

In recent years U.S. olive oil producers have expressed interest in initiating a federal 

marketing order for olive oil in order to ensure the integrity of olive oil labeled as extra 

 71 Beck, “Governor Signs Senate Bill 634,” October 1, 2008; Strom, “Trade Group Lawsuit Challenges 

Olive Oil Labeling,” February 6, 2013. 72 In February 2013, the NAOOA filed suit against Kangadis Food Inc., a New York-based firm 

operating under the name The Gourmet Factory, accusing the firm of falsely labeling its Capatriti brand as 

olive oil when it was actually olive pomace oil, a substance extracted from olive pits and skins using 

industrial solvents. Strom, “Trade Group Lawsuit Challenges Olive Oil Labeling,” February 6, 2013. 
3-18 

virgin.73 As of the time this report was prepared, however, no specific proposals for a 

marketing order had been submitted to USDA by the domestic industry. Marketing 

orders, if approved by growers in the industry and USDA after public hearings, can be 

used to establish, among other things, quality standards and financial assessments that 

can fund research, marketing promotion, and testing. The terms of a marketing order can 

vary. However, marketing orders can apply to imports only if the commodity is listed in 

section 7 U.S.C. 608e-1 (section 8e) of the Agricultural Marketing Agreement Act of 

1937.74 Olive oil is not currently listed, and adding olive oil to this statute would require 

U.S. legislation to that effect.75 

Although a federal marketing order for olive oil has not formally been proposed, such a 

marketing order would ostensibly be focused on establishing the authority to monitor 

olive oil quality in the U.S. marketplace.76 This would likely be done through a testing 

regime that would specify the rate, method, and timing of testing. Costs for such testing 

would be borne by individual firms. Quality standards may be specified in the marketing 

order which may or may not match current USDA or IOC standards. 77 NAOOA, 

representing large U.S. importers, claims that a marketing order would serve as a trade 

barrier if applied to imports because of significant additional compliance and testing costs 

and extensive delays in shipment of product. NAOOA asserts that this action would 

ultimately lead to higher prices for all olive oil in the U.S. market. 78 AOOPA, 

representing U.S. olive oil producers, states that all interested parties will be able to 

participate in the process of developing the grade standards for a marketing order and that 

the testing program would have to be prepared and approved by U.S. producers and 

importers. In addition, AOOPA notes that the EU currently has a mandatory olive oil 

inspection program in place.79 

Estimates of costs for a testing regime associated with a USDA marketing order vary 

(box 3.7), but would likely be relatively low per liter of olive oil. However, current 

bottlenecks would significantly undercut the efficiency of any testing regime in the 

United States, at least initially. Depending on which tests are required, results can take 

from several hours to several days to be completed, resulting in delays for shippers. In 

addition, there is at present only one official USDA lab for olive oil testing, located in 

Blakely, GA. The availability of sensory testing is limited as well, as currently there are 

only a few olive oil sensory panels in the United States (only one of which had IOC 

accreditation in 2013). These include a panel associated with the USDA Blakely lab and 

three panels in California with several overlapping members. 

 73 Cord, “American Olive Oil Producers Draft Federal Marketing Order,” March 18, 2012. 74 USDA, AMS, “International Marketing” (accessed June 18, 2013). Inspection of imports under 

section 7 U.S.C. 608e-1 “is required to ensure that the standards of quality of imported products are equal to 

the standards imposed on domestically produced products regulated under Federal Marketing Orders.” 

USDA, AMS, “8e Marketing Order Manual,” July 2012. 75 U.S. government officials, interview by USITC staff, Washington, DC, October 24, 2012. The most 

recent U.S. House of Representatives version of the Farm Bill (H.R. 1947, the Federal Agriculture Reform 

and Risk Management (FARRM) Act of 2013) contained a provision (Section 10010) to add olive oil to 7 

U.S.C. 608e-1 of the Agricultural Marketing Agreement Act of 1937. On June 20, 2013, this provision was 

struck from H.R. 1947. Later that same day, H.R.1947 failed to pass in the House by a 195-234 vote. 76 Cord, “American Olive Oil Producers Draft Federal Marketing Order,” March 18, 2012. 77 U.S. government officials, interview by USITC staff, Washington, DC, October 24, 2012. 78 NAOOA, written submission to the USITC, December 17, 2013, 49. 79 AOOPA, “U.S. Olive Oil Industry Response,” n.d. 
3-19 

BOX 3.7 Costs for hypothetical testing regime in the U.S. market 

Although a federal marketing order for olive oil has not formally been proposed, any such proposal would likely 

involve mandatory testing of olive oil in the U.S. market.a A mandatory testing scheme would specify particular tests 

to be conducted, as well as the amount of testing––whether of every shipment or a random sampling. These tests 

would be applied to specific lots, defined by USDA as “any number of containers of the same size, type, and style 

located in the same warehouse or conveyance.”b

 U.S. importers report that 15,000–20,000 lots of olive oil enter the 

United States each year. 

The American Olive Oil Producers Association (AOOPA) has advocated for a set of six core tests to be done for extra 

virgin olive oil at an estimated cost of $300 per lot.c

 For refined olive oils and their blends, AOOPA proposes a slightly 

different set of six core tests at an estimated total cost of $400 per lot.d

 According to AOOPA, mandatory testing of 

U.S. olive oil, at an average testing cost of $350 per lot, would translate into an additional testing cost of $0.02 per 

liter.e One EU exporter of bottled olive oil to the U.S. market estimated that testing costs could range from $0.05 to 

$0.08 per liter if every lot were required to be tested; this range covers a variable number of lots and variable 

container packaging (glass or plastic).f

 

Testing regimes performed in other countries are illustrative. The Canadian government tests 80–100 retail samples 

annually; it may target products subject to consumer or trade complaints of alleged mislabeling or adulteration. In the 

EU, current legislation regulates testing at 1 check per 1,000 mt of olive oil. The Australian Olive Association and the 

Australian Consumer and Competition Commission test approximately 100 retail samples annually out of a total of 40 

million liters of retail sales per year and report that this testing is done at an annual cost of $35,000 per year, or less 

than $0.001 per liter.g

_____________ 

a U.S. government official, interview by USITC staff, Washington, DC, October, 24, 2012. 

b 75 Fed. Reg. 22363 (Apr. 28, 2010). 

c U.S. producers suggest that tests of extra virgin olive oil include tests for free fatty acids (FFA), peroxide value 

(PV), UV coefficients (UV), panel (sensory) test (PAT), pyropheophytins (PPP), and diacylglycerols (DAGs). AOOPA, 

written submission to the USITC, February 12, 2013, 13. d U.S. producers suggest that tests of refined olive oil include tests for free fatty acids, peroxide value, UV 

coefficients, fatty acid profile (FAP), sterols (STE), and erythrodiol and uvaol (E+U). AOOPA, written submission to 

the USITC, February 12, 2013,15. e AOOPA, written submission to the USITC, February 12, 2013, 16. 

f Industry representative, interview by USITC staff, Tuscany, Italy, January 30, 2013. g AOOPA, written submission to the USITC, December 12, 2013, 13. 

 

Potential FDA Standard of Identity 

Like U.S. producers, U.S. importers also view mandatory, enforceable standards, backed 

by a testing regime focused both on random samples and a targeted review of actors 

suspected of economic fraud, as necessary in the U.S. market.80 For this reason, in June 

2012, for the second time since 1990, the NAOOA proposed the creation of a federal 

standard of identity for olive oil, which would be mandatory and enforceable by the 

FDA.81 The NAOOA favors a mandatory standard of identity over the voluntary USDA 

olive oil standards because it carries the weight of enforcement and legal sanctions.82 

According to the FDA, once a standard of identity is in place, products are inspected for 

compliance with the standard typically only after a complaint is received from a 

consumer or industry. The discovery of products that do not meet the standard, 

considered “misbranded,” can lead to a warning letter, giving the shipper a time period to 

 80 NAOOA, written submission to the USITC, December 17, 2013, 58. 81 The original olive oil petition of 1990 was never acted upon by FDA. Industry representative, 

telephone interview by USITC staff, August 5, 2013. 82 NAOOA, written submission to the USITC, December 17, 2013, 4. 
3-20 

act to correct the problem, or the FDA can move to an injunction or seizure. In addition 

to compliance with the standard, FDA has the authority to act in cases of “economic 

adulteration,” which involves substituting an ingredient in order to defraud the consumer. 

Economic adulteration is cause for going straight to injunction or seizure, followed by 

prosecution.83 While a standard of identity could potentially be a vehicle for standards 

enforcement for olive oil, based on the FDA’s inaction to date, U.S. producers do not 

believe that it is likely that one will be adopted soon.84 

 

 83 U.S. government official, interview by USITC staff, College Park, MD, March 14, 2013. 84 AOOPA, written submission to the USITC, February 12, 2013. 
3-21 

Bibliography 

American Olive Oil Producers Association (AOOPA). “U.S. Olive Oil Industry Response to Importer 

Allegations about the Farm Bill’s Olive Oil Provision,” n.d. 

American Society for Testing and Materials (ASTM). “Sensory Evaluation Methods.” 

http://www.astm.org/Standards/sensory-evaluation-standards.html (accessed June 18, 2013). 

Aubrey, Allison. “U.S. Olive Oil Makers Say Imports Aren’t Always So ‘Extra-Virgin.’” National Public 

Radio, December 6, 2012. http://www.npr.org/blogs/thesalt/2012/12/06/166662525/u-s-olive-oilmakers-say-imports-arent-always-so-extra-virgin.

Australian Olive Association (AOA). “Code of Practice.” 

http://www.australianolives.com.au/content/code-of-practice (accessed March 14, 2013). 

Beck, Caroline J. “Governor Signs Senate Bill 634,” October 1, 2008. 

http://www.oliveoilsource.com/article/governor-signs-senate-bill-634. 

Bungaro, Michele. “Olio: le novità introdotte dalla nuova legge anti contraffazione dell’olio dell’extra 

vergine di olive.” [Oil: New law combating counterfeiting of extra virgin olive oil introduces 

innovation.] Agronotizie, n.d. http://agronotizie.imagelinenetwork.com/materiali/Varie/File/LASCHEDA-della-nuova-legge-def-.pdf (accessed June 5, 2013). 

Butler, Julie. “Unaprol President Urges European Commission to Lower Alkyl Ester Limits.” Olive Oil 

Times, January 8, 2012. http://www.oliveoiltimes.com/olive-oil-business/europe/unaprolmassimo-gargano/23777. 

California Olive Council, “The Certification Process.” http://www.cooc.com/ (accessed June 18, 2013). 

Chen, Joanne. “Forget the IRS––There’s an Olive Oil Scandal Afoot.” Time Ideas, May 17, 2013. 

http://ideas.time.com/2013/05/17/forget-the-irs-theres-an-olive-oil-scandal-afoot/.

Codex Alimentarius, Standard for Olive Oils and Olive Pomace Oils, 2009. 

Cord, Curtis. “American Olive Oil Producers Draft Federal Marketing Order.” Olive Oil Times, March 18, 

2012. http://www.oliveoiltimes.com/olive-oil-basics/federal-marketing-order-for-olive-oil/25421. 

Devarenne, Alexandra Kicenik. “Olive Oil Analysis Discussed at American Oil Chemists’ Society 

Annual Meeting.” Olive Oil Times, May 7, 2012. 

Devarenne, Alexandra Kicenik, and Paul Vossen. “Understanding the USDA Olive Oil Standards.” 

University of California, Division of Agriculture and Natural Resources, September 2010. 

http://cesonoma.ucanr.edu/files/48283.pdf. 

European Commission (EC). “Scientific Workshop on Olive Oil Authentication (Madrid, 10-11 June 

2013).” News release, n.d. 

Frankel, E. N., R. J. Mailer, C.F. Shoemaker, S.C. Wang, and J.D. Flynn. Report: Tests Indicate That 

Imported “Extra Virgin” Olive Oil Often Fails International and USDA Standards. University of 

California, Davis, Olive Oil Center, July 2010. 

http://olivecenter.ucdavis.edu/publications/olive%20oil%20final%20071410%20updated.pdf. 
3-22 

Frankel, E. N., R. J. Mailer, S.C. Wang, C.F. Shoemaker, J.X. Guinard, J.D. Flynn, and N.D. 

Sturzenberger. Evaluation of Extra-Virgin Olive Oil Sold in California. University of California, 

Davis, Olive Oil Center, April 2011. 

http://olivecenter.ucdavis.edu/files/report%20041211%20final%20reduced.pdf.

Gertz, Christian. “Keynote Presentation—New Analytical Possibilities to Survey Quality and Identity of 

Olive Oils.” Official Institute of Chemical Analysis, Germany. Presented at the 99th American 

Oil Chemists’ Society (AOCS) Annual Meeting and Expo, May 18, 2008. 

http://www.aocs.org/archives/am2008/index.cfm?page=am08_oliveoil.htm. 

———. “Rapid Assessment of Quality Parameters in Olive Oil Using FT-NIR and Conventional 

Standard Methods.” Presented at the European Commission Workshop on Olive Oil 

Authentication, Madrid, Spain, June 10–11, 2013. 

Gómez-Coca, R.B., W. Moreda, M.C. Pérez-Camino. “Fatty Acid Alkyl Esters Presence in Olive Oil vs. 

Organoleptic Assessment.” Food Chemistry 135, number 3 (December 2012): 1205–9. 

Government of Australia. “Discussion Paper on the Revision of the Limit for Campesterol in the Codex 

Standard for Olive Oils and Olive Pomace Oils,” November 2012. Presented at the Codex 

Committee on Fats and Oils, Twenty-third Session, Langkawi, Malaysia, February 25–March 1, 

2013. ftp://ftp.fao.org/codex/meetings/ccfo/ccfo23/fo23_09e.pdf. 

Gustafson, Christopher R., and Travis J. Lybbert. “What’s Extra Virgin?” University of California, n.d. 

(accessed June 18, 2013).

International Olive Council (IOC). “List Of Laboratories Undertaking the Sensory Analysis of Virgin 

Olive Oils Recognised by the International Olive Council for the Period from 1.12.2012 to 

30.11.2013.” T. 28/Doc. No. 3/Rev. 15, December 2012. 

———. “Nota de Prensa” [news release], May 27, 2013. 

Izquierdo, J.R. “Frauds in Olive Oil Sector in Spain.” Presented at the European Commission Workshop 

on Olive Oil Authentication, Madrid, Spain, June 10-11, 2013. 

Mailer, Rod. “A World Tour of Olive Oil Standards,” n.d. 

———. “Chemistry and Quality of Olive Oil.” New South Wales Department of Primary Industries, 

August 2006. http://www.dpi.nsw.gov.au/__data/assets/pdf_file/0003/87168/pf227-Chemistryand-quality-of-olive-oil.pdf. 

Moore, Jeffrey C., John Spink, and Markus Lipp. “Development and Application of a Database of Food 

Ingredient Fraud and Economically Motivated Adulteration from 1980 to 2010.” Journal of Food 

Science 77, no. 4 (April 2012): R118–R126. 

Mueller, Tom. “Slippery Business.” New Yorker, August 13, 2007. 

http://www.newyorker.com/reporting/2007/08/13/070813fa_fact_mueller. 

North American Olive Oil Association (NAOOA). “Frequently Asked Questions on Recent Olive Oil 

News,” February 2012. 

———. “Quality.” http://www.aboutoliveoil.org/quality.html. (accessed June 18, 2013). 
3-23 

Olive Oil Times. “IOC Weighs In on Davis Study,” n.d. http://www.oliveoiltimes.com/olive-oilbusiness/north-america/ioc-uc-davis-olive-oil-study/4926 (accessed June 18, 2013). 

———. “Olive Oil Analysis Discussed at American Oil Chemists’ Society Annual Meeting,” May 7, 

2012. http://www.oliveoiltimes.com/olive-oil-basics/aocs-meeting/26397.

Parrott, Charles. “Quality Monitoring Program Expands to Olive Oil.” U.S. Department of Agriculture, 

Agricultural Marketing Service, April 3, 2012. http://blogs.usda.gov/2012/04/03/qualitymonitoring-program-expands-to-olive-oil/. 

Pérez-Camino, M.C., A. Cert, A. Romero-Segura, R. Cert-Trujillo, and W. Moreda. “Alkyl esters of fatty 

acids a useful tool to detect soft deodorized olive oils.” Journal of Agricultural Food Chemistry. 

13;56 (15):6740-4. doi: 10.1021/jf801131b, August 2008. 

http://www.ncbi.nlm.nih.gov/pubmed/18642925. 

Sheridan, A., M. Gunville-Vachon, and C. Gibeault. “Olive Oil Authenticity: A Canadian Perspective.” 

Presented at the European Commission Workshop on Olive Oil Authentication, Madrid, Spain, 

June 10-11, 2013. 

Sheridan, Angela. “Surveillance and Analysis of Olive Oil in Canada.” Canadian Food Inspection Agency, 

2007. 

Standards Australia. “About Us.” 

http://www.standards.org.au/OurOrganisation/AboutUs/Pages/default.aspx (accessed March 15, 

2013). 

———. “Olive Oils and Olive-Pomace Oils,” July 20, 2011. 

Strom, Stephanie. “Trade Group Lawsuit Challenges Olive Oil Labeling.” New York Times, February 6, 

2013. http://www.nytimes.com/2013/02/07/business/trade-group-lawsuit-challenges-olive-oillabeling.html?_r=0. 

U.S. Department of Agriculture (USDA). Agricultural Marketing Service (AMS). “8e Marketing Order 

Manual,” July 2012. http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=stelprdc5091538.

———. “Grading, Certification and Verification.” 

http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?startIndex=1&startIndex=2&star

tIndex=1&startIndex=2&template=TemplateN&navID=QualityMonitoringProgram&rightNav1=

&topNav=&leftNav=&page=QualityMonitoringProgram&resultType=&acct=procsdgrdcert 

(accessed May 7, 2013). 

———. “International Marketing.” 

http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?template=TemplateN&page=Co

mmoditiesCoveredUnderSection8e (accessed May 7, 2013). 

U.S. Department of Agriculture (USDA). Food Inspection and Safety Service (FSIS). “Draft U.S. 

Positions for the 23nd Session of the Codex Committee on Fats and Oils, 25 February – 1 March, 

2013, Langkawi, Malaysia,” n.d. 

———. “Report of the U.S. Delegate to the 22nd Session of the Codex Committee on Fats and Oils,” 

May 19, 2013. http://www.fsis.usda.gov/wps/wcm/connect/fsiscontent/internet/main/topics/international-affairs/us-codex-alimentarius/recent-delegationreports/delegate-report-22nd-session-ccfo/ct_index. 
3-24 

Vivante, Lucy. “Tests Find Higher Alkyl Ester Levels in Supermarket Olive Oils.” Olive Oil Times, n.d. 

http://www.oliveoiltimes.com/olive-oil-business/italy-alkyl-ester-olive-oil-test/9384 (accessed 

June 18, 2013).
4-1 

CHAPTER 4 

The U.S. Market for Olive Oil 

Overview 

Olive oil consumption is increasing in the United States, owing to rising interest in its 

health benefits and the decrease in its price over time—factors that are expected to fuel 

future domestic sales growth as well. At the same time, most U.S. consumers are 

generally unaware of the wide range of choices associated with olive oil, including 

grades, flavor attributes, and uses. Imports account for the vast majority of olive oil in the 

U.S. market; U.S.-produced olive oil supplied only 3 percent of U.S. consumption in 

2012. About one-third of imported olive oil arrives in bulk to be bottled in U.S. bottling 

facilities, and two-thirds is imported in retail packaging. The U.S. market for olive oil is 

highly price competitive, and the nascent U.S. olive oil industry struggles to compete 

with large volumes of lower-priced imports.

Consumption and competition in the U.S. olive oil market are shaped by a number of 

factors, including consumer preferences, product differentiation, quality, costs, and 

pricing. The business strategies adopted by olive oil producers (both foreign and 

domestic) selling into the U.S. market tend to emphasize either cost leadership or product 

differentiation. 1 Cost-leadership firms focus on selling large volumes of lowercost/lower-value olive oil at lower prices. Firms focused on product differentiation and 

quality focus on selling smaller volumes of higher-cost/higher-quality olive oil at higher 

prices. The two strategies target two distinct U.S. consumer groups: those that are 

knowledgeable about olive oil quality and are willing to pay a premium for it, and those 

that are less concerned with olive oil quality or are unable or unwilling to pay the 

premium. U.S. retail prices for extra virgin olive oil reflect these distinct pricing 

strategies. Generally, price remains one of the most important factors in U.S. consumer 

purchasing decisions for olive oil, in part due to a lack of consumer awareness of quality 

differences. 

The first part of this chapter provides information on key characteristics of the market for 

olive oil in the United States, including the factors driving increased U.S. consumption, 

the sources of U.S. olive oil supply, and U.S. consumption patterns by market channel. 

This section compares consumption in the various market segments with regard to olive 

oil grades, flavors, uses, and prices. This is followed by a discussion of the competitive 

factors affecting consumption in the U.S. retail market. Several key factors include U.S. 

consumer awareness of and preferences for olive oil, as well as firms’ marketing and 

pricing strategies. This section relates firms’ pricing strategies to retail prices observed in 

the U.S. market, using retail sales data. Finally, the chapter concludes with an 

econometric analysis of demand for olive oil in the U.S. market. 

 1

 Cost leadership strategies involve aggressively pursuing preferential access to low-cost inputs, 

seeking economies of scale, and minimizing costs. Product differentiation strategies involve creating an 

advantage in the market by offering a product perceived by purchasers as being special or unique. Porter, 

Competitive Advantage, 1985. 
4-2 

U.S. Market Characteristics 

Olive oil has not yet become a mature product category in the U.S. market, but it is 

growing rapidly.2

 In 2009, olive oil accounted for nearly 8 percent of total edible oil sales 

and was the fourth most consumed oil in the United States, by volume.3

 Growth in the 

consumption of olive oil was double that of any other fat, oil, or spread product over the 

period 2004–08, with an average annual value growth rate approaching 13 percent.4

 This 

is especially noteworthy considering its high price in the United States compared to other 

vegetable oils. U.S. household penetration for olive oil was about 40 percent in 2011, and 

given the size of the U.S. market, even a small increase would have a significant impact 

on total U.S. consumption.5

Olive oil competes for sales in the U.S. market with other available fats and oils, 

including butter and spreads, shortening, and cooking oil. In the United States, olive oil is 

primarily used for cooking and in dressings and marinades and competes with an array of 

other available edible oils, such as canola, corn, soy, and vegetable oil blends. Currently, 

health is a key driver in U.S. consumers’ decisions about fats and oils generally, and olive 

oil is seen as one of several healthy oil choices.6

 The regulation of trans fats in the United 

States in 2006, along with the promotion of “healthy fats,” helped to bring this notion to 

the forefront for many Americans.7

 

Overall, the U.S. olive oil market can be characterized by lack of consumer knowledge 

about the quality/price tradeoff and the uses of olive oil (e.g., for cooking versus finishing 

dishes).8

 Market segmentation by brand, country of origin, or flavor preferences is not 

clearly defined; the labels on U.S. retail olive oil products lack consistent, meaningful 

terms that designate country of origin or varietal. At the same time, price competition is 

intense in the U.S. market. 

Factors Driving Increased U.S. Consumption 

From a relatively small base, U.S. olive oil consumption has grown rapidly in the last 

decade. U.S. consumers increasingly recognize the health benefits of olive oil, and the 

U.S. Food and Drug Administration authorized sellers of olive oil to make certain 

 2

 Datamonitor, Study on the Promotion of Olive Oil, January 20, 2010, 49. In a product category life 

cycle, products can reach a stage of maturity after the successful introduction of a new product followed by a 

growth stage. While the growth stage is characterized by a period of rapid revenue growth, a mature product 

generally experiences a leveling off of revenue growth levels. Product Arts, “The Product Category Lifecycle” 

(accessed June 20, 2013). 3

 Datamonitor, Study on the Promotion of Olive Oil, January 20, 2010, 49. The three most consumed 

edible oils in the United States are soybean, canola, and corn oils. 4

 Datamonitor, Study on the Promotion of Olive Oil, January 20, 2010, 49. 5

 Bauer, “The U.S. Import Market,” 2011, 29. 

6

 Datamonitor, Study on the Promotion of Olive Oil, January 20, 2010, 50. Healthy cooking oils are 

those that contain high levels of monounsaturated and polyunsaturated fats. CDC, “Monounsaturated and 

Polyunsaturated Fats” (accessed June 5, 2013). 7

 Since 2006, trans fat levels must be stated on food nutrition labels in the United States. 8

 Datamonitor, Study on the Promotion of Olive Oil, January 20, 2010; industry representatives, 

interviews by USITC staff, Tuscany, Italy, January 30, 2013; industry representatives, interviews by USITC 

staff, California, November 13–15, 2012. 
4-3 

qualified health claims on their products in 2004.9 Olive oil is low in saturated fat and 

high in omega-3 fatty acids that reduce the risk of heart disease. While other vegetable 

oils, such as canola, also have low levels of saturated fat providing similar health 

benefits, olive oil has additional beneficial properties, such as antioxidants and 

polyphenols (anti-inflammatory compounds that promote healthy cardiovascular 

function). Virgin olive oils contain more polyphenols than other grades of olive oil, 

elevating their health benefits.10 Consumer awareness of the health benefits associated 

with olive oil as part of the “Mediterranean diet” has particularly helped heighten 

consumer interest in olive oil. Other factors contributing to increased U.S. consumption 

are the decreasing U.S. market price of olive oil over time and a growing cooking and 

gourmet food culture in the United States.

Sources of Supply in the U.S. Market 

Imports accounted for 97 percent of U.S. consumption of olive oil in 2012, by volume, 

with the remainder supplied by U.S.-produced olive oil. 11 In 2012, approximately 

62 percent of U.S. olive oil imports were in consumer-ready bottles,12 generally in sizes 

between 250 ml and 3 liters in glass or plastic (PET) bottles or metal tins. The remainder 

entered the United States in bulk, either in tankers, 20-ton flexitanks, 1,000-liter totes, or 

200-kg steel drums. The United States is unique among countries that import significant 

quantities of olive oil in that there are large local bottlers of imported bulk oil. Imported 

bulk oil destined for retail sale is shipped to these U.S. bottling plants, which blend 

several imported olive oils, often from multiple source countries and olive varieties, to 

obtain preset flavor profiles. These firms then package the products for sale to retail 

businesses, under brand names or private labels (products sold under a store’s own brand 

label), or to the food service segment. Some imported bulk oil is also delivered directly in 

large tanker trucks to large food processors (figure 4.1). 

Consumption Characteristics in the U.S. Market

Consumption by Market Segment 

Olive oil is sold in three main market segments: retail outlets, food service, and the food 

processing industry. The food service segment includes full-service and quick-service 

restaurants, hotels, and institutions (e.g., hospitals, schools, cafeterias, and prisons), while 

the food processing industry uses olive oil as an ingredient in processed foods. Data 

representing the shares by value and volume of these segments are presented in table 4.1. 

 

9

 Effective November 2004, the U.S. Food and Drug Administration (FDA) allowed olive oil products 

to carry the following claim: “Limited and not conclusive scientific evidence suggests that eating about 2 

tablespoons (23 grams) of olive oil daily may reduce the risk of coronary heart disease due to the 

monounsaturated fat in olive oil. To achieve this possible benefit, olive oil is to replace a similar amount of 

saturated fat and not increase the total number of calories you eat in a day. One serving of this product 

contains [x] grams of olive oil.” FDA. “Summary of Qualified Health Claims,” (accessed August 2, 2013).

10 Covas, “The Effects of Polyphenols in Olive Oil,” September 5, 2006. 11 USITC DataWeb/USDOC (accessed May 14, 2013); California Olive Oil Council, data provided to 

USITC staff, June 20, 2013. 12 USITC DataWeb/USDOC (accessed May 14, 2013). 
4-4 

FIGURE 4.1 Sources of U.S. olive oil supply and market channels 

Source: GTIS, Global Trade Access database (accessed June 19, 2013); Datamonitor, “Study on the promotion of 

olive oil,” January 20, 2010; USITC estimates. 

TABLE 4.1 U.S. olive oil consumption, by market segment, selected years 

2004 2008 2009

Value ($1,000) 

 Retail 587,900 954,700 984,643

 Food service and food processing 586,903 824,758 670,705

Volume (1,000 liters) 

 Retail 78,600 91,900 98,333

 Food service and food processing 173,640 187,872 191,630

Price per liter ($) 

 Retail 7.48 10.39 10.01

 Food service and food processing 3.38 4.39 3.50

Consumption per capita (liters) 

 Retail 0.268 0.302 0.320

 Food service and food processing 0.593 0.618 0.624

 Total 0.861 0.920 0.944

Source: Datamonitor, “Study on the Promotion of Olive Oil,” January 20, 2010. 
4-5 

While 66 percent of the total volume of olive oil was sold into food service and food 

processing channels in 2009, these channels only accounted for 41 percent of the total 

sales value.13

The share of olive oil sold into the main market segments has been fairly consistent over 

the last three years. Based on industry estimates for 2012, roughly 35–40 percent (by 

volume) of olive oil in the United States was sold in the retail segment, 40–45 percent to 

food service, and 20 percent to the food processing segment.14 In the United States, each 

of these market segments has different demands with regard to olive oil qualities, 

characteristics, and prices. While both U.S. olive oil and imported olive oil are sold to 

each segment, price sensitivity in the food service and food processing sectors limits the 

demand for (typically higher-priced) extra virgin olive oil, which accounts for the vast 

majority of U.S. olive oil production. 

Food Service and Food Processing 

Primary food service markets include full- and quick-service restaurants and institutional 

customers. Olive oil is used mainly in full-service restaurants because of its high cost and 

general unsuitability as a multi-use deep-frying oil used in most American quick-service 

restaurants. In high-end restaurants, extra virgin olive oil may be used at the table for 

dipping, for pouring over plated food before serving (“finishing”), or in the kitchen for 

salad dressings, sautéing, and frying. Food processors use olive oil as an ingredient in a 

wide variety of foods, including tomato sauce, salad dressing, cooking spray, and frozen 

entrees. 

Olive oil customers in the food service and food processing market segments tend to be 

price sensitive and purchase lower grades of olive oil and blends of olive oil with other 

edible oils. However, flavor also is a key consideration for many restaurant buyers.15

Olive oil sold to restaurants tends to be in large packages, including “bag-in-a-box” (10 

or 20 liters) or 3-liter tins, and extra virgin oil can range in price between $3 and $8 per 

liter, depending on quality.16 

Although the restaurant and food processing segments of the market typically have lower 

price points than the retail segment, they offer certain cost and marketing advantages for 

olive oil producers. Pricing and profit margins in the retail segment tend to vary 

somewhat due to a variety of added costs that differ from year to year, such as shelf 

placement fees (discussed in more detail below) and promotional campaigns that most 

retailers require. In contrast, prices in the food processing segment are typically 

determined on a simple cost-plus-margin basis. 17 In addition, from a marketing 

standpoint, restaurant purchasers tend to be chefs, who are readily accessible to suppliers 

and familiar with the type and quality of olive oil they need.18 

Most food processor consumers of olive oil are large, often multinational, food 

companies that use large volumes of consistently flavored oil as an ingredient in a variety 

of food products with national distribution. These types of olive oil consumers often 

 13 Datamonitor, Study on the Promotion of Olive Oil, January 20, 2010, 23. 14 Commission estimates based on industry estimates. AOOPA, written submission to the USITC, 

December 12, 2012, 6; NAOOA, written submission to the USITC, December 17, 2012, 55. 15 Industry representative, telephone interview by USITC staff, March 17, 2013. 16 Ibid. 

17 Industry representative, interview by USITC staff, Washington, DC, April 9, 2013. 18 Industry representative, telephone interview by USITC staff, March 17, 2013. 
4-6 

demand third-party audits and traceability from all their suppliers. These customers may 

rely on importers to store the olive oil themselves and provide just-in-time delivery to 

food processing plants. This type of olive oil customer typically purchases lower grades 

of olive oil, since it is merely one of many ingredients included in the final food 

product.19

Retail 

Retail market channels for olive oil include big box stores, supermarkets, boutique olive 

oil shops, farmers markets, online vendors, and roadside stands. Although the current 

volume of olive oil sold into the food service and food processing segments outstrips that 

for retail, future growth in U.S. olive oil consumption is likely to be in the retail 

segment.20 

Olive oil grades and flavor profiles 

Olive oil products available in the U.S. market range from high-grade extra virgin 

(usually higher-priced, with distinctive flavor characteristics) to lower-grade olive oil 

(usually lower-priced, lacking in distinctive flavor characteristics). In the U.S. retail 

market, consumers prefer products labeled as extra virgin olive oil; virgin olive oil is not 

widely marketed. During 2010–12, U.S. retail olive oil consumption was 66 percent extra 

virgin grade and 33 percent refined olive oil; less than 0.5 percent of sales were of virgin 

olive oil.21 Generally U.S. consumers prefer a milder, buttery-flavored olive oil to strong, 

pungent and bitter oils, often because this is the flavor profile to which they have most 

commonly been exposed. However, consumption of fruity, flavorful, and bitter extra 

virgin olive oils is rising as more U.S. consumers try them.22 Historically, U.S. imports 

consisted mainly of lower olive oil grades, such as “pure” olive oil (refined olive oil 

blended with a small amount of extra virgin), but over time demand for extra virgin has 

increased. “Light” or “sweet” flavor profiles characterize mass-marketed extra virgin oils 

in the United States. Such oils are typically on the low end of the extra virgin price range 

in the United States market, appealing to price-conscious U.S. retail consumers.23 

Extra virgin olive oil is recognized by many U.S. consumers as the highest quality oil 

and, as a result, receives a price premium in the U.S. market. Based on national Nielsen 

retail sales data, extra virgin olive oil sold at retail enjoys a $0.12 per ounce price 

premium over other olive oil grades, including refined olive oil and refined olive oil 

blended with virgin olive oils. 24 The average retail price of extra virgin olive oil during 

2010–12 was $0.47 per ounce compared to $0.35 per ounce for all other olive oil grades. 

This price premium is due to a number of factors, including the additional costs 

associated with producing extra virgin olive oil, global wholesale price differences 

between refined and extra virgin oil, and consumer willingness to pay more for perceived 

higher quality. 

Flavor profiles of extra virgin olive oils range from light, to medium, to intensely fruity, a 

term used to describe flavorful olive oils that often have a bitter, pungent aftertaste 

 19 Industry representative, interview by USITC staff, Washington, DC, April 9, 2013. 20 Datamonitor, Study on the Promotion of Olive Oil, January 20, 2010. 21 The remainder was flavored olive oil. Nielsen, U.S. Retail Market Data, 2013. 22 Industry representative, interview by USITC staff, California, November 14, 2012. 23 Industry representative, interview by USITC staff, Puglia, Italy, February 4, 2013. 24 All price data in this section, unless otherwise indicated, is sourced from Nielsen, U.S. Retail Market 

Data, 2013. 
4-7 

resulting from high levels of polyphenols. However, specific descriptors are not typically 

found on current labeling, making purchasing decisions harder for consumers. Consumer 

palates in the United States are slowly changing, and in a small but growing market 

segment, demand for bolder profiles of extra virgin olive oil is increasing.25 This niche 

market segment for flavorful olive oil includes consumers drawn to natural, organic, 

gourmet, and specialty foods, whose interest in food quality and sourcing has increased in 

recent years. 

Consumers in this segment are willing to pay higher prices for premium extra virgin olive 

oil, typically characterized by bolder flavor profiles. Such premium oils can range in 

price from $12 to $20 per liter in the U.S. market, with specific regional or varietal extra 

virgin sold at wineries, gourmet stores, and stand-alone olive oil and vinegar shops for 

$25 to $60 per liter. 26 While data from many of these specialty sales outlets is not 

tracked, estimates are that olive oils priced at $25 per liter or higher, whether domestic or 

imported, represent just 2 percent of total U.S. market sales.27 Demand for organic olive 

oil is growing as well; it has experienced double-digit growth in recent years, ranging 

from 15 percent to 30 percent, depending on the channel of distribution. However, 

organic oil still represents an extremely small share—less than 2 percent—of total retail 

sales.28

Retail consumption by region 

U.S. olive oil consumption is concentrated along the East Coast of the United States, 

particularly in the northeastern states. This reflects both historical Italian immigration 

patterns and high population density. Per capita consumption is highest in New England, 

at 25.1 ounces, followed by the Middle Atlantic states at 21.2 ounces (see figure 4.2). Per 

capita consumption rates drop dramatically in the center and west of the country, ranging 

between 7.5 and 10 ounces per capita.29 While olive oil consumption is expanding and 

becoming more common even in the center of the country, more than half of the olive oil 

sold in U.S. retail food outlets is sold in the East Coast.30

U.S. retail prices for olive oil also vary by region. Average price per ounce of extra virgin 

olive oil ranged from $0.46 in the New England and South Atlantic regions to $0.56–

0.58 in the Pacific and Mountain regions. The higher West Coast price may reflect the 

additional costs for transporting imported oil from U.S. bottling facilities on the East 

Coast. In addition, because the majority of U.S. consumption occurs in the northeastern 

states, retail turnover is higher and almost all major brands have a significant presence in 

the region, resulting in highly competitive pricing. 

Retail consumption by brand 

The domestic olive oil market is fragmented, with more than 500 brands sold in retail 

outlets around the country.31 Nonetheless, the largest brands all have a national presence 

as well as market power in terms of pricing and distribution. There are distinct market

 25 Industry representative, interview by USITC staff, Tuscany, Italy, January 31, 2013. 26 NAOOA, written submission to the USITC, December 17, 2012, 63; Nielsen, U.S. Retail Market 

Data, 2013. 27 NAOOA, written submission to the USITC, December 17, 2012, 63. 28 Ibid., 62. 

29 Nielsen, U.S. Retail Market Data, 2013.

30 Bauer, “The U.S. Import Market,” 2011, 29. 

31 Nielsen, U.S. Retail Market Data, 2013. 
4-8 

FIGURE 4.2 Average annual U.S. per capita sales, by region, February 2010–February 2013 

Sources: Compiled by USITC staff. Nielsen, U.S. Retail Market Data, 2013. 

leaders in the retail segment, with the three largest national brands (Bertolli, Felipo Berio, 

and Pompeian) accounting for a combined 36 percent of total retail sales between 2010 

and 2012. 32 During this same period, retail private label, non-branded oils made up 

29 percent of national retail sales, a larger share than any individual brand in the olive oil 

category. 33 Considering that private label products are typically (but not always) 

marketed as lower in price relative to branded products, this seems to indicate that, 

despite the market power of the large brands, U.S. consumers are price-conscious and 

only moderately brand loyal when choosing olive oil, viewing low price as a more 

important factor in purchasing decisions.34 

 32 Nielsen, U.S. Retail Market Data, 2013. 

33 Ibid. 

34 Industry representative, interview by USITC staff, Andalusia, Spain, January 24, 2013; JiménezGuerrero et al., “Consumer Preferences for Olive Oil Attributes,” February 2012. 
4-9 

Despite the large volume of sales by the top few national brands, market shares for the 

top brands vary greatly by region. Certain brands have targeted their marketing and 

distribution efforts in certain regions of the country. Such targeted distribution 

contributes to relatively higher levels of retail private label sales in regions where fewer 

branded options are available. For example, during 2010–12, 43 percent of sales in the 

East South Central region were of private label product, versus 18 percent in the New 

England region.35 In certain regions, the market leaders face stiff competition for market 

share from smaller firms that supply higher-quality domestic oils. For example, in the 

Pacific region, California Olive Ranch, a domestic producer, was tied for fifth place with 

Felippo Berio in 2012, with a 4 percent market share (versus 1.3 percent nationally). Yet 

Felippo Berio was the market leader in the large consuming regions of New England and 

the Middle Atlantic, with market shares of 38 and 23 percent, respectively, in 2012.36 

Factors Affecting Consumption in the U.S. Retail Market 

Overview 

Certain supply and demand factors have a particularly strong impact on consumption of 

olive oil in the U.S. market and the competition among supplying firms. Supply-side 

factors include firms’ ability to differentiate their products in terms of quality and other 

favorable characteristics (e.g., country of origin and health benefits). Among the demandside factors are U.S. consumers’ perceptions of differentiated products and their 

willingness to pay price premiums for those differences. 

While health claims for olive oil may boost demand for all types of olive oil, individual 

olive oil producers work to differentiate their products by level of quality, branding and 

marketing strategies, and price. At one level, product differentiation can be achieved by 

complying with internationally recognized grade standards (see chapter 3). But standards 

are useful as a means of product differentiation only to the extent that consumers both 

understand the relationship between standards and quality and embrace the value of 

different olive oil grades or quality levels. However, because current standards allow a 

wide range of olive oil qualities to be marketed as extra virgin, meeting the standards is 

not an effective means of product differentiation. Moreover, many U.S. consumers 

choose olive oil based only on price, giving an advantage to producers with low costs of 

production and large economies of scale. 

This section discusses the competitive factors affecting U.S. olive oil consumption in 

light of the business strategies, or business models, of olive oil firms supplying the U.S. 

market. Domestic olive oil producers include both small artisanal firms and larger 

integrated mills. Both of these types of firms may also market imported olive oils. This 

activity, however, is dominated by large bottlers, headquartered mainly in Spain and Italy 

but also in the United States. These firms procure large volumes of raw-material olive oil 

globally from various sources, including cooperative mills and private millers. In regard 

to the competitive factors presented below, each of these business models has inherent 

competitive strengths and weaknesses that determine a firms’ product mix and target 

market segment, its ability to conduct marketing and support a brand, and its pricing 

strategy. 

 35 Nielsen, U.S. Retail Market Data, 2013. 

36 Ibid. 
4-10 

Consumer Awareness and Flavor Preferences 

Broadly, two types of olive oil consumers exist in the U.S. market: (1) those with 

knowledge of the product and who generally prefer flavorful oils, and base purchases on 

product attributes, and (2) those who are less knowledgeable about the product, are 

accustomed to milder-flavored oil, and base purchases primarily on price. Currently, the 

second type of consumer comprises the domestic mass market for olive oil, due at least in 

part to a lack of exposure to flavorful extra virgin olive oil. 

Research shows that most U.S. retail consumers do not distinguish among the various 

grades of olive oil,37 let alone among extra virgin olive oils made from different varietals 

or from different countries or regions. Some olive oil marketers report that at producttasting events hosted at U.S. retail outlets, many consumers were trying olive oil for the 

first time.38 Other research has suggested that some U.S. consumers actually consider oil 

defects, such as rancidity and mustiness, to be positive taste attributes.39 The lack of 

consumer awareness suggests that there is considerable room for consumption growth in 

the extra virgin category in the United States if more consumers were better educated 

about olive oil quality differences, its health benefits, and usage. 40 However, national 

promotional campaigns are costly, often prohibitively so for small olive oil producers, 

including those in the United States. 

In the absence of consumer education and outreach efforts, U.S. consumers tend to 

gravitate toward less costly oils, since they are unable to distinguish quality differences at 

the point of purchase, benefitting large olive oil bottlers that focus on cost leadership. 41

This negatively affects U.S. producers, in particular, who almost exclusively sell 

premium extra virgin olive oil and struggle to market the unique attributes of their high 

quality product to consumers. Large-scale olive oil firms view their global sourcing 

strategies as a competitive strength for targeting price-conscious U.S. consumers. By 

blending different oil varieties, they report that they are able to match customer 

preferences in specific markets,42 as well as supply consistently flavored olive oils, a key 

criterion for many customers, at low prices.43 Large bottler/blenders report that the flavor 

profile and price they offer responds to the demands of most U.S. customers.44 U.S. 

producers, in contrast, offer a bolder flavor profile more suited to the knowledgeable, 

quality-conscious consumer, a much smaller but growing segment. 

 37 Wang, Moscatello, and Flynn, “Survey: Consumer Attitudes on Olive Oil,” May 2013, 1–2. 38 Industry representatives, interview by USITC staff, California, November 13, 2012. 39 Delgado and Guinard, “How Do Consumer,” March 2011, 218; Industry representative, interview by 

USITC staff, California, November 14, 2012. 40 U.S. industry representatives report that a growing segment of U.S. consumers, once exposed to 

fruity, flavorful extra virgin olive oil, actually prefer it to neutral-flavored extra virgin olive oil. U.S. industry 

representatives, interviews by USITC staff, California, November 14, 2012. 41 A review of the empirical literature on the importance of particular product attributes that contribute 

to consumer preferences for extra virgin olive oil (such as price, origin, variety, color, or flavor) found that in 

all cases, price was the most important attribute. Jiménez-Guerrero et al., “Consumer Preferences for Olive 

Oil Attributes,” February 2012. 42 Industry representative, interview by USITC staff, Madrid, Spain, January 22–23, 2013. 43 Industry representative, interview by USITC staff, Madrid, Spain, January 22–23, 2013; industry 

representative, interview by USITC staff, Maryland, December 20, 2012. 44 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 23, 2013; industry 

representatives, interviews by USITC staff, Tuscany, Italy, January 30, 2013. 
4-11 

Branding and Marketing 

The U.S. olive oil market is home to long-standing brand names, some in existence for 

generations and often of Italian origin. Branding involves companies’ efforts to associate 

their product with high quality or other attributes desirable to consumers (such as flavor 

profile, country origin, or organic production). In addition, some firms acquire 

certifications for their olive oil that attest to high quality or other attributes with 

corresponding seals on labels. California olive oil production has also benefited from the 

California-grown cachet that has developed around other products grown in the state. 

Locally grown products are also developing their own following in the U.S. food market. 

Although branding can be an effective marketing strategy, not all olive oil producers 

choose to market branded olive oil in the United States. Several firms produce large 

volumes of olive oil of various grades for private label sales. These products are 

generally sold under the retailer’s label and name (e.g., Safeway, Kroger, or Publix). 

These store brands are often positioned as bargain brands, although not exclusively so.45

Focusing on the segment of the market that looks for bargain brands has been an effective 

strategy for some firms to gain market share in the price-competitive U.S. olive oil 

market. 

Seals and Certifications 

Producers of olive oil use seals and certifications to promote certain oil characteristics to 

consumers and to differentiate their products based on quality. For a producer to qualify 

for certification and a seal, requirements specific to either methods of production, regions 

of production, and/or product characteristics must be met. The level of difficulty of 

meeting these requirements varies and, as a result, there is a wide disparity in how 

consumers perceive the quality of the oil associated with each seal and certification. 

In the United States, in addition to the U.S. Department of Agriculture’s (USDA) Quality 

Monitoring Program (QMP) (see text box 3.6), several other certifications are available to 

domestic olive oil producers. These programs do not provide a legal certification of the 

market grade of the oil, but rather a promotional evaluation for the oil for their target 

market. The California Olive Oil Council (COOC) has a quality seal program that grants 

members a “COOC Certified Extra Virgin” seal for California-produced olive oil. The 

Texas Olive Oil Council has also initiated a seal program that certifies Texas-grown extra 

virgin olive oil. The standards for these two state seals are more rigorous than the IOC 

chemical standards and are therefore meant to promote only premium-quality brands. In 

addition, the North American Olive Oil Association (NAOOA), whose members are 

importers of olive oil into the United States, has a quality seal program requiring 

imported products to meet IOC standards as determined by an IOC-accredited laboratory. 

Many of the leading extra virgin brands in the U.S. retail market, including Bertolli, 

Pompeian, Crisco, and 365 brands (the Whole Foods private label product), display the 

NAOOA seal on their bottles. 

 45 Consumers have variable perceptions of private label products in the U.S. market. For example, 

certain food retailers, such as Wegman’s and Whole Foods, promote their private label products as “high end.” 

The private label goods offered by many other retailers, such as ShopRite, are not marketed to or perceived 

by U.S. consumers that way. Industry representatives, interviews by USITC staff, Andalusia, Spain, January 

24, 2013. 
4-12 

Some imported olive oil in the U.S. market has been certified through programs that exist 

in several other countries. The EU oversees a certification program that provides a seal 

for the labels of protected designation of origin products (PDOs), designating olive oil 

made from a particular olive variety or varieties, grown in a designated region, and 

harvested and milled using specific production techniques. 46 The Australian Olive 

Association (AOA) also has a quality seal for oils produced in Australia that requires that 

the producer sign a Code of Practices addressing olive oil quality, food safety, ethical 

marketing, environmental standards, and other issues.47 

Each certification and seal has a varying degree of consumer recognition and value in the 

market. Some industry sources report that consumer recognition of quality seals is 

minimal,48 while others report receiving a price premium––this is the case for PDOs in 

particular. In Italy, certain producers report they typically receive a 15 percent price 

premium for a PDO, but at the retail level the price disparity is even greater.49 U.S. retail 

market data show that olive oil marketed under a PDO sells at a 50 percent per ounce 

premium. 50 These prices, however, also reflect higher costs associated with the 

production methods required by many PDO certifications. The large number and 

diversity of seals used on olive oil bottles in the U.S. retail market reduces the value of 

individual seals and certifications to consumers. 

Italian Brand Cachet 

Some producers rely on the cachet of Italian olive oil, which is still perceived by many 

U.S. consumers of olive oil to denote authenticity and quality. U.S. consumer preferences 

for Italian olive oil can be traced to the late 1800s, when immigrants from Italy created 

demand for Italian olive oil, an important ingredient in Italian cuisine. Olive oil import 

businesses developed in the United States to meet this demand.51 In olive oil marketing, 

Italian cachet is linked not only to the country of Italy, but to certain Italian regions 

identified with olive oil, such as Tuscany. Although the Tuscany region today has 

relatively little olive production, the global olive oil brands Bertolli, Carapelli, and Sasso 

were all originally located in this region, and large Italian bottling companies see their 

location there as valuable for marketing purposes.52 The Carapelli brand, for example, is 

called “Carapelli Firenze”; it is the only Italian brand to include the city name of 

Florence, permanently linking it to the region.53 

Some brands make use of Italian cachet by using Italian words or images in their 

marketing without actually having any connection to the country. Others highlight the 

fact that they were “packed in Italy” or are a “product of Italy” without revealing on the 

label that the majority of the oil supplied was imported from other countries, not made 

from olives actually grown in Italy. Because most consumers are largely unaware of the 

implications of the terminology used, these practices are often misleading. 

Some in the global olive oil industry feel that among knowledgeable olive oil consumers, 

Italian brand cachet is diminishing, partly because high-quality olive oils are increasingly 

 46 More information on PDOs is in chapter 6. 47 More information on the AOA quality seal is in chapter 8. 48 Industry representative, interview by USITC staff, Rome, Italy, February 1, 2013. 49 Industry representative, interview by USITC staff, Puglia, Italy, February 4, 2013. 50 Nielsen, U.S. Retail Market Data, 2013. 

51 NAOOA, written submission to the USITC, December 17, 2012; USITC, hearing transcript, 

December 5, 2012, 175–76 (testimony of Eryn Balch, NAOOA). 52 Industry representative, interview by USITC staff, Tuscany, Italy, January 2013. 53 Ibid. 
4-13 

emerging from other, nontraditional producing countries. 54 Others report that Italian 

producers are losing their reputation for high-quality extra virgin olive oil because large 

bottlers that rely on “Italian” identity in their marketing have set a mediocre standard for 

extra virgin.55

California Brand 

The California brand cachet has been successful in promoting several other agricultural 

products, including almonds, pistachios, and pomegranates, and now is growing for olive 

oil. California olive oil has also benefited from the “locally grown” food movement in the 

United States. Some established international olive oil importers have recognized the 

marketing value of the Californian brand and have even begun sourcing California olive 

oil in order to develop a California product line and take advantage of consumer demand 

for California-produced products. There has also been some recent investment in 

agricultural land in California by foreign firms wishing to produce their own olive oil 

with California olives.56 

 Pricing 

 The U.S. retail price for olive oil is a function of the delivered cost of the packaged oil, 

which includes the cost of producing or procuring the oil, as well as costs for packaging, 

storage, transportation, distribution, marketing, and promotions. It is also a function of 

the firm’s pricing strategy, which takes into account consumer and retailer price demands 

and expectations. Pricing strategies also reflect a firm’s business model, size, and the 

characteristics of the product it wishes to market. 

The U.S. mass market for olive oil is extremely price competitive. Olive oil firms, 

supplying one of hundreds of food items in the grocery store, vie for the attention of a 

generally price-sensitive U.S. food consumer with many food choices. U.S. grocery 

retailers, in turn, face intense competition with each other as well as with mass 

merchandisers, such as Walmart and Costco, which market food in addition to a wide 

range of consumer items. 57

In this competitive environment, the pricing strategies of firms that supply U.S. grocery 

retailers are designed to retain their products’ grip on limited shelf space, as 

underperforming products can quickly be replaced by others. Several strategies that can 

be adopted by olive oil firms to compete in this environment are discussed below. 

Cost leadership pricing 

Cost leadership pricing focuses on customers’ price sensitivity and aims to provide low 

cost products. Firms that focus on cost leadership require low-cost inputs and economies 

of scale to lower unit costs of bottling, transportation, and distribution.58 Most of the olive 

oil sold in the United States is bottled and packed by large firms, based in the EU and the 

 54 Industry representative, interview by USITC staff, Meknes, Morocco, January 27, 2013. 55 Industry representative, interview by USITC staff, Tuscany, Italy, January 31, 2013. 56 Industry representative, interview by USITC staff, Maryland, December 20, 2012. 57 U.S. grocery retailers have their own pricing strategies, such as everyday low prices or revolving 

promotional discounts. 58 Porter, Competitive Advantage, 1985. 
4-14 

United States, that execute this type of pricing strategy. 59 These firms benefit from 

considerable economies of scale with virtually no vertical integration of growing, milling, 

and bottling. Most firms of this type source the vast majority of their raw material olive 

oil supplies from independent sources all over the world, in arms-length transactions, 

because their business model relies on extremely large volumes of oil of various grades, 

flavor profiles, and prices. This strategy enables them to produce consistent blends of 

various grades of olive oil, including neutral-flavored extra virgin, at low prices. 60 These 

firms report that they aim to provide a consistent, average-quality extra virgin olive oil to 

satisfy their customers with a balance between quality and price.61 This pricing strategy is 

successful for these firms because most U.S. consumers purchase olive oil based 

primarily on price. 

The cost leadership pricing strategy requires low-cost olive oil because the cost of olive 

oil represents such a large share of the final retail price. Worldwide, olive oil costs of 

production at the grower level vary somewhat (see table 2.2), with higher production 

costs per unit of oil typically associated with both higher-quality extra virgin olive oil and 

inefficient traditional growing methods. However, because large bottlers/blenders are 

typically not involved in producing the oil themselves, global wholesale prices, not 

growers’ costs of production, are the bottlers/blenders’ main consideration. 62 While 

global wholesale prices for olive oil fluctuate depending on global supply and demand 

conditions, there has typically been an oversupply of olive oil on the global market owing 

to the structure of the EU olive oil sector, including EU government support. This 

oversupply has contributed to low global wholesale prices for olive oil, to the benefit of 

large bottler/blenders. 63

In addition to large supplies of wholesale olive oil, large olive oil bottler/blenders further 

benefit from considerable market power in procuring their oil. The concentration and 

large size of bottler/blenders and the fragmented supply chains in many olive-growing 

regions give them the ability to control price negotiations for olive oil supplies.64 In 

addition, the bottler/blenders’ large storage capacities, as well as the limited storage of 

many producers, allow bottler/blenders to maximize their purchases when prices are low. 

The ability to diversify input sources and reduce procurement costs leads to lower prices 

at the retail level for companies that follow this business model. 

 

 59 In 2012, 79 percent of U.S. retail sales were accounted for by the top eight brands, including private 

label products aggregated into one “brand.” The brands included Bertolli, Felippo Berio, Pompeian, Colavita, 

Star, Boticelli, and Carapelli. Nielsen, U.S. Retail Market Data, 2013. 60 Many large olive oil bottlers/blenders in the EU also operate refining facilities. Their refining 

operations have an important impact on their business model. Not only is an additional income stream created 

from refined oil sales, but high-value byproducts are separated out in the refining process, including two free 

fatty acids—squalene and its hydrogenized form, squalane—which are used in personal care products such as 

moisturizers. (In 2012, squalene sold for €20–€22/kg and squalane sold for €25–€26/kg. Industry 

representative, interview by USITC staff, Andalusia, Spain, January 23, 2013.) Refining operations can also 

involve other vegetable oils, such as sunflower oil, creating a diversity of income streams which can protect a 

producer from downturns in a given market. 61 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 23–24, 2013. 62 Industry representative, interviews by USITC staff, Andalusia, Spain, January 23–24, 2013. 63 International olive oil prices declined over the 2008–12 period owing to increased production 

(mainly in Spain), which outpaced consumption (see box 2.2). However, in MY 2012/13 global wholesale 

prices rose when a poor harvest drastically reduced production in Spain. 64 EC, “Action Plan for the EU Olive Oil Sector,” June 18, 2012, 5. See chapter 6 for further 

information. 
4-15 

Product-Differentiated Pricing 

Product-differentiated pricing involves pricing products to reflect their unique quality 

attributes. Firms using this strategy create brand loyalty among customers, who respond 

by being less sensitive to price.65 A small fraction of olive oil sold in the U.S. market is 

produced by smaller, vertically integrated olive oil producers, including those in the 

United States. Such producers focus on selling premium extra virgin olive oil at prices 

generally above the industry average, prices which reflect the quality attributes of their 

product. These producers target U.S. consumers willing to pay more for higher-quality 

olive oil. 

Higher production costs contribute to a higher delivered cost for these producers. U.S. 

producers’ focus on producing almost exclusively high-quality extra virgin olive oil 

requires intensive use of inputs; early harvesting; costly, high-tech milling machinery; 

and, in many cases, mechanical harvesting. These producers are also generally vertically 

integrated in growing and milling, which can increase quality control but has typically 

been associated with smaller-scale production. The smaller operational scale translates 

into relatively high fixed production costs, higher delivered costs, and higher prices at the 

retail level. 

Distribution and Retailing Costs 

Beyond the cost of olive oil production, the magnitude of other costs, such as 

transportation, marketing, and distribution, differ among firms competing in the U.S. 

market and affect their pricing strategies and the retail prices of various olive oil 

products. Economies of scale allow large blender/bottlers to gain volume discounts for 

transportation and distribution logistics. Conversely, the small scale of many U.S. olive 

oil producers translates into relatively high costs. In addition, small firms often find 

themselves at a disadvantage in entering large, national retail grocery chains. These 

outlets require large financial investments in retail shelf-placement fees (slotting fees) 

and an extremely large volume of product, particularly to support in-store promotions. 

Moving from local to nationwide sales requires olive oil firms to make significant 

investments in retail distribution. Firms deliver olive oil to retailers using either their own 

transportation infrastructure or through national distribution companies. Distributing 

directly to national retailers requires building a logistics infrastructure that is sufficient to 

supply products throughout the country. Although some larger California producers have 

made significant annual investments to support this type of distribution infrastructure,66

smaller firms currently lack the resources and sales volumes to make these types of 

investments feasible.67 As a result, smaller firms are forced to use distribution companies, 

which is costly. Using national distributors can add an additional 30 percent to a 

producer’s delivered cost to the retailer, making it difficult for small firms to compete on 

price.68 

Supplying national food retailers with olive oil also involves considerable investments 

and volumes of olive oil. Shelf placement fees are payments a supplier makes to a retailer 

 65 Porter, Competitive Advantage, 1985. 66 USITC, hearing transcript, December 5, 2012, 122–124 (testimony of Gregg Kelly, California Olive 

Ranch). 67 USITC, hearing transcript, December 5, 2012, 64–66 (testimony of Gregg Kelly, California Olive 

Ranch). 68 Industry representative, telephone interview by USITC staff, June 19, 2013. 
4-16 

as a condition for each placement of the supplier’s product on the retailer’s store shelves 

or warehouse space.69 These required payments can be in the tens of thousands of dollars 

per item, although they do not guarantee sales or profitability for the paying supplier.70

The high cost of these fees can be a barrier to entry for many smaller U.S. olive oil 

producers who want to move from farmers’ market sales into the branded retail category. 

One U.S. producer has spent more than $2.5 million buying shelf space over the last 

several years for only 50 percent market penetration in the U.S. retail segment.71

Because of the price sensitivity of U.S. olive oil consumers, retail grocery promotions 

play an important role in determining retail price points and sales of olive oil, and can 

account for more than 50 percent of retail olive oil sales.72 Promotions are temporary 

price reductions on a particular brand that are advertised locally and are used by retailers 

to entice customers into the store and to boost sales. Typically, retailers require a supplier 

to have a minimum number of promotions on its product per year. Although the price 

reduction can be absorbed by both the retailer and the supplier in some instances, more 

typically the majority of the promotional discount is absorbed by the supplier, making 

promotions costly per unit even though they may move a considerable volume of product. 

In order to have a promotion, an olive oil supplier must have a large enough volume of 

product available to satisfy promotion-seeking customers.73 

Firms selling U.S.-produced olive oil report that they have had considerable success with 

selling small volumes of high-quality extra virgin olive oil in niche markets. Now U.S. 

producers believe that they have developed a cost-effective way of producing very high 

quality olive oil on a large scale, which has not been done before in the United States. 

However, they have stated that they are currently finding it difficult to break into national 

retail sales, citing distribution costs and retail pricing practices as major obstacles to 

doing so.74

Retail Market Prices 

As noted, olive oil prices in the U.S. retail market vary by grade, region of the country, 

and business strategy of the producing company. U.S. retail market data for olive oil 

show a wide range of prices for extra virgin olive oil. According to Nielsen, U.S. extra 

virgin prices for major national imported brands ranged from $0.17 per ounce to 

$0.60 per ounce, 75 while U.S. retail prices for domestic extra virgin ranged from $0.47 to 

$1.89 per ounce. 76 

 69 FTC, “Slotting Allowances,” November 2003; USITC, hearing transcript, December 5, 2012, 122–24 

(testimony of Gregg Kelly, California Olive Ranch). 70 Industry representative, interview by USITC staff, Andalusia, Spain, January 24, 2013; industry 

representatives, interview by USITC staff, Madrid, Spain, January 22, 2013. 71 USITC, hearing transcript, December 5, 2012, 122–24 (testimony of Gregg Kelly, California Olive 

Ranch). This U.S. producer sells to about one-half of the large grocery retailers in the country. Industry 

representative, telephone interview by USITC staff, June 19, 2013. 72 Industry representative, telephone interview by USITC staff, June 11, 2013; industry representative, 

telephone interview by USITC staff, June 19, 2013. 73 Ibid. 

74 USITC, hearing transcript, December 5, 2012, 122–25 (testimony of Gregg Kelly, California Olive 

Ranch). 75 The top 10 major national brands (including private label sales as a “brand”) during 2010–12 by 

market share included private label sales, Bertolli, Felippo Berio, Pompeian, Star, Colavita, Carapelli, 

Botticelli, Crisco, and Capatriti. 76 Price data in this section are from Nielsen, U.S. Retail Market Data, 2013, unless otherwise noted. 
4-17 

Global olive oil prices have been declining in recent years, a result of oversupply 

following three consecutive bumper crops in Spain. U.S. market pricing data reflect the 

general decline in global wholesale prices. Retail prices of the top 10 national brands fell 

by 7 percent on average during 2010–12. The recent decline in prices may now be 

beginning to reverse, following a severe drought in Spain in MY 2012/13 that reduced 

global supplies by about 26 percent. Prices at the U.S. retail level were slow to respond to 

the dramatic increase in wholesale prices because of previously high inventory levels, but 

U.S. retail prices have risen recently as inventory levels continue to decline.77 

As discussed above, firms’ pricing strategies are influenced by their business model, 

which dictates their cost structure and target market. Average retail prices of extra virgin 

olive oil of selected firms are presented in table 4.2. U.S. producers and importers of 

single-source olive oil tend to follow product-differentiated pricing, emphasizing the 

premium quality and flavor of their product (reflected in its higher price), while the large 

blenders/bottlers tend to follow a cost leadership strategy, competing primarily on price. 

TABLE 4.2 Average extra virgin olive oil price per ounce by brand, February 2010–February 2013 

Brand by type Average price ($ per ounce)

Domestic 

 California Olive Ranch 0.47

 Lodi Olive Oil Company 0.99

Large blenders/bottlers 

 Capatriti a

0.17

 Felipo Berio 0.26

 Bertolli 0.26

 Star 0.35

 Pompeian 0.37

Single source 

 Colavita 0.60

 Lucini 0.96

Source: Nielsen, U.S. Retail Market Data, 2013. 

a

Kangadis Food Inc., which operates under the name The Gourmet Factory and markets the brand Capatriti, 

was sued in February 2013 by the North American Olive Oil Association (NAOOA) in U.S. District Court for 

deceptively marketing products that included pomace oil and were not labeled as such. Kagadis admitted that its 

“100% Pure Olive Oil” product “contained only olive-pomace oil” prior to the suit. Reportedly, NAOOA pursued the 

case because of the price disparity between Capatriti and other competitive brands in the retail market. North 

American Olive Oil Ass'n v. Kangadis Food Inc., (S.D.N.Y. April 25, 2013); Storm, “Trade Group Lawsuit,” New 

York Times, February 6, 2013. 

Prices of domestically produced extra virgin olive oil vary dramatically, depending on 

scale and the production method used. California Olive Ranch, the largest producer in the 

United States, is a vertically integrated operation that uses mechanical harvesting. This 

firm’s relative scale and efficiency allowed it to market its olive oil at an average price of 

$0.47 per ounce during this period. In contrast, the Lodi Olive Oil Company, also of 

California, hand-harvests its olives and markets smaller volumes of oil, which sold at an 

average retail price of $0.99 per ounce. While California Olive Ranch is much more 

widely distributed in the U.S market, both firms target consumers whose purchasing 

decisions are not entirely based on price, but also consider the flavor profile.78 

 77 In response to the fall in Spanish production, between June 2012 and January 2013 producer prices in 

Italy and Greece rose by approximately 30 percent while prices in Spain increased by about 60 percent. 

Industry representative, interview by USITC staff, Washington DC, June 26, 2013; industry representative, 

interview by USITC staff, Andalusia, Spain, January 23, 2013. 78 Industry representatives, interview by USITC staff, November 13–15, 2012. 
4-18 

Average retail prices per ounce of extra virgin olive oil supplied by large 

blenders/bottlers, which accounted for over 90 percent of extra virgin olive oil sales in 

the U.S. retail market during 2010–12, were much lower than those for U.S.-produced 

extra virgin olive oil during this period. These large blenders/bottlers generally market an 

extra virgin olive oil that is cheaper to produce than premium extra virgin. Likely because 

of their low production, transportation, and distribution costs, these firms offered the 

lowest prices for extra virgin olive oil in the U.S. retail market, ranging from between 

$0.17 and $0.37 per ounce during 2010–12. 

Single-source imported extra virgin olive oils are often produced by premium and 

artisanal olive oil producers in other countries, as well as non-integrated companies that 

bottle and market oil from premium producers in a single foreign country. These 

premium products tend to have a higher cost structure and market price than many mildflavored extra virgin products sold in the U.S. market. Both Lucini and Colavita market 

100 percent Italian olive oil in the United States and source their oil from producers that 

primarily use higher-cost production methods, including hand harvesting and modern 

milling technology. Yet Colavita is much larger than Lucini, and Colavita’s greater 

economies of scale likely contribute to lower costs per unit relative to Lucini, resulting in 

a lower average retail price during this period ($0.60 per ounce versus $0.96 per ounce). 

Lucini’s target market is consumers with a knowledge of olive oil who prefer premium 

oils with fruity and bitter flavor characteristics. 79 For its part, Colavita’s U.S. market 

approach targets consumers that enjoy a fruitier olive oil and are willing to pay a slight 

premium for 100 percent Italian oil, but are also slightly more cost conscious than 

premium customers.80 Colavita’s pricing strategy places its products at the price point 

below premium brands but above the low price of the large blender/bottlers. 

Econometric Analysis of Demand 

One important issue for the development of the U.S. industry is the effect that imported 

olive oils have on the consumption of U.S.-produced oil. This issue can be explored 

through an econometric estimation of demand for olive oil products available at the retail 

level. Although many factors could affect a consumer’s decision to purchase domestically 

produced oil (including availability, the range of imported products being offered, and 

consumer perception of grades and quality), this approach measures the responsiveness of 

demand for any one category of oil to changes in its own price and the price of other oils. 

The olive oil categories for which demand relationships were estimated included 

(1) domestically produced branded extra virgin, (2) branded foreign extra virgin, 

(3) private label extra virgin, and (4) all other non-extra virgin grades of olive oil. These 

relationships were estimated using an “almost ideal demand system” (AIDS) applied to 

weekly U.S. regional retail sales data from February 2010 to February 2013.81

The results of this analysis provide some insights into consumption patterns in the U.S. 

market (table 4.3).82 All own-price elasticities show that demand is inversely related to 

 79 Industry representative, telephone interview by USITC staff, December 13, 2012. 80 Industry representatives, interview by USITC staff, April 9, 2013. 81 See appendix E for further detail. 

82 The same analysis was conducted on disaggregated regional sales data for the Pacific region, since 

the availability of domestically produced olive oil there exceeded the national average. Estimated elasticities 

from this model showed similar statistical significance and were of the same direction and order of magnitude 

as the national results. For that reason, the results have been omitted here, but they can be found in appendix 

E. 
4-19 

TABLE 4.3 Price elasticities for major olive oil categoriesa

 Change in price of 

Effect on 

Foreign 

Branded EVOO

Private Label 

EVOO 

Domestic 

Branded EVOO 

Other NonEVOO 

Foreign Branded EVOO -1.792 0.235 0.009 0.528

Private Label EVOO 0.619 -2.058 -0.025 0.598

Domestic Branded EVOO 0.495 -0.350 -1.002 0.226

Other Non-EVOO 0.656 0.289 0.003 -2.008

Source: Nielsen, U.S. Retail Market Data, 2013; USITC staff estimates. 

Notes: EVOO is used here as an abbreviation for “extra virgin olive oil.” The bolded numbers can be 

distinguished statistically from zero at conventional significance levels. Please refer to appendix E for the 

specific standard errors. Elasticities are conditional on total expenditures in non-flavored olive oil. 

Elasticities were evaluated at mean values. 

 aAverage of 9 U.S. Census geographic divisions. 

price, as expected. The demand elasticity for domestic branded extra virgin is about 1 (in 

absolute value)—i.e., for every 1 percent increase in the price of domestic extra virgin 

olive oil at the retail level, there is an identical 1 percent decrease in consumer purchases. 

In contrast, own-price elasticities for all other categories are greater than 1 (i.e., more 

elastic)—a 1 percent increase in price for any of these categories results in a 1.8 to 

2.1 percent decrease in purchases. These findings suggest that consumers of domestic 

branded extra virgin olive oil are less sensitive to changes in price than consumers of 

other extra virgin categories. They also suggest that if the price of all olive oil categories 

were to rise, possibly as a result of a reduction in global supplies or new mandatory 

testing costs for oil sold in the U.S. market, demand for domestically produced extra 

virgin olive oil would be less affected by the increase (i.e., would tend to drop less).83 

Further information about consumer perceptions of olive oil category offerings and the 

positioning of domestic extra virgin olive oil in the U.S. retail market is provided by the 

cross-price elasticities of demand (i.e., how demand for one oil is affected by price 

changes in another). The model results provide little evidence that purchases of domestic 

branded extra virgin olive oil are affected by price changes for branded foreign extra 

virgin olive oil, private label extra virgin olive oil, or all other grades of olive oil.84 The 

model results suggest that retail consumers largely consider domestic olive oil to still be a 

niche product, such that their purchases are less motivated by cross-price relationships 

than by some other intrinsic attributes of the product, such as the product’s domestic 

origin or its reputation for high quality. At the same time, all other categories are little 

affected by changes in the price of domestic branded extra virgin olive oil.85 This finding 

may be explained by the fact that domestic olive oil is not yet available in all retail 

establishments, so a change in the price of domestic olive oil may not affect product 

offerings at a consumer’s local supermarket. This finding also suggests that although the 

retail sales volume of domestic olive oils is growing, domestic olive oils are being 

 83 For example, if prices of all varieties rise by the same percentage, then the percentage decline in the 

quantity of domestic extra virgin olive oil purchased is less than the decline in other categories, and the 

difference is statistically significant at conventional levels. 84 None of the cross-price elasticities in the domestic branded extra virgin olive oil row are statistically 

significantly different from zero. 85 For example, a 1 percent rise in the price of domestic olive oil results in only a 0.009 percent increase 

in the quantity demanded of foreign branded extra virgin olive oil; further, none of the cross-price elasticities 

in this column are statistically significantly different from zero. 
4-20 

purchased by a particular type of consumer and have not yet achieved mainstream 

status.86

In contrast, consumers appear willing to switch between branded foreign extra virgin, 

private label extra virgin, and other grades of olive oil in response to a change in price of 

one of the other categories.87 Foreign extra virgin olive oil (branded and private label) 

even appears quite substitutable with non-extra virgin olive oil. 88 These patterns of 

substitutability may imply that American consumers are unaware of the differences 

between olive oil grades or that consumers are aware of the differences between grades, 

but it is not a significant factor in their purchasing decisions. 

 86 The largest domestic extra virgin brand has only a 1 percent retail market share and is still not yet 

available nationally. 87 All cross-price elasticities between these three categories are highly significant and positive. 88 For example, a 1 percent rise in the price of non-extra virgin oil results in a 0.528 percent increase in 

the quantity demanded of foreign branded extra virgin olive oil. 
4-21 

Bibliography 

American Olive Oil Association (AOOPA). Written submission to the U.S. International Trade 

Commission in connection with inv. no. 332-537, Olive Oil: Conditions of Competition between 

U.S. and Major Foreign Supplier Industries, December 12, 2012. 

Bauer, Bob. “The U.S. Import Market: An Inside View.” OLIVÆ 116, 2011. 

Cargill. “Cargill and Hojiblanca Inaugurate Olive Oil Bottling Plant in Spain.” Press release, 

September 30, 2009. http://www.cargill.com/news/releases/2009/NA3020648.jsp. 

Centers for Disease Control and Prevention (CDC). “Monounsaturated and Polyunsaturated Fats.” 

http://www.cdc.gov/nutrition/everyone/basics/fat/unsaturatedfat.html (accessed June 5, 2013). 

Covas, M.I., K. Nyyssönen, H.E. Poulsen, J. Kaikkonen, H.J. Zunft, H. Kiesewetter, A. Gaddi, R. de la 

Torre, J. Mursu, H. Bäumler, S. Nascetti, J.T. Salonen, M. Fitó, J. Virtanen, and J. Marrugat. 

“The Effect of Polyphenols in Olive Oil on Heart Disease Risk Factors: A Randomized Trial.” 

Annals of Internal Medicine 145, no. 5 (September 5, 2006): 333–41. PubMed PMID: 16954359. 

http://www.ncbi.nlm.nih.gov/pubmed/16954359. 

Datamonitor. Study on the Promotion of Consumption of Olive Oil and Olives in the USA and Canada. 

Report code CYCM0372, January 20, 2010. 

Delgado, Claudia, and Jean-Xavier Guinard. “How Do Consumer Hedonic Ratings for Extra Virgin Olive 

Oil Relate to Quality Ratings by Experts and Descriptive Analysis Ratings?” Food Quality and 

Preference 22, no. 2 (March 2011): 213–25. 

http://olivecenter.ucdavis.edu/files/consumer%20liking%20brief%20020711.pdf. 

FTC. See U.S. Federal Trade Commission. 

Gustafson, Christopher R., and Travis J. Lybbert. “What’s Extra Virgin? An Economic Assessment of 

California’s Olive Oil Labeling Law.” Giannini Foundation of Agricultural Economics, 

University of California, n.d. http://giannini.ucop.edu/media/are-update/files/articles/v12n3_2.pdf 

(accessed June 18, 2013). 

Hill, Kendall. “Inside the Murky World of Olive Oil.” Australian, March 3, 2012. 

International Olive Council (IOC). “Table 1: [World] Production.” World Olive Oil Figures, November 

2012. http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures. 

Jiménez-Guerrero, José Felipe, Juan Carlos Gázquez-Abad, Juan Antonio Mondéjar-Jiménez, and Rubén 

Huertas-García. “Consumer Preferences for Olive Oil Attributes: A Review of the Empirical 

Literature Using a Conjoint Approach.” In Olive Oil: Constituents, Quality, Health Properties, 

and Bioconversions, edited by Dr. Dimitrios Boskou, 233–46. Intech, February 2012. 

Nielsen, U.S. Retail Market Data, 2013. 

North American Olive Oil Association (NAOOA). Written submissions to the U.S. International Trade 

Commission in connection with inv. no. 332-537, Olive Oil: Conditions of Competition between 

U.S. and Major Foreign Supplier Industries, December 17, 2012, and February 12, 2013. 
4-22 

North American Olive Oil Ass'n v. Kangadis Food Inc. slip op. and order, No. 13-cv-868, 2013 WL 

1777774 (S.D.N.Y. April 25, 2013). 

Porter, Michael E. Competitive Advantage. New York: The Free Press, 1985. 

Product Arts. “The Product Category Lifecycle.” http://www.productarts.com/resourcemain/articlemenu/3700-product-category-lifecycles (accessed June 20, 2013). 

Strom, Stephanie. “Trade Group Lawsuit Challenges Olive Oil Labeling.” New York Times. February 6, 

2013. http://www.nytimes.com/2013/02/07/business/trade-group-lawsuit-challenges-olive-oillabeling.html?_r=0 (accessed July 9, 2013). 

U.S. Customs and Border Protection (USCBP). Customs Net Import File, November 2012. 

U.S. Federal Trade Commission (FTC). “Slotting Allowances in the Retail Grocery Industry.” November 

2003. http://www.ftc.gov/os/2003/11/slottingallowancerpt031114.pdf. 

U.S. Food and Drug Administration (FDA). “Summary of Qualified Health Claims Subject to 

Enforcement Discretion.” 

http://www.fda.gov/Food/IngredientsPackagingLabeling/LabelingNutrition/ucm073992.htm#oliv

e (accessed August 2, 2013). 

U.S. International Trade Commission (USITC). Hearing transcript in connection with inv. no. 332-537, 

Olive Oil: Conditions of Competition between U.S. and Major Foreign Supplier Industries,

December 5, 2012. 

———. Interactive Tariff and Trade Dataweb (Dataweb). http://dataweb.usitc.gov/ (accessed May 14, 

2013). 

Wang, Selina, Ben Moscatello, and Dan Flynn, “Survey: Consumer Attitudes on Olive Oil,” University of 

California at Davis Olive Center, May 2013. 
5-1 

CHAPTER 5 

U.S. Olive Oil Production 

Overview 

While olive oil production in California dates back to the 1700s, the recent growth of the 

industry has been driven by the adoption of the modern super-high-density (SHD), 

mechanically harvested production system in California. The new system substantially 

altered cost structures and drove investment in the sector at a time when domestic 

demand for olive oil was growing and farmers were looking to diversify into crops that 

both had low water needs and could be mechanically harvested. Despite its growing 

investment, the United States is still a small global producer of olive oil. 

From the olive-growing phase to the final consumer, two separate value chains are 

generally used by U.S. olive oil firms.1

 The first value chain is made up of small-scale 

growers using traditional production systems that either run their own small mills or 

employ contract milling services. Their niche products are typically more expensive and 

sold at farmer’s markets, high-end boutique stores, and over the Internet. The second 

value chain is composed of a small number of medium and large mills that both produce 

their own olives using SHD production systems and/or contract for olives from growers 

who use the SHD method. This production segment accounts for the bulk of olive oil 

produced in the United States—around 80 percent. This product is often marketed to 

retail establishments but can enter niche markets as well. 

U.S. growers are efficiently producing a high-quality olive oil, but certain competitive 

factors, both positive and negative, affect their ability to compete with the world’s largest 

olive oil-producing nations. These factors include product differentiation, government 

policies or support mechanisms, cost structure at the farm level, industry size, and 

competition from alternative crops. 

This chapter reviews U.S. olive oil production and the factors affecting the 

competitiveness of firms that produce oil in the United States. The chapter describes the 

two distinct value chains and business models that U.S. producers employ, including 

differences in production practices, scale, and marketing outlets. For information 

regarding olive oil consumption patterns and the factors affecting olive oil demand in the 

U.S. market, see chapter 4. 

 1

 U.S. olive oil-producing firms employ a wide range of business strategies and have their own 

individual characteristics. However, most producers and processors fall into one of the two value chains 

outlined here. 
5-2 

Production Profile 

Production Overview 

Olive oil production has grown substantially in the United States over the past decade, 

and total olive plantings have risen as well, driven by new SHD groves intended for 

production of olive oil. The total olive-bearing acreage, for both table olives and oil 

olives, reached an estimated 44,000 acres or 17,806 hectares (ha) in 2012, the highest 

level on record.2

 Although the acreage data are not subdivided by usage, industry experts 

estimate that about 30,000 acres (12,141 ha) were devoted to olive oil production in 

2012.3

 This growth in oil olive acreage also can be illustrated by the rise in the quantity 

of olives diverted to oil usage (figure 5.1). In 2012, approximately 46 percent of 

California’s olive production was projected to be crushed for oil, up from an average 

share of 4 percent in the 1990s.4

 Increased plantings of oil olives led U.S. oil production 

to grow from 400 metric tons (mt) in marketing year (MY) 2000/01 to the more than 

8,000 mt projected for MY 2012/13 (table 5.1).5

 2

 Official records for olives date back to 1920. At present, California is the only state included in the 

annual USDA NASS statistical surveys for olives. More details on acreage and production in other states is 

included in box 5.2 below. USDA, NASS, Noncitrus Fruits and Nuts 2012, January 25, 2013, 26; USDA, 

NASS, “California Olives, 1920–2010,” February 2011, 1–2. 3

 Industry representative, interview by USITC staff, California, November 14, 2012. 4

 USDA, NASS, Noncitrus Fruits and Nuts 2012, January 2013, 30. 5

 Industry representative, email to USITC staff, June 11, 2013. 

 -

 10

 20

 30

 40

 50

 60

 70

 80

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

1,000 metric tons

FIGURE 5.1 U.S. olive fruit crushed for oil, 2000-2012

Source: Staff calculation based on USDA, NASS, Fruit and Tree Nut Annual, 2000-2012.
5-3 

 

TABLE 5.1 United States: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt)

 2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 0.4 1.4 1.8 2.9 4.1 4.5 8.3

Imports 205.0 245.2 255.3 258.4 274.9 300.4 305.7

Consumption 201.7 240.4 251.6 255.8 272.1 296.2 302.2

Exports 3.7 6.2 5.5 5.5 6.9 8.8 11.7

Source: California Olive Oil Council representative, email to USITC staff, June 11, 2013; GTIS, Global Trade Atlas 

database (accessed June 19, 2013); USITC staff calculation based on industry representatives, email to USITC staff, 

June 11, 2013. 

Note: A marketing year spans October 1 to September 30 the following year. 

a

Provisional. 

b

Imports and exports projected based on annualized pace-to-date through April 2013. 

As noted, the United States remains a minor global producer, accounting for just 

0.2 percent of global olive acreage and 0.3 percent of production. 6

 Even within the 

United States, domestic production of olive oil accounts for only around 3 percent of 

domestic consumption.7

Olive-Growing Sector 

Olive trees can be grown in only the warmer parts of the United States, and an estimated 

99 percent of total U.S. olive oil production presently comes from California, mostly the 

state’s Central Valley.8

 Olives have been grown in California for centuries, but the largescale production of olive oil began only in the last decade with the adoption of SHD olive 

farming using mechanical harvesters (box 5.1). 

Olives are grown in six main production regions in California: North Coast, Central 

Coast, South Coast, Sacramento Valley, San Joaquin Valley, and Sierra Foothills 

(figure 5.2).9

 Acreage is highly concentrated in the Sacramento and San Joaquin Valleys, 

accounting for 46 and 48 percent, respectively, of the state’s total harvested olive acreage 

in 2011.10

In 2012, industry experts estimated that there were about 700 growers specifically 

dedicated to oil olives in California.11 Although the California industry encompasses a 

 6

 USITC calculation based on data from IOC, “40th Meeting,” 14–15 November, 2012, 3; USITC 

calculation based on data from industry representative, email to USITC staff, June 11, 2013 and IOC, 

“Table 1: [World] Production,” November 2012. 7

 USITC calculation based on the ratio of MY 2012/13 production (which will be marketed mostly in 

2013) to U.S. imports in 2011/12. 8

 USITC calculation based on production estimates for 2012 from the various olive-growing states. 

Industry representative, telephone interview by USITC staff, March 15, 2013; industry representatives, 

emails to USITC staff, March 27, 2013; April 4, 2013; and April 19, 2013. 9

 SAGE Center, “2010 California Olive Oil,” August 2010, 3. The Sacramento and San Joaquin Valleys 

together make up California’s Central Valley. 10 USITC calculation based on data from CDFA, “California County,” December 17, 2012, 57; SAGE 

Center, “2010 California Olive Oil,” August 2010, 3. This estimate is derived by assigning all of San Joaquin 

County’s acreage to the San Joaquin Valley region, although the county falls into both the San Joaquin 

Valley and Sacramento Valley production regions as shown in figure 5.2. 11 Industry representative, interview by USITC staff, California, November 14, 2012. USDA’s last 

Census of Agriculture (2007) identified 1,696 olive-growing operations in the United States, with both 

bearing and nonbearing acreage for oil and canning olives combined. Of these, 1,660 were located in 

California, 23 in Texas, 8 in Oregon, and 5 in Arizona. USDA, NASS, Census of Agriculture: 2007, 2009, 

549. 
5-4 

BOX 5.1 Development of the olive oil industry in California 

Olives were first brought to California by Spanish missionaries in 1769.a While most olives were initially destined for 

oil use, in the early 1900s the focus shifted to canning olives for table use due to the advent of new canning 

technologies and more attractive returns for growers.b

 Olive oil production became a secondary operation in the 

production of olives for table use—the culls from canned fruit production were pressed to produce low-quality oil.c

 In 

the 1980s, an increasing number of growers began to emerge as producers of small-quantity, high-quality olive oils 

designed for the niche gourmet food market.d

 In the late 1990s Spanish investors introduced modern SHD olive 

farming to the state. This production system is characterized by closer tree spacing and significant tree pruning and 

maintenance, such that olives can be harvested mechanically by an over-the-row mechanical harvester. The 

adoption of this production system in California makes olives a much more attractive cropping option because it 

does not rely on manual labor for harvest, can be grown on marginal land, requires less water than most other 

cropping alternatives, faces few pests, and enjoys rapidly rising domestic consumer demand. Olive plantings in 

California increased rapidly over the last decade, and most of this growth was in SHD farms.e

 Some of the first 

developers of SHD groves were not professional farmers, but were investors interested in a new industry that 

offered the potential of high returns.f Most SHD farmers today run diversified operations producing a wide array of 

other crops, including almonds, tomatoes for canning, pistachios, and wine grapes. More recently, many U.S. firms 

that bottle imported olive oil have started their own California groves or have contracted with producers in the state 

so that they can begin to bottle their own “California-grown” line and capitalize on the state’s reputation for 

producing high-quality oils.g

_____________

a

 Warnert, “New Methods,” January–March 2011, 6. 

 b Senise Barrio and Carman, “Olive Oil,” May/June 2005, 1. c Vossen and Kicenik Devarenne, “UC Cooperative Extension,” January–March 2011, 9. d Ibid. 

 e Industry representatives, interviews by USITC staff, California, November 14, 2012; Tous et al., 

“Mediterranean Clonal Selections,” January–March 2011, 35. f Industry representative, interview by USITC staff, California, November 15, 2012. 

 g Industry representative, interview by USITC staff, Maryland, December 20, 2012; industry representative, 

interview by USITC staff, Rome, Italy, February 4, 2013. 

 
5-5 

FIGURE 5.2 California olive production regions

Source: SAGE Center, “2010 California Olive Oil,” August 2010, 3–4. 

 
5-6 

range of farm sizes and structures, it can be divided broadly into two segments based on 

farm size. The first segment is made up of small or medium-density operations (typically 

less than 20 acres, or 8 ha) that rely mostly on manual labor for harvest.12 This artisanal 

segment accounts for nearly 90 percent of the state’s oil olive farms but only 20 percent 

of total production. The second segment consists of large, SHD farms that account for 80 

percent of production. 

Outside California, certain Southern states, including Arizona, Florida, Georgia, and 

Texas, are currently producing olives for olive oil. Although industry leaders express 

enthusiasm about the growth potential for olive oil production in their respective states, at 

present it is mostly produced as a high-value niche product (see box 5.2). 13 Because U.S. 

production is centered in California, this chapter focuses on production in that state. 

Small-Scale Medium-density and Artisanal Segments 

There are about 620 small-scale oil olive growers in California practicing low- to 

medium-density production on about 8,000 acres (3,237 ha).14 Most of these operations 

grow 0.5 to 5 acres of olives (or 0.2 ha to 2 ha), although a few harvest as many as 

40 acres (16 ha).15 Most small-scale groves are planted using more traditional production 

methods at an average density of 100 to 150 trees per acre (247 to 371 trees per ha), 

although planting densities in some more intensive groves can reach as many as 270 trees 

per acre (667 trees per ha).16 Because these types of farms rely mostly upon manual labor, 

groves can be planted on steeper grades. 

Olives grown in this system cannot be harvested until at least the fourth year after 

planting, and plants typically reach their maximum yield potential after 6 to 10 years, 

depending on tree variety and management practices.17 Owing mostly to lower planting 

densities, yields for these operations range between 2.5 and 3.0 short tons of fruit per acre 

(5.6-6.7 mt/ha), much lower than yields under SHD systems.18 Also, alternate bearing 

production cycles can substantially affect annual production levels for growers of this 

size because the trees are not as intensively managed as in SHD systems.19 

One advantage of lower-density production systems is that several varieties can be 

grown, compared with only three varieties (Arbequina, Arbosana, and Koroneiki) 

available to SHD growers. More than 150 varieties of olives are grown by small 

producers in California, including Arbequina, Arbosana, Ascolano, Coratina, Frantoio, 

Koroneiki, Leccino, Manzanillo, Maurino, Mission, Pendolino, Sevillano, and 

Taggiasca.20 This wide array of varieties allows small growers to produce more specialty, 

niche oils than SHD growers. 

 12 Vossen and Kicenik Devarenne, “UC Cooperative Extension,” January–March 2011, 8. 13 Industry representatives, emails to USITC staff, May 7, 2013; May 8, 2013; and May 9, 2013. 14 Industry representative, interview by USITC staff, California, November 14, 2012. 15 Ibid. 

16 SAGE Center, “2010 California Olive Oil,” August 2010, 4; UCCE, Sample Costs to Establish a 

Medium-Density, 2011, 3. 17 UCCE, “Sample Costs,” 2001, 6; UCCE, Sample Costs to Establish a Medium-Density, 2011, 6. 18 Ibid. 

19 Alternate bearing is a phenomenon that affects olive trees and other fruit and nut crops, whereby fruit 

production alternates between large crops during an “on” year and smaller crops during an “off” year. These 

production swings can be somewhat mitigated through more intensive management techniques. See Fichtner, 

Wilson, and Lovatt, “Understanding Alternate Bearing in Olive,” May/June 2012, 6. 20 SAGE Center, “2010 California Olive Oil,” August 2010, 5. 
5-7 

BOX 5.2 The U.S. olive oil industry outside of California

Although California presently accounts for most U.S. olive oil production, there is increasing interest in olive oil 

production outside of the state. New investment in both olive groves and processing facilities in Florida, Georgia, and 

Texas, among others, suggests that these states may increase their share of U.S. olive oil production in the future. 

The largest olive oil-producing state outside of California is Texas. In 2012, the state produced nearly 14,400 gallons 

of olive oil from 50 growers on 920 acres.a

 As in California, most groves at present (around 80 percent) are small and 

use traditional production methods. However, area planted to olives in Texas is projected to grow to 5,000 acres by 

2014, with nearly all this growth in SHD groves.b Industry experts in the state feel that Texas has great potential for 

the growth of this industry due to its suitable land in various microclimates, ample agricultural water supply, and 

favorable regulatory environment.c On the processing and marketing side, the state currently has four small mills—

the largest of which has a 1.5 ton per hour capacity—and a new larger mill is planned for 2014. The majority of the 

state’s production is sold at farmers’ markets and specialty stores, but industry experts estimate that 10–15 percent of 

Texas olive oil is currently being marketed at the retail level—specifically at Whole Foods, which is headquartered in 

Texas, and the regional supermarket chain HEB.d

 The Texas Olive Oil Council is active in promoting the industry and 

will be underwriting research on best management practices funded by the U.S. Department of Agriculture’s Specialty 

Crop Block Grant Program beginning late in 2013. 

In contrast to Texas, growers in the state of Georgia are putting in olive groves entirely under the SHD system, and 

the 2012/13 harvest was the first year that the oldest groves reached full production. The 2012 harvest yielded about 

600 gallons of oil from 11 farms on 180 acres (not all of the trees on these farms have reached bearing age).e

Industry leaders report widespread interest in the new crop and project that olive area will climb to 500 acres.f

Georgia’s groves are located in the extreme southern part of the state, and growers report that this is a production 

advantage since their harvest occurs prior to any threat of early frost, which means that the fruit has a better chance 

of reaching optimal ripeness before being damaged by freeze. Additionally, Georgia’s East Coast location makes the 

state ideally positioned to access the largest U.S. olive oil consumer markets.g The state currently has one 300 

pound-per-hour capacity mill, but an additional mill will be installed in time for the 2013 harvest. About 90 percent of 

Georgia olive oil is currently marketed in specialty stores, restaurants, and farmers’ markets, with the remainder sold 

in retail grocery chains. The University of Georgia Extension Service, Georgia Department of Agriculture, and 

Georgia Agribusiness Innovation Center have been supportive of the new industry, and the state is also the site of the 

USDA laboratory at Blakely. 

Olive production is also set to rise in Florida, where industry experts feel that olives could be a promising replacement 

for citrus groves ravaged by citrus greening disease.h

 Industry experts report that there are currently three SHD 

groves in the state and several smaller traditional groves, with 2012 production estimated at around 300 gallons of 

oil.i At the current rate of planting, the Florida Olive Council estimates that an additional 500–1,000 acres will be 

under cultivation by 2015.j

 Florida growers currently haul their olives to the Georgia mill for processing, but a small 

mill is planned to be installed in North Florida in 2014. As in Georgia, most Florida production is currently marketed in 

specialty outlets. With an eye to the future of this industry in the state, the University of Florida Institute of Food and 

Agricultural Sciences has several olive research plots underway, and industry leaders report cooperation with out-ofstate research institutions as well. 

Besides these states, production of olives for oil has been documented in Arizona and Oregon. In addition, industry 

experts have noted that parts of South Carolina, Alabama, Mississippi, and Louisiana also have adequate olivegrowing conditions in certain areas, dubbing these states (along with Florida, Georgia, and Texas) “the Southern 

Olive Belt” due to their potential.k 

_____________

a

 Industry representative, email to USITC staff, March 27, 2013. b

 Ibid. 

c

 Industry representative, email to USITC staff, March 27, 2013; USITC, hearing transcript, December 5, 2012, 

274 (testimony of Abigail Rutledge, Next Door Pantry LLC). d

 Industry representative, email to USITC staff, May 7, 2013. e

 Industry representative, email to USITC staff, April 4, 2013. f

 USITC, hearing transcript, December 5, 2012, 245 (testimony of Sydne Smith, Georgia Department of 

Agriculture). 

g

 Industry representative, email to USITC staff, April 4, 2013. h

 USITC, hearing transcript, December 5, 2012, 262 (testimony of Michael O’Hara Garcia, Florida Olive 

Council). i

 Industry representative, email to USITC staff, April 19, 2013. j

 Ibid. 

k

 USITC, hearing transcript, December 5, 2012, 272 (testimony of Jason Shaw, Georgia Olive Farms). 
5-8 

Super-high-density Segment 

The SHD olive production segment expanded rapidly over the past decade, as Californian 

farmers recognized a market opportunity in a new crop production method that has many 

appealing attributes (see box 5.1). Introduced to California in 1999, operations of this 

type have been the source of most recent growth in U.S. olive oil production.21 Today, 

nearly three-quarters of oil olive acreage in California is estimated to be under SHD.22 

Only 4 years after planting, olive production per acre under SHD typically ranges 

between 4 and 5 short tons per acre (9.0-11.2 mt/ha)—an amount that can be processed 

into between 40 and 45 gallons of olive oil per short ton based on olive varietal, harvest 

maturity, and other factors. This output is equivalent to a 15 to 17 percent oil yield.23 One 

of the advantages of SHD systems is that annual olive yield variations (because of the 

alternate bearing nature of the tree) can be reduced by aggressive mechanical pruning that 

takes fruit off the trees to prevent them from becoming overstressed.24 This helps mills 

more accurately forecast their production levels and storage needs. SHD producers 

estimate that their yields may fluctuate 15 percent from one year to the next, while for 

traditional groves in parts of the Mediterranean the fluctuation can be as high as 60 

percent.25

One of the disadvantages of SHD production is that only a limited number of cultivars 

have been adapted for mechanical harvesting, preventing operations from producing a 

wide variety of niche products. However, development of additional varieties suited to 

the system is underway.26 

Growth Projections for U.S. Oil Olive Production 

Despite the sharp rise in SHD olive acreage over the past decade, the long-term 

production trend is unclear, since oil olive plantings compete for acreage with other 

crops. The vast majority of California farmers growing olives for oil production operate 

diversified farms, so if olive returns become less attractive than returns for competing 

crops, farmers may stop planting additional olive acreage or remove their olive groves 

altogether. California farmers adjust their crop mixes frequently according to market 

conditions.27 For this reason, future growth in the domestic olive oil sector depends on 

how the price of olive oil compares with prices of other commodities that could be grown 

on the same land. 

The sharp drop in global olive oil prices after two large Spanish crops were harvested in 

2010 and 2011 resulted in a dramatic decline in new plantings of olives for oil.28 Farm 

prices for many growers in 2011 were between $12 and $13 per gallon ($3.17–$3.43 per 

liter), whereas growers estimate that farm prices for olive oil would need to rise to at least 

$14 per gallon (approximately $3.70 per liter) to drive further expansion of olive groves 

 21 UC Davis Olive Center, “Survey: Super-High-Density,” November 2009, 2–3. 22 Industry representative, interview by USITC staff, California, November 14, 2012. 23 UCCE, Sample Costs: Sacramento Valley, 2007, 6–7; UCCE, Sample Costs: San Joaquin Valley, 

2007, 7; industry representatives, interviews by USITC staff, California, November 13–15, 2012. 24 Intensive nutrient regulation also contributes to higher olive yields, but to a much lesser extent than 

pruning. Industry representative, interview by USITC staff, California, November 15, 2012. 25 Industry representative, interview by USITC staff, California, November 15, 2012. 26 Ibid. 

27 Industry representatives, interviews by USITC staff, California, November 12–15, 2012. 28 Industry representative, interview by USITC staff, California, November 15, 2012. 
5-9 

in California.29 More land suitable for olive growing in California could be brought into 

production if prices improve. In 2010, industry experts forecast that over the next decade 

plantings could increase by 4,500 acres (1,821 ha) annually, leading to production growth 

of 15 million gallons (nearly 57 million liters).30 Because olives require much less water 

than other crops grown in the Central Valley (such as almonds, walnuts, and tree fruit), 

higher prices for olives could, by one estimate, increase oil olive plantings by an 

additional 200,000 acres (80,937 ha).31 

Outside of California, plantings in Texas are projected to rise to 5,000 acres by 2014, 

plantings in Florida are projected to increase to 500 to 1,000 acres by 2015, and plantings 

in Georgia are projected to rise to 500 acres in the next five years, resulting in nearly 

5,000 total projected new acres outside of California, nearly all in SHD.32

Olive Oil-Processing Sector 

California’s roughly 40 olive oil mills are concentrated in the main growing regions of 

the Sacramento and San Joaquin Valleys. 33 The proximity of mills to growers is 

important in maintaining the quality of the oil produced. Nearly all olives are milled 

within 24 hours of harvest, helping to minimize olive degradation and average free fatty 

acid levels.34 Additionally, olives are typically harvested and delivered to the mill at a 

ripeness level that delivers more of the compounds that provide desirable oil attributes 

(such as fruitiness and bitterness), even though the olives have a lower oil content.35 For 

this reason, Californian mills must process more olives to produce the same amount of oil 

as their Mediterranean counterparts, who harvest later in order to maximize oil output. 

Like the olive groves, California’s olive oil mills vary greatly in terms of size and 

capacity, with processing rates ranging from 250 pounds per hour up to 80 short tons 

(160,000 pounds) per hour exclusively for first extraction.36 The overall olive milling 

process is similar regardless of the scale of the mill (for more information on olive 

processing, see chapter 1). However, small and large mills differ in their sourcing 

strategies and quality control initiatives. For this reason the two are addressed separately. 

Milling 

Small and medium-scale mills 

Almost all California olive mills are small and medium-sized operations, most using twostage processing systems, with processing capacities up to around 10 short tons per 

 29 Industry representatives, interviews by USITC staff, California, November 15, 2012. 30 SAGE Center, “2010 California Olive Oil Industry,” August 2010, 8. 31 Industry representative, interview by USITC staff, California, November 14, 2012. 32 Industry representatives, emails to USITC staff, March 27, 2013, and April 19, 2013; USITC, 

hearing transcript, December 5, 2012, 245 (testimony of Sydne Smith, Georgia Department of Agriculture). 33 SAGE Center, “2010 California Olive Oil Industry,” August 2010, 5. 34 As soon as olives are harvested, they begin to degrade. Olive oils milled from oxidized or fermented 

olives can have flavor defects like fustiness and rancidity. See USITC, hearing transcript, December 5, 2012, 

28 (testimony of Bruce Golino, Santa Cruz Olive Tree Nursery); Frankel et al., “Evaluation of Extra Virgin,” 

April 2011, 5. 35 Industry representative, interview by USITC staff, California, November 13, 2012. 36 Many mills in other countries include processing of pomace oils in their capacity estimates, while 

these numbers reflect the fact that California mills only process whole fruit in a single oil extraction. Industry 

representatives, emails to USITC staff, April 23, 2013, and May 15, 2013. 
5-10 

hour.37 Milling costs range between $300 and $500 per short ton for these mills.38 Small 

mills acquire their olives through several sourcing strategies, including exclusively 

processing their own olives, contracting with other area growers for part or all of their 

supply, and custom-milling olives for small growers and then returning the oil to the 

grower to market independently.39

Small and medium-sized mills use a range of approaches to quality control. For example, 

many small mills are not HACCP (Hazard Analysis and Critical Control Points) certified, 

although most are interested in acquiring the certification in the near future.40 Some mills 

have on-site labs, testing every lot of oil run through their operations for traits such as 

free fatty acid levels and peroxide values.41 In addition to a mill’s own internal quality 

control practices, reportedly about half of small mills send oil samples to the California 

Olive Oil Council (COOC) for quality testing.42 Further, many operators of small mills 

state that because they produce in small batches and personally monitor their oils from 

the field to the bottle, they have a deep understanding of their oil quality. The success of 

several small brands at international olive oil competitions suggests that this may be the 

case for some. However, the large number of growers and the range of producer expertise 

(among several factors) mean that a wide array of qualities is produced in this segment. 

Large-scale mills 

While there are relatively few large-scale mills in California, they process most of the 

state’s olive oil production, with milling capacities in excess of 25 short tons per hour.43

California’s large mills acquire olives from their own groves as well as from independent 

growers under contract arrangements. Contract periods vary, but a 6- or 12-year contract 

is typical. 44 Production contracts often contain quality specifications for the olives 

delivered to the mill, and growers are almost always paid on a price per gallon basis.45

Quality and traceability throughout the production chain is a priority for large mills. Staff 

from the mills make field visits to contract growers, offering recommendations on 

irrigation, fertilizer, and crop protection and suggesting harvest dates.46 Also, the oil and 

moisture content of the olives are measured every 1–2 weeks so that crop progress is 

tracked and harvest dates for each grove are estimated in advance. Although, as noted 

above, olives grown under contract must meet certain quality standards, these are almost 

always met because of constant mill involvement throughout the entire growing phase. 

Once olives arrive at the mill, samples are drawn and tested to decide which storage tank 

the milled oil should be diverted to. Additionally, the miller tests the oil from each load 

as it is processed to ensure that the oil is directed to the proper tank based on its varietal 

 37 Industry representative, email to USITC staff, April 23, 2012. 38 Industry representative, interview by USITC staff, California, November 13, 2012. 39 Industry representative, telephone interview by USITC staff, March 15, 2013. 40 Industry representative, telephone interview by USITC staff, March 15, 2013. The FDA defines 

HACCP as “a management system in which food safety is addressed through the analysis and control of 

biological, chemical, and physical hazards from raw material production, procurement and handling, to 

manufacturing, distribution, and consumption of the finished product.” FDA, “HACCP Principles and 

Application Guidelines,” August 14, 1997. 41 Industry representative, interview by USITC staff, California, November 13, 2012. 42 Industry representative, telephone interview by USITC staff, March 15, 2013. 43 As in footnote 37, the rate reported here is for first extraction. Industry representatives, interview by 

USITC staff, California, November 14, 2012; emails to USITC staff, April 23, 2013 and May 15, 2013. 44 Industry representative, interview by USITC staff, California, November 15, 2012. 45 Ibid. 

46 Ibid. 
5-11 

and taste profile.47 Retained samples are then regularly drawn from the storage tanks to 

constantly monitor various chemical parameters of the oil. All of the largest mills have 

in-house labs where they test samples to ensure the oil falls within their own accepted 

quality parameters.48 Typically the largest mills are HACCP certified.49

Each load is tracked from the field to the final storage tank, and bottling lot numbers can 

be traced back to the tank. Capacity in storage tanks ranges between 35,000 and 

175,000 gallons, while one load of fruit can yield 900–1,300 gallons.50 For this reason, if 

a problem were to be identified in a tank of oil, the traceback system would make it easier 

to pinpoint where in the production process the problem occurred and to prevent it from 

happening again. Finally, oil is sampled and tested again at the bottling phase. 

Almost all the oil produced at large-scale mills meets the extra virgin grade because the 

olives are harvested at the point when their chemical makeup is optimal and within hours 

are sent to the mills for processing. Most large mills aim to process all olives within 

12 hours of harvest, and nearly all loads are milled within 24 hours of coming off the 

tree.51

Bottling and Marketing 

Bottling and marketing of olive oil is a large domestic industry involving several U.S. 

firms. However, the majority of these firms bottle and market imported oil, which is not 

marketed as a U.S. product as covered in this chapter (for more information on this 

segment of the industry, see chapter 4). This section focuses on the bottling and 

marketing of only U.S.-produced oil. 

Bottling 

As in growing and milling, bottling and marketing of domestically grown oil takes place 

in two mostly separate value chains. Many small growers use custom milling services but 

carry out their own bottling and marketing.52 Small growers who do their own bottling 

report that their bottling costs per unit are higher than those of larger mills because they 

are more likely to use unique (and more expensive) containers in order to differentiate 

their product.53 

Outside of custom operations, U.S. olive mills do their own bottling (regardless of mill 

size). However, these bottling operations vary in capacity and degree of automation. 

Small and medium-sized mills may bottle their product entirely by hand, while the largest 

mills have fully automated bottling lines. 

Marketing 

Olive oil produced from U.S.-grown olives is sold primarily into three market segments: 

boutique sales, supermarket retail, and food service. Because of the high per unit 

production costs of small mills, their sales are mostly made through specialized or high-

 47 Industry representative, interview by USITC staff, California, November 14, 2012. 48 Industry representatives, interviews by USITC staff, California, November 14, 2012. 49 Industry representative, interview by USITC staff, California, November 14, 2012. 50 Ibid. 

51 Industry representatives, interviews by USITC staff, California, November 12–13, 2012. 52 Industry representative, email to USITC staff, April 23, 2013. 53 Industry representative, interview by USITC staff, California, November 14, 2012. 
5-12 

end marketing outlets, such as farmers’ markets, roadside stands, specialty retail outlets 

that focus on gourmet food products, tasting room sales, and direct Internet sales. Firms 

expend a lot of effort in finding the right market outlet to target their sales efforts.54 Few 

small mills sell beyond the West Coast because transportation costs are high compared to 

the small volumes shipped. 55 Even considering the higher prices boutique oils command, 

some growers stated that they need additional income sources to keep their firms 

profitable. An estimated 20 percent of boutique olive oil operations pair their oil 

production with either a tasting room or an agritourism venture.56

The decision whether to pursue boutique or supermarket retail sales largely depends on 

the amount of oil a mill produces. Boutique sales outlets and niche high-end markets 

purchase only small volumes from mills, and the number of such outlets is limited. Once 

mills produce enough volume to exhaust these niche marketing chains, they typically use 

retail supermarket outlets to sell their oil.57 However, moving to mass retail requires a 

large production volume in order to provide the quantities demanded by national grocery 

chains.58 It also requires a firm to pay for a national marketing presence, which includes 

not only the development of distribution networks, but also the shelf placement fees 

(slotting fees) and promotion packages commonly required by large retailers.59 Today, 

while the majority of olive oil produced in the United States is sold at the supermarket 

retail level, only a few firms have achieved the size needed to jump from niche to 

national distribution.60 

Another marketing option for a few of the larger U.S. olive oil firms is the restaurant food 

service market. This market is highly price driven, and only the largest companies have 

the economies of scale to supply the product at a competitive cost.61 Even so, Californian 

firms marketing to the restaurant food service market sell almost exclusively to “white 

tablecloth” restaurants, and this market segment is willing to purchase olive oil at the 

upper end of the price distribution (for more information on this marketing segment, see 

chapter 4). 

While the focus of California-grown olive oil is on the domestic market, there is interest 

in exporting oil to higher-value Northeast Asian markets, such as Japan. Some California 

growers also sell to Canada, where there is a well-established market for olive oil and a 

legally enforced standard for extra virgin olive oil.62

 54 Industry representative, interview by USITC staff, California, November 13, 2012. 55 Ibid. 

56 Ibid. 

57 Because olives begin degrading as soon as they are picked, and olive oil is a fresh product, it cannot 

be stored like wine and then sold in a subsequent season. This complicates the marketing process, as timing 

becomes an issue. See USITC, hearing transcript, December 5, 2012, 63 (testimony of Kyle Sawatzky, Bari 

Olive Oil Company). 58 USITC, hearing transcript, December 5, 2012, 65–66 (testimony of Gregg Kelley, California Olive 

Ranch). 59 Industry representatives, interview by USITC staff, California, November 14, 2012. 60 USITC, hearing transcript, December 5, 2012, 122–23 (testimony of Gregg Kelley, California Olive 

Ranch). 61 Industry representative, interview by USITC staff, California, November 14, 2012. 62 Industry representative, interview by USITC staff, California, November 15, 2012. 
5-13 

Factors Affecting Competitiveness 

As outlined above, the California industry is composed of two largely discrete groups of 

producers with different cost structures and mostly separate value chains. Large 

producers (whose products most frequently appear on retail shelves) compete directly 

with imports, while the second group, consisting largely of small producers, sells mostly 

in boutique sales channels and suffers less from the price-dampening effect of cheaper 

imported oils.63 Several factors influence the competitive landscape of the global olive oil 

market from the perspective of U.S. growers. Prominent among these are: (1) the extent 

to which U.S. producers are able to differentiate their products; (2) the lack of 

government involvement in the olive oil sector, with no mandatory U.S. government 

regulation of olive oil grades and standards and little government financial support to the 

sector; (3) comparative farm gate cost structures; (4) industry scale; and (5) the viability 

of alternative crops in the areas currently devoted to olive production. 

Product Differentiation 

U.S. olive oil production has grown substantially over the past decade, largely due to the 

industry’s success at differentiating their product from less expensive oils with a certain 

segment of consumers, and thus creating higher demand. This product differentiation has 

taken place on various levels. First, the U.S. industry has been able to distinguish its 

product simply on the basis of quality—most firms are producing high-quality extra 

virgin oils. The industry has also had success with some consumers because of its 

product’s specialty-item appeal as both a gourmet item and a “local” food. Nevertheless, 

the industry has struggled to disseminate its message about the unique attributes of its 

product to the broader U.S. consumer base, which tends to be more price sensitive than 

quality conscious. 

Quality of the Product 

As described above, intensive management of SHD groves and quality control practices 

throughout the production process mean that most Californian olive oil meets the extra 

virgin grade. For example, quality control contributes to lower average fatty acid levels 

for Californian oils—virtually all producers report producing oils with less than 

0.225 percent free fatty acid (FFA) levels, well below the USDA standard of 0.8 percent 

for the extra virgin grade.64 Rigorous quality control regimes are put in place by U.S. 

producers to target the high quality segment of the extra virgin olive oil market,65 and 

U.S. oils are now winning recognition for quality from a wide range of sources. For 

example, of the 23 products sampled by Consumer Reports in 2012, the top two oils (and 

the only ones to receive “Excellent” ratings) were products of California.66 

 63 Econometric evidence presented in chapter 4 suggests that at present in the aggregate U.S. market, 

this effect is small. 64 Industry representative, interview by USITC staff, California, November 13, 2012. 65 Industry representatives, interviews by USITC staff, California, November 13–15, 2012. 66 Additionally, half of the oils that received “Very Good” ratings were of Californian origin. See 

Consumer Reports, “How to Find the Best Extra-Virgin Olive Oil,” September 2012. 
5-14 

Value as a Specialty Item 

Even before the rise of SHD production, small boutique Californian olive oil producers 

were successful at marketing to a consumer segment seeking gourmet, high-value food 

products. While this remains an important market for the majority of California’s 

producers, both growers and retailers report that the high-value niche segment is 

crowded, which decreases profitability as producers compete among themselves and with 

high-value imports for shelf space and consumer dollars.67

Some U.S. consumers are responding increasingly to products that are marketed as a 

“local food,” even without knowing anything about a product’s comparative quality 

attributes. Producers in California, Texas, Georgia, and Florida all report consumer 

satisfaction over buying olive oil sourced from their local area.68 In response to the rising 

reputation of Californian oils, many large imported oil bottlers are investing in the state 

to capture some of the value in the “California brand” in their own product lines.69 For 

typical consumers, however, the “California is local” campaign may not be effective 

because many still have the mindset that olive oil should be Italian.70

Consumer Awareness 

U.S. consumers represent both an opportunity and a challenge for domestic olive oil 

producers. While U.S. producers have ready access to the domestic olive oil market, one 

of the world’s largest,71 most consumers are not knowledgeable about the product and, as 

noted earlier, tend to base their purchasing decisions on price.72 This creates a particular 

challenge for Californian producers, with their higher-cost, high-quality offerings.73 U.S. 

producers and bottlers of imported oil have tried to educate consumers through a variety 

of initiatives, including holding open-house tastings at mills, offering product tastings at 

retail stores, publicizing chef endorsements in gourmet magazines, and even issuing 

nationally circulated product coupons. 74 But large-scale consumer education and 

marketing campaigns are expensive and therefore not affordable for most U.S. firms 

operating on small margins.75 However, many Californian producers report that whatever 

the outreach mechanism, once consumers are introduced to their olive oil products, they 

are highly likely to become repeat customers.76

Government Policies and Support Mechanisms 

In contrast to many Mediterranean countries where the government takes an active role in 

regulating the olive oil industry, the U.S. government has a comparatively hands-off 

 67 Industry representative, interview by USITC staff, California, November 15, 2012. 68 USITC, hearing transcript, December 5, 2012, 247 (testimony of Sydne Smith, Georgia Department 

of Agriculture), 252 (testimony of Abby Rutledge, Next Door Pantry), 269 (testimony of Jason Shaw, 

Georgia Olive Farms). 69 Industry representative, interview by USITC staff, Maryland, December 20, 2012; industry 

representative, interview by USITC staff, Rome, Italy, February 4, 2013. 70 Industry representative, interview by USITC staff, California, November 14, 2012. 71 IOC, “Table 4: [World] Consumption,” November 2012. 72 Industry representatives, interviews by USITC staff, California, November 15, 2012. 73 Industry representatives, interviews by USITC staff, California, November 13, 2012. 74 Industry representatives, interviews by USITC staff, California, November 13 and 15, 2012; USITC, 

hearing transcript, December 5, 2012, 252–53 (testimony of Abigail Rutledge, Next Door Pantry), 258 

(testimony of Jim Henry, Texas Olive Ranch). 75 Industry representative, interview by USITC staff, California, November 14, 2012. 76 Industry representatives, interviews by USITC staff, California, November 13–15, 2012. 
5-15 

approach in the domestic sector. The U.S. government has no mandatory olive oil testing 

regime, and although legal grading standards have recently been updated, there is no 

official enforcement mechanism. The U.S. industry contends that the lack of enforced 

grading standards allows oils that do not meet extra virgin standards to be marketed as 

such without any negative ramifications, thereby misleading U.S. consumers. 77 U.S. 

producers have begun to explore all avenues that can be used to provide any enforcement 

of standards or to make them more stringent, including the possible future institution of a 

U.S. Department of Agriculture (USDA) federal marketing order. Lastly, as is the case 

for most specialty crops, the U.S. government provides no direct monetary support to the 

sector. This puts U.S. growers at a delivered cost disadvantage compared to producers 

abroad who receive government support through direct payments. The industry does, 

however, benefit indirectly from a variety of publicly funded research and extension 

efforts. All of these issues are discussed in more detail below. 

Grading and Marketing Standards 

Because there is no regulatory enforcement of grading standards in the U.S. market, there 

is a financial incentive for some firms to misrepresent lower-priced, lower-grade olive 

oils as extra virgin.78 Official USDA olive oil standards exist but are merely definitions of 

grades; currently, there is no mechanism to enforce these grades, no government agency 

that collects and tests random samples of oils, and no penalty for noncompliance with the 

standards.79 As a result, studies have found that oils purchased by U.S. consumers that are 

labeled as extra virgin often do not meet extra virgin criteria as established by the USDA 

and IOC.80 

Observers contend that widespread misrepresentation of lower-grade oils as extra virgin 

depresses retail prices for all true extra virgin oils.81 Because most domestic growers 

produce extra virgin grade oil, such misrepresentation puts U.S. olive oils (as well as 

high-quality imported varieties) at a disadvantage. Lower retail prices translate into lower 

grower income, which, in the long run, could result in less U.S. production. 

Prospective Federal Marketing Order 

U.S. producers of high-quality olive oils maintain that the misrepresentation described in 

the previous section hinders their ability to compete in the U.S. market. For this reason, 

these producers, represented by the American Olive Oil Producers Association 

(AOOPA), are seeking mandatory standards that would be enforced by a government 

 77 Industry representatives, interviews by USITC staff, California, November 13–15, 2012; USITC 

hearing transcript, December 5, 2012, 41 (testimony of Adam Englehardt, California Olive Ranch). USITC 

hearing transcript, December 5, 2012, 41 (testimony of Alex Ott, American Olive Oil Producers Association). 78 This misrepresentation is common in products where consumers are unable to distinguish the quality 

of the product by looks alone. There is ample economic literature detailing this phenomenon, which is based 

on George Akerlof’s work on the market for “lemons” in the automobile market. This principle is applied to 

the olive oil market in Gustafson and Lybbert, “What’s Extra Virgin?” January/February 2009. 79 Several private companies and nonprofit organizations conduct olive oil quality testing, however, as 

noted in chapter 3. U.S. government officials, meetings with USITC staff, Washington, DC, October 24, 

2012, and March 4, 2013. 80 For example, as noted in chapter 3, a 2011 UC Davis study found that 73 percent of samples failed 

IOC sensory standards, while 28 percent of samples failed at least one IOC chemical test as well. A higher 

percentage of samples failed tests that are included in the German and Australian olive oil standards. UC 

Davis has since conducted additional studies that came to similar conclusions, and an evaluation conducted 

by Consumer Reports also found that many national brands had some organoleptic flaws. See Frankel et al, 

“Evaluation of Extra-Virgin,” April 2011, 2, 6; “How to Find the Best,” Consumer Reports, September 2012. 81 Gustafson and Lybbert, “What’s Extra Virgin?” January/February 2009. 
5-16 

agency. One option under consideration by U.S. producers is the institution of a USDA 

federal marketing order that would include mandatory quality standards for all U.S.-

produced oil and possibly imports (for more information on a potential USDA marketing 

order, see chapter 3). 

To date, the U.S. industry has not submitted a marketing order proposal to the USDA.82

However, industry representatives expect that mandatory quality enforcement would 

bring some quality transparency to the market and ensure that U.S. production is 

competing with true extra virgin olive oil. While Californian producers have difficulty 

competing with Mediterranean imports on the basis of cost alone, they believe that 

competing on the basis of both cost and quality will improve their position in the 

domestic market.83

Government Support Programs 

According to U.S. producers, the lack of direct payment support puts them at a significant 

disadvantage vis-à-vis their EU counterparts that receive significant government support 

(for more information on EU support programs, see chapter 6). While the U.S. industry 

receives no direct support payments, several other government programs (although small 

in scale) directly and indirectly provide assistance to the sector. 

Crop insurance 

The USDA’s Risk Management Agency offers subsidized crop insurance coverage 

through the Federal Crop Insurance Corporation (FCIC) for olives produced in 13 

California counties for both table olive and olive oil end uses.84 In 2012, approximately 

22,500 acres (9,105 ha) of California olives were covered by the FCIC, but the end use of 

the olives covered by the program is not known.85 Producers growing olives for oil 

reported that the program is more appropriate for table olives and is not a cost-effective 

risk management tool for oil olive operations.86 

Research grants, education, and extension service 

The U.S. olive oil industry has received some competitive grants awarded under the 

USDA’s Specialty Crop Block Grant Program (SCBGP).87 In fiscal year (FY) 2012, six 

grants totaling $1.2 million were directed toward the olive and olive oil sectors in 

 82 U.S. government official, telephone interview by USITC staff, Washington, DC, June 7, 2013. 83 Industry representatives, interviews by USITC staff, California, November 13–15, 2012. 84 Under this program, the government covers about 65 percent of the total policy premium. 

Government official, email to USITC staff, November 15, 2012. See also USDA, RMA, “Olive Pilot Crop 

Insurance,” December 6, 2012; USDA, FCIC, “Olive Crop Provisions,” n.d. (accessed November 1, 2012). 85 USDA-FCIC, “Summary of Business,” n.d. (accessed May 7, 2013). 86 The current olive insurance program contains large annual yield adjustment factors due to alternate 

bearing, which is mostly mitigated by the SHD production system under which most oil olives are grown. 

Industry representative, interview by USITC staff, California, November 15, 2012. 87 These competitive block grants, awarded directly to state departments of agriculture (often in 

conjunction with another entity) are designed solely to enhance the competitiveness of specialty crops. They 

can be targeted toward a multitude of project types, including food safety, marketing and promotion, 

education, research, and pest and plant health. For more information, see USDA, AMS, “Specialty Crop 

Block Grant Program,” October 2012. 
5-17 

California, and Texas received two olive-related grants totaling $174,000.88 These grants 

were targeted toward specific objectives, and it is not yet clear what total economic 

benefit they provided to the domestic industry. Funding for the SCBGP was provided for 

through FY 2012 under the 2008 Farm Bill, and without a new farm bill, the future of this 

program is uncertain. 

Various California universities provide research and extension services to the olive oil 

industry in California.89 The most prominent provider is the Olive Center, located within 

the Robert Mondavi Institute for Wine and Food Science at UC Davis.90 Established in 

2008, the Olive Center has published several widely disseminated studies analyzing the 

quality of olive oil sold at retail establishments in California; provided technical 

assistance when the COOC was developing mandatory California olive oil grade 

standards and labeling requirements; established a sensory laboratory; and provided 

educational workshops and events for the industry.91

Cost Structure at the Farm Level 

Operating costs for U.S. producers and for producers in Spain (the world’s largest 

producer) appear to overlap.92 However, U.S. producers tend to have higher fixed costs 

reflecting the recent origin of the U.S. industry and the fact that the majority of growers 

are still paying debt service on their fixed-cost investments. Most competitor producers in 

Mediterranean countries have no comparable costs because they are producing olive oil 

from long-established groves. Hence on a variable-cost basis at the farm level, U.S. olive 

oil producers are cost competitive with producers in other countries, but their total costs 

may exceed those of Mediterranean producers in the years that they are paying off their 

initial investments in items such as land, mechanical harvesters, planting costs, and trellis 

systems for SHD groves. 

Operating Costs 

Operating costs for oil olive production include various expenses associated with 

growing the crop, such as fertilizer and labor for pruning, plus harvest and post-harvest 

costs. These costs can vary widely by production area conditions, production system, and 

even olive varietal. Although recent U.S. and Spanish studies have found that operating 

costs per unit of output at the grower level overlap, these studies should be compared 

cautiously, with the caveat that they were based on different data series, are from slightly 

 88 Grants were awarded to fund research on the olive psylla, on olive knot-resistant cultivars, and on 

best management practices for wastewater from olive processing, as well as on a targeted marketing program 

for California-produced olive oil, a campaign to improve consumer and grower awareness for olives as a 

Texas specialty crop, and improvements in management practices for olive oil production in Texas. For more 

information, see USDA-AMS, “Fiscal Year 2012 SCBGP-FB Awards,” October 1, 2012; CDFA, 

“Research—Environmental Concerns,” n.d. (accessed May 13, 2013); CDFA, “Marketing—International 

Trade/Market Enhancement,” n.d. (accessed May 13, 2013); CDFA, “Research—Plant Health,” n.d. 

(accessed May 13, 2013); TDA, “2012 Specialty Crop Block Grant,” March 28, 2013. 89 Various California universities are conducting olive oil-related research, including the University of 

California (UC), Davis; California State University (CSU), Fresno; CSU Chico; UC Riverside; California 

Polytechnic at San Luis Obispo; and Sonoma State University. 90 The Olive Center is a self-funded coalition of university and industry experts whose goal is to “do for 

olives what UC Davis did for wine”—essentially, to centralize research efforts for the crop, with an aim 

toward increasing the quality of California olive oil and helping it succeed in the market. For more 

information, see UC Davis Olive Center, “What We Do,” n.d. (accessed March 26, 2013). 91 UC Davis Olive Center, “What We Do,” n.d. (accessed March 26, 2013). 92 UCCE, Sample Costs: Sacramento Valley, 2007, 19; AEMO, “Aproximación a los Costes del 

Cultivo del Olivo” [Approximating the costs of olive growing], June 2010, 42.
5-18 

different time periods, and they are based on the work and methodologies of different 

organizations. A 2007 UC Davis study estimated SHD production costs in the 

Sacramento Valley at between $6.38 and $8.92 per gallon (€1.43 to €2.00 per kilogram 

(kg)), assuming yields of 147.9–210.0 gallons per acre.93 Industry estimates gathered in 

2012 support these estimates, with reported production cost ranges of $7.50 to $9.00 per 

gallon (€1.69 to €2.02 per kg).94 In comparison, a 2010 study by the Spanish Association 

of Olive Municipalities (AEMO) estimated Spanish production costs at between 

€1.29 ($1.66) and €3.06 ($3.95) per kg, depending upon the production system used.95

Thus while the costs of individual production components (like labor or mechanical 

pruning) may vary substantially from one country to another, bottom-line farm gate 

operating cost ranges are similar. 

In addition to overlapping, these cost ranges also illustrate the diversity of production 

costs that can coexist within a country due to production system, input needs, and degree 

of technological advancement. At the same time, cost comparisons such as these fail to 

take into account differences in oil quality among producers. Such differences may be 

rewarded with a higher price in some markets and not in others, leading to different 

producer returns. 

Debt Service on Grove Establishment Costs 

As mentioned earlier, most of the world’s olive production comes from long-established 

groves, so grower production expenses are mostly operating costs. In contrast, the 

majority of U.S. oil olive groves were planted in the past 15 years. Total grove 

establishment costs would be in excess of half a million dollars in California for a SHD 

grove of 100 acres (40 ha), based on establishment costs of between $5,680 and $6,726 

per acre.96 Establishment costs can be even higher depending on land costs and scale. 

Land prices fluctuate significantly depending on the quality of soil and location, so 

establishment costs can be closer to $10,000 per acre for smaller operations and in certain 

areas where land is more expensive.97 The majority of U.S. growers finance all or part of 

this investment.98 Based on financing terms available at the time many groves were 

established, the Californian oil olive farmer typically pays about $3.50 in debt service for 

every gallon of oil produced ($0.92 per liter), equivalent to more than one-quarter of the 

average per gallon value of virgin olive oil imported into the United States.99 At MY 

2011/2012 price levels, for many growers, nearly all revenue after operating costs went to 

debt service.100 Moreover, given that standard loan terms are for 25 years, U.S. growers 

will continue to incur debt service costs for at least another decade, while most of their 

“Old World” counterparts have no comparable expense.101

 93 Although the cost estimates for California are from 2007, industry experts estimate that operating 

costs have not changed significantly since that time. There is one exception: labor rates have increased, but 

not enough to significantly affect the average cost estimates. Industry representative, telephone interview by 

USITC staff, May 6, 2013; industry representative, interview by USITC staff, California, November 15, 2012; 

UCCE, Sample Costs: Sacramento Valley, 2007, 19. 94 Industry representative, interview by USITC staff, California, November 15, 2012. 95 It is important to note that these estimates do not include producer subsidies. AEMO, “Aproximación 

a los Costes del Cultivo del Olivo” [Approximating the costs of olive growing], June 2010, 42. 96 UCCE, Sample Costs: Sacramento Valley, 2007, 5; UCCE, Sample Costs: San Joaquin Valley, 2007, 

5. 97 Industry representative, interview by USITC staff, California, November 13, 2012. 98 Industry representative, email to USITC staff, May 2, 2013. 99 Industry representative, interview by USITC staff, California, November 15, 2012; GTIS, Global 

Trade Atlas database (accessed June 19, 2013). 100 Industry representative, interview by USITC staff, California, November 15, 2012. 101 Ibid. 
5-19 

Industry Size 

U.S. olive oil production is negligible compared with major producing countries like 

Spain and Italy, accounting for just 0.3 percent of global production. 102 Moreover, 

although U.S. growers sell almost exclusively to the U.S. market, U.S. production 

currently accounts for only around 3 percent of domestic consumption.103 The size of the 

industry puts U.S. growers at a disadvantage relative to many “Old World” suppliers 

because they are less able to benefit from economies of scale. 

The large-scale olive oil production and marketing carried out by producers in many 

competitor countries allow them to capture cost advantages through economies of scale, 

particularly in storage and bottling.104 The scale of European bottling firms, which source 

oils from around the world, enables them to blend a number of different varietals to 

create a consistent flavor profile and to blend lower-quality with better-quality oils to 

produce an oil of average quality at a lower unit cost. Because U.S. olive production is 

primarily higher-quality extra virgin oil from three main olive varieties, U.S. processors 

cannot lower their unit costs this way, given their current business model. Scale is also 

important at the retail level. For example, U.S.-grown brands pay shelf placement fees 

(slotting fees) typically charged on a “per SKU” basis,105 as do companies with many 

times their sales volume.106 As a result, small domestic brands tend to pay higher per unit 

placement costs than the largest retail brands, which sell mostly imported oils.107 

The largest retail brands in the United States (most bottling imported oil) have welldeveloped, nationwide marketing channels. Even the largest U.S.-grown brand does not 

have nationwide coverage. Therefore, domestic producers must also devote resources to 

developing marketing networks and passing through the “no man’s land” between being a 

small niche producer and a national brand.108 

Cropping Alternatives and Long-Term Availability of Supply 

Although California olive groves are often planted on the state’s less productive land, in 

almost all areas currently under SHD production, another cropping option is viable. For 

this reason, most growers weigh comparative returns of olives against other crops in their 

production decisions. At the grower level, this cropping diversity is positive, but for the 

industry in the aggregate, it could mean uncertain long-term survival of the U.S. olive oil 

industry if alternative crops offer comparatively better returns. 

 102 USITC calculation based on data from industry representative, email to USITC staff, June 11, 2013 

and IOC, “Table 1: [World] Production,” November 2012. 103 USITC calculation assuming MY 2012/13 domestic production of 2.7 million gallons and U.S. 2012 

imports of 307 million kg. Industry representative, telephone interview by USITC staff, March 15, 2013; 

GTIS, Global Trade Atlas database (accessed June 19, 2013). 104 As an example, a single Spanish firm was reported to have a stock of 30 million kg of oil equivalent 

to more than three times California’s entire production. Industry representative, interview by USITC staff, 

Spain, January 23, 2013. 105 SKU stands for “stock-keeping unit,” and refers to each unique product offered for sale, taking into 

account attributes such as brand, size, and packaging. Each SKU is assigned a unique identifier number, and 

this number is also sometimes referred to as a SKU. 106 Industry representative, email to USITC staff, June 7, 2013. 107 Ibid. 108 USITC, hearing transcript, December 5, 2012, 66 (testimony of Gregg Kelley, California Olive 

Ranch). 
5-20 

Most California growers of SHD olives are professional farmers, accustomed to 

readjusting their tree crop mixes depending on market conditions and evaluating 

projected comparative returns before investing in a new crop.109 In the Sacramento and 

San Joaquin Valleys, where SHD production predominates, olives currently compete for 

acreage against almonds, walnuts, wine grapes, and more than a dozen other options. 

Farmers there have the flexibility to switch out of olive production if the returns from 

alternative crops are expected to be higher. At present, returns for oil olives are 

comparatively lower, and some growers have already removed olive acreage in order to 

plant more profitable alternative crops.110 Given this production dynamic, the long-term 

forecast for oil olive production is uncertain. This long-term availability of olives is a 

concern for mills that produce oil using grower contracts. Many mills operate under 6–12 

year contracts, but beyond that time frame, contracted growers are under no obligation to 

continue raising olives. This leaves mills the problem of ensuring sufficient supplies in 

planning for the future unless they increase production on their own olive holdings. 

In contrast, in most countries around the Mediterranean, land in olive oil production is 

not suitable for growing alternative crops. In some areas, the marginal quality of the land 

and/or the lack of irrigation infrastructure make olives the only viable planting option, 

while in others the only available cropping alternative has less favorable returns than 

olives.111 Italian farmers are legally prohibited from removing olive trees, so are unable to 

grow alternative crops even if they wished to do so.112 For this reason, European mills 

and bottlers have little doubt regarding their long-term availability of supply. 

 109 Industry representative, interview by USITC staff, California, November 15, 2012. 110 Golden Olive Ranch, written submission to the USITC, February 11, 2013, 1. 111 Industry representative, interview by USITC staff, Madrid, Spain, January 22, 2013. 112 Italian government official, interview by USITC staff, Rome, Italy, February 1, 2013. 
5-21 

Bibliography 

AEMO. See Spanish Association of Olive-growing Municipalities. 

California Department of Food and Agriculture (CDFA). California County Agricultural Commissioners’ 

Reports 2011, December 17, 2012. 

http://www.nass.usda.gov/Statistics_by_State/California/Publications/AgComm/201112cactb00.p

df. 

———. “Marketing—International Trade/Market Enhancement and Promotion.” 2012 Specialty Crop 

Block Grant Program, n.d. (accessed May 13, 2013). 

http://www.cdfa.ca.gov/Specialty_Crop_Competitiveness_Grants/pdfs/MarketingIntlTradeMarke

tEnhance.pdf. 

———. “Research – Environmental Concerns and Conservation,” 2012 Specialty Crop Block Grant 

Program, n.d. (accessed May 13, 2013). 

http://www.cdfa.ca.gov/Specialty_Crop_Competitiveness_Grants/pdfs/ResearchEnvironConcernsConserve.pdf. 

———. “Research – Plant Health and Pest Challenges,” 2012 Specialty Crop Block Grant Program, n.d. 

(accessed May 13, 2013). 

http://www.cdfa.ca.gov/Specialty_Crop_Competitiveness_Grants/pdfs/ResearchPlantHealthPestChallenges.pdf. 

Consumer Reports. “How to Find the Best Extra-Virgin Olive Oil,” September 2012. 

Fichtner, Elizabeth, Katie Wilson, and Carol Lovatt. “Understanding Alternate Bearing in Olive,” West 

Coast Olive Guide, May/June 2012. 

http://www.olivecouncil.com/WCOG_2012_05_Print_Proof.pdf. 

Frankel, E.N., R.J. Mailer, S.C. Wang, C.F. Shoemaker, J.X. Guinard, J.D. Flynn, and N.D. Sturzenberger. 

“Evaluation of Extra-Virgin Olive Oil Sold in California.” UC Davis Olive Center. April 2011. 

http://olivecenter.ucdavis.edu/files/report%20041211%20final%20reduced.pdf. 

U.S. Food and Drug Administration (FDA). “HACCP Principles and Application Guidelines.” August 14, 

1997. http://www.fda.gov/Food/GuidanceRegulation/HACCP/ucm2006801.htm#execsum. 

Global Trade Information Service, Inc. (GTIS). Global Trade Atlas database (accessed various dates). 

http://www.gtis.com/english/GTIS_GTA.html (fee required). 

Gustafson, Christopher R., and Travis J. Lybbert. “What’s Extra Virgin? An Economic Assessment of 

California’s Olive Oil Labeling Law.” University of California Giannini Foundation Agricultural 

and Resource Economics Update 12, no. 3 (Jan/Feb 2009). 9-11. 

http://giannini.ucop.edu/media/are-update/files/articles/v12n3_2.pdf. 

International Olive Council (IOC). “40th Meeting of the Advisory Committee,” November14–15, 2012. 

http://www.internationaloliveoil.org/documents/viewfile/7118-powerpoint-presentation-advisorycommittee/2. 

———. “Table 1: [World] Production.” World Olive Oil Figures, November 2012. 

http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures. 
5-22 

———. “Table 4: [World] Consumption.” World Olive Oil Figures, November 2012. 

http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures. 

Leiva Dimter, Arturo. “Negocio Mundial del Aceite de Oliva: Oportunidades de Inversión en Chile” [The 

world olive oil business: Investment opportunities in Chile]. Presentation for Expo Corfo, 

Santiago, Chile, May 2009. 

Senise Barrio, Olga, and Hoy Carman. “Olive Oil: A ‘Rediscovered’ California Crop.” University of 

California Giannini Foundation Agricultural and Resource Economics Update 8, no. 5 

(May/June 2005), 1–4. http://ucce.ucdavis.edu/files/datastore/391-403.pdf. 

Spanish Association of Olive-growing Municipalities (AEMO). “Aproximación a los Costes del Cultivo 

del Olivo.” [Approximation of the costs of olive cultivation]. Presentation prepared for AEMO 

seminar, June 2010. http://www.aemo.es/get.php?pathext=descargas/Costes_AEMO.pdf. 

Sustainable Agriculture Education (SAGE) Center. “2010 California Olive Oil Industry Survey Statistics,” 

August 2010. http://issuu.com/oliveoiltimes/docs/agsurvey2010/3?mode=a_p. 

Texas Department of Agriculture (TDA). “Specialty Crop Block Grant Selected Projects.” Public 

Information Request Response, March 28, 2013. 

Tous, Joan, Agusti Romero, Juan Francisco Hermoso, and Antonia Ninot. “Mediterranean Clonal 

Selections Evaluated for Modern Hedgerow Olive Oil Production in Spain.” California 

Agriculture 65, no. 1 (January–March 2011), 34–40. 

http://ucce.ucdavis.edu/files/repositoryfiles/ca6501p34-82943.pdf. 

University of California Cooperative Extension (UCCE). Sample Costs to Establish a Medium-Density 

Olive Orchard and Produce Bottled Olive Oil: North and Central Coasts, 2011. 

http://coststudies.ucdavis.edu/files/OliveOilNC_CC_2011.pdf. 

———. Sample Costs to Establish a Super-High Density Olive Orchard and Produce Olive Oil in the 

Sacramento Valley, 2007. http://coststudies.ucdavis.edu/files/oliveoilsv2007.pdf. 

———. Sample Costs to Establish a Super-High Density Olive Orchard and Produce Olive Oil in the 

San Joaquin Valley, 2007. http://coststudies.ucdavis.edu/files/oliveoilsjv2007.pdf. 

———. Sample Costs to Establish an Olive Orchard and Produce Olive Oil, 2001. 

http://coststudies.ucdavis.edu/files/2001oliveoil.pdf. 

UC Davis Olive Center. “Survey: Super-High-Density Olive Production in California,” November 2009. 

http://olivecenter.ucdavis.edu/files/survey%20111509%20revised.pdf. 

———. “What We Do.” n.d. http://olivecenter.ucdavis.edu/who-we-are/what-we-do (accessed March 26, 

2013). 

U.S. Department of Agriculture (USDA). Agricultural Marketing Service (AMS). “Specialty Crop Block 

Grant Program,” October, 2012. 

http://www.ams.usda.gov/AMSv1.0/ams.fetchTemplateData.do?template=TemplateN&navID=S

pecialtyCropBlockGrant0Program&rightNav1=SpecialtyCropBlockGrant0Program&topNav=&l

eftNav=CommodityAreas&page=SCBGP&resultType. 

———. “Fiscal Year 2012 SCBGP-FB Awards,” October 1, 2012. 

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5100734. 
5-23 

U.S. Department of Agriculture (USDA). Federal Crop Insurance Corporation (FCIC). “Olive Crop 

Provisions,” n.d. http://www.rma.usda.gov/policies/2012/12-0501.pdf (accessed November 1, 

2012). 

———. “Summary of Business Application,” n.d. http://www3.rma.usda.gov/apps/sob/ (accessed May 7, 

2013). 

U.S. Department of Agriculture (USDA). National Agricultural Statistics Service (NASS). 2007 Census 

of Agriculture: United States Summary and State Data, February 2009. 

http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_1_US/usv1.p

df. 

———. Noncitrus Fruits and Nuts: 2012 Preliminary Summary, January 25, 2013. 

http://usda01.library.cornell.edu/usda/current/NoncFruiNu/NoncFruiNu-01-25-2013.pdf. 

———. Noncitrus Fruits and Nuts Annual Summary, 2000–2012. 

http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1113. 

———. California Field Office. “California Olives, 1920–2010,” February 2011. 

http://www.nass.usda.gov/Statistics_by_State/California/Historical_Data/Olives.pdf. 

U.S. Department of Agriculture (USDA). Risk Management Agency (RMA). “Olive Pilot Crop 

Insurance,” December 6, 2012. http://www.rma.usda.gov/fields/ca_rso/2012/olive.pdf. 

Vossen, Paul M., and Alexandra Kicenik Devarenne. “UC Cooperative Extension Sensory Analysis Panel 

Enhances the Quality of Califorina Olive Oil.” California Agriculture 65, no. 1 (January–March 

2011), 8–13. http://ucce.ucdavis.edu/files/repositoryfiles/ca6501p8-82774.pdf. 

Warnert, Jeannette. “New Methods Are Transforming Table Olive and Olive Oil Production in California.” 

California Agriculture 65, no. 1 (January–March 2011), 6–7. 

http://ucce.ucdavis.edu/files/repositoryfiles/ca6501p6-83152.pdf. 

6-1

CHAPTER 6 

European Union 

Overview 

The European Union (EU) is the global nexus for the production, consumption, and 

trading of olive oil. Countries in the EU1

 produce approximately 70 percent of the 

world’s supply of olive oil, with over 2.4 million metric tons (mt) produced in marketing 

year (MY) 2011/12 (table 6.1). Production is concentrated in three countries, with Spain 

accounting for 66 percent of the EU total in MY 2011/12, Italy for 18 percent, and 

Greece for 12 percent. A few other countries, most notably Portugal, account for much 

smaller shares. 

TABLE 6.1 EU: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt)

 2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 1,940.5 2,118.5 1,939.0 2,224.5 2,209.0 2,444.0 c1,739.0 

Extra-EU imports 126.8 160.8 94.9 75.9 79.0 85.6 90.9 

Consumption 1,835.1 1,865.9 1,856.0 1,846.0 1,866.5 1,916.9 1856.9

Extra-EU exports 291.0 357.0 37.2 440.4 481.3 509.1 542.3

Source: IOC, “Tables 1–4: [EU] Production, Imports, Exports, Consumption,” November 2012. 

Note: A marketing year spans October 1 to September 30 the following year. 

 aProvisional. 

b

Projected. cThis MY 2012/13 projection for EU production from the IOC does not include the most up to date data from the 

Spanish Olive Oil Agency. According to the Spanish Olive Oil Agency, MY 2012/13 production in Spain was 

614,100 mt, down from the 820,000 mt projection used by the IOC in the calculation in this table. 

This chapter reviews region-wide production and consumption trends before describing 

the EU agricultural and regulatory policies that affect the olive oil industry’s operations 

in European countries and, by extension, worldwide. Following the policy description, 

individual country profiles are provided for Spain, Italy, and Greece, the three largest 

producing countries. The country sections examine the olive oil industries in each of 

these countries and consider the factors affecting their competitiveness. 

Each of the three major producing countries in the EU has different competitive strengths 

and plays a different role in the global supply chain (table 6.2). Spain produces the 

greatest volume of oil by far, is the lowest-cost producer, and enjoys greater economies 

of scale throughout the sector. Italy’s growers and millers rely more heavily on traditional 

production methods than their Spanish counterparts, but Italy also plays an important role 

in the global olive oil supply chain as a blender and bottler. Greece is known for 

producing high-quality oil, but relies on expensive traditional production methods. Both 

Spain and Greece have less capability to bottle and market than Italy. Significant volumes 

of oil produced in Spain and Greece (as well as North Africa) are sent to Italy for 

blending and bottling. Bottlers believe consumers in export markets place a premium on 

olive oil imported from Italy, and Italians have historical experience and skill in blending 

oil. 

 1

 “European Union” and “EU” refer to the EU-27. 
6-2

TABLE 6.2 Comparison of key production and consumption characteristics in Spain, Italy, and Greece

Spain Italy Greece 

Total production (MY 2011/12) 1,613,400 mt 450,000 mt 295,000 mt 

Total oil olive acreage 2.0 million ha 

(4.9 million acres) 

1.1 million ha 

(2.7 million acres) 

621,000 ha 

(1.5 million acres) 

Average olive farm size 5.3 ha 

(13.1 acres) 

1.3 ha 

(3.2 acres) 

1.6 ha 

(4.0 acres) 

Olive yield 2,980 kg/ha 2,760 kg/ha 2,100 kg/ha 

Total number of mills 1,740 5,000 2,200 

Production characteristics - Widespread involvement 

of grower cooperatives 

- Comparatively intensive 

and large scale, but still 

many traditional growers 

- Mostly groves with 

traditional planting 

densities 

- Small, local mills 

- Global hub for large 

bottlers 

- Many groves with 

traditional planting 

densities on difficult 

terrain 

- Very little bottling incountry 

Total consumption (MY 2011/12) 582,100 mt 724,500 mt 213,000 mt 

Consumption per capita 14 liters 13 liters 20 liters 

Source: IOC, “Table 1 and 4: [EU] Production and Consumption,” November 2012; EC, “Economic Analysis of the Olive 

Sector,” July 2012; EU, Eurostat database (accessed March 8, 2013). 

EU consumption and extra-EU exports are both important sales channels for the region’s 

producers. EU countries consumed about 60 percent of the world’s olive oil in 

MY 2011/12. While producing countries lead consumption, with Italy, Spain, and Greece 

being the world’s first, second, and fourth leading consumers respectively, growth in 

olive oil consumption in nonproducing EU countries is an important source of sales for 

producers. Nonproducing countries increased their share of EU consumption from 

6 percent in MY 2000/01 to 11 percent in MY 2011/12.2

 Exports to countries outside the 

EU are also important, with the United States the world’s third-largest consumer of olive 

oil and sales growing rapidly in many developing countries. 

EU policies heavily affect olive oil production and marketing in member countries. Most 

significantly, the EU provides assistance to olive oil producers through the Common 

Agricultural Policy (CAP). In each EU olive-growing country, there are significant 

numbers of small growers who rely on costly traditional methods of production, and 

therefore have costs that are at or above global prices before direct payments from the 

CAP are included in their income. Because some of these producers would likely cease 

production in the absence of income support from the EU, the CAP has the indirect effect 

of increasing total global olive oil supply, although it is unclear by how much.3

 EU 

policies also govern the marketing and labeling of olive oil in member countries and, in 

conjunction with the International Olive Council (IOC), set uniform chemical standards 

for the region (see chapter 3). Since EU policies govern trade in olive oil and the EU is 

the world’s largest supplier, these policies influence olive oil bottlers’ practices 

worldwide. 

 2

 IOC, “Table 4: [EU] Consumption,” November 2012. 3

 The EU notified the WTO that CAP payments provided through the Single Payment Scheme are 

“green box payments” (no more than minimally trade- or production-distorting) under the WTO Agreement 

on Agriculture. WTO, Agriculture Information Management System (accessed May 13, 2013). 
6-3

Production and Consumption Trends 

Production of olive oil in the EU encompasses both intensive and traditional methods, 

with stark differences in production costs and profitability between the two. These 

differences are described throughout the chapter. Italy and Greece rely more heavily on 

traditional methods than Spain, although even in Spain, the traditional segment still 

accounts for the majority of olive farms.4

 Because about 60 percent of olive growing land 

in Europe is on heavily sloped terrain, 5 conversion from traditional to modern or 

intensive methods of production is not always possible. Approximately one-third of 

plantings are in intensive, irrigated groves.6

 These groves tend to have been planted more 

recently and are on relatively flat land, which is required for the mechanized harvesting 

and efficient water management practices that are associated with higher-density 

plantings. The remaining two-thirds of plantings that are in traditional groves tend to be 

on steeper terrain. Harvesting on this terrain is done either by hand or with partial 

mechanization. Many of these groves are not irrigated. The steepness of the terrain and 

low soil quality makes the land unsuitable for most other crops. 

A wide range of olive mill types operate in the EU, with modern, two-phase mills most 

common in Spain, and older three-phase mills and traditional presses most common in 

Italy and Greece.7

 Mills in Spain tend to be larger, while in Italy and Greece there are a 

greater number of smaller, local mills. Most mills are not owned by bottling companies, 

as bottlers tend to focus on blending, packaging, and marketing oil, with limited vertical 

integration into olive oil production. 

Once olives are grown and milled, the oil moves to the next step in the value chain—

bottling—which is far more concentrated than earlier steps. A few large firms account for 

the majority of the oil that is packaged for commercial sale. Although much of EU 

bottling takes place in Italy, both Spain and Greece aim to increase their competitiveness 

by exporting oil bottled in their countries rather than sending it in bulk to Italy. The major 

firms that perform most of the world’s blending and bottling are headquartered in Spain, 

Italy, and Portugal. These relatively few large bottling firms make use of global 

distribution chains. Growers and millers claim that as a result, these bottlers are able to 

drive down prices for oil; accordingly, producers report that they are seeking ways to 

capture more of the value of their oil by bottling it themselves for sale to retail markets. 

EU countries are the largest consumers of olive oil, with 1.9 million mt consumed in 

MY 2011/12, representing almost 80 percent of EU production.8

 Italy is the world’s 

largest consumer, followed closely by Spain. Total annual consumption for Italy and 

Spain is two to three times higher than in the United States, which is the world’s thirdlargest consumer. Greece is a close fourth behind the United States.9

 However, on a per 

capita basis, EU consumption of olive oil is much higher—20 liters per capita in Greece, 

14 in Spain, and 13 in Italy, compared with approximately 1 in the United States in 

MY 2011/12—due to the significantly smaller populations in these countries than the 

 4

 AEMO, “Aproximación a los Costes del Cultivo del Olivo” [Approximation of the costs of olive 

cultivation], June 2010. 5

 De Graaff, Kessler, and Duarte, “Financial Consequences of Cross-Compliance and Flat-rate-per-ha 

Subsidies,” 2011, 389. 6

 EU official, interview by USITC staff, Washington, DC, December 11, 2012. 7

 See box 1.1 in chapter 1 for a further description of mill types. 

8

 IOC, “Table 4: [EU] Consumption,” November 2012. 9

 Ibid. 
6-4

United States. This is largely due to the role of olive oil as a traditional staple in the diet 

and cuisine of Mediterranean countries. 

Despite high domestic consumption levels, the volume of production in the EU makes the 

region the world’s largest olive oil exporter. Excluding intra-EU trade, the EU accounted 

for well over 80 percent of world olive oil exports (by value) in 2012.10 Intra-EU exports, 

however, are even larger than EU exports to countries outside the region. 

European Union Policy 

Agricultural Policy 

The European Commission (EC) provides support to the olive oil industry via the CAP. 

This support includes direct payments to farmers (called “Pillar 1”), rural development 

programs (called “Pillar 2”), storage aid when olive oil prices fall below a certain 

threshold, and funding for quality improvement initiatives. CAP funds are provided to 

member governments, and these governments are responsible for distributing them to 

producers in accordance with EU regulations. 

Direct support payments 

Direct support payments to farmers are governed by the Single Payment Scheme (SPS), 

which decouples payment amounts from annual production levels. Direct payments 

generally comprise between 25 and 50 percent of olive farm income, depending on the 

year and the type of farm in question.11 Before 2004, most EU farmers, including olive 

farmers, received payments based on the volume they produced of a specific crop. 

Reforms enacted in 2003 and 2004 changed the payment scheme for most agricultural 

products, so that farmers receive a fixed annual amount based either on historical 

production levels or on a flat regional payment-per-hectare formula. 12 Under the 

historical production model—used in the major olive oil-producing countries—farms 

receive a fixed payment amount based on what they received during the 2000–2002 

reference period, a period in which payments were coupled with production levels.13

Accordingly, payments to olive oil producers are no longer linked to production, and may 

in fact be based on payments originally coupled to production of another crop grown on 

the land during the reference period.14 Further reforms to the direct payment system are 

being contemplated for 2013–14 (box 6.1). 

In the olive oil sector, member states were given the option to keep up to 40 percent of 

payments linked to production until 2010. During this transitional period, Italy and 

 10 GTIS, Global Trade Atlas database (accessed June 19, 2013). 11 EC, “Economic Analysis of the Olive Sector,” July 2012, 10. Various countries, including Mexico 

and Argentina, have enacted countervailing duties on imports of olive oil from the EU. In 2006, the EU filed 

a trade dispute at the WTO concerning Mexican countervailing duties. In 2008, the WTO dispute panel ruled 

against Mexico by finding that the countervailing measures were inconsistent with certain requirements of the 

Agreement on Subsidies and Countervailing Measures. WTO, “Mexico—Definitive Countervailing Measures 

on Olive Oil,” September 4, 2008. 12 European Parliament, The Single Payment Scheme after 2013, 2010, 17. Support payments are 

conditional upon compliance with environmental and agricultural regulations. For olive oil, “this mechanism 

can help minimize damaging practices such as excessive use of herbicides, intensive soil tillage, and illegal 

water extraction.” EC, LIFE among the Olives, 2010, 6. 13 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 14 Ibid. 
6-5

BOX 6.1 CAP reforms for 2013–14 

CAP reforms for 2013–14 are currently being discussed among EU policymakers. One proposal is to move away 

from support payments based on historical production levels and towards a flat regional payment-per-hectare system. 

All three of the major olive oil-producing countries oppose this change.a

 One study of the olive oil industry in Italy 

found that a move to this system would result in reduced farm income for olive growers in Puglia, one of Italy’s main 

growing regions.b Another study found, however, that the change would result in a more equitable distribution of 

payments between traditional and intensive producers. Because of the link to historical production levels, 

semi-intensive and intensive producers tend to receive a greater share of total payments to olive producers than 

traditional producers at present. Under a flat regional payment system, traditional producers would receive up to 

30 percent of total payments, compared with 15 percent under the current system.c

_____________ 

 a

 European Parliament, The Single Payment Scheme after 2013, 2010. b

 Roselli et al., “The Effects of the Health Check,” 2009. 

c

 De Graaff, Kessler, and Duarte, “Financial Consequences of Cross-Compliance and Flat-rate-per-ha 

Subsidies,” 2011, 392. 

Greece moved to the SPS immediately, while Spain elected to preserve some coupled 

support.15 Spain’s coupled support for olive groves during this period typically amounted 

to around €100 million annually.16 

Starting in 2010, all payments to olive oil growers in the EU were integrated into the 

decoupled SPS, with one exception. Under Article 68 of Regulation 73/2009 (the socalled Health Check), countries are permitted to reallocate up to 10 percent of payments 

in order to improve the quality of agricultural products, support economically or 

environmentally vulnerable farming activities, or prevent land abandonment.17 A share of 

these reallocated funds can take the form of payments linked to production (i.e., coupled 

support). In the olive oil sector, Italy and Greece elected to reallocate small amounts from 

their total payments to provide coupled support for olive oil quality improvement. The 

annual amounts for Italy and Greece are €9 million and €10 million, respectively, and are 

fixed for a three-year period (table 6.3).18

Because support payments are independent of current production under the SPS scheme, 

farmers are free to produce any crop using any production method. This means that 

traditional olive growers may convert their land to intensive or super-high-density (SHD) 

groves or grow another crop altogether and still receive a payment. But in practice, many 

of the olive groves receiving payments are located on land that is too steep for conversion 

to other uses, including SHD production of olives.19 The link between payments and 

historical production also means that groves that have been planted on new acreage may 

not be eligible for payments, since the land may not have been in agricultural use during 

the reference period.20 Furthermore, Italy has a law banning the removal of olive trees 

under most circumstances.21 Thus it is unlikely that most traditional olive growers can 

convert their land to SHD groves or other crops. 

 15 Roselli et al., “The Effects of the Health Check,” 2009, 5; EC, LIFE among the Olives, 2010, 6. 16 EU, “Section III: Commission,” February 29, 2012, 255. 

17 European Parliament, The Single Payment Scheme after 2013, 2010, 20. 18 EC official, interview by USITC staff, Brussels, Belgium, February 25, 2013. In addition, Portugal 

has elected to use Article 68 for decoupled support to the olive oil industry in the amount of €6.7 million 

annually. 19 Spanish government official, interview by USITC staff, Andalusia, Spain, January 24, 2013. 20 EU official, interview by USITC staff, Washington, DC, December 11, 2012. 21 Roselli et al., “The Effects of the Health Check,” 2009, 4. 
6-6

TABLE 6.3 2012 EU CAP Funding (million €) 

CAP Funding for Programs for All Agricultural Producers 

Spain Italy Greece 

Single Payment Scheme 4,913 4,202 2,225

Rural development programs 1,051 1,267 626

CAP Funding for Programs Specific to Olive Oil 

Private storage aid (total sum for all producing countries) 23 

Spain Italy Greece 

Quality improvement measures 0 36 11

Article 68 coupled direct aid 0 9 10

Source: Commission Implementing Regulation (EU) No 564/2012 of 27 June 2012 establishing budgetary ceilings for 

2012; Commission Decision 2007/383/EC of 1 June 2007 amending Decision 2006/636/EC; European Union, 

Statement of Revenue and Expenditure by Section, "Section III: Commission," Official Journal of the European 

Union, February 29, 2012, 255; EC officials, interviews by USITC staff, Brussels, Belgium, February 26, 2013.

The lack of crop alternatives in the olive-growing sector causes the direct payments, even 

though they are decoupled from production, to have a greater impact on production than 

payments given to farmers on land suitable for multiple crops. Typically, farmers base 

their production decisions on the relative profitability of existing crops compared with 

available alternatives. But if farmers have no alternatives and are tied to a single crop, 

they are likely to produce it even when market conditions are difficult. In the case of EU 

olive farmers, many continue to harvest olives despite costs that are at or above market 

prices (before support payments are included in their income) because they have no 

flexibility to move to alternative crops.22

Rural development plans 

In addition to producer payments, the CAP provides funding for rural development plans 

in each member state. 23 These measures are known as “Pillar 2” of the CAP, to 

distinguish them from the direct support payments that fall under Pillar 1. Rural 

development plans are not sector-specific; rather, olive oil producers are among the many 

beneficiaries throughout the agricultural sector in each country. EC funding levels for 

rural development plans in Spain, Italy, and Greece are in table 6.3. 

The plans are proposed by an individual member state and, if approved, co-funded by the 

EC and contributions from the member state. Upon submission to the EC, the plans are 

reviewed to ensure that the funds are entirely decoupled from production and that they 

contribute to the EU’s broad strategic objectives for rural development (such as 

protection of the environment and diversification of economic activity in rural areas).24

Areas of focus may include, for example, funding for specific marketing initiatives or 

support for organic production. Once the plan is approved and funds are provided to the 

member state, it is up to national or regional authorities to evaluate project proposals 

 22 Particularly where agricultural products are grown on marginal land, such as the steep slopes of 

many EU olive groves, economic analysis has found that the removal of support payments would likely lead 

to land abandonment. Acs et al., “The Effect of Decoupling on Marginal Agricultural Systems,” 2010. 23 The broad themes of the rural development program are “improving the competitiveness of the 

agricultural and forestry sector; Improving the environment and the countryside; and improving the quality of 

life in rural areas and encouraging diversification of the rural economy.” EC, “Rural Development Policy 

2007–2013” (accessed May 8, 2013). 24 EC official, interview by USITC staff, Brussels, Belgium, February 27, 2013. 
6-7

from farmers, villages, agricultural product processors, nongovernmental organizations, 

and other potential beneficiaries, and to grant funds for specific projects. Olive oil 

producers, like their counterparts in other agricultural industries, may apply for funding 

for any initiative that meets the criteria. The EU requires national government 

contributions ranging from 15 to 50 percent, depending on the country’s level of 

development and whether the project falls in an EU policy priority area. Member states 

may choose to implement plans at the national or regional level. Spain and Italy 

implement plans on a regional basis, while Greece implements its plan nationally. 25

Additional detail on Spain, Italy, and Greece’s rural development plans is provided in the 

respective country sections below. 

Private storage aid 

The CAP also has provisions for private storage aid (PSA) for olive oil.26 The impact of 

the PSA program has been both debated within the EU and criticized by producers 

outside the region. For example, Spanish officials have voiced concerns that PSA could 

have an “anticompetitive” effect by driving up prices, and U.S. producers have 

questioned the effects of storage on olive oil quality.27 

The EC may elect to provide funding for EU olive oil producers to place certain amounts 

of olive oil in private storage when the market price drops below set thresholds, called 

trigger prices. The trigger prices are €1.77/kg for extra virgin, €1.71/kg for virgin, and 

€1.52/kg for lampante olive oils, and these prices have not been modified since the PSA 

system was established in 1998.28 The EC compares these trigger prices with the various 

market prices in Spain (Jaén), Italy (Bari), and Greece (Crete), although when PSA is 

offered it is typically extended to all producing member states. EC officials report that 

they consider PSA to be a last resort and that, in addition to price, they consider other 

factors, including how soon prices are likely to improve (e.g., the forecast for the next 

marketing year), climatic conditions (e.g., rainfall and temperatures), and the availability 

of credit to producers and their organizations.29

PSA operates as a solicitation for bids from private storage providers. The EC receives 

the bids and accepts the lowest price offered. Olive oil producers are then free to enter 

into contracts with storage providers at any time during the PSA window. Storage periods 

are therefore staggered and do not all begin and end on the same date. PSA is fixed at a 

flat rate based on the bids received and does not always cover the entire cost of storage. 

In the most recent round of PSA in May 2012, the amount of aid provided was €0.65 per 

mt of olive oil stored, per day.30 According to EC representatives, the share covered by 

the EC varies based on the producer’s arrangement with the storage provider. 

Cooperatives, for example, may have their own storage facilities and therefore be able to 

store oil for their producers at a more competitive rate than a third-party provider.31

PSA has been granted five times since its inception in 1998. It was first granted in 

MY 2000/01 and again in MY 2009/10. More recently, it was granted three times—in 

 25 Ibid.

26 Commission Regulation (EC) No. 826/2008. 

27 Butler, “Spanish Watchdog Says Private Storage Aid Potentially Anti-Competitive,” April 17, 2011; 

USITC, hearing transcript, December 5, 2012, 110 (testimony of Gregg Kelley, California Olive Ranch). 28 There is a proposal pending in the European Parliament to raise the trigger prices. Butler, “EU Likely 

to Increase Private Storage Aid Trigger Prices,” January 7, 2013. 29 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 30 Spanish government officials, interview by USITC staff, Madrid, Spain, January 21, 2013. 31 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 
6-8

October 2011 (for up to 100,000 mt of virgin olive oil to be stored for up to six months), 

February 2012 (for up to 100,000 mt of extra virgin and virgin olive oil to be stored for 

up to four months), and May 2012 (for up to 100,000 mt of extra virgin and virgin olive 

oil to be stored for up to six months). The actual amounts stored are usually less than the 

maximums. For example, in the October 2011 PSA round, 44,338 mt were stored out of a 

maximum of 100,000 mt.32 In the May 2012 round, producers used the program more 

heavily, storing 86,000 mt.33 According to EC officials, PSA was provided three times 

recently over a relatively short period due to historically high production levels and the 

resulting low market prices.34

Other measures 

Additional support for the EU olive oil sector is provided through funding for quality 

improvement measures under the “interventions in agricultural markets” section of the 

EC budget. (This is separate from Article 68 coupled support for quality improvement 

programs mentioned above.) Under this program, member states may reallocate funds 

from the SPS in order to finance operator organizations’ efforts to improve the quality of 

olive oil. 35 Member states receive and evaluate proposals from eligible operator 

organizations and provide additional financing (up to 50 percent) for the programs they 

approve. In 2012, Italy reallocated €36 million to this program and Greece reallocated 

€11 million. Spain does not reallocate funds under this program. 

Olive Oil Action Plan 

In 2012, the EC issued its draft “Action Plan for the EU Olive Oil Sector.” The impetus 

for the plan was the growth in production and consumption of olive oil worldwide and a 

desire to “preserve and promote the image of olive [oil] and improve the quality” of EU 

products.36 The plan also highlights structural challenges in the olive oil industry in the 

EU, namely that “Spain currently overproduces olive oil” and that “this structural surplus 

deepens imbalances in bargaining power in the production chain” by making it more 

difficult for farmers to influence prices.37 This imbalance of power in the production 

chain is a defining feature of the olive oil industries in each of the major producing 

countries of the EU, as described for Spain, Italy, and Greece below. 

The plan focuses on six priorities,38 although so far most of the work on the Action Plan 

relates to the section titled “quality and control.” To this end, the EU adopted legislation 

in March 2013 to standardize the number of quality checks that members must perform 

on olive oil, and to require that results of these checks be transmitted to the EC. The 

regulation will enter into force in January 2014.39 Before this legislation, member states 

were responsible for implementing quality checks and the EC had no record of the 

 32 Butler, “EU Offers Olive Oil Storage Aid,” February 8, 2012. 

33 Spanish government officials, interview by USITC staff, Madrid, Spain, January 21, 2013. 34 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 35 This program was established by Article 103 of Council Regulation (EC) No. 1234/2007 and is 

governed by Commission Regulation (EC) No. 867/2008. 36 EC official, email to USITC staff, April 26, 2013. 37 EC, “Action Plan for the EU Olive Oil Sector,” June 18, 2012, 5. 

38 The six areas are quality and control; restructuring the sector; structure of the industry; promotion; 

working with the IOC; and competition with third countries. The areas of the Action Plan related to 

promotion and restructuring the sector are subject to CAP funding and are therefore considered longer-term 

priorities by EC officials. EC, “Action Plan for the EU Olive Oil Sector,” June 18, 2012, 2; EC official, 

interview by USITC staff, Brussels, Belgium, February 26, 2013. 39 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 
6-9

frequency of testing being carried out at the national levels. The new regulation requires 

at least one chemical check per 1,000 mts of oil marketed in the member state, with more 

frequent checks for producers deemed to be a higher risk. These checks will be 

performed at the bottling stage. The Action Plan also calls for work with the IOC to 

speed up research on testing methods, and this work is in progress.40

The Action Plan recommendations are also being implemented on marketing and labeling 

standards to improve clarity for consumers, with draft legislation proposed. So far, the 

EC has made recommendations that bottlers put storage suggestions on the label, improve 

legibility and readability (e.g., font size), and put all mandatory labels in the same field of 

vision.41 These new labeling recommendations are not yet binding. The Action Plan also 

proposes to prohibit the reuse of olive oil packages in restaurants and the foodservice 

sector,42 although the EC put its attempt to implement this recommendation on hold in 

May 2013 after it was criticized by representatives of the foodservice sector in northern 

Europe because of the additional costs the proposal would require.43

Regulatory Policy 

EU regulatory policy for olive oil mainly relates to two areas: chemical standards and 

marketing requirements. The EU’s policies on chemical standards and marketing for 

olive oil are influential because they govern the sale of olive oil in most of the world’s 

largest consuming markets. Because the EU market accounts for such a large share of the 

major bottlers’ sales, the requirements they face in the EU impact their operations and the 

products they sell worldwide. EU regulatory policies for olive oil are heavily influenced 

by the large producing countries, although their perspectives must be balanced with the 

perspectives of the other olive oil-consuming countries that make up the majority of EU 

members. 44

 

With respect to chemical standards, the EU adopts IOC decisions. In fact, the EU 

regulation that sets these standards, Commission Regulation (EEC) No. 2568/91, 

“transposes IOC norms” into EU law,45 and the EU regulation is amended whenever IOC 

standards change. There may be more stringent standards that exist on a voluntary basis 

(that is, within the private sector) in member states, but EU member states may not 

impose any additional mandatory chemical standards. 46 Chapter 3 provides more 

information on IOC chemical standards. 

Marketing standards for olive oil in the EU are set by Commission Implementing 

Regulation (EU) No. 29/2012. The regulation prescribes the information required on 

olive oil labels, including the category of olive oil (extra virgin olive oil, virgin olive oil, 

 40 As part of its continuing efforts in this regard, an international olive oil seminar jointly organized by 

the European Commission’s Directorate-General for Agriculture and the Joint Research Centre (located in 

Geel, Belgium) with the IOC was held in June 2013. The seminar focused on “the evaluation of the quality 

parameters of edible olive oils as well as their traceability and authentication” and resulted in the creation of 

“terms of reference” for an international research project, open to EU Member States and any international 

cooperation, on olive oil authentication to be launched by early 2014. EC, “Scientific Workshop on Olive Oil 

Authentication (Madrid, 10-11 June 2013),” n.d (accessed July 25, 2013); EC official, email to USITC staff, 

April 17, 2013; EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 41 See the section below on regulatory policy for more information on mandatory labels. 42 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 43 Bremner, “EU Gives In to North’s Mockery,” May 24, 2013. 44 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013; industry 

representatives, interview by USITC staff, Tuscany, Italy, January 30, 2013. 45 EC official, interview by USITC staff, Brussels, Belgium, February 26, 2013. 46 Ibid. 
6-10

olive oil, and olive pomace oil are the recognized categories for human consumption) and 

the designation of origin (based on both the harvest location and the milling location). 

The regulation also governs the use of optional labels such as “first cold pressing,” 

references to sensory characteristics, and the acidity level. A “best before” date is 

required on all food products in the EU, but because there is no rule for what that 

timeframe should be for olive oil, the bottlers decide. EC officials stated that they would 

like to have a reliable method for determining a “best before” date in relation to the 

harvest or bottling date, but in lieu of that, they recommend that bottlers label oil with the 

harvest date.47 Member states are responsible for uncovering labeling irregularities and 

reporting them to the EC, along with an account of what penalties were imposed. 

Spain 

Overview 

Spain is the world’s largest producer of olive oil and, outside of Italy, grows more olive 

varieties than any other olive oil-producing country.48 As a Mediterranean country with a 

long tradition of olive growing and consumption, Spain has built on its history by 

becoming home to the world’s major olive oil bottlers. It also has the world’s largest 

olive-growing area. Its production volume and relatively low production costs make 

Spain the price setter in global olive oil markets. The size of the Spanish olive oil sector 

gives it an important place in the country’s agricultural sector, and EU, national, and 

regional government policies play a major role in its operation, from support payments to 

farmers through inspection of exports. 

The Spanish olive oil industry is concentrated compared to other producing countries. 

The growing sector includes a wide variety of farm types and production methods, from 

small family farms to large, highly mechanized operations, but olive farms are generally 

larger than in other European countries. Spanish-owned bottling companies account for 

most of the world’s olive oil sales and specialize in blending, marketing, and distribution; 

much of the bottling itself takes place in Italy. Most of these bottlers are not vertically 

integrated and source oil from mills around the world, seeking the lowest price. While 

Spanish bottlers hold considerable market power to influence global purchase prices for 

bulk olive oil, local olive growers in Spain are making efforts to become more 

competitive by bottling and marketing more of their own oil, especially through “secondorder” cooperatives—organizations made up of multiple grower cooperatives designed to 

increase economies of scale. 

The first half of this section provides a descriptive profile of Spanish production and 

processing, and discusses trends in both domestic consumption and Spain’s role in global 

trade. The second half focuses on the major factors affecting Spain’s competitiveness in 

the global market, including large scale production, low costs of production, and 

supportive government programs. The impact of Spanish cooperatives on 

competitiveness is also discussed. 

 47 Ibid. 

48 Spain grows 262 varieties of olives, with 24 of them commonly grown. The most important of these 

are Picual, Hojiblanca, Cornicabra, and Arbequina. Royal Spanish Academy of Gastronomy, “Olive Oils in 

21st Century Gastronomy,” 2010, 75. 
6-11

Production Profile 

 Production Overview 

Spain produced a record high 1.6 million mt of olive oil in MY 2011/12 (table 6.4), 

which was 47 percent of world production and more than three times as much as the 

second-largest producer, Italy. Because of its size, fluctuations in Spain’s production 

significantly impact global prices and export markets for olive oil. Three consecutive 

bumper crops in Spain between MY 2009/10 and MY 2011/12 depressed global olive oil 

prices. However, a recent drought in Spain reduced production to only 614,100 mts in 

MY 2012/2013, a decline of more than 60 percent.49 This drop in production from the 

world’s largest producer has driven up olive oil prices worldwide. Spain accounts for 

50 percent of the EU’s olive acreage, but over 60 percent of its olive oil production, due 

to slightly higher olive yields and its focus on harvesting olives with high oil content. In 

large measure because of the quest for high oil content, only about one-third of Spanish 

olive oil production is extra virgin (compared with 60 percent in Italy and 65–80 percent 

in Greece). The majority of Spain’s extra virgin production is for the export market. 

TABLE 6.4 Spain: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt)

 2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 973.7 1,236.1 1,030.0 1,401.5 1,391.9 1,613.4 c820.0

Extra-EU imports 15.8 40.3 10.8 13.7 14.7 21.2 25.5

Consumption 580.8 546.3 533.6 539.4 554.2 582.1 550.0

Extra-EU exports 88.3 133.9 153.4 196.5 196.2 205.9 240.0

Source: IOC, “Tables 1–4: [EU] Production, Imports, Exports, Consumption,” November 2012. 

Note: A marketing year spans October 1 to September 30 the following year. 

 aProvisional. bProjected. cThese projections for Spanish MY 2012/13 production and consumption do not include the most up-to-date data 

from the Spanish Olive Oil Agency, which show significantly lower production. According the Spanish Olive Oil Agency, 

MY 2012/13 production was 614,100 mts. 

Olive-Growing Sector 

Spanish olives for oil are grown on 413,000 holdings50 totaling 2.4 million ha51 (about 

5.9 million acres), second in land area only to that for cereals in Spain.52 Olive growing in 

Spain comprises larger, more commercial farms than elsewhere in the EU. Spanish olive 

farms, at 5.3 ha (13.1 acres) on average, are 3 to 4 times larger than Italian and Greek 

olive farms, thereby providing a cost advantage through economies of scale. In 

Andalusia, the southern region of Spain that accounts for over 60 percent of Spanish 

acreage, the average farm size is 8 ha (19.7 acres) (figure 6.1). 

 49 Government of Spain, Olive Oil Agency, “Aceite de Oliva: Producción” [Olive oil: Production] 

(accessed May 9, 2013). 50 EC, “Economic Analysis of the Olive Sector,” July 2012, 2. 51 EU, Eurostat database (accessed March 8, 2013). 52 EC, LIFE among the Olives, 2010, 1; MARM, “The Value Chain and Price Formation,” January 

2010, 13. 
6-12

While olive farms in Spain are larger than elsewhere in the EU, the most common 

method of production in Spain remains a traditional olive grove (80 to 100 trees per ha) 

with mechanized or semi-mechanized harvesting. This type of cultivation accounts for 

about 50 percent of holdings (1.3 million ha), but for a smaller share of production, since 

olive yields are lower on these farms than on those using intensive planting methods. The 

remaining 50 percent is split roughly evenly between hand-harvested traditional groves 

(575,000 ha) and intensive groves, which are always harvested mechanically (550,000 

ha). Farm size determines whether a grove relies solely on family labor or hires 

workers.53 Another factor determining harvesting methods is the steepness of the land. 

Many Spanish olive groves are situated on steep land, including about half of those in 

 53 According to one industry source, farms over about 20 ha tend to rely on outside labor. 

FIGURE 6.1 Spain: Share of olive hectarage and production by region 

Source: Government of Spain, Ministry of Agriculture, Food and the Environment, Olive Oil Agency website, 

http://aplicaciones.magrama.es/pwAgenciaAO/OlivarEspanol.aao?opcion_seleccionada=2100&idioma=ING&numPag

ina=2101 (accessed April 24, 2013). 

Note: Percentages may not sum to 100 percent because regions not highlighted account for a combined 3 percent of 

acreage and less than 1 percent of oil production. 
6-13

Andalusia, limiting the ability of producers to mechanize, irrigate, or grow other crops.54

As a result of groves commonly being located on steep slopes and the reliance on 

traditional growing methods, most Spanish olive production remains non-irrigated.55

Production of olives for oil on SHD holdings, the most common method in California, 

accounts for only 2 percent of Spanish holdings (45,000 ha). Most of Spain’s investment 

in SHD occurred between 1995 and 2005. Since the global financial crisis that began in 

2007, investment in SHD has been limited by a lack of access to capital and high interest 

rates. New investment in SHD is also constrained by the lack of additional flat land and 

water scarcity.56 In addition, some earlier investment in SHD groves occurred at a time 

when cereal prices were low and producers were looking to diversify into more profitable 

enterprises. 57 Cereal prices have since recovered, and significant new investments in 

SHD are not expected in the near future.58 However, there have been investments in other 

intensive plantings in areas that have a high concentration of large-scale producers, 

especially near Jaén, Córdoba, Seville, Ciudad Real, Toledo, and Badajoz.59 

 

Cooperatives are an important part of the olive production system in Spain. Cooperatives 

are grower-owned and -operated associations that produce oil from the olives they grow 

and then sell it. Thus, the cooperative structure provides greater selling power for smaller 

growers. The cooperatives, however, tend to lack marketing expertise and rely on bulk 

sales to bottlers. There are approximately 900 cooperatives in Spain, ranging in size from 

100 growers to 55,000 growers in the case of Hojiblanca, which is Spain’s largest 

cooperative and accounts for 15 percent of Spanish production.60 Many of the largest 

cooperatives, including Hojiblanca, are second-order cooperatives.61 About 70 percent of 

Spanish olive oil producers belong to cooperatives, the highest share in the EU.62 

With a few exceptions, the formulas cooperatives use to pay farmers encourage larger 

production volumes rather than incentivizing higher-quality oil beyond minimum 

standards. In fact, Spanish olive production systems in general tend to minimize costs by 

rewarding high oil yields over quality. Spanish oil producers primarily pay growers on 

the basis of the oil content of their olives, versus providing additional compensation for 

higher-quality olives. Riper olives yield more oil, but the quality is lower than for olives 

picked earlier in the season because the olives lose fruitiness and polyphenols as they 

ripen.63 The difference in the average olive and olive oil yields per hectare between Spain 

and Italy are illustrative. The average yield in Spain of olives for oil was 2.98 mt/ha in 

2011, just 8 percent higher than the 2.76 mt/ha in Italy.64 However, yields diverge more 

 54 Spanish government official, interview by USITC staff, Andalusia, Spain, January, 25, 2013. 55 Estimates of the share of Spanish olive groves that are irrigated range from between 18 percent to 

around one-third. The discrepancy in estimates may be because there are a number of farms that are 

minimally or inconsistently irrigated. Industry representatives, interviews by USITC staff, Madrid, Spain, 

January 22, 2013. 56 Industry representatives, interviews by USITC staff, Madrid, Spain, January 22, 2013. 57 Ibid. 

58 Industry representatives, interviews by USITC staff, Madrid, Spain, January 22, 2013; industry 

representatives, interviews by USITC staff, Andalusia, Spain, January 23–24, 2013. 59 EC, LIFE among the Olives, 2010, 10. Three of these cities are within Andalusia, two in Castile-La 

Mancha, and one in Extremadura. 60 Industry representative, interview by USITC staff, Andalusia, Spain, January 23, 2013. 61 Second-order cooperatives are organizations made up of multiple grower cooperatives designed to 

further increase economies of scale. 62 In all, Spanish cooperatives account for over two-thirds of Spanish olive oil production. Industry 

representative, interview by USITC staff, Madrid, Spain, January 22, 2013. 63 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 23, 2013; industry 

representatives, interviews by USITC staff, Puglia, Italy, February 4, 2013. 64 EU, Eurostat database (accessed March 8, 2013). 
6-14

sharply for oil. The average olive oil yield in Spain in 2010 was 0.56 mt/ha of olives 

planted, 27 percent higher than the yield of 0.44 mt/ha in Italy.65 Many olives in Spain are 

harvested as late as February or March, when oil content can approach 22 percent or 

higher, while many premium producers in Spain, Italy, and California harvest their olives 

in November, often with oil contents between 10 and 15 percent.66

Olive Oil Processing Sector 

Milling 

With fewer but larger mills, the milling segment of the Spanish olive oil supply chain is 

more concentrated than in other major producing countries, such as Italy and Greece. 

Spanish olive oil is processed in 1,740 mills (compared to about 5,000 mills in Italy 

which produce far less volume). Spanish mills focus mostly on sales to commercial 

buyers and are less likely to sell in the traditional way—directly to local consumers—

than their Italian and Greek counterparts; in Spain, most consumers buy their olive oil 

from supermarkets. 

With a larger average mill size than most producing countries, Spanish mills are efficient 

and tend to have lower costs per unit of oil processed; most use 2-phase milling. These 

mills process an average of 8,000 mt of olives per year, although there is a wide range in 

size and some mills are significantly smaller than this. The largest mill in Spain processes 

about 90,000 mt of olives per year,67 which is more than seven times total production in 

California. Nonetheless, when crops are large, there can be a wait during the peak of 

harvest to have olives processed due to lack of local milling capacity, and capacity needs 

to be increased to maintain quality.68 

Integration between milling and bottling is limited. About 55 percent of Spanish mills are 

owned by cooperatives, and they account for 70 percent of oil produced. Mills owned by 

either sole proprietors or corporate entities account for the remaining output.69 Many 

Spanish cooperatives, however, lack the marketing expertise to promote their own brands 

at the retail level, and large Spanish companies, such as Deoleo, are able to exert 

significant control over bottling and distribution to retail outlets owing to their market 

share. However, some mills integrate their own bottling lines into their operations, 

especially those producing premium-quality oil. But many mills with a bottling line still 

sell a portion of their olive oil in bulk to other bottlers.70

Refining and bottling 

Spanish bottling and refining operations are highly concentrated. There are 1,471 bottling 

plants, although the few largest firms account for the majority of output. The top five 

bottling plants in most years account for 35 percent of oil packed in Spain, and the top 20 

 65 EC, “Economic Analysis of the Olive Sector,” July 2012, 3. 66 Industry representatives, interviews by USITC staff, California, November 14, 2012; industry 

representatives, interviews by USITC staff, Madrid and Andalusia, Spain, January 21–22, 2013, industry 

representative, interview by USITC staff, Tuscany, Italy, January 31, 2013. 67 Industry representative, interview by USITC staff, Madrid, Spain, January 22, 2013. 68 Industry representative, interview by USITC staff, Madrid, Spain, January 22, 2013; industry 

representatives, interview by USITC staff, Tuscany, Italy, January 31, 2013. 69 MARM, “The Value Chain and Price Formation,” January 2010, 26. 

70 Industry representative, interview by USITC staff, Andalusia, Spain, January 24, 2013. 
6-15

plants accounted for 65 percent of packed oil. Of the 15 olive oil refineries in Spain, nine 

are located in Andalusia. Ten of the 15 refineries are owned by bottling companies.71

Spanish bottling companies are major players in global olive oil markets. For example, 

Deoleo (formerly Grupo SOS) is the world’s largest distributor of olive oil and markets 

the brands Bertolli and Carapelli in the United States. The company also owns the brand 

Carbonell, which is the world’s most widely sold olive oil. Most large Spanish bottlers 

specialize in bottling and distribution and are not vertically integrated in growing and 

milling.72 While these Spanish companies own the brands and account for a large share of 

the blending and bottling of oils (allowing Spanish producers to benefit from these 

companies’ large global sales), much of the bottling takes place in Italy. This is 

reportedly due to the strong brand recognition of Italian labels in the United States and 

other large olive oil-consuming markets, as well as Italy’s historical expertise in blending 

olive oils.73 Still, while major Spanish bottlers continue to do much of their bottling for 

export in Italy, bottling in Spain has become increasingly important as the Spanish 

industry has sought to increase the share of its exports that are bottled. 

Both mills and bottlers are subject to inspection by Spanish regional and national 

government agencies. Regional governments have authority to test for fraud and assess 

fines. The national Olive Oil Agency also collects samples, sends them to government 

labs for testing, and notifies regional authorities when fraud is found, so that fines may be 

assessed at the regional level.74 This number of samples is relatively small in comparison 

to the scale of Spanish production. For example, the number of samples tested from mills 

averages to less than one sample annually for every two mills in operation, and at the 

bottling level, just over one sample annually for every two bottling plants in operation.75 

Consumption 

Olive oil is an important staple item in the Spanish diet, accounting for about 70 percent 

of annual edible oil consumption. 76 Extra virgin oil accounts for just 36 percent of 

consumption in Spain,77 while the IOC category “olive oil” (a blend of refined and virgin 

olive oils) accounts for the majority of the market, and virgin olive oil (that is not extra 

virgin) accounts for a very small share. Olive oil consumption in Spain was relatively 

stable between MY 2007/08 and MY 2010/11 and experienced a modest increase (of 

5 percent) in MY 2011/12, to 582,000 mt (table 6.4). 

Spanish consumers’ reliable demand for olive oil and their preference for refined grades 

give producers a valuable market for oils that are in lower demand in export markets, 

such as United States, many of which are dominated by extra virgin oils. Even though 

virgin olive oil is not a widely consumed product on its own, it is still an important 

product in Spain because it is often blended with refined olive oil and called simply 

 71 MARM, “The Value Chain and Price Formation,” January 2010, 27. 

72 Among the large companies interviewed in Spain by USITC staff, only one sources a significant 

share of olive oil from its own groves. Industry representative, interview by USITC staff, Andalusia, Spain, 

January 24, 2013. 73 USITC, hearing transcript, December 5, 2012, 80 (testimony of Tom Mueller); industry 

representative, interview by USITC staff, Maryland, December 20, 2012. 74 In 2012, the Olive Oil Agency collected 840 samples from olive oil mills, 740 from bottlers, and 60 

from refineries. This does not include sampling done by regional government authorities directly. Spanish 

government official, interview by USITC staff, Madrid, Spain, January 21, 2013. 75 See chapter 3 for additional information on official olive oil testing in Spain. 76 Spanish government official, interview by USITC staff, Madrid, Spain, January 21, 2013. 77 Ibid. 
6-16

“olive oil.”78 While the Spanish olive oil market remains a market with many price 

conscious consumers who view olive oil as a commodity instead of a premium food 

product, extra virgin’s share of the market is rising. Consumption of virgin oils (mostly 

extra virgin) grew 23 percent between 2004 and 2008, a result of low prices relative to 

other grades and educational campaigns on the benefits of extra virgin oil.79 

Trade 

In 2012, Spain was the world’s largest exporter of olive oil, exporting approximately 

827,000 mt worth $2.4 billion (table 6.5). About 41 percent of the total volume consisted 

of exports to Italy, most of which were blended, bottled, and exported to third countries. 

Other leading direct export markets were Portugal, France, the United States, and the 

United Kingdom. In addition, Spanish olive oil exports to China grew more than 10-fold 

between 2006 and 2012, and China is now Spain’s fifth-largest export destination. The 

growth of the olive oil market in China is due to rising incomes, which allow more 

Chinese consumers to purchase olive oil in place of other, less expensive cooking oils; 

growing awareness of the health benefits of olive oil; and marketing efforts, including 

recent IOC and Spanish promotional campaigns. 80 Given the volume of domestic 

production, Spain imports very little olive oil—around 73,000 mt in 2012, most of which 

was virgin or extra virgin oil. 

TABLE 6.5 Spain: Exports of olive oil (HS 1509), 2008–12 

Country 2008 2009 2010 2011 2012

 Value (million $) 

Italy 1,145 876 1,087 1,104 845 

Portugal 287 200 206 211 234 

France 318 232 204 220 216 

United States 175 151 199 190 204 

China 19 26 44 92 114 

United Kingdom 113 98 99 105 98 

All other 647 575 637 666 664 

 Total 2,704 2,157 2,477 2,589 2,374 

 EU 27 2,021 1,541 1,737 1,781 1,523 

Quantity (metric tons) 

Italy 311,275 303,501 422,768 412,806 339,834 

Portugal 71,975 70,976 74,938 82,478 90,188 

France 74,852 69,098 84,388 72,043 73,851 

United States 38,838 40,008 56,941 56,848 70,741 

China 3,834 6,052 11,316 18,773 30,120

United Kingdom 27,223 29,201 32,692 35,167 36,614 

All other 126,526 142,736 168,683 172,617 185,518 

 Total 654,523 661,572 851,726 850,732 826,866 

 EU 27 520,112 508,632 656,336 642,474 581,616 

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

The composition of Spain’s exports underscores the importance of extra virgin olive oil 

in its export markets, more so than in its domestic market. This is reflected in the fact that 

35 percent of Spanish production is extra virgin oil, but about 55 percent of its extra-EU 

exports are extra virgin. 81 Spanish producers are simultaneously serving a domestic 

 78 Industry representative, interview by USITC staff, Andalusia, Spain, January 23, 2013. 79 MARM, “The Value Chain and Price Formation,” January 2010, 17. 

80 Butler, “Adulteration Risk As Olive Oil Gains Ground,” May 14, 2012; Baker, “Spain Pulls Ahead in 

Olive Oil Sales,” March 22, 2011. 81 Spanish government, data provided to USITC staff, Madrid, Spain, January 21, 2013. 
6-17

market, in which refined blends are in demand, and export markets, dominated by sales 

of extra virgin. 

Some Spanish companies reportedly are seeking to increase the share of their bottled 

exports at the expense of bulk, because bottled oils have a higher value added and sell for 

higher prices.82 It is difficult to assess the degree to which they have been successful in 

doing so, as export statistics broken out by bottled and bulk are available only for 

shipments to the United States. Between 2008 and 2011, the share of exports of olive oil 

to the United States that was bottled fluctuated between 41 and 52 percent.83 

The Spanish government employs a risk-based system of testing on olive oil exports, 

through an agency called SOIVRE.84 The oil is checked for adulteration and adherence to 

quality standards. Failure results in 100 percent inspection of future shipments, but not in 

sanctions. In 2012, SOIVRE chemically tested about 11 percent of olive oil exports.85

Factors Affecting Competitiveness 

Market Power and Scale of Production 

The scale of Spain’s production gives its bottlers a cost advantage that allows them to 

undercut other producers on price. As the source of over 40 percent of the world’s olive 

oil, supplied at a relatively low cost, Spanish production drives the global market. 

Because consumers in most markets are sensitive to the price of olive oil, Spain’s ability 

to offer a consistent supply at low prices means that its olive oil is a mainstay in most 

export markets, whether imported directly from Spain or as a major component of 

blended bottled imports from Italy. Spain’s high production levels in MY 2009/10 and 

2010/11, and the record MY 2011/12 crop, only increased the supply available to bottlers 

and Spain’s ability to undercut competing countries on price. 

Spain’s large production volumes and ability to sell for a low price appears to benefit 

bottlers while reducing the bargaining power of upstream growers and millers who have 

large quantities to sell to a concentrated number of large buyers. According to the EU 

Action Plan for olive oil: 

Spain currently overproduces olive oil. This structural surplus deepens 

imbalances in bargaining power in the production chain, due mainly to the 

difference in economic size between the producers/primary processors and 

downstream operators. The economic crisis has worsened this imbalance and 

led to producers/primary processors, deprived of access to credit, precipitating 

falling prices by selling off their production at reduced prices to clear stocks.86

 82 Spanish government official, interview by USITC staff, Madrid, Spain, January 21, 2013. 83 In 2012, however, the share of bottled dropped to 24 percent, perhaps due to the effects of the record 

harvest and oversupply in Spain. The oversupply resulted in more oil sold in bulk because of increased 

pressure on producers to find buyers and sell their oil as quickly as possible, even if it meant accepting the 

lower margin that bulk sales offer. Spanish government, data provided to USITC staff, Madrid, Spain, 

January 21, 2013. 84 SOIVRE stands for the Servio Oficial de Inspección, Vigilancia y Regulación de las Exportaciones 

(Spanish office of export surveillance, certification, and regulation). 85 Spanish government official, interview by USITC staff, January 21, 2013. 86 EC, “Action Plan for the EU Olive Oil Sector,” June 18, 2012, 5. 
6-18

The Action Plan also points out that while Spain’s overproduction creates a situation 

where its producers must sell for a low price, consumers benefit from these lower prices. 

Low Cost of Production 

Olives account for the majority of the cost of producing olive oil. An analysis of the 

Spanish extra virgin olive oil supply chain found that olive production accounted for 

72 percent of the cost of olive oil, milling for 6 percent, bottling for 18 percent, and 

distribution for less than 4 percent.87 This is reflected in the fact that the cost of procuring 

oil accounts for 75 percent to 80 percent of bottlers’ total cost.88 Final costs per kilogram 

of olive oil have increased in recent years, but only slightly, and in MY 2012/13 they 

ranged from less than €2.00 to around €3.00.89 

Spain is generally one of the world’s lowest cost producers of olives for oil production, 

due in part to harvesting practices that maximize oil yields and to the prevalence of large 

farms benefiting from economies of scale. Costs, however, vary widely depending on 

production methods. While there are three distinct production systems (traditional, 

intensive, and SHD), between 2006 and 2009 the average cost across all systems was 

€287 per mt of olives in Spain (compared with €334 in Italy).90 

Harvesting practices are important in lowering the average cost of production in Spain. 

As noted earlier, olives tend to be harvested later in the season, when they yield higher oil 

content. There is also a substantial segment of premium olive oil producers in Spain who, 

like premium producers worldwide, tend to harvest early in order to preserve the flavor 

and polyphenol content of the oil. But in general, as was pointed out above, the Spanish 

production system across all growing methods tends to incentivize higher oil yield over 

quality to lower costs. To illustrate the difference between early and late harvest and its 

impact on costs, one industry source stated that this difference translates into needing 8 

kg of olives to produce one liter of oil if they are harvested early (at 12 percent oil 

content), as compared with needing only 5 kg of olives per liter of oil if they are 

harvested later (at 20 percent oil content).91

The cost of producing oil from Spanish olive groves is also highly dependent on the 

production model used. Olives are grown under a wide range of conditions, from 

traditional, hand-harvested groves to SHD production. Traditional producers who have 

been on their land for generations, harvest their groves by hand, do not irrigate, and have 

few costs other than family labor. This cost structure is much different from operations 

that largely harvest mechanically, and have costs associated with land, machinery, and 

irrigation. 

Underscoring the wide range of costs depending on the production method, according to 

the Spanish Association of Olive Municipalities, the cost of producing a kilogram of 

olive oil in an intensive grove (non-SHD) in Spain was €1.29 on average in 2009, 

 87 MARM, “The Value Chain and Price Formation,” January 2010, 39. For refined olive oil, the 

combined refining and bottling costs were lower than the bottling costs for extra virgin olive oil, which is 

reflected in the lower total cost and lower selling price for refined olive oil. 88 Industry representatives, interview by USITC staff, Madrid, Spain, January 22, 2013; industry 

representatives, interviews by USITC staff, Andalusia, Spain, January 23, 2013. 89 Industry representatives, interviews by USITC staff, Madrid, Spain, January 22, 2013; industry 

representatives, interviews by USITC staff, Andalusia, Spain, January 23, 2013. 90 These costs do not include the value of family labor. EC, “Olive Oil Farms Report,” February 2012, 

8. 91 Industry representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 
6-19 

compared with €1.97 in a traditional, irrigated grove and €3.06 in a traditional, 

non-irrigated grove (table 6.6). 92 According to industry sources, overall costs have 

remained relatively stable since 2009.93 

TABLE 6.6 Constructed comparative costs by production method in Spain 

 

Traditional, 

hand-harvested 

Traditional, semimechanized/ 

mechanized Intensive SHD 

Share of Spanish acreage Appx. 25% Appx. 50% Appx. 25% <2% 

Irrigated? No Sometimes Sometimes Yes 

Average yields 1,750 3,500 (non-irrigated) 5,000 (non-irrigated) 10,000 

(kg olives/ha) 6,000 (irrigated) 10,000 (irrigated) 

Common harvest method Hand harvested, 

sometimes 

assisted by the 

use of branch 

shakers 

Branch shakers with 

mechanized 

collection 

Trunk shaker with 

inverted umbrella 

Over-row 

harvester 

Total costs per hectare (€) 1,023 1,448 (non-irrigated) 1,528 (non-irrigated) 2,366 

 2,197 (irrigated) 2,305 (irrigated) 

Total costs per kg of olive oil (€) 3.06 2.20 (non-irrigated) 1.66 (non-irrigated) 1.32 

 1.97 (irrigated) 1.29 (irrigated) 

Source: AEMO, “Aproximación a los Costes del Cultivo del Olivo” [Approximation of the costs of olive cultivation], 

June 2010. 

The costs in table 6.6 are constructed cost averages based on the typical per hectare costs 

in Spain, not actual producer costs. One of the main drivers of low production costs in 

Spain is that growers typically have low or nonexistent land costs. Many Spanish farms 

do not have rent expenses because the land has been owned by the grower’s family for 

generations. Consequently, rent is not included in the cost estimates. On the other hand, 

farms planted more recently do have land costs, so the omission of these costs may result 

in averages that are slightly lower than actual costs for certain growers. Finally, the 

analysis assumes a fixed oil yield of 18 to 19 percent. Even with these caveats, the data 

are useful for comparing methods of production. Because 75 percent of Spanish olivegrowing area uses higher-cost (per unit of olive oil) traditional cultivation methods (and, 

in many cases, cannot be converted to intensive production due to the steeply sloped 

landscape), total Spanish costs of production are higher than they would be if Spain had a 

greater share of production in intensive or SHD groves. 

After establishment costs have been paid and the grove has matured, labor-intensive 

practices drive costs of production in Spain. Harvesting costs, which are driven by labor 

in all production methods except SHD, accounted for the largest share of total cost 

(between 34 and 41 percent) in the constructed cost analysis. The second-largest share of 

costs for non-irrigated farms was in labor-intensive land maintenance and pruning.94 The 

cost of on-farm labor for Spanish olive farms in MY 2012/13 was between €8 and 

€10 per hour, which includes social security payments.95 The costs of fertilizer and pest 

 92 AEMO, “Aproximación a los Costes del Cultivo del Olivo” [Approximation of the costs of olive 

cultivation], June 2010, 42. 93 Industry representatives estimated that the costs per kilogram of olive oil in MY 2012/13 ranged 

from just less than €2.00 to around €3.00. Industry representatives, interviews by USITC staff, Madrid, Spain, 

January 22, 2013; industry representatives, interviews by USITC staff, Andalusia, Spain, January 23, 2013. 94 The combined cost of land maintenance and pruning was estimated to be between €452 and €653 per 

hectare. “Land maintenance” includes such activities as soil preparation and weed management. 95 Industry representatives, interview by USITC staff, Andalusia, Spain, January 23, 2013. 
6-20 

and disease management measures were generally the lowest shares of total costs, 

partially because many groves in Spain do not use these inputs.96

Irrigation and mechanization raise the per hectare cost of producing olives, but lower the 

unit costs of producing olive oil. This is demonstrated by the fact that the lowest costs per 

kilogram of olive oil produced are found in intensive, irrigated groves, followed closely 

by SHD groves. The use of irrigation lowers the cost of producing olive oil by 

dramatically increasing olive yields. Irrigation improved yields by about 70 percent in 

traditional, semi-mechanized groves and doubled yields in intensive groves (table 6.6). 

Meanwhile, mechanization reduces labor costs, especially for hand harvesting. This is 

important because relative labor costs affect Spain’s global competitiveness—the hourly 

cost of labor in Spain is often more than a full day’s wage in North Africa (see 

chapter 7).97 

According to the Spanish Association of Olive Municipalities (AEMO) analysis, only 

intensive and SHD producers had costs of production below the market price of olive 

oil.98 Traditional producers that were mechanized or semi-mechanized had income equal 

to or greater than their costs of production only after EU CAP direct payments were 

included. 

Supportive Government Programs 

Government support to the Spanish olive oil industry, mostly through the CAP, is an 

important source of income in the sector. CAP funding for the industry in Spain comes in 

the form of direct payments to farmers and through Spain’s rural development plan. 

According to the Spanish Minister of Agriculture, the EU’s CAP payments to Spanish 

olive oil producers are approximately €1.03 billion ($1.38 billion) per year.99 However, 

under the SPS, payments are significantly lower than before 2004 (when payments were 

coupled to production).100 Estimates of direct payments as a share of farm income for 

olive growers in Spain are between 22 and 40 percent on average, depending on the year 

and the type of farm. Typical payments to olive growers vary significantly, ranging from 

no payments at all to more than €500 ($670) per ha.101 Payments may be as high as 

€690 ($924) per ha in certain olive-intensive regions, although this rate is region-wide 

and not specific to olive farms.102 The range of per hectare payments is wide due to the 

historical formula for determining payments, as described above. About 85 percent of 

Spanish olive area receives direct payments.103

The income received from CAP payments enables producers to operate at margins that 

would be unsustainable without this source of support. One EU-wide survey of olive 

groves concluded that only producers using intensive methods would be “financially 

viable without subsidies” but that many traditional growers “show negative financial 

 96 Industry representatives, interviews by USITC Staff, Andalusia, Spain, January 23, 2013. 97 Industry representatives, interview by USITC staff, Andalusia, Spain, January 23, 2013. 98 AEMO, “Aproximación a los Costes del Cultivo del Olivo” [Approximation of the costs of olive 

cultivation], June 2010, 42. 99 Government of Spain, Ministry of Agriculture, “Arias Cañete subraya,” February 22, 2012; Butler, 

“Olive Regions Work on Joint Strategy to Maintain EU Subsidies,” April 2, 2012. 100 EC, “Olive Oil Farms Report,” February 2012, 11. 101 Industry representatives, interviews by USITC staff, Andalusia, Spain, January 24, 2013. 102 Butler, “European Parliament Provides Some Comfort for Spanish Olive Oil” March 18, 2013. 103 Spanish government official, interview by USITC staff, Madrid, Spain, January 21, 2013. 
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results even with subsidies.”104 For Spain, these results are supported by the AEMO cost 

analysis of Spanish groves detailed above, which found that only intensive and SHD 

groves have costs below market prices without direct payments, while mechanized and 

semi-mechanized traditional producers break even only after direct payments are 

included, and hand-harvested traditional producers often have costs that exceed the 

selling price even after direct payments are included.105 In the absence of direct payments 

supporting their income, some of the producers with negative margins would likely cease 

production over time. Consequently, government payments, although decoupled from 

production, likely keep supplies higher than they would otherwise be each year. Because 

each Spanish olive farm has a unique cost structure, it remains unclear how much 

Spanish olive production would decline in the absence of government payments. 

Assistance from the EU is also provided through Spain’s rural development plan, 

although the impact of these programs has waned in the current difficult fiscal 

environment. The plan presently in effect runs from 2007 through 2013 and is 

implemented through tailored programs at the regional level. This regional focus means 

that areas with significant olive oil production, such as Andalusia, are likely to have 

regional development plans that benefit the olive oil sector, however indirectly because 

rural development programs are not sector-specific. Available funding to modernize 

agricultural holdings and to increase the value of Spanish agricultural products is 

particularly likely to assist the local olive oil industry.106 For example, with the goal of 

increasing the value of agricultural products, Andalusia’s regional rural development plan 

states that it will fund investments in quality assurance, evaluation, and certification 

programs for enterprises involved in agricultural processing and marketing. 107 In 

addition, Spain’s rural development plans provide payments to compensate for additional 

difficulties faced by farms in mountainous areas, a criterion that applies to many olive 

growers. Through their focus on agri-environmental initiatives, the plans also provide 

funding for olive oil growers converting to integrated production models or organic 

production.108

Limiting the impact of EU rural development programs is the requirement that national or 

subnational governments co-fund these initiatives. Co-financing contributions by member 

states range between 15 and 50 percent of the total cost, with Spain generally 

contributing 50 percent. According to industry and government officials in Spain, the 

availability of co-financing has declined in the current financial environment, including 

from local and regional governments; thus, not all available EU rural development 

funding for Spain is being used. One source estimated that up to 40 percent of available 

EU funds have recently gone unused due to lack of available matching funds.109

Reliance on Bulk Market 

The advantage of the Spanish production system is that it is structured to provide a 

reliable supply of oil to the major bottlers at relatively low prices, but this also creates 

difficulties for producers seeking to serve alternative market segments. Bottlers’ control 

 104 De Graaff, Kessler, and Duarte, “Financial Consequences of Cross-Compliance and Flat-rate-per-ha 

Subsidies,” 2011, 390. 105 AEMO, “Aproximación a los Costes del Cultivo del Olivo” [Approximation of the costs of olive 

cultivation], June 2010, 42. 106 EC official, interview by USITC staff, Brussels, Belgium, February 27, 2013. 107 Government of Spain, Junta de Andalucía, Programa de Desarrollo Rural de Andalucía [Andalusia 

rural development program], n.d., 168–74. 108 EC official, interview by USITC staff, Brussels, Belgium, February 27, 2013. 109 Industry representative, interview by USITC staff, Madrid, Spain, January 22, 2013. 
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over distribution channels leads to the perception among many Spanish growers that they 

are forced to accept the prices these firms set.110 Though many olive oil producers are 

working on ways to differentiate their product by improving quality and looking to new 

export markets, the relatively low-quality of Spanish oil, coupled with the lack of 

marketing experience found in cooperatives, perpetuates Spain’s reliance on exporting 

bulk product to Italy. 

Quality 

Most Spanish olive oil is produced by mill cooperatives. The impetus for forming 

cooperatives is to gain economies of scale by centralizing milling, thereby offering 

consistent availability of oil to buyers. As already noted, the cooperative system in many 

cases does not incentivize growers to harvest their olives early and produce quality oil 

because the formula used to determine payments to the member farmer emphasizes oil 

quantity over quality—oil yield increases, but quality degrades, as the olive is left 

unpicked and becomes overripe.111 The equation used to determine a grower’s payment is 

typically a function of the total annual sales revenue for the cooperative and differences 

in grower pay are primarily based on oil volumes. Farmers may receive a slight premium 

for olives delivered earlier in the season (since these olives should be fresher and more 

flavorful), but there is often little or no testing done to determine a farmer’s actual quality 

level and one grower’s oil is rarely differentiated from another before the olives are 

milled or when the final product is sold.112 

Because consumers expect branded olive oil to have a consistent quality and flavor 

profile, a producer is unlikely to be able to support its own brand if its oil is unable to 

reliably meet those quality standards. Like fully integrated premium producers around the 

world and unlike larger bottlers that buy oil from many different sources, most Spanish 

cooperatives cannot overcome quality variation by blending a range of oils to make a 

consistent product.113 A few of the largest cooperatives have sufficient supply to be able 

to blend oils and produce a consistent flavor, but most do not. Therefore, many 

cooperatives must instead rely on sales in bulk to major bottlers, who purchase oils of 

varying quality levels. 

Outside of the cooperative system, premium olive oil producers in Spain are also engaged 

in efforts to differentiate their products, serve market segments that recognize differences 

in quality, and counter the influence of large bottlers in the market. One notable result of 

this effort is the Extra Virgin Alliance, a group of premium producers from several 

countries working together to create a new product category that would distinguish very 

high quality extra virgin oils far exceeding IOC standards from extra virgin oils that 

barely meet those standards.114 In general, premium producers, including those in Spain, 

tend to support additional testing requirements or stricter standards as a way of helping 

them distinguish their product. 

 110 Industry representative, interview by USITC staff, Andalusia, Spain, January 24, 2013. 111 Industry representatives, interviews by USITC staff, Madrid, Spain, January 21, 2013. 112 Industry representative, interview by USITC staff, Andalusia, Spain, January 23, 2013. 113 Industry representative, interview by USITC staff, Madrid, Spain, January 22, 2013. 114 Industry representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 
6-23 

Marketing 

Spanish producer cooperatives, especially the smaller ones, usually lack professional 

management and marketing staff, instead relying on member growers to manage their 

operations. 115 The lack of marketing perspective within cooperatives has historically 

limited their ability to carve out a greater role for their producers in bottling and 

distribution.116 As a result of both quality and marketing limitations, a typical cooperative 

may sell more than 80 percent of its oil in bulk, but even among larger, more professional 

cooperatives, 50 to 75 percent is sold in bulk.117

Highlighting the fact that both quality and marketing expertise are essential to a 

cooperative’s success in differentiating its product is the fact that even those cooperatives 

that incentivize quality still sell much of their oil in bulk. For example, one mid-sized 

cooperative reported that they conduct numerous chemical tests on olives brought to the 

mill by growers, assign the olives a score, and pay growers accordingly. As a producer of 

only high-quality extra virgin oil, the cooperative imposes price penalties on olives that 

result in oil with greater than 0.5 percent free fatty acids (a sign of low quality), and 

prefers to buy those that result in oil with less than 0.2 percent acidity. The result is that 

the prices paid for the lowest- and highest-quality olives can differ by as much as 

€600 per mt of oil. Yet, while this cooperative has been successful in export markets, a 

large share of its sales are still in bulk and, like other cooperatives, they are still working 

to increase the share of their production sold in bottles.118 This example demonstrates the 

marketing challenges that even Spanish producers of premium oil face, in part due to the 

major role that large bottlers play in global distribution channels. 

Italy 

Overview 

Italy is the world’s largest consumer and second-largest producer of olive oil after Spain. 

But Italy’s size as a producer and consumer is only part of the reason the country plays a 

pivotal role in the global production chain for olive oil. Traditionally, olive oil has been 

considered primarily an Italian product by consumers in the U.S. and European markets, 

and the association of Italy with olive oil is still prevalent today. Consequently, Italy is 

home to large blending and bottling operations owned by multinational companies. These 

companies import large quantities of olive oil from foreign producers, primarily in the 

Mediterranean region, which is then blended for consistent taste profiles. Most of the 

olive oil is sourced from Spain, Greece, and Tunisia. Once blended and bottled, the olive 

oil is exported from Italy to consumers all over the world. The large bottlers tend to exert 

a substantial degree of control over distribution chains, making it difficult for smaller 

producers of Italian olives and olive oil to commercialize for export. 

Given the challenges facing domestic producers and the historical importance of the 

sector in Italy, olive oil is a perennial focus for policymakers in agriculture. Initiatives 

 115 Montegut, Cristóbal, and Marimon, “The Singularity of Agrarian Cooperatives Management,” 

November 2010, 17; industry representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 116 Industry representative, interview by USITC staff, Madrid, Spain, January 21, 2013. 117 Industry representative, interview by USITC staff, Andalusia, Spain, January 23, 2013. 118 Industry representative, interview by USITC staff, Andalusia, Spain, January 24, 2013. 
6-24 

related to marketing, standards enforcement, and support for producers are frequently 

promoted at all levels of government. 

The first half of this section will provide a descriptive profile of Italian production and 

processing methodologies, as well as discuss trends in both domestic consumption and 

Italy’s role in global trade. The second half will focus on the major factors affecting 

Italy’s competitiveness in the global market. Chief among these are the tradeoff between 

cost and quality. In addition, Italy’s olive oil industry benefits from supportive 

government programs, the reputation of the “Italian brand” in international markets, and 

the slight price premium that Italian oils command. However, the tension between 

growers and bottlers in Italy over the fact that most of the oil bottled in Italy is not of 

Italian origin is also discussed. 

Production Profile 

Production Overview 

Italy produced 450,000 mt of olive oil in MY 2011/12, a typical harvest compared with 

that of MY 2008/09, when Italy produced a bumper crop of 540,000 mt (table 6.7). Italy 

accounts for about one-quarter of the EU’s olive acreage and 20 percent of its olive oil 

production, with producers generally focused on producing higher-quality, extra virgin 

oil. 

TABLE 6.7 Italy: Olive oil supply, consumption, and trade, 2000/01, 2007/08 –12/13 (1,000 mt)

 2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 509.0 510.0 540.0 430.0 440.0 450.0 490.0

Extra-EU imports 110.8 116.6 79.5 56.3 58.0 58.2 58.2

Consumption 729.0 705.0 710.0 675.7 660.0 724.5 695.0

Extra-EU exports 173.0 180.2 176.9 195.1 223.5 232.1 232.1

Source: IOC, “Tables 1–4: [EU] Production, Imports, Exports, Consumption,” November 2012. 

Note: A marketing year spans October 1 to September 30 the following year. 

 aProvisional. 

b

Projected. 

Olive-Growing Sector 

Average farm size in Italy is only 1.3 ha, much smaller than in Spain and slightly smaller 

than in Greece. Over three-quarters of Italian olive groves have 250 trees or fewer.119

Small farm size is partly the result of land fragmentation, as farms are split up among 

family members when they are handed down. Industry sources state that many of the 

olive groves were originally 10 to 12 ha.120 Owing partially to the small average size of 

each holding, Italy has 776,000 olive holdings, the highest number of all EU member 

states.121

 119 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 6. 120 Industry representative, interview by USITC staff, Puglia, Italy, February 4, 2013. 121 EC, “Economic Analysis of the Olive Sector,” July 2012, 2. 
6-25 

The majority of Italian olive oil production is in the southern regions of Puglia, Calabria, 

and Sicily, which together account for about three-quarters of Italy’s production. 122

Puglia and Calabria, in particular, have relatively high yields and a smaller share of 

family farms, making them the most profitable growing regions in the country.123 Certain 

regions further north, such as Tuscany, are also important producers, but their importance 

is primarily due to their reputation for producing premium quality oils rather than their 

scale of production (figure 6.2). 

Although about 40 percent of Italian olive groves are irrigated, slightly more than in any 

other EU country, the Italian government considers this percentage too low and is 

focused on increasing irrigation rates. Government support for investment in installing 

irrigation is available, although these funds may not cover the full cost in all cases. This 

is especially true when the terrain requires that wells be over 1,000 meters deep in some 

areas, making installation very costly.124 In Puglia, where olive growing tends to be more 

modernized, the irrigation rate is slightly higher, at 50 percent.125

Italian olive growing is generally focused on producing olives that yield high-quality oil. 

The use of growing methods that emphasize quality is driven by several factors, including 

Italian consumer preference for extra virgin oil and the long-standing tradition of extra 

virgin production among Italy’s many smaller producers. As a result, about 60 percent of 

Italian production is extra virgin olive oil, a much higher share than in Spain.126 In 

addition, approximately 15 percent of Italian olive-growing areas have organic 

certification, a higher percentage than other global producers and an indication of the 

emphasis Italian olive growers place on quality and marketing.127

Italy grows a wider range of olive varieties than any other country.128 Several hundred 

varieties are cultivated, but among the more common are Coratina, Frantoio, Leccino, 

and Taggiasca. Coratina, which is widely grown in Puglia, is known for a somewhat 

bitter flavor and is often used in blends rather than alone.129

Olive Oil Processing Sector 

Milling 

Milling in Italy involves a large number of mills—about 5,000—many of which are small 

and use traditional processes. Approximately 20 percent of Italian mills are very small, 

operating only on a local scale. Of mills with substantial operations (those large enough 

to be tracked by the Italian government), 70 percent are located in southern Italy. About 

14 percent of Italian mills are run by cooperatives. Three-phase milling, which is an older 

process than two-phase milling, is much more common in Italy than in other olive oilproducing countries.130 About 15 percent of mills have bottling operations. Integration 

between milling and bottling is more common among small and medium-sized 

 122 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 7. 123 EC, “Olive Oil Farms Report,” February 2012, 23. 124 Industry representative, interview by USITC staff, Rome, Italy, February 1, 2013. 125 Industry representative, interview by USITC staff, Puglia, Italy, February 5, 2013. 126 USDA, FAS, Italy: Olive Oil Update, July 6, 2010, 1. 127 EC, LIFE among the Olives, 2010, 11. 128 FAO, “Importance of Olive Oil Production in Italy,” 17. 129 Industry representative, interview by USITC staff, Tuscany, Italy, January 30, 2013. 130 Three-phase milling is described in chapter 1. 
6-26 

FIGURE 6.2 Italy: Share of olive hectarage and production by region 

Source: Fontanazza, “Importance of Olive Oil Production in Italy,” 2005, 14. 

Note: Percentages may not sum to 100 percent because regions not highlighted account for a combined 3 percent of 

acreage and 4 percent of oil production. 
6-27 

operations, since the larger bottlers tend to focus solely on sourcing, blending, and 

bottling oil rather than producing it.131

The structure of the milling sector in Italy helps differentiate the Italian product by 

contributing to quality, but raises costs. Mills tend to be smaller operations in Italy than 

in Spain, and there are far greater numbers of them. Tuscany, for example, accounts for 

just 3 percent of Italian olive oil production, but that 3 percent is processed in 363 

mills,132 which is more than one-fifth of the total number of mills in all of Spain. Given 

the small scale of many mills, most growers have verbal agreements with mills rather 

than formal contracts.133 These arrangements are possible because, with a large number of 

mills, growers tend to use mills that are very close to their farm and where they may have 

long-standing relationships. The Italian Ministry of Agriculture considers this both a 

strength of the olive oil sector and a weakness, according to its analysis of its 

competitiveness. It is a strength because it ensures that the olives are milled when they 

are fresher, since they do not have to be transported long distances to a mill and are 

processed in a timely fashion.134 However, it also raises costs by limiting economies of 

scale. Very small mills have costs that are up to 2.5 times higher than industrial mills.135

Refining and bottling 

The bottling sector includes companies of all sizes, from village millers that have 

installed small bottling lines to the largest olive oil companies in the world. Italy plays a 

major role as bottler of oil for export to global markets. Bottling is often integrated with 

refining, which was conducted by just 12 companies in Italy as of 2007.136 Italian-owned 

brands with a substantial market share in the United States include Colavita, DeCecco, 

and Filippo Berio. Some of the large bottlers operating in Italy are subsidiaries of Spanish 

companies, as formerly Italian-owned brands have been bought by Spanish firms (for 

instance, the Carapelli and Bertolli brands are owned by Deoleo). While some of these 

bottlers, such as Colavita, specialize in 100 percent Italian oil, most of the oil bottled in 

Italy by the large companies is a blend of oils from a number of countries. 

The primary concern of the major blenders and bottlers is maintaining a consistent flavor 

profile that appeals to consumers in export markets. This means that the mix of oils used 

in the blends changes depending on the particular characteristics of olive oil from various 

regions at any particular time. Bottling industry representatives noted that 100 percent 

Italian oil is often more difficult to market because certain olive varieties widely grown in 

Italy tend to be more bitter than consumers prefer.137 

Bottling takes place in Italy, then, not because of the importance of its domestic olive oil 

production, but because oil bottled and then sold as an Italian product is highly 

marketable to consumers, particularly U.S. consumers. A secondary reason to bottle oil in 

 131 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 7–8. 132 Industry representative, interview by USITC staff, Tuscany, Italy, January 31, 2013. 133 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 8. 134 Italian government official, interview by USITC staff, Rome, Italy, February 1, 2013. 135 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 19. 136 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 8-9. 137 Industry representatives, interviews by USITC staff, Tuscany, Italy, January 30, 2013. 
6-28 

Italy is that Italy has a long history of and expertise in blending.138 Thus, an additional 

advantage for firms locating in Italy is the availability of experts skilled in creating olive 

oil blends to match bottlers’ specifications. 

Large bottlers that import and blend oil from many sources tend to be located in central 

and northern Italy.139 Specifically, several of the major bottlers operate in Tuscany, either 

for historical reasons or because they believe consumers have positive associations with 

the region. The bottlers are not located there for its importance in production—in fact, 

little to no Tuscan oil is used by the major bottlers, who bring about nine times more oil 

into Tuscany to blend and bottle there than the region itself produces.140

Consumption 

Italy is the world’s largest consumer of olive oil. In MY 2011/12, Italian consumption 

reached a record 725,000 mt of olive oil, although the IOC projects it to fall in 

MY 2012/13 to 695,000 mt (table 6.7). Household penetration of olive oil is around 

90 percent, 141 compared with only 40 percent in the United States. Traditional 

distribution channels, where consumers purchase olive oil directly from producers, 

account for about one-fifth of Italian production.142 Given the wide range of olives grown 

for oil in Italy and the continued importance of local distribution, Italian consumers tend 

to prefer oils with flavor profiles similar to those produced locally.143

Italian consumers generally focus on perceived quality rather than price in making their 

purchasing decisions. Over 80 percent of consumption is extra virgin, and almost all sales 

are in tinted glass bottles rather than PET.144 Some consumers still prefer traditional tins, 

even though the shelf life of oil in tins is much shorter.145 An Italian association of olive 

farmers reports that product differentiation is important in the Italian market, with 

customers increasingly interested in products that have protected designations of origin 

(PDOs), protected geographical indicators (PGIs), are certified organic, or are 

100 percent Italian. 146 Industry sources also report that Italian consumers are less 

responsive to price changes compared with consumers in the United States. Because olive 

oil is considered a staple in the Italian diet, consumers are unlikely to substitute it with 

other oil unless the cost savings is very large.147

 138 Industry representative, interview by USITC staff, Maryland, December 20, 2012. 139 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 7–8. 140 Industry representatives, interviews by USITC staff, Tuscany, Italy, January 30–31, 2013. 141 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 14. 142 USDA, FAS, Italy: Olive Oil Update, July 6, 2010, 2. 143 Industry representative, interview by USITC staff, Tuscany, Italy, January 31, 2013. 144 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 15; industry representative, interview by USITC staff, Tuscany, Italy, January 30, 2013. 145 Industry representative, interview by USITC staff, Tuscany, Italy, January 31, 2013. 146 Italian National Olive Farmers' Consortium (CNO or Consorzio Nazionale degli Olivicultori), 

document provided to USITC staff, 6. 147 Industry representative, interview by USITC staff, Tuscany, Italy, January 30, 2013. 
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Trade 

Imports 

Italy imported approximately 559,000 mt of olive oil valued at $1.4 billion in 2012, 

making it the world’s leading importer (table 6.8). A significant share of the imported oil 

is blended and bottled in Italy for export, although some is also imported for domestic 

consumption; unlike Spain and Greece, Italy relies on imports to help meet domestic 

demand. Italy imports olive oil primarily from Spain, Greece, Tunisia, and Portugal. 

Spain solidified its importance as an import source between 2008 and 2012, while 

imports from Tunisia fell. Most of Italy’s imports are duty free, either because they are 

intra-EU trade or because they are covered by preferential trade agreements.148

TABLE 6.8 Italy: Imports of olive oil (HS 1509), 2008–12 

Country 2008 2009 2010 2011 2012

 Value (million $) 

Spain 1,157 880 1,128 1,177 927 

Greece 262 251 229 268 285 

Tunisia 377 197 146 112 178 

Portugal 6 7 9 20 26 

Chile 0 1 3 4 5 

France 16 8 5 2 4 

All other 44 25 21 37 5 

 Total 1,862 1,370 1,542 1,622 1,430 

 EU 27 1,443 1,150 1,375 1,475 1,244 

Quantity (metric tons) 

Spain 309,112 304,433 426,577 429,868 369,533 

Greece 67,896 80,917 76,593 90,593 100,196 

Tunisia 98,232 71,302 52,125 40,974 76,043 

Portugal 1,798 1,955 3,144 6,502 8,647 

Chile 22 419 840 1,339 1,823 

France 3,916 2,942 1,856 886 1,568 

All other 11,837 8,061 7,910 13,989 1,598 

 Total 492,813 470,029 569,045 584,151 559,408 

 EU 27 383,792 391,307 508,969 529,873 480,496 

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

Because the large bottlers operating in Italy seek to create a consistent flavor at the 

lowest price by blending oils from various countries, import sources fluctuate based on 

production levels, specific flavor characteristics, and price levels in other major 

producing countries. For instance, Tunisian oil is known for being mild and buttery, 

while Greek oil is known for stronger flavors and is also used to raise the overall quality 

of a blend.149 As a result, the specific needs of the blending and bottling companies to 

create consistent flavor profiles while minimizing costs are an important factor in 

determining the composition of Italian imports. 

Exports 

In 2012, Italy exported approximately 378,000 mt of olive oil worth $1.5 billion 

(table 6.9). Leading destinations for Italian exports, mostly bottled, were the United 

 148 See chapter 2 box 2.3. 149 Industry representatives, interviews by USITC staff, Tuscany, Italy, January 30, 2013. 
6-30 

TABLE 6.9 Italy: Exports of olive oil (HS 1509), 2008–12 

Country 2008 2009 2010 2011 2012

 Value (million $) 

United States 580 443 466 520 504 

Germany 207 180 183 211 201 

France 115 108 120 144 112 

Japan 87 83 91 97 107 

Canada 88 72 95 97 90 

United Kingdom 107 82 82 80 70 

All other 447 374 428 484 462 

 Total 1,631 1,342 1,466 1,633 1,546 

 EU 27 638 541 567 628 569 

Quantity (metric tons) 

United States 113,107 100,315 109,226 118,401 126,216 

Germany 35,560 36,732 40,083 43,751 46,699 

France 22,673 24,663 28,833 32,455 28,495 

Japan 14,699 15,438 18,596 18,398 22,754 

Canada 16,933 16,871 24,315 23,094 23,314 

United Kingdom 21,000 18,738 20,246 18,833 17,719 

All other 82,298 81,665 102,027 108,445 112,849 

 Total 306,270 294,422 343,326 363,377 378,046 

 EU 27 119,480 119,188 136,384 140,158 140,820 

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

States, Germany, France, Canada, Japan, and the United Kingdom. Exports to these 

established markets have generally been stable, showing little growth between 2008 and 

2012. The only significant growth among Italy’s top 10 export markets was to China. The 

quantity of oil exported to China more than doubled in just one year, between 2009 and 

2010, and was almost four times greater in 2012 than in 2008 (2,585 mt in 2008 and 

9,737 mt in 2012). 

The unit value of Italian exports is nearly 50 percent higher than the unit value of Spanish 

exports. This reflects both the price premium for Italian oil and the fact that a greater 

share of Spanish oil is exported in bulk (much of it to be bottled in Italy) rather than in 

bottles. Unit values of exports are higher than unit values of imports, again reflecting 

Italy’s position as an importer of bulk and exporter of bottled olive oil. 

Factors Affecting Competitiveness 

Cost/Quality Tradeoff 

Owing to the reliance on traditional, labor-intensive methods of production, some of 

which Italian producers believe ensure high-quality oil, Italy is not a low-cost olive oil 

producer.150 Cost structures differ depending on the production methods used, however. 

Average costs of production are lower in the southern region (i.e., Puglia and Calabria), 

where commercialized, intensive olive groves with mechanization are widespread. These 

large farms are relatively few in number, but important to Italian production. For 

instance, groves with over 1,000 olive trees account for about 1 percent of Italian groves, 

 150 Industry representatives, interviews by USITC staff, Tuscany, Italy, January 31, 2013; industry 

representatives, interviews by USITC staff, Puglia, Italy, February 4, 2013. 
6-31 

but 25 percent of production. 151 Costs of production average €3.53 and 

€3.64 per kilogram of olive oil in Puglia and Calabria, respectively. In comparison, in 

central and northern Italy, where a greater share of small farms use traditional methods of 

production and focus on quality, costs are much higher at €5.80 per kilogram.152 In its 

analysis of the olive sector, the Italian government identified the prevailing presence of 

traditional growing systems and the limited spread of mechanization and irrigation as a 

weakness.153 At the mill level, as mentioned above, Italy relies on a large number of 

small-capacity mills, so average milling costs are also higher due to this fragmentation. 

Like other countries, in Italy the cost of olive production accounts for a large share (about 

70 percent) of the final cost of olive oil. Between 2006 and 2009, Italian production costs 

were roughly 16 percent higher than in Spain and 17 percent higher than in Greece, 

according to the EC’s annual farm accounting survey.154 The farm accounting survey also 

provides typical costs for Italian olive producers, which totaled between €334 and 

€412 per mt of olives during the 2006-09 period, not including the value of family labor. 

One of the largest costs was wages, which accounted for between one-fourth and 

one-third of total costs, and the share is slightly greater if “contract work” is included in 

labor costs. Taken together, the importance of family labor and the share of costs spent 

on wages and contract work demonstrate that olive growing is a very labor-intensive 

activity in Italy. 

Many Italian producers believe that higher costs associated with certain production 

methods (including early harvesting, hand harvesting, and pruning) and traditional 

milling methods provide a payoff in terms of quality, even though they raise costs. Thus, 

a significant share of Italian producers has consciously chosen to use traditional 

production methods rather than modern ones. Unlike in Spain, where the majority of 

harvesting is at least semi-mechanized, much of the harvesting in Italy is done by hand. 

To some extent, this is driven by the number of groves located on steep slopes, but it is 

also done to ensure higher quality.155 Many premium producers use the same harvesting 

and pruning crews every year and consider pruning to be skilled labor because it is 

important to the health of the trees. Pruners are paid about €140 per day (including 

insurance) and harvesters receive €70–€80 per day. While hand harvesting does improve 

quality, it is much slower than semi-mechanized methods. One person can hand-harvest 

200 kgs of olives per day, but with a shaker, one worker can harvest up to 800–900 kgs 

per day. 156 As a result, during MY 2012/13, labor for harvesting, maintenance, and 

pruning accounted for almost 70 percent of the production costs for some Tuscan growers 

focusing on high-quality production.157 Similarly, a substantial segment of Italian millers 

prefer traditional pressing systems over modern centrifuge systems. This preference also 

contributes to the higher overall cost of production in Italy because traditional mills have 

lower throughput than modern mills. 

 151 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 6. 152 Bungaro, “Olio: le novità introdotte dalla nuova legge anti contraffazione” [Oil: new law combating 

counterfeiting], n.d. (accessed May 9, 2013). 153 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 19. 154 These cost comparisons do not include the value of family labor, which is particularly important in 

Italy and may be as high as 56 percent of total costs if included. EC, “Olive Oil Farms Report,” 

February 2012, 8. 155 Italian government official, interview by USITC staff, Rome, Italy, February 1, 2013; industry 

representative, interview by USITC staff, Puglia, Italy, February 4, 2013. 156 Industry representative, interview by USITC staff, Puglia, Italy, February 5, 2013. 157 Industry representatives, interviews by USITC staff, Tuscany, Italy, January 31, 2013. 
6-32 

Price Premium 

Italy’s reputation for high-quality extra virgin oil means that Italian products command a 

price premium in the market,158 with prices paid to Italian producers typically the highest 

among EU producing countries.159 While higher costs and quality differences are the 

main driver of this price difference, the higher prices in Italy also reflect domestic 

demand that exceeds production, unlike in Spain and Greece. Moreover, the recent 

drought in Spain has cut total European supply and increased demand for Italian oil. This 

has pushed up Italian prices even further.160 

The Italian price premium translates into higher average margins for Italian producers, 

which are among the highest in the EU. Even so, while the higher Italian prices provide 

an advantage for Italian producers in general, for many—especially those facing the most 

difficult growing conditions—margins are very low. As a result, land abandonment by 

the most disadvantaged farmers is a concern of the Italian government.161

Preservation of the “Italian Brand” 

Because the interests of the bottlers and the growers diverge sharply in Italy, there is 

tension between the two segments. Italian producers are concerned that some low-quality 

blends marketed as an Italian product damage the reputation of Italian oils.162 The ability 

to market olive oil as “Italian” is an important brand advantage that benefits both the 

producers of 100 percent Italian oil and the blending and bottling firms. The Italian brand 

cachet originates from the idea among consumers that Italy is historically “the cradle of 

olive oil quality,” and from the fact that, especially “over the last 50 years...the 

marketing appeal of Italian food, in general, and Italian olive oil, as a central part of that 

Italian food, has simply grown in the American [and other countries’] consciousness.”163

Large bottling firms locate in Italy because they view olive oil perceived as Italian as 

highly marketable in key export countries. The Italian cachet also provides an advantage 

for smaller Italian producers seeking to export, as compared to their counterparts in other 

producing countries. Helped by the Italian cachet, some smaller producers interviewed in 

Italy have succeeded in differentiating and selling their products to quality-conscious 

buyers in markets such as China, Russia, Japan, Australia, the United States, and other 

EU countries. Still, this advantage should not be overstated. Most of these producers 

qualified their success by noting that it is difficult to break into export markets because 

larger bottlers dominate the distribution chain.164

There is concern throughout the Italian industry that the national brand reputation is at 

risk of being damaged by low-quality blends that contain very little Italian oil, but are 

marketed as Italian products. Italian exporters, both large and small, of 100 percent 

Italian oils stated that the Italian image suffers when there is a lack of differentiation 

 158 Industry representative, interview by USITC staff, Rome, Italy, February 4, 2013. 159 See chapter 2 for global price comparisons. Compared to prices of U.S. olive oil, one Italian 

industry official reported that the margin for a large U.S. brand is 10 percent above Italian prices, down from 

30 percent previously, and that the U.S. margin is decreasing due to higher U.S. production. Industry 

representative, interview by USITC staff, Rome, Italy, February 4, 2013. 160 Industry representative, interview by USITC staff, Puglia, Italy, February 4, 2013. 161 Government of Italy, Ministry of Agriculture, “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010, 18. 162 Industry representative, interview by USITC staff, Tuscany, Italy, January 31, 2013. 163 USITC, hearing transcript, December 5, 2012, 80 (testimony of Tom Mueller). 164 Many Italian producers stated that the United States was a particularly difficult export market to 

break into, as they perceived the distribution channels and buyers as focused more on price than on quality. 
6-33 

between their oils and the lower-quality oils being bottled in Italy.165 To preserve the 

Italian brand, some producers are seeking to change policy and regulation relating to 

quality, testing, and labeling. 

Responding to concerns primarily from growers and bottlers of 100 percent Italian olive 

oil, the Italian government promulgated a number of additional domestic regulations and 

enforcement measures that go beyond EU regulations. The focus of these regulations is 

“traceability,” i.e., ensuring that the origin of 100 percent Italian oils can be verified 

(mostly through records checks) as they move through the supply chain.166 The Italian 

government is creating a database to assist in this effort. The Italian olive growers’ 

association (UNAPROL) reports that 600 oil producers, representing 7,000 farms, are 

participating in traceability certification programs.167 

Regulations also focus on uncovering fraud. The fraud investigation unit of the Italian 

national police force (the Carabinieri) dispatches inspectors to conduct chemical 

inspections and audit companies’ records, at the milling, bottling, and retail levels.168

Penalties for fraud usually include fines. In October 2012, Italy passed a law, the “Legge 

Mongiello,” which aims to improve the “quality and transparency of the supply chain for 

virgin olive oils.”169 Most notably, the law increases penalties and fines for producers 

convicted of adulteration and counterfeiting, encourages the use of alkyl esters testing 

and the publication of the test results, mandates a “best before” date of 18 months from 

harvest, and bans the use of refillable unlabeled olive oil containers in restaurants.170

Reflecting the divergent views between bottlers and growers in Italy, a representative 

from the large Italian bottling industry expressed the view that the Italian government’s 

focus on inspection, enforcement, and origin labeling is mostly in response to pressure 

from farmers to protect the domestic industry.171 

Government Support 

According to the EC’s annual farm accounting survey, between 22 and 50 percent of 

Italian olive grower income comes from CAP payments, depending on the year and the 

type of farm.172 Because of low production margins, many Italian producers might not be 

able to operate without this additional source of income. According to industry sources 

and government officials, direct payments amount to €500 to €800 per ha on average in 

Italy, 173 slightly higher than the average payment in Spain (as reported by industry 

sources there). 

Support for Italian growers and others in the olive oil industry is also provided through 

rural development programs, which are implemented at the regional level. Rural 

 165 Industry representatives, interviews by USITC staff, Rome and Tuscany, Italy, January 31 and 

February 4, 2013. 166 Italian government officials, interview by USITC staff, Rome, Italy, February 1, 2013; industry 

representative, interview by USITC staff, Rome, Italy, February 1,2013. 167 UNAPROL, document provided to USITC staff, February 2010. 168 Italian government officials, interviews by USITC staff, Rome, Italy, February 1, 2013. 169 Legislative Proposal Approved by the 9th Permanent Commission (Agriculture and Agri-food 

Production) of the Italian Senate, Senate printed version no. 3211, “Standards on the Quality and 

Transparency of the Supply Chain for Virgin Olive Oils” (October 30, 2012). 170 Bungaro, “Olio: le novità introdotte dalla nuova legge anti contraffazione” [Oil: new law combating 

counterfeiting], n.d. (accessed May 9, 2013). 171 Industry representative, interview by USITC staff, Rome, Italy, February 1, 2013. 172 EC, “Olive Oil Farms Report,” July 2012, 10. 173 Industry representatives, interviews by USITC staff, Puglia, Italy, February 4–5, 2013; Italian 

government official, interview by USITC staff, Rome, Italy, February 1, 2013. 
6-34 

development programs are better funded in Italy than in other EU countries because of 

the commitment of the Italian government to co-finance the initiatives more than one-toone. (Italy is only required by the EU to contribute 50 percent towards approved projects, 

but has chosen to contribute more in many cases.) For example, in the area of farm 

modernization (a major focus in Italy), the Italian government contributes approximately 

€2 for every €1 received from the EU (table 6.10). As applied to the olive oil sector, farm 

modernization includes support for installing irrigation, new SHD plantings, and the 

purchase of mechanical harvesters and pruning machines.174 Farm modernization is the 

second-largest funding priority in Italy’s rural development plan, after the promotion of 

organic agriculture. Table 6.10 gives 2007–13 budget totals (Italian government and EU 

funding) for major rural development priorities both at the national level as well as in 

Puglia and Calabria, the two largest olive producing regions of Italy. The figures in the 

table represent total funding over the eight-year period, and the table includes only 

funding for those objectives the Italian government identified as most significant. 

TABLE 6.10 Italian government and EU rural development funds, 2007–13 totals, major olive growing regions and 

national totals (€, millions) 

Objective Funding source Puglia Calabria 

Italy (total for 

all regions)

Setting up young farmers Italian government 75 33 700

 EU 43 20 330

Advisory services for farm and forest holders Italian government 19 5 116

 EU 11 3 56

Modernization of agricultural holdings Italian government 306 174 3,055

 EU 178 105 1,494

Adding value to agricultural and forestry products Italian government 146 87 1,280

 EU 84 52 623

Support for food quality schemes Italian government 2 2 63

 EU 1 1 29

Support for producer groups' Italian government 4 12 148

information/promotional campaigns EU 2 7 69

Support for organic agriculture Italian government 350 250 3,771

 EU 205 149 1,983

Source: Italian government officials, email correspondence with USITC staff, April 17, 2013. 

Greece 

Overview 

Greece plays an important role in global olive oil production, but little of its oil enters 

world markets as a Greek product. Rather, most Greek olive oil is consumed domestically 

(mostly through direct sales to consumers), as Greece has the highest per capita olive oil 

consumption in the world. Most of the remainder is exported to major bottlers in Italy for 

blending with extra virgin olive oils from various sources. Greek extra virgin oil is 

known among blenders and bottlers as a component that raises the overall quality and 

flavor profile of a blend. Recent industry and government initiatives seek to reduce the 

 174 Italian government official, email to USITC staff, April 18, 2013; industry representatives, interview 

by USITC staff, Puglia, Italy, February 4, 2013. 
6-35 

sector’s dependence on bulk exports to Italy and to increase competitiveness by focusing 

more on selling differentiated Greek product. 

The first half of this section will provide a descriptive profile of Greek production and 

processing methodologies, as well as discuss trends in both domestic consumption and 

Greece’s role in global trade. The second half will focus on the major factors affecting 

Greece’s competitiveness in the global market. Specifically, the main advantage of the 

Greek olive oil industry is the widely recognized quality of Greek olive oil, which creates 

consistent demand for it. The industry also benefits from substantial government support. 

The section also discusses two major disadvantages of the Greek production system: high 

costs of production due to a lack of economies of scale; and an absence of product 

differentiation, which results in continuing overreliance on bulk exports. 

Production Profile 

Production Overview 

Greece is the world’s third-largest olive oil producer, after Spain and Italy. Greece 

produced 295,000 mt of olive oil in MY 2011/12, down from 327,000 mt in MY 2007/08 

(table 6.11). Production declined in MY 2010/11 and 2011/2012 owing to unusually cool 

weather conditions,175 but is forecast to recover to 350,000 mt in MY 2012/13. Until 

recently, Greek production levels were subject to the alternate bearing cycle of the olive 

tree, but the variation between crop years is now lower, likely due to the increased use of 

irrigation and pruning techniques that reduce the effects of this cycle. 

TABLE 6.11 Greece: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt)

 2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 430.0 327.2 305.0 320.0 301.0 295.0 350.0 

Extra-EU imports 0 0 0 0 0 0 0

Consumption 270.0 264.0 229.0 228.5 227.5 212.5 208.0

Extra-EU exports 10.0 9.8 11.0 12.0 13.0 15.0 16.0

Source: IOC, “Tables 1–4: [EU] Production, Imports, Exports, Consumption,” November 2012. 

Note: A marketing year spans October 1 to September 30 the following year. 

 aProvisional. bProjected. 

Olive-Growing Sector 

Olive production is among the most important agricultural sectors in Greece, accounting 

for 20 percent of agricultural land and 60 percent of the total number of holdings.176 Olive 

holdings, the majority of which are small, total approximately 531,000.177 Most of the 

olive groves are dedicated to the production of olives for oil, although the table olive 

sector is also important in Greece. Some Greek olive varieties, such as Kalamata, are 

used for both oil production and table use, so it is difficult to separate total olive-growing 

area based on its use. In general, however, Greece harvests at least 10 tons of oil olives 

for every ton of table olives each year.178

 175 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 2. 176 EC, LIFE among the Olives, 2010, 1. 177 EC, “Economic Analysis of the Olive Sector,” July 2012, 2. 178 EU, Eurostat database (accessed March 8, 2013); IOC, “Table 1: [EU] Production,” November 2012.
6-36 

In general, Greece’s climate and soil are very well suited to olive growing, and olive oil 

is produced throughout the country. Greece produces a high share of extra virgin oil, 

much of it high quality, owing to its favorable climate and soil, reliance on olive varieties 

that tend to yield high-quality extra virgin oil, and timely harvesting and milling of 

olives.179 The regions of Crete and the Peloponnese are the most concentrated growing 

areas, accounting for 65 percent of olive oil output.180 Most of the newer, intensive farms 

are located in these regions. 

Greece relies more heavily on a single olive variety than Spain or Italy, with the 

Koroneiki olive accounting for about 80 percent of production. The Koroneiki variety 

produces high-quality oil for which there is strong demand. Other common varieties are 

Manaki and Athinolia, grown primarily in the Peloponnese.181

The average farm size in Greece is only 1.6 ha, just slightly larger than in Italy.182 About 

70 percent of Greece’s olive-growing land is considered “disadvantaged” by the EU, 

meaning that it is either steeply sloped or has other geographic features that make it 

difficult to farm. Often olive trees are the only crop that can be grown on the land.183

Because many farms are small and located on difficult terrain, most olives are hand 

harvested,184 and fewer Greek farmers employ modern production methods than either 

Spain or Italy. The sector’s low efficiency is reflected in the fact that Greece accounts for 

22 percent of EU oil olive acreage, but just 14 percent of its olive oil production.185 

The number of small olive farms in Greece is decreasing due to land abandonment and 

competing land use priorities. Small, traditional olive farms, many of which are located 

on the Greek islands, face “competition from real estate development and tourism. . . . 

Alternative and more lucrative employment activities have led many owners of olive 

groves to abandon them. This trend has strengthened in the wake of the last CAP reform 

due to the complete decoupling of subsidies from production.”186 Many of these smallest 

olive farms do not make a profit even after support payments are received, so alternatives 

to olive growing are attractive.187

Despite Greece’s continued reliance on traditional growing methods on most of its olive 

farms, intensive plantings have increased in recent years.188 These new plantings are 

largely in Crete and the Peloponnese and are mostly Koroneiki olive trees, a variety that 

is well suited to intensive production where it can be employed. 189 While intensive 

plantings increased over the last five years, this is not expected to continue, as most of the 

land suitable for intensive production has already been converted.190

 

 179 Industry representative, telephone interview by USITC staff, April 19, 2013. 180 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 2. 181 Industry representative, telephone interview by USITC staff, April 19, 2013. 182 EC, “Economic Analysis of the Olive Sector,” July 2012, 2. 183 Ibid., 3. 184 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 2. 185 EC, “Economic Analysis of the Olive Sector,” July 2012, 2. 186 Vlontzos and Duquenne, “Greek Olive Oil,” 2008, 44. 187 Ibid. 188 EC, LIFE among the Olives, 2010, 10. 189 Ibid. 190 Industry representative, telephone interview by USITC staff, April 19, 2013. 
6-37 

Olive Oil Processing Sector 

Milling 

Greece has 2,200 mills in operation, a large number relative to its level of production,191

with a prevalence of small, local mills. Even in remote areas, olives are typically 

processed the day they are picked. Because it is processed soon after harvest, Greek oil is 

generally of high quality,192 but also high cost because many of the mills do not use the 

most efficient technology and cannot benefit from economies of scale. Many of the small 

mills serve traditional sales channels, with consumers buying olive oil directly from the 

mill. About 80 percent of mills in Greece use the three-phase milling process. There are 

also some traditional presses, and very few of the more modern two-phase mills.193

Farmers may sell their olives to mills either through cooperatives or through relationships 

with Greek bottlers, with the latter generally offering a better opportunity for farmers to 

sell into higher-value production chains. About 60 percent of Greek olive growers belong 

to cooperatives, which often focus on bulk sales rather than seeking higher-value market 

outlets. About 20 percent of Greek mills are owned by cooperatives; they dominate 

production only in the region of Crete.194 In order to sell their olives into higher-value 

production chains, some farmers enter into agreements with mills that also bottle and 

market Greek oil. For example, the largest olive oil producer in Crete sources 25 percent 

of its oil from its own groves, and relies on 800 local farmers for the remaining 

75 percent of its oil. The company aims to produce only high-quality extra virgin oil, so 

farmers are paid based on the quality of the olives, following testing performed at 

delivery.195 This generally results in a higher price for those farmers that meet the quality 

standard. 

Greek olive oil has a reputation for being of high quality, and extra virgin grade 

dominates production. Between 65 and 80 percent of production is extra virgin depending 

on the year’s crop,196 a share higher than in any other Mediterranean country. This is the 

result of excellent climate, olive varieties that yield particularly good oil, and the short 

time from harvest to milling.197 Within the extra virgin grade, Greek oil is known by 

bottlers and importers as high quality and very flavorful, and it is often used to raise the 

quality and flavor profile of blends. 

Bottling 

Despite industry fragmentation at the mill level, production downstream is highly 

concentrated; there are few firms marketing Greek oil for export and even fewer large 

bottling operations. Oil for export is rarely bottled in Greece, being mostly sold in bulk to 

the major global bottlers in Italy for use in their blends. Only about 20 percent of Greek 

production is bottled in Greece, while the rest is either exported in bulk or sold directly to 

consumers through local sales.198 There are about 350 firms that are licensed by the 

 191 EC, “Economic Analysis of the Olive Sector,” July 2012, 5. 192 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 2. 193 National Bank of Greece, “Olive Oil,” September 2011. 194 Industry representative, telephone interview by USITC staff, April 19, 2013. 195 Butler, “How Terra Creta Makes and Markets Olive Oil,” October 22, 2012. 196 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 3. 197 Industry representative, telephone interview by USITC staff, April 19, 2013. 198 National Bank of Greece, “Olive Oil,” September 2011.
6-38 

Greek government to pack olive oil for retail use; most of these are mills that have a 

small bottling line for local sales only.199

 

Consumption 

Greece consumed 212,500 mt of olive oil in MY 2011/12 (table 6.11). Consumption has 

been fairly stable since MY 2008/09 at just under 230,000 mt annually, but fell in 

MY 2011/12 and is forecast to fall even lower in MY 2012/13. The drop is likely due to 

both lower domestic production and the fall in consumer spending following the recent 

financial crisis in Greece. Decreasing purchasing power has led some consumers to 

substitute olive oil with lower-priced sunflower or soybean oil.200 Normally, however, 

because olive oil is a major staple in the Greek diet with historic and cultural 

significance, consumption is relatively insensitive to price and income changes.201

Almost all consumption is domestically produced, and direct sales from producers to 

consumers remain an important source of olive oil for many Greek households. About 

70 percent of olive oil is consumed on the farm or sold in non-branded, bulk packages to 

customers in the local community, while the remaining 30 percent is sold in retail 

packages.202 Some Greek consumers view oil purchased from local producers as assuring 

higher quality, but tests show these oils are often lower quality than those found on retail 

shelves. 203 Producers report that they often sell olive oil to local customers in bulk 

packages as large as 17 liters.204An advantage of these bulk sales is that they allow 

producers to avoid paying value-added tax (VAT). One study found that charging VAT 

on these olive oil sales would provide €65 million in additional revenue to the 

government.205

Trade 

Greece’s export pattern reveals both its dependence on bulk exports to Italy and its efforts 

to diversify away from reliance on this single export channel. Greece exported about 

128,000 mt of olive oil worth $416 million in 2012 (table 6.12). Italy was the major 

destination for Greek olive oil, accounting for 73 percent of the volume and 64 percent of 

the value that year. More than 80 percent of Greek olive oil exports are intra-EU, while 

major non-EU markets include the United States, China, Canada, and Russia. 

Although statistics for Greek olive oil exports do not separate bulk from bottled, unit 

values provide an indicator of the trade in each type. For example, between 2008 and 

2012, unit values for Greek exports to Italy were about $3,200 per mt on average, by far 

the lowest of all major destinations, and well below exports to non-EU countries, for 

which unit values were about $5,300 per mt. This suggests that exports to Italy are mostly 

shipped in bulk to be blended and bottled, while exports to non-EU destinations are likely 

in bottles. 

 199 Industry representative, telephone interview by USITC staff, April 19, 2013. 200 Vasilopoulos, “Production Up, Consumption Down in Greece,” December 1, 2012. 201 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 3. 202 Industry representative, telephone interview by USITC staff, April 19, 2013. 203 National Bank of Greece, “Olive Oil,” September 2011. 204 Tejada, “Greece’s Backroad ‘Bulk’ Olive Oil Trade,” April 23, 2012. 205 National Bank of Greece, “Olive Oil,” September 2011.
6-39 

TABLE 6.12 Greece: Exports of olive oil (HS 1509), 2008–12 

Country 2008 2009 2010 2011 2012

 Value (million $) 

Italy 245 200 160 232 268

Germany 30 24 28 37 37

United States 18 16 16 16 16

China 2 4 4 9 12

Canada 13 11 11 13 11

Russia 2 3 6 9 8

All other 75 68 57 63 65

 Total 385 325 283 379 416

 EU 27 326 267 219 303 338

Quantity (metric tons) 

Italy 61,187 64,126 53,898 75,952 93,578

Germany 5,751 4,500 5,712 12,921 8,653

United States 3,114 3,230 3,267 3,295 3,701

China 338 756 937 1,821 2,497

Canada 2,256 2,249 2,458 2,872 2,518

Russia 286 459 1,090 1,472 1,475

All other 13,881 16,660 12,375 13,789 16,005

 Total 86,813 91,980 79,737 112,123 128,427

 EU 27 76,918 80,459 66,628 97,190 112,057

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

The overall share of Greek olive oil production being exported to Italy has remained 

relatively stable on a volume basis at around 70 percent in most years.206 On a value 

basis, however, the share of Greek exports sent to Italy has declined in recent years. In 

the early and mid-2000s, this share was generally above 70 percent. Between 2008 and 

2012, however, this share declined to between 57 and 64 percent annually, suggesting 

that higher-value, most likely bottled, exports to other markets are becoming more 

important. For historical context, Greece’s number of export markets has more than 

doubled since the 1990s, and the share of bottled exports has grown from just under 

10 percent to over 20 percent.207 Taken together, the data suggest that while sales of oil in 

bulk to Italy have remained a consistently important outlet for Greek olive oil, Greece is 

making some progress in exporting higher-value product to other markets. For example, 

there are a few companies successfully bottling and marketing 100 percent Greek oil in 

export markets. Trader Joe’s and Colavita are among the major brands offering 

100 percent Greek oil in the U.S. market. Additionally, JCS Tradecom, Inc., reports 

success with its Zoe Diva Select Koroneiki Extra Virgin Olive Oil, which is 100 percent 

Koroneiki olive oil from Greece and won the 2008 Sofi Silver for outstanding shelf stable 

food service product from the Specialty Food Association.208 

Greece does not import substantial volumes of olive oil. Imports in 2012 were 1,318 mt, 

almost all from Italy and Spain. This small volume of imports is equal to less than 

1 percent of consumption. As noted above, demand is met almost exclusively through 

domestic production. 

 206 Vlontzos and Duquenne, “Greek Olive Oil,” 2008, 36; GTIS, Global Trade Atlas database (accessed 

June 19, 2013). 207 National Bank of Greece, “Olive Oil,” September 2011; industry representative, telephone interview 

by USITC staff, April 19, 2013. 208 USITC, hearing transcript, December 5, 2012, 132 (testimony of John Sessler, JCS Tradecom, Inc.).
6-40 

Factors Affecting Competitiveness 

High Cost of Production 

Greece has high costs of olive oil production, largely owing to its reliance on traditional, 

small-scale growing and milling methods. Several factors contribute to the high cost of 

producing olives. Greece has a prevalence of old groves with declining tree productivity 

and yields, resulting in high per-unit costs of production.209 Low yields are also attributed 

to a lack of irrigation in most of the country’s olive groves.210 Further, wage rates are 

high and rising even as rates of labor productivity remain low. Labor costs were 

identified by a Greek bank as a major limitation on Greece’s competitiveness in the olive 

oil industry. 211 Also, only about half of olive growers are considered professional 

farmers,212 and many operators rely on activities besides olive growing to supplement 

their income. Some only produce for personal consumption.213 Costs are also high in the 

milling sector, which, as noted earlier, is dominated by smaller mills using older 

technology, unable to benefit from economies of scale. 

High Quality 

Although production costs are high, Greece also enjoys a reputation for producing highquality olive oil. In a good year, as much as 80 percent of Greek olive oil meets the 

standard for extra virgin grade, the highest share in the Mediterranean.214 Even within the 

extra virgin category, Greek oils can be differentiated from others because they have 

desirable flavor profiles and score well on chemical tests measuring quality.215 This is 

partially because oil milled from Koroneiki olives tends to be the highest in polyphenol 

content and low in FFA among all olive oils.216 Greek oils are also considered among the 

fruitiest and most robust. As a result, they are in high demand by bottlers for blending 

with other extra virgin oils to raise the overall quality and increase the flavor of the final 

product. 217 As California growers who have planted Koroneiki explain, “Blending 

Koroneiki into our other EVOOs [extra virgin olive oils] ‘kicks up’ an oil’s flavor and 

fruitiness, giving the oil a better and more complex taste.”218 

Lack of Marketing and Reliance on Bulk Exports to Italy 

Despite producing mostly high-quality extra virgin oil, most Greek oil is exported in bulk 

for blending, rather than as single-source branded products.219 The Greek association of 

 209 Since the early 2000s, olive oil yields have declined slightly unlike in most other producing 

countries, where yields have increased. EC, “Olive Oil Farms Report,” February 2012, 74. 210 Vlontzos and Duquenne, “Greek Olive Oil,” 2008, 42. 211 National Bank of Greece, “Olive Oil,” September 2011. 212 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 2. 213 EC, “Economic Analysis of the Olive Sector,” July 2012, 2. 214 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 3. 215 Vlontzos and Duquenne, “Greek Olive Oil,” 2008, 33. 216 Militsa Olive Oil website, http://www.militsaoliveoil.com/koroneiki.html (accessed April 22, 2013). 217 Industry representative, interview by USITC staff, Washington, DC, April 9, 2013. 218 California Olive Ranch Web site, http://consumers.californiaoliveranch.com/2010/07/23/olive-oilprimer-a-look-at-the-koroneiki-olive/ (accessed April 22, 2013). 219 In addition, unit values of Greek olive oil exports are typically 15 to 25 percent higher than Spain’s, 

but about 20 percent lower than Italy’s. This reinforces the observation that Greek olive oil tends to be of 

higher grade and quality than Spanish oil, but also tends to be exported at bulk prices, unlike the mostly 

bottled Italian exports. 
6-41 

olive oil manufacturers attributes reliance on bulk sales to a lack of consumer awareness 

of the quality of Greek oil in overseas markets, owing to insufficient focus on consumer 

education and marketing on the part of Greek producers.220 As a result, at least 80 percent 

of exports are in bulk in a typical year.221 

Most bulk exports are to Italy and used in blends by bottlers, and as much as 20 percent 

of the content of oil blended and bottled in Italy may be of Greek origin.222 This sales 

channel dates back many years and is firmly entrenched. Because producers have few 

alternative marketing outlets, Italian buyers often procure Greek oil at prices below 

market value with cash. Longer-term contracts are rare, a source of frustration for one 

U.S. blender who had experience purchasing Greek oil.223 While farmer cooperatives in 

Greece have attempted to increase the market power of the farmers, they generally 

“perform poorly, leaving room for private buyers to pay lower prices to producers.”224 An 

analysis of the strengths and weaknesses of the sector in Greece concluded, “A 

progressive reduction in the dependence of Greek olive oil on bulk exports to Italy is the 

key to significant improvement in its international success and the basis for a 

differentiation strategy that will increase the export price that can be garnered for the 

product.”225 Though Greece has made some progress in reducing the share of its exports 

flowing through the established Italian channel, product differentiation remains a major 

challenge for the Greek industry. 

Government Programs 

The substantial share of farm income coming from CAP payments enables producers to 

operate at margins that may not be sustainable otherwise. According to the EC’s annual 

farm accounting survey,226 direct payments account for almost half of Greek olive oil 

producers’ income, depending on the year and the type of farm. This is slightly higher on 

average than in Spain and Italy. Many smaller producers have costs that are above 

average prices before support payments are included. 227 If CAP payments were 

eliminated, it is possible that land abandonment on Greek olive farms would become 

even more widespread. 

In addition, the Greek Ministry of Agriculture reportedly has historically implemented 

CAP programs to maximize the total level of support. Specifically, “the ministry gave 

priority to the expansion of arable crops based on readily available CAP subsidies. Olive 

trees were, as a result, planted in non-irrigated areas where sustainable production is 

problematic.”228 If government support is reduced or eliminated, olive growing may no 

longer be attractive in these marginal areas. 

Low olive farm incomes in Greece increase growers’ reliance on direct payments. 

Average olive farm income in Greece is $8,600 (compared with $15,000 in Spain and 

Italy) and has fallen since 2005.229 About 30 percent of Greek olive farms—generally 

 220 Tejada Benekos, “Panagiotis Karantonis: Greek Olive Oil Must Build on Quality,” January 30, 2011. 221 USDA, FAS, Greece Olive Oil 2012, May 10, 2012, 3. 222 Kouparanis, “No Greek Olive Oil in German Supermarkets,” November 13, 2012. 223 Industry representative, interview by USITC staff, Washington, DC, April 9, 2013; Kouparanis, “No 

Greek Olive Oil in German Supermarkets,” November 13, 2012. 224 Vlontzos and Duquenne, “Greek Olive Oil,” 2008, 42. 225 Ibid., 44. 226 EC, “Olive Oil Farms Report,” February 2012, 8. 227 Ibid., 35. 228 Vlontzos and Duquenne, “Greek Olive Oil,” 2008, 34. 229 EC, “Olive Oil Farms Report,” February 2012, 8.
6-42 

those that are very small—are not profitable even with support from direct payments. An 

additional 50 percent are profitable when direct payments are included, leaving just 

20 percent of Greek olive farms profitable without assistance from government 

programs.230

Greece’s rural development plan is also an important source of funding for the olive oil 

sector. As described above, rural development plans are proposed and co-funded by the 

member states. Unlike Spain and Italy, which contribute at least 50 percent of the funding 

for their plans, Greece is only expected to contribute 15 percent (and for some Greek 

proposals, as little as 5 percent, due to an exemption that was granted in the wake of 

Greece’s financial crisis).231 While the programs are open to any agricultural industry, 

olive oil is a key beneficiary due to its importance in the Greek economy. In the 2007–

2013 rural development plan for Greece, the measures most relevant to olive oil include 

those to improve quality and to promote organic products. The quality improvement 

measures provide funding for organic production, and promotion measures fund 

television, radio, Internet, and print campaigns, as well as product exhibitions, for 

marketing organic Greek olive oil within the EU.232 

 

 230 National Bank of Greece, “Olive Oil,” September 2011. 231 EC, “Commission Welcomes the Top Up of Co-financing Rates,” December 1, 2011. 232 EC official, interview by USITC staff, Brussels, Belgium, February 27, 2013.
6-43 

Bibliography 

Acs, Szvetlana, Nick Hanley, Martin Dallimer, Kevin J. Gaston, Philip Robertson, Paul Wilson, and Paul 

R. Armsworth. “The Effect of Decoupling on Marginal Agricultural Systems: Implications for 

Farm Incomes, Land Use and Upland Ecology.” Land Use Policy 27, issue 2 (April 2010): 550–

563.AEMO. See Spanish Association of Olive Municipalities. 

Baker, Tom. “Spain Pulls Ahead in Olive Oil Sales to China.” Olive Oil Times, March 22, 2011. 

http://www.oliveoiltimes.com/olive-oil-business/asia/spain-leads-olive-oil-sales-to-china/14091. 

Bremner, Charles. “EU Gives In to North’s Mockery.” Times (London), May 24, 2013. 

http://www.thetimes.co.uk/tto/news/world/europe/article3773002.ece?CMP=OTH-gnwsstandard-2013_05_23 (subscription required). 

Bungaro, Michele. “Olio: le novità introdotte dalla nuova legge anti contraffazione dell’olio dell’extra 

vergine di olive.” [Oil: New law combating counterfeiting of extra virgin olive oil introduces 

innovation.] Agronotizie, n.d. http://agronotizie.imagelinenetwork.com/materiali/Varie/File/LASCHEDA-della-nuova-legge-def-.pdf (accessed May 1, 2013). 

Butler, Julie. “Adulteration Risk As Olive Oil Gains Ground in China.” Olive Oil Times, May 14, 2012. 

http://www.oliveoiltimes.com/olive-oil-basics/world/olive-oil-adulteration-china/26554. 

———. “EU Likely to Increase Private Storage Aid Trigger Prices.” Olive Oil Times, January 7, 2013. 

http://www.oliveoiltimes.com/olive-oil-business/europe/private-storage-aid-trigger-prices/32065. 

———. “EU Offers Olive Oil Storage Aid amid Tumbling Prices.” Olive Oil Times, February 8, 2012. 

http://www.oliveoiltimes.com/olive-oil-business/europe/eu-storage-aid-olive-oil-prices/24645. 

———. “European Parliament Provides Some Comfort for Spanish Olive Oil.” Olive Oil Times, March 

18, 2013. http://www.oliveoiltimes.com/olive-oil-business/europe-provides-some-comfort-forspanish-olive-oil/33402. 

———. “How Terra Creta Makes and Markets Olive Oil.” Olive Oil Times, October 22, 2012. 

http://www.oliveoiltimes.com/olive-oil-basics/terra-creta-olive-oil-crete/29730. 

———. “Olive Regions Work on Joint Strategy to Maintain EU Subsidies.” Olive Oil Times, April 2, 

2012. http://www.oliveoiltimes.com/olive-oil-business/europe/olive-regions-joint-strategy-eusubsidies/25672. 

De Graaff, Jan, Aad Kessler, and Filomena Duarte. “Financial Consequences of Cross-Compliance and 

Flat-rate-per-ha Subsidies.” Land Use Policy 28, issue 2 (2011): 388–94. 

European Commission (EC). Directorate-General for Agriculture and Rural Development. “Economic 

Analysis of the Olive Sector,” July 2012. http://ec.europa.eu/agriculture/olive-oil/economicanalysis_en.pdf. 

———. “Action Plan for the EU Olive Oil Sector.” DG Agri Working Paper, n.d. (accessed June 18, 

2013) http://ec.europa.eu/agriculture/olive-oil/action-plan_en.pdf. 

———. Directorate-General for Agriculture and Rural Development. “Olive Oil Farms Report,” February 

2012. http://ec.europa.eu/agriculture/rica/pdf/Olive_oil%20_report2000_2010.pdf. 
6-44 

———. Environment Directorate-General. LIFE among the Olives, 2010. 

http://ec.europa.eu/environment/life/publications/lifepublications/lifefocus/documents/oliveoil.pd

f. 

———. “Rural Development Policy 2007–2013,” http://ec.europa.eu/agriculture/rurdev (accessed May 8, 

2013). 

———. “Scientific Workshop on Olive Oil Authentication (Madrid, 10-11 June 2013).” News release, 

n.d. 

European Parliament. The Single Payment Scheme after 2013: New Approach—New Targets, 2010. 

http://www.luhan.ro/docs/The%20single%20payment%20scheme%20after%202013.pdf. 

European Union (EU). “Section III: Commission.” Statement of Revenue and Expenditure by Section, 

February 29, 2012. 

Fontanazza, G. “Importance of Olive Oil Production in Italy.” In Integrated Soil and Water Management 

for Orchard Development, ed. José Benites, 13–20. Rome: Food and Agriculture Organization of 

the United Nations, 2005. 

Gázquez-Abad, Juan C., and Manuel Sánchez-Pérez. “Factors Influencing Olive Oil Brand Choice in 

Spain.” Agribusiness 25, issue 1 (2009): 36–55. 

Global Trade Information Service, Inc. (GTIS). Global Trade Atlas database (accessed various dates). 

http://www.gtis.com/english/GTIS_GTA.html (fee required). 

Government of Italy. Ministry of Agriculture. “Piano Olivicolo-Oleario” [Olive and olive oil plan], 

April 2010. http://www.politicheagricole.it/flex/cm/pages/ServeBLOB.php/L/IT/IDPagina/1984. 

Government of Spain. Junta de Andalucía. Programa de Desarrollo Rural de Andalucía 2007–2013 

[Andalusia rural development program 2007–13], versión 7, n.d. (accessed May 16, 2013). 

Government of Spain. Ministry of Agriculture, Food, and Natural Environment, Olive Oil Agency, 

“Aceite de Oliva: Producción” [Olive oil: Production], (accessed June 18, 2013). 

http://aplicaciones.magrama.es/pwAgenciaAO/InfMercadosAceite.aao?dato_de=PRODUCCION&

opcion_seleccionada=4120&control_acceso=S&idioma=ESP. 

———. Ministry of Agriculture, Food, and the Environment. “Arias Cañete subraya ‘el 

fracaso de las negociaciones del Gobierno socialista sobre el sector del aceite.’” [“Arias Cañete 

emphasizes ‘the failure of the Socialist government’s oil sector negotiations.’”] February 22, 2012. 

http://www.magrama.gob.es/es/prensa/ultimas-noticias/notas-de-prensa-din.aspx?tcm=tcm:7-

194462-16 (accessed June 19, 2013). 

———. Observatorio de Precios de los Alimentos (MARM). “The Value Chain and Price Formation in 

the Spanish Olive Oil Sector,” January 2010.

http://www.internationaloliveoil.org/documents/viewfile/4406-the-olive-oil-value-chain. 

International Olive Council (IOC). “Tables 1–4: [EU] Production, Imports, Exports, Consumption.” 

World Olive Oil Figures, November 2012. 

http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures. 

Kouparanis, Panagiotis. “No Greek Olive Oil in German Supermarkets.” DW, November 13, 2012. 

http://www.dw.de/no-greek-olive-oil-in-german-supermarkets/a-16374878. 
6-45 

Montegut, Yolanda, Eduard Cristóbal, and Frederic Marimon. “The Singularity of Agrarian Cooperatives 

Management.” International Journal of Business and Management 6, no. 6 (November 2010). 

http://www.ccsenet.org/journal/index.php/ijbm/article/view/10806. 

National Bank of Greece. “Olive Oil: Improving Quality through Consolidation and Standardization” [in 

Greek], September 2011. 

Roselli, Luigi, Bernardo DeGennaro, Orlando Cimino, and Umberto Medicamento. “The Effects of the 

Health Check of the Common Agricultural Policy on Italian Olive Tree Farming.” New Medit 8, 

no. 2 (June 2009): 4–13. http://newmedit.iamb.it/edizioni_new_medit,229,229,2009,86,251,theeffects-of-the-health-check-of-the-common-agricultural-policy-on-italian-olive-tree-farming.htm. 

Royal Spanish Academy of Gastronomy, “Olive Oils in 21st Century Gastronomy,” 2010. 

Spanish Association of Olive Municipalities (AEMO). “Aproximación a los Costes del Cultivo del 

Olivo.” [Approximation of the costs of olive cultivation]. Presentation prepared for AEMO 

seminar, June 2010. 

Tejada, Marissa. “Greece’s Backroad ‘Bulk’ Olive Oil Trade.” Olive Oil Times, April 23, 2012. 

http://www.oliveoiltimes.com/olive-oil-basics/rural-greece-olive-oil-trade/26246. 

Tejada Benekos, Marissa. “Panagiotis Karantonis: Greek Olive Oil Must Build On Quality.” Olive Oil 

Times, January 30, 2011. http://www.oliveoiltimes.com/features/esvite-greek-olive-oilassociation/11977. 

U.S. Department of Agriculture (USDA). Foreign Agricultural Service (FAS). Greece Olive Oil 2012, by 

Ornella Bettini. GAIN Report no. GR1203, May 10, 2012. 

———. Italy: Olive Oil Update, by Cyndi Barmore. GAIN Report no. IT1028, July 6, 2010. 

U.S. International Trade Commission (USITC). Hearing transcript in connection with inv. no. 332-537, 

Olive Oil: Conditions of Competition between U.S. and Major Foreign Supplier Industries, 

December 20, 2012. 

Vasilopoulos, Costas. “Production Up, Consumption Down in Greece.” Olive Oil Times, December 1, 

2012. http://www.oliveoiltimes.com/olive-oil-business/europe/less-olive-oil-consumption-ingreece/31081. 

Vlontzos, George N., and Marie-Noelle Duquenne. “Greek Olive Oil: How Can Its International Market 

Potential Be Realized?” Estey Centre Journal of International Law and Trade Policy 9, issue 2 

(2008): 32–47. 

Williams, Daniel. “In Italy, Spanish Olive Oil Prices Too Good to Pass Up.” Olive Oil Times, 

September 28, 2010. http://www.oliveoiltimes.com/olive-oil-business/europe/spanish-olive-oilexports-italy/7106. 

World Trade Organization (WTO), “Mexico—Definitive Countervailing Measures on Olive Oil from the 

European Communities,” WT/DS341/R, September 4, 2008. 

7-1

CHAPTER 7 

North Africa 

Overview 

North Africa is the world’s largest olive oil-producing region outside the European Union 

(EU). Within the region, Tunisia and Morocco are by far the most important, ranking 

sixth and seventh among leading global producers in marketing year (MY) 2011/12.1

 

Together they accounted for almost 10 percent of global production and a quarter of 

global exports over the last five years.2 Algeria, Egypt, and Libya also produce and 

export olive oil, but on a minor scale; during MY 2006/07–2011/12, together these three 

countries accounted for 2 percent of global production and less than 0.3 percent of 

exports. 

Both the proximity of North Africa to southern Europe and minimal trade barriers in the 

EU for North African exports have resulted in close market integration between olive 

producers in Tunisia and Morocco and large bottlers in Italy and Spain. However, 

because of differences in olive oil consumption patterns, Tunisia and Morocco pursue 

different approaches to supplying retail customers in Europe and the United States. In 

Tunisia, only about 20 percent of production is consumed domestically, freeing up large 

export volumes that are mostly blended with other olive oil by Italian bottlers and sold 

under Italian brand names in the United States or Italy. In contrast, much of the olive oil 

produced in Morocco is consumed domestically, leaving relatively little for export. 

Moroccan olive oil exports are mostly shipped either to the United States under a free 

trade arrangement or to bottlers in Spain and Italy. 

Tunisia and Morocco produce most of their olive oil using traditional methods of olive 

growing and milling. 3 However, the adoption of newer production and processing 

technology is on the rise, especially in Tunisia, and an increasing share of the olive oil 

output from both these countries is produced by modern mills. Olive oil from modern 

mills is more likely to enter the export market, while oil produced by traditional mills is 

consumed domestically. In both Tunisia and Morocco, some modern mills are vertically 

integrated with olive growers using super-high-density (SHD) plantings. 

Tunisia and Morocco have different competitive strengths and weaknesses. While both 

struggle somewhat in attempting to differentiate their product, Morocco has seen more 

success in diversifying its export markets than Tunisia, which relies heavily on the EU. 

The two countries differ greatly on the grade and quality of their oil. Only 35 percent of 

 1

 Countries with more production that year were Spain, Italy, Greece, Syria, and Turkey. IOC, “Table 1 

[World] Production,” November 2012. 2

 IOC, “Table 3: [World] Exports,” November 2012. Data do not include intra-EU trade. 3

 Many traditional mills (called maasras in Morocco) are patterned after those introduced by the 

Romans. Millers use large millstones to grind olives into paste, which is then spread on fiber disks. The disks 

are stacked on top of one another and then pressed. Oil is forced out along with water. Water may be added in 

order to speed the extraction of the oil. After pressing, the water is separated by decantation, skimming the oil, 

which is less dense, off the water. 
7-2

Morocco’s oil meets the standards for extra virgin, versus about 65 percent of Tunisia’s 

oil. However, of the extra virgin oil each country produces, Morocco’s tends to be more 

flavorful and generally of a higher quality. Tunisia’s extra virgin oil is usually considered 

more neutral-flavored and ideal for blending. In addition to the grade and quality 

differences, Tunisia is a lower-cost producer because of its low input and labor costs. 

Tunisia 

Overview 

Olive oil is an important sector in Tunisia’s agricultural economy. Growing and 

processing olives and olive oil employs approximately 1 million people, over half of all 

farm employment.4

 Olives and olive oil production account for about 15 percent of the 

value of total agricultural production and half the value of agricultural exports.5

 Olive oil 

is the country’s largest agricultural source of foreign currency and the fifth largest for the 

economy as a whole.6

 Tunisia’s olive oil sector accounts for 20 percent of the world’s 

total land area planted with olive trees, though it supplies only 6 percent of global oil 

production.7

Tunisia’s olive oil sector is diverse, encompassing a range of farm sizes and milling 

technologies. There are several thousand growers, a large numbers of millers, relatively 

few bottlers, and a growing number of exporters.8

 There is little vertical integration along 

the supply chain, although a few bottling firms also own mills and groves.9

 

Tunisia produces mostly neutrally flavored extra virgin olive oil and exports oil mostly in 

bulk for blending in the EU. The production of lower-quality oil is a result of cultivation 

practices and insufficient quality control along a fragmented supply chain. While 

Tunisian olive oil quality is improving because of increasing efficiency throughout the 

supply chain, the majority of oil is considered to be lower-quality and neutrally flavored, 

even when the oil has chemical traits that test within the bounds of the extra virgin grade. 

And although the close commercial ties to the EU benefit Tunisia because they provide a 

readily available market to absorb its large supply, the continually open market means 

that Tunisian producers have less incentive to improve quality. It also means that the 

producers are missing out on potentially more profitable marketing outlet opportunities 

by not bottling and branding their own high-quality oil. 

The first half of this section will provide a profile of Tunisia’s olive growing and 

processing industry, as well as discuss trends in both domestic consumption and 

Tunisia’s role in global trade. The second half will focus on the major factors affecting 

Tunisia’s global competitiveness and position in the world market. The main factors that 

diminish Tunisia’s competitiveness include its reliance on the bulk market, lower-quality 

extra virgin oil as a result of cultivation practices and a fragmented supply chain, a lack 

 4

 Tunisian Olive Oil, “Olive Growing in Tunisia” (accessed January 9, 2013). 5

 Ibid. 

6

 Ibid 

7

 IOC, Tunisia 2012, n.d., 1–10 (accessed May 6, 2013). 8

 As of 2012, there were over 300,000 growers, 1,700 mills, 25 operational packaging plants, and over 

150 exporters. Tunisian Olive Oil, “Olive Growing in Tunisia” (accessed January 9, 2013). 9

 Industry representative, telephone interview by USITC staff, March 1, 2013. 
7-3

of product differentiation, and a lack of access to credit. The factors increasing Tunisia’s 

competitiveness include proximity to the EU, supportive government programs, and a 

low cost of production. 

Production Profile 

Production Overview 

Tunisia is the world’s sixth-largest olive oil-producing country and the third largest 

outside the EU. Between MY 2007/08 and MY 2010/11, production steadily trended 

down from 170,000 metric tons (mt) to 120,000 mt, although it rebounded in 

MY 2011/12 and is projected to reach a record high of 220,000 tons in MY 2012/13 

(table 7.1).10 Production varies significantly from year to year owing to both the alternate 

annual fruit-bearing pattern of olive trees and weather fluctuations. Although production 

averages have slightly declined over the period, Tunisia remains one of the largest olive 

oil-producing countries in the world. 

TABLE 7.1 Tunisia: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt) 

 2000/01 2007/08 2008/09 2009/10 2010/11 a

2011/12 b2012/13

Production 130.0 170.0 160.0 150.0 120.0 180.0 220.0

Imports 0 0 0 0 0 0 0

Consumption 58.0 50.0 21.0 30.0 30.0 40.0 40.0

Exports 85.0 130.0 142.0 97.0 108.0 140.0 60.0

Source: IOC, “Tables 1–4: [World] Production, Imports, Exports, Consumption,” November 2012. 

Note: A marketing year spans October 1 to September 30 the following year. 

a

Provisional. 

b

Projected. 

Although olive production varies from year to year, planted area has increased steadily in 

recent years. Planted area, which was 1.63 million hectares (ha) in 2003, is projected to 

reach 1.85 million ha by 2014, equal to a third of all arable land in Tunisia.11 Yields vary 

significantly by region, planting density, and year, but typically range between about 500 

and 900 kilograms (kg) of olives per ha on traditional, low-density groves.12 Annual 

fluctuations in yield and production weaken Tunisia’s ability to supply a consistent 

amount of oil to Europe and other markets. Despite this, Tunisia is an important link in 

the European supply chain, delivering largely mild-flavored, lower-priced, lower-quality 

extra virgin oil to Italian bottling operations for blending with higher-quality, fullerflavored olive oils. 

Olive-Growing Sector 

Tunisia’s olive-growing sector is characterized by large numbers of small, older groves. 

In 2013, there were over 300,000 farms with olive groves, of which about 85 percent had 

 10 IOC, Tunisia 2012, n.d., 2–10 (accessed May 6, 2013). 11 Government of Tunisia, “Tunisian Olive Oil,” data sheet provided to USITC staff, January 17, 2013. 12 Table olives can see yields of 1,400 kg per hectare in Tunisia. Tunisian Olive Oil, “Olive Growing in 

Tunisia” (accessed January 9, 2013). 
7-4

less than 5 ha.13 On average, the cropping density in Tunisia is about 60 trees planted per 

ha, although in areas with ready access to consistent water supplies, densities range 

between 100 and 150 trees per ha.14 However, only around 4 percent of all olive groves 

are irrigated.15 Some of the newer groves are planted more intensively, and there were 

over 2,000 ha of SHD plantings in Tunisia in 2005. While SHD plantings have increased 

since 2005, total SHD area is still only around 3,500 ha, or under 5 percent of all olive 

groves.16

Olive groves are widespread throughout all regions of Tunisia, with about 46 percent 

located in the center, 32 percent in the north, and 22 percent in the south.17 Typically, 

olive trees in the north and center are often mixed with other agricultural activities on the 

same farm, while in the south they tend to be the only crop planted because the arid 

climate and lack of irrigation are not conducive to growing other products. Planting 

density is positively correlated with regional rainfall. In the North, which receives the 

most rain, planting densities average about 100 trees per ha, while in the South, the 

country’s driest region, densities are only 17–20 trees per ha. Planting densities in the 

Center are around 50–60 trees per ha.18 

While many olive varieties are grown in Tunisia, two varieties predominate. The 

Chemlali de Sfax variety accounts for the vast majority of olive area.19 This variety is 

preferred because it requires little water and matures later than other varieties, so it can be 

harvested as late as early spring. Chemlali de Sfax has medium to high oil content and is 

used in the production of table olives as well as for processing into oil.20 To produce table 

olives, groves must have adequate access to water, and input costs are higher than for 

groves producing olives for oil. As a result, there is little integration between the olive oil 

and table olive sectors and limited direct competition between them. The Chemlali 

variety generally has a mild taste, lacking pungency and bitterness 21 and therefore 

desirable for blending with the stronger-flavored oils found in many other producing 

countries.22 The other main olive variety is Chetoui, commonly planted in the NorthCoastal area and accounting for about 15 percent of Tunisia’s olive groves.23 

Tunisia’s warm climate allows harvesting to take place from late fall to early spring, a 

much longer window than in most EU countries. However, most harvesting occurs late in 

the season, even into March. Because farmers are paid based on oil quantity, rather than 

 13 Tunisian Olive Oil, “Olive Growing in Tunisia” (accessed January 9, 2013). 14 IOC, Tunisia 2012, n.d., 5–10 (accessed May 6, 2013). 15 Tunisian government official, email to USITC staff, August 1, 2013. 16 Tunisian government official, email to USITC staff, August 1, 2013; industry representative, 

telephone interview by USITC staff, April 29, 2013. 17 IOC, Tunisia 2012, n.d., 5–10 (accessed May 6, 2013). 18 Ibid. 

19 Estimates of the prevalence of the Chemlali variety vary among sources, but are generally reported to 

represent between 60 and 85 percent of olive area, and around 80 percent of domestic olive oil production. 

While the flavor characteristics of all varieties change dependent on soil and climate conditions, the IOC 

reports that Chemlali olives are generally not bitter or pungent. IOC, Tunisia 2012, n.d., 6–10 (accessed 

May 6, 2013). 20 IOC, Tunisia 2012, n.d., 6–10 (accessed May 6, 2013). 21 Ibid. 

22 Industry representative, telephone interview by USITC staff, March 21, 2013; industry 

representatives, interview by USITC staff, Tuscany, Italy, January 30, 2013. 23 IOC, Tunisia 2012, n.d., 6–10 (accessed May 6, 2013). The Chetoui variety is used mainly for 

processing into oil, although it has relatively low oil content and requires more water. Chetoui olives are 

known for their high phenolic compound content and presence of other antioxidants. IOC, “Tunisia 

Indicators,” n.d., 3 (accessed May 6, 2013). 
7-5

quality, and because the oil content of the fruit increases the longer it is left on the tree, 

there is an incentive to harvest late in the season. As an illustration of this, Tunisian 

olives yield an average of 20 percent oil when milled, while averages span from 14–

16 percent in premium SHD producing areas of California. 24 Also, olives that are 

harvested in late winter and early spring produce a neutrally flavored oil desired by the 

major European buyers of Tunisian olive oil because it is good for blending with other 

olive oils. 

Olive Oil Processing Sector 

In addition to a small number of bottlers, Tunisia’s processing sector consists of a large 

number of mills differing by level of vertical integration, scale, and efficiency.25 In 2012, 

over 1,700 olive oil mills were in operation, with a crushing capacity of 43,680 mt of 

olives per day. Of these, about 1,000 were traditional or press mills,26 while 757 were 

more modern continuous-process mills.27 A traditional crushing facility in Tunisia can 

typically mill between 15 and 20 mt of olives per day, compared with 40 to over 100 mt 

at modern mills.28 While mills still using traditional practices slightly outnumber those 

using newer technology, both the number and milling share of modern operations is 

growing over time.29 Larger-capacity, modern mills account for less half of all mills, but 

are responsible for about 80 percent of production.30 Because of the larger capacity and 

faster milling times, the modernization of the milling sector allows Tunisia to produce a 

growing volume of higher-quality oil.31 

Olive oil processing is dispersed widely throughout the country, although Sfax in the 

Center operates as a general hub. Several mills and most exporters are in Sfax, which is 

also the site of one of the country’s largest ports. Approximately 33 percent of mills are 

located in Sfax, 28 percent in the Sahel region,32 18 percent in the North,33 15 percent in 

the Center and Southwest,34 and 6 percent in the Southeast (figure 7.1).35 Many of the 

olives produced in the North and South are transported to the Center for processing, and 

time in transit can lead to fruit degradation, potentially diminishing quality along the 

way. 

 24 UCCE, Sample Costs: Sacramento Valley, 2007, 6–7; UCCE, Sample Costs: San Joaquin Valley, 

2007, 7; industry representatives, interviews by USITC staff, California, November 13–15, 2013. 25 As of 2012, Tunisia had only a dozen bottling plants that specialize only in olive oil packing. In 

addition, there were 10 pomace extraction facilities. ONH, “Production,” (Accessed March 27, 2013). 26 While the definition of traditional milling varies, generally it means that instead of employing a press 

or a decanter centrifuge, the miller uses a large stone to crush the olives and then uses water to extract the oil. 27 IOC, Tunisia 2012, n.d., 7–10 (accessed May 6, 2013). While it appears that the number of 

traditional mills is larger, many of these have halted milling and are no longer operational. Industry 

representative, telephone interview by USITC staff, April 29, 2013. 28 Industry representative, telephone interview by USITC staff, March 21, 2013. 29 Ibid. 

30 Industry representative, telephone interview by USITC staff, April 29, 2013. 31 Tunisian government official, email to USITC staff, August 1, 2013. 32 The Sahel region includes Sousse, Monastir, and Mahdia. 33 The North includes Tunis, Manouba, Ariana, Ben Arous, Bizerte, Beja, Jendouba, Le Kef, Siliana, 

Zaghouan, and Nabeul. 34 The Center and Southwest includes Kairouan, Kasserine, Gafsa, and Sidi Bouzid. 35 The Southeast includes Mednime, Gabès, and Tatouine. 
7-6

FIGURE 7.1 Tunisia: Share of olive oil milling by region 

Source: Compiled by USITC staff, using data from the International Olive Council. 

Olive oil processing in Tunisia occurs in two distinct supply chains, though both use 

traditional as well as modern milling techniques. The first supply chain is fragmented: it 

consists of smaller, more traditional mills that buy olives from local farms, process them 

into oil, and sell the resulting product to either domestic bottling facilities or directly to 

an exporter. The majority of Tunisian producers and mills operate in this disjointed 

supply chain, with little vertical integration between production and processing.36 This 

has led to the emergence of middlemen, who travel from farm to farm collecting 

harvested olives and bringing them swiftly to mills to limit degradation time. Although 

the middlemen’s activity creates employment for Tunisians and reduces the time 

 36 Industry representative, telephone interview by USITC staff, March 1, 2013. 
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harvested olives sit before transit to mills, it increases costs and lowers profit margins for 

both growers and millers.37 

The second supply chain comprises between 5 and 10 larger, vertically integrated 

companies that own groves, mills, and occasionally bottling operations. These operations 

also supplement their own supply by contracting both olives and olive oil from 

independent farms and mills. These integrated firms typically brand their products and 

export directly to buyers overseas. While many of these companies own modern mills, 

some employ historical techniques, such as crushing stones, and use their traditional 

practices as a marketing tool. With the adoption of better production methods and 

processing techniques in both supply chains, the quality of Tunisian olive oil has 

improved, and production of extra virgin oil has risen. According to an International 

Olive Council (IOC) survey, an average of 65 percent of Tunisian production is classified 

as extra virgin, while 15 percent is virgin and 20 percent is lampante.38

Consumption 

Tunisian domestic consumption of olive oil is low in comparison with its production. 

Tunisia’s small population and reliance on other edible oils explain its low domestic 

consumption. Per capita consumption is about 4 to 5 liters annually (significantly below 

most European countries, though well above the United States), and therefore domestic 

consumption typically absorbs only 20 to 30 percent of annual production.39 This is partly 

due to the fact that the primary distribution outlets for Tunisian producers are export 

markets, leaving smaller volumes available for domestic consumption. 40 Tunisian 

domestic olive oil consumption varied significantly from year to year between 

MY 2007/08 and MY 2011/12, ranging between 21,000 mt and 50,000 mt (table 7.1).41

While global prices are important, this variability is driven mostly by changes in 

production, with consumption determined by what remains in the domestic market after 

export demand has been met. Many consumers purchase their oil directly from mills, 

carrying empty jugs to fill straight off the production line,42 and, like most food purchases 

in Tunisia, only a small share of domestic consumption passes through retail grocery 

outlets.43 

Tunisia’s edible oil consumption mainly consists of refined oils, such as corn and 

soybean oil; only one-third of total edible oil consumed is olive oil.44 This is partly 

because of a history of government policies aimed at suppressing olive oil consumption. 

For example, until 1993, the government set family quotas on purchases of olive oil, in 

accordance with its strategy of importing large amounts of cheaper edible oils to supply 

domestic consumption, while exporting higher-valued olive oil to gain foreign currency. 

This approach created a legacy of low demand for olive oil compared with other edible 

oils.45

Domestic olive oil consumption is not expected to rise in the future because of two 

important constraints. The first constraint is the legacy of historical Tunisian culinary 

 37 Industry representative, telephone interview by USITC staff, March 21, 2013. 38 IOC, Tunisia 2012, n.d., 7–10 (accessed May 6, 2013). 39 Consumption data were sourced from IOC, “Table 4: [World] and [EU] Consumption,” November 

2012; population data were sourced from the Food and Agriculture Organization database. 40 IOC, “Table 1 and 3: [World] Production and Exports,” November 2012. 41 IOC, “Table 4: [World] Consumption,” November 2012. 42 Industry representative, telephone interview by USITC staff, February 5, 2013. 43 USDA, FAS, Tunisia: Retail Foods, December 19, 2012, 2. 44 USDA, FAS, Tunisia: Oilseeds and Products Annual, March 1, 2013, 5. 45 McEvoy and Gomez, The Olive Industry, August 1999, 21. 
7-8

habits: olive oil is unlikely to become a mainstay of the national diet as is the case in 

some European countries, and instead Tunisians likely will continue to consume a 

significant amount of other seed oils, such as soybean oil.46 Second, continued low per 

capita income and high relative prices mean that high-quality olive oil likely will remain 

unaffordable for many. 

Trade 

Tunisia’s global exports, and especially exports to the EU, fell during 2008–11 

(table 7.2). This contraction followed a drop in Tunisian production, coupled with weaker 

export demand. Spain and Tunisia compete to supply bulk oil to Italy, and the Spanish 

bumper olive crops in 2010 and 2011 flooded the market with Spanish oil at historically 

low prices, making Spain a more attractive source of supply than Tunisia.47 The situation 

has reversed as Tunisian production increased in MY 2011/12 and MY 2012/13 and as 

drought struck Spain in 2012, resulting in renewed demand from Italy, Spain, and the 

United States. 

The EU is the largest market for mostly bulk Tunisian olive oil, taking about two-thirds 

of Tunisia’s exports during 2008–12. Italy is consistently Tunisia’s largest overseas 

market and in 2012 accounted for 54 percent of its exports (76,000 mt). Other major EU 

destinations are Spain (9 percent, 13,000 mt) and France (4 percent, 6,000 mt).48 Between 

2008 and 2012, on average, Tunisia supplied 88 percent of Italy’s extra-EU olive oil 

imports (by value), 72 percent of Spain’s, and 94 percent of France’s.49 In addition to 

geographic proximity, Tunisia benefits from duty-free access to the EU market under a 

tariff-rate quota (more details appear later in this chapter). 

Tunisia has expanded its exports into non-EU markets in recent years, including to the 

United States, China, and some Middle Eastern countries. Since 2000, U.S. imports of 

Tunisian olive oil have increased almost 10-fold, from 4,656 mt (less than $10 million) in 

2000 to almost 40,000 mt ($100 million) in 2012.50 Of these imports, 80–90 percent were 

shipped in bulk and 10–20 percent in bottles.51 The United States accounts for about onequarter of Tunisia’s olive oil exports, while Tunisia is responsible for approximately 

13 percent of U.S. olive oil imports by volume.52 Due to its proximity, Tunisia also 

exports olive oil to other North African and Middle Eastern countries. For example, as 

Moroccan domestic consumption is larger than Tunisian consumption, Tunisia exports 

olive oil to Morocco when Moroccan production cannot fully supply demand, such as in 

2009. China, with rising incomes and greater awareness of the health benefits of olive oil, 

has also increased its purchases of Tunisian oil in recent years.53

 46 USDA, PSD Online (accessed March 29, 2013). 

47 Williams, “In Italy, Spanish Olive Oil Prices Too Good,” n.d. (accessed May 3, 2013). 

48 European Commission, Eurostat database (accessed April 26, 2013). 49 GTIS, Global Trade Atlas database (accessed June 19, 2013). 50 Ibid. 

51 GTIS, Global Trade Atlas database (accessed June 19, 2013). Tunisian olive oil is eligible to be 

imported into the United States duty free under the Generalized System of Preferences (GSP). 52 GTIS, Global Trade Atlas database (accessed June 19, 2013). 53 Ibid.
7-9

TABLE 7.2 Tunisia: Exports of olive oil (HS 1509), 2008–12a

Country 2008 2009 2010 2011 2012 

Value (million $) 

Italy 377 197 146 112 178 

USA 97 97 81 74 101 

Spain 123 25 24 27 29 

France 17 15 17 20 18 

Canada 5 7 8 9 6 

China 0 0 1 2 4 

Russia 4 3 2 4 2 

Lebanon 1 4 3 2 1 

Switzerland 0 0 0 0 1 

Morocco 14 28 0 4 1 

Belgium 0 1 3 3 1 

Japan 0 0 0 0 0 

All other 9 22 21 14 2 

 Total 645 398 307 270 344 

 EU-27 517 239 193 162 225 

Quantity (metric tons) 

Italy 98,232 71,302 52,125 40,974 76,043 

USA 25,436 34,769 26,484 24,116 39,630 

Spain 33,472 8,930 8,547 9,676 12,640 

France 4,073 4,336 5,370 5,866 5,963 

Canada 1,253 1,933 2,223 2,870 1,967 

China 44 81 384 455 1,396 

Russia 1,035 1,069 937 1,608 939 

Lebanon 0 1,311 954 566 548 

Switzerland 0 37 25 113 220 

Morocco 3,635 10,351 15 1,946 252 

Belgium 19 347 1,054 1,012 146 

Japan 2 6 8 22 53 

All other 232 6,074 6,116 4,154 668 

 Total 169,433 140,546 104,242 93,378 140,465 

 EU-27 135,859 85,192 68,192 57,578 94,927 

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

a

Mirror data. 

Much of Tunisia’s olive oil exports are shipped in bulk rather than in bottles. While the 

share of bulk exports is falling over time with development of a bottling sector in Tunisia, 

they still accounted for 90 percent of exports by volume and 86 percent by value in 

MY 2011/12, compared with 99 percent (both volume and value) in MY 2007/08. 54 Over 

the last decade, efforts have been made to develop a modern bottling sector and brands in 

order to market the country’s increasing volume of high-quality oil. The Tunisian 

government hopes to increase its share of bottled exports to 20 percent in the next few 

years.55 

Factors Affecting Competitiveness 

As noted earlier, Tunisia’s olive oil sector currently focuses chiefly on supplying lowerquality, low-cost extra virgin oil in bulk shipments for bottling in the EU. Tunisian oil is 

then blended with olive oil sourced from other countries and resold in third-country 

markets. Its competitiveness in this market is driven by its low costs of production, 

cultivation practices that emphasize high volume, lower-quality olive production, and 

 54 Government of Tunisia, “Tunisian Olive Oil,” data sheet provided to USITC staff, January 17, 2013. 55 Industry representative, telephone interview by USITC staff, March 1, 2013. 
7-10

historic relationships with Italy. In order to derive more added value from the sector, the 

Tunisian government instituted several programs to encourage exports of branded and 

bottled olive oil, and has had some success. 

Quality 

Although almost two-thirds Tunisian olive oil meets the standard for extra virgin, it is 

neutrally flavored and its chemical compound levels mirror the current extra virgin 

thresholds, meaning its quality generally falls at the low end of this grade. For this reason 

Tunisian olive oil is viewed as a lower-quality product compared with the olive oil of 

some other global suppliers. 56 Several factors tend to diminish quality, including 

historical cultivation practices and the fragmentation of the supply chain. Recently, as 

noted above, Tunisia has seen an emergence of middlemen and more modern, highcapacity mills, both of which have reduced processing times and increased the prevalence 

of higher-quality extra virgin oil.57

Upon export, the Office National de l’Huile (National Olive Board, or ONH) extracts 

samples and tests the quality of the product to assign it a grade. Samples of olive oil are 

shipped to an ONH lab that has been certified by the IOC. 58 While this serves as 

certification that exported oil was properly tested and graded, many private importers and 

bottling companies prefer to run their own internal tests to verify specific chemical 

parameters.59

Cultivation practices 

Many Tunisian growers employ cultivation techniques that lower the quality of their oil. 

Although olive tree yields naturally fluctuate in alternating years, Tunisia’s hot climate 

and sporadic rainfall exacerbate this phenomenon.60 Irrigation would provide the olive 

trees with a more consistent supply of water, but less than 5 percent of olive groves are 

irrigated.61 In addition, more grove maintenance, such as pruning the trees, would smooth 

out production over time, lessening the high variance in annual production. 

Harvesting methods and timing also play an important role in determining the quality of 

Tunisian oil. Many growers harvest late in order to extract more oil from the olive, but 

this practice can lead to overripening of the fruit and defects in the taste of the resulting 

oil, even if the olives are processed quickly.62 It also results in blander oils, preferred for 

blending rather than for direct consumption. Because mills pay growers based on oil 

volumes as opposed to quality, farmers have an incentive to harvest late and to sacrifice 

high quality for volume. The lower quality of Tunisian oil is also a result of harvesting 

techniques. Most olive harvesting is still done by hand, with workers shaking the olive 

tree with hand-held tools and letting the olives fall to the ground. This method can 

damage the fruit as it falls from tree branches. Also, after harvest, growers transport their 

olives to mills in containers which allow heat and light to degrade the fruit, resulting in 

lower-quality oil. 

 56 Industry representatives, interview by USITC staff, Washington, DC, April 9, 2013. 57 Tunisian government official, email to USITC staff, August 1, 2013. 58 Government of Tunisia, “Tunisian Olive Oil,” data sheet compiled for and provided to USITC staff, 

January 17, 2013. 59 Industry representatives, interview by USITC staff, Washington, DC, April 9, 2013. 60 Karray, Olive Oil World Market Dynamics and Policy Reforms, 2006, 6; Tunisian government 

official, email to USITC staff, August 1, 2013. 61 Industry representative, telephone interview by USITC staff, April 29, 2013. 62 Industry representative, telephone interview by USITC staff, February 5, 2013. 
7-11

Fragmentation in supply chain 

Tunisia’s supply chain for olive oil is fragmented among many thousands of growers and 

large numbers of mills.63 This market structure makes quality control challenging because 

it is difficult for each mill to test each individual batch of olives that arrives from 

hundreds of small growers.64 Exacerbating the challenges of a fragmented supply chain is 

poor transportation and milling infrastructure. Olives often become degraded because of 

lengthy transit time between groves and mills.65 Moreover, it is expensive to move fruit 

on unpaved roads over long distances, and some growers in remote areas wait until 

neighboring farmers harvest enough olives to make a trip to the mill cost-effective. In 

addition, some traditional mills have such low capacity that olives sit in containers, 

degrading in quality while waiting to be milled.66

An emphasis on increasing efficiency along the supply chain is improving the quality of 

Tunisian oil. For example, as recently as the mid-1990s, about half of Tunisian olive oil 

production was lampante grade; this figure had gone down to 20 percent in 2012.67 

Whereas olives used to sit on the farm waiting to be transported to a mill, middlemen 

have begun to collect harvests from multiple farms to bring to mills, ensuring that olive 

degradation is minimized.68 In addition, modern mills with higher capacities have been 

built, and now mill 80 percent of Tunisian oil production. In this case, olives can be 

milled immediately after their arrival to a facility.69 While the supply chain has not 

consolidated and reduced the number of steps from grove to export, these advances have 

helped improve both the grade and quality of Tunisian oil. 

Lack of Product Differentiation 

The mild flavor of the majority of Tunisian olive oil makes it difficult for companies to 

highlight unique traits that can be used to differentiate their products. While some 

countries enjoy a branding cachet that results in price premiums, Tunisia has not 

established itself as a quality producer and is therefore at a disadvantage when trying to 

break into new markets and gain consumer attention. In addition, as previously 

mentioned, until the mid-2000s, almost 100 percent of Tunisia’s olive oil exports were 

shipped in bulk instead of bottled.70 This was due to both the role of ONH and Tunisia’s 

proximity to the European market. EU demand for oil for blending incentivizes Tunisia to 

continue producing bulk, neutrally flavored oil. This historical focus on bulk production 

means that Tunisian companies have little experience in creating brands and 

differentiating their oils. 

For many years, another barrier to developing a unique identity for Tunisian olive oils 

was government control of the sector. Exports used to be controlled solely through the 

government via ONH, which exported mostly bulk olive oil to the EU, until the sector 

was liberalized in 1994. After the liberalization, there was no state-run enterprise selling 

olive oil. The absence of such an enterprise made it difficult for firms to establish a clear 

 63 Tunisian government official, email to USITC staff, August 1, 2013. 64 While this fragmented supply chain is the most common, there are a small number of integrated 

companies that operate through the entire chain, from grove to export, and where strict quality control 

measures are in place. 65 Industry representative, telephone interview by USITC staff, February 5, 2013. 66 Ibid. 

67 Industry representative, telephone interview by USITC staff, April 29, 2013. 68 Ibid. 

69 Ibid. 

70 Government of Tunisia, “Tunisian Olive Oil,” data sheet compiled for and provided to USITC staff, 

January 17, 2013. 
7-12

channel for export of olive oils, especially to non-EU countries, and limited opportunities 

for individual producers to market their unique product.71 However, starting in the mid2000s some Tunisian producers, with support from the government, began bottling, 

branding, and directly marketing their domestic oil.72 Even so, differentiated and branded 

Tunisian olive oil continues to account for a small share of exports. 

One area of success in differentiating Tunisian product is organic olive oil. As Tunisians 

noted the growth in global demand for organic products, including in the United States, 

some brands capitalized on their traditional production methods by having them certified 

organic by bodies such as the EU and the U.S. Department of Agriculture (USDA).73 As 

of 2009, approximately 75,000 ha of Tunisian olive groves were considered organic.74

This marketing strategy has had some success, as evidenced by restaurant chain Le Pain 

Quotidien, which sources only organic 100 percent Tunisian olive oil. The production of 

organic olive oil increased from 12,000 mt in 2006 to 25,000 mt in 2009, making Tunisia 

the largest global producer of this product.75 

EU Proximity and Trade Preferences 

Geographic and geopolitical factors offer Tunisian olive oils several competitive 

advantages over other potential suppliers. Tunisia benefits from its nearness to the EU 

market, inclusion in EU trade preference programs, a long history of European 

investment, and access to the world’s largest importing country, Italy. 76 Tunisia’s 

historical tradition in olive production has helped it become a large global producer and 

ingrained a trade relationship with Europe. 

Tunisia and the EU are geographically close: the port of Sfax in Tunisia is one of the 

closest ports to Genoa in Italy, a major location for olive oil trade.77 Because olive oil is a 

perishable product, transit times of only a few days favor Tunisia. Short travel distances 

to the EU also mean lower transportation and delivery costs, and allow Tunisian 

exporters to offer their EU customers “just in time” deliveries. Though these factors 

permit Tunisia to be a link in the European supply chain, Tunisian industry 

representatives claim that the historical relationship and geographic proximity has made 

Tunisia too reliant on the EU market as a buyer, perpetuating the demand for less 

flavorful oils for blending and restricting Tunisia’s presence on the global market.78

Tunisian olive oil also benefits from favorable access to the EU market.79 For example, as 

a result of the EU-Tunisia component of the Euro-Mediterranean Association 

Agreements, the EU grants Tunisia a preferential annual import quota of 56,700 mt of 

oil.80 Tunisia also benefits from the EU’s inward processing arrangement, under which 

 71 Karray, Olive Oil World Market Dynamics and Policy Reforms, 2006, 5. 72 Government of Tunisia, “Tunisian Olive Oil,” data sheet provided to USITC staff, January 17, 2013. 73 Industry representative, telephone interview by USITC staff, April 29, 2013. 74 IOC, “Tunisia Indicators,” n.d., 3 (accessed May 6, 2013). 75 ONH, “Organic Olive Oil” (accessed March 27, 2013). 76 Dating back to the Roman Empire, Carthaginians, Greeks, and Italians planted olive trees in Tunisia 

and encouraged expansion of olive groves. IOC, Tunisia 2012, n.d., 5–10 (accessed May 6, 2013). 77 Industry representative, interview by USITC staff, Tuscany, Italy, January 30, 2013. 78 Industry representative, telephone interview by USITC staff, April 29, 2013. 79 See chapter 2, box 2.3, for more information on the EU’s preferential tariffs and inward processing 

arrangements. 80 It is important to note that the EU limits quantities allowable under this duty-free quota during the 

highest-producing months of January and February, meaning olives must be milled later, oil must be stored 

longer, or duties must be paid on oil exported from Tunisia to the EU unless it is brought in under the inward 

processing structure. Government of the United Kingdom, RPA, “Leaflet ET4,” (accessed March 26, 2013), 

13. 
7-13

oil imports receive duty-free treatment provided an equivalent amount of oil is reexported.81 Because most olive oil exported from Tunisia to the EU is blended with other 

oils, bottled, and exported, the majority of Tunisian-sourced olive oil is eligible for dutyfree treatment under the inward processing scheme.82

 

Limited Access to Credit 

The Tunisian banking sector is highly regulated, with state ownership of three of the 

largest state-run banks accounting for 37 percent of banking assets.83 The private banking 

sector is also highly regulated by the government. According to Tunisian sources, access 

to credit in the economy is poor. Loans are preferentially awarded to borrowers well 

connected with lenders, and collateral requirements are restrictive.84 For the olive oil 

sector, the lack of credit availability means that growers and millers without ready cash 

have difficulty acquiring short-term operating loans and investing in their businesses. The 

effects of this credit gap are twofold: millers lack the working capital to run a mill 

throughout the entire harvest season, and also face a restricted ability to invest in 

increased storage.85

Industry experts have observed that Italian buying agents take advantage of the lack of 

credit by traveling to Tunisia during harvest and processing season and offering to buy oil 

in cash at a price below market value. Because mills are often short on storage 

availability and working capital due to limited access to bank loans, Tunisian producers 

often accept the low prices in order to acquire the cash they need to sustain them during 

the processing season.86 Difficulty in obtaining capital to invest in increased storage 

perpetuates this relationship. 

Low Cost of Production 

Tunisia’s low cost of production has allowed it to export to the EU in bulk at a very low 

price and to maintain its share of the global market. It enjoys a cost of production 

advantage over its competitors in the EU, mainly because of its lower wages and lack of 

mechanization.87 In Tunisia, most olive harvesting is done by hand, and there has been 

little investment in mechanized harvesting. Although the minimum wage for a 40-hour 

workweek in Tunisia was 246 dinars ($178) 88 in 2011, agricultural labor rates are 

reportedly much lower.89 The Tunisian government estimates wage rates for olive oil 

workers at around 15 to 20 dinars ($8.50–$11.50) per day.90 The labor costs for pruning 

and harvesting in Tunisia are considerably lower than those in Spain and Italy.91 In 

addition, the practice of harvesting olives relatively late in the season, when the oil 

 81 European Commission Taxation and Customs website, 

http://ec.europa.eu/taxation_customs/customs/procedural_aspects/imports/inward_processing/index_en.htm

(accessed May 3, 2013). 82 Industry representative, interview by USITC staff, Rome, Italy, February 1, 2013. 83 IMF, “Tunisia: Financial System Stability Assessment,” July 6, 2012, 13. 84 Ibid., 4. 

85 Tunisia has about 350,000 mt of storage capacity, but only approximately 55 percent is privately 

owned. ONH, “Production” (accessed March 27, 2013). 86 Industry representative, telephone interview by USITC staff, March 21, 2013. 87 Karray, Olive Oil World Market Dynamics and Policy Reforms, 2006, 5. 88 This equates to approximately $35 per day, based on a five-day work week. 89 Encyclopedia of the Earth, “Tunisia” (accessed April 4, 2013). 90 Tunisian government official, email to USITC staff, August 1, 2013. 91 In Spain, harvesters are typically paid up to $80.00 per day, while pruners in some regions of Italy 

might earn up to €140 ($181.00). Industry representatives, interview by USITC staff, Andalusia, Spain, 

January 23, 2013; industry representatives, interview by USITC staff, Puglia, Italy, February 5, 2013. 
7-14

content of the fruit is high, translates into lower cost per unit of oil produced. Overall, the 

cost to harvest and mill olive oil in Tunisia is approximately 3.5 dinars ($2.00) per kg.92

When the cost of bottling is included, the total cost of production of olive oil in Tunisia is 

around 5 dinars ($2.85) per kg.93

Supportive Government Policy 

Historically, the government has played an important role in overseeing the country’s 

olive sector through the ONH, the state trading enterprise. The ONH enjoyed a monopoly 

in the exportation of olive oil until 1994.94 After the 1994 liberalization of the olive oil 

industry, the influence of ONH diminished, although it continues to be active in the 

sector in several areas. ONH works with the Ministry of Agriculture to create action 

plans for the sector, to coordinate campaigns for the preservation and treatment of olive 

trees, and to promote the quality of Tunisian olive oil globally. 95 It also provides 

technical assistance to olive farmers and continues to purchase, store, and export some 

oil, although its share of the export market decreased to only 6 percent during 2008–12.96 

In addition to ONH, there are several programs supported by the Tunisian government to 

encourage both production and exports of olive oil, and to improve quality standards. The 

Agriculture Investments Promotion Agency (APIA) provides incentives to invest in new 

groves and rejuvenate existing ones. The Special Fund for the Development of Olive 

Growing (FSDO) promotes the production of olives and olive oil: in 2012, the fund was 

allocated a budget of 789,000 dinars (around $480,000). The Tunisian government also 

promotes olive oil exports through a variety of programs. The largest is a program that is 

paid for by the industry itself through a tax of 0.5 percent of the customs value of exports, 

with revenues used for promotional activities in export markets. 97 Other government 

programs include the Export Market Access Fund (FAMEX), which promotes packaged 

olive oil to growth markets; the Export Promotion Fund (FOPRODEX), which helps 

exporters gain access to the international market by offering up to 50 percent of 

transportation costs; 98 and the Fund for the Promotion of Bottled Olive Oil 

(FOPROHOC), which, from its inception in 2006 to mid-2010, granted $8.5 million to 

fund the establishment of distribution channels for exporting firms and the exploration of 

new potential markets.99 Most Tunisian government programs typically do not subsidize 

the cost of olive production, but focus on marketing olive oil and raising the quality of 

Tunisian oil. In addition, they promote olive oil exports over domestic consumption and, 

to a limited extent, encourage the production of higher-quality branded and bottled 

Tunisian olive oil in premium export markets. 

 92 Tunisian government official, email to USITC staff, August 1, 2013. 93 Ibid. 

94 ONH website, http://www.onh.com.tn/index.php/en/evolution-de-l-activite (accessed March 27, 

2013). 95 ONH website, http://www.onh.com.tn/index.php/en/l-onh (accessed March 27, 2013). 96 Government of Tunisia, “Tunisian Olive Oil,” data sheet provided to USITC staff, January 17, 2013. 97 Promotion activities include participating in food shows and fairs, developing quality branded labels, 

obtaining trademarks, and marketing packed product to supermarkets abroad. Government of Tunisia, 

“Tunisian Olive Oil,” data sheet provided to USITC staff, January 17, 2013. 98 For conventional bulk olive oil, excluding organic, support is provided to all markets except France, 

Italy, and Spain. For organic olive oil (bulk and packaged) and for bottled olive oil, support is granted to 

export operations to all destinations. The support rate for transport is 33 percent for maritime transport and 

combined transport, and 50 percent for air transport. 99 Government of Tunisia, Ministry of Industry and Technology, Tunisian Olive Oil, “FOPROHOC 

Key Figures” (August 2010). 
7-15

Morocco 

Overview 

As in Tunisia, the olive oil industry plays an important role in the Moroccan economy. 

Olives are grown on about 800,000 ha on 450,000 holdings,100 and the industry generates 

about 125,000 full-time jobs.101 Olives are grown throughout the country, except for the 

Atlantic coastal areas. 102 Approximately 75 percent of olives grown in Morocco are 

pressed for oil, while the rest are table olives. The Meknes region accounts for nearly half 

of all olive oil produced in Morocco, the majority of the country’s extra virgin olive oil 

production, and most of its exports. 103 Most of the olive oil produced is consumed 

domestically, so Morocco is not a major exporting country. 

The first half of this section will provide a descriptive profile of Morocco’s production 

and processing, and discuss trends in domestic consumption and Morocco’s role in global 

trade. The second half will focus on the major factors affecting Morocco’s 

competitiveness in the global market. Factors that increase the competitiveness of 

Morocco’s olive oil industry include its proximity and close ties with the EU, business 

relationships that some Moroccan producers have established with U.S. bottlers, the 

generally high quality of its olive oil exports, and programs established by the 

government of Morocco and certain international aid organizations that are designed to 

promote the olive oil industry. Besides boosting production, these programs promote 

higher-quality olive oil and encourage producers to meet international standards for 

export. The competiveness of Morocco’s olive oil sector is weakened by high production 

costs, limited supplies available for export, and poor quality in certain segments of the 

industry. 

Production Profile 

Production Overview 

Morocco is the world’s seventh-largest olive oil-producing country, accounting for about 

3.5 percent of global production in MY 2011/12.104 During the 2000s production rose 

significantly, increasing from 35,000 mt in 2000/01 to a record 140,000 mt in 2009/10 

(table 7.3). Since then, production has steadily fallen and is projected at 100,000 mt in 

2012/13, largely because of unfavorable weather. The majority of olive groves in 

Morocco are not irrigated, and production levels fluctuate dramatically because yields 

depend on adequate rainfall. For example, in MY 2009/10 and MY 2010/11, Morocco 

received adequate and well-timed seasonal rainfall resulting in yields of 2.5 and 2.1 mt 

 100 Government of Morocco, “Olive Sector Data,” data sheet provided to USITC staff, Rabat, Morocco, 

January 29, 2013. 101 IOC, “Policies: Morocco,” 2012. The FAO reported in 2010 that 50 million olive trees were planted 

on approximately 580,000 ha in Morocco. FAO, Olive GAP Manual, 2010, 36; Government of Morocco, 

“Olive Sector Data,” data sheet compiled for and provided to USITC staff, Rabat, Morocco, January 29, 2013. 102 IOC, “Policies: Morocco,” 2012. 103 Industry representative, interview by USITC staff, Meknes, Morocco, January 27, 2013. Some of 

the olive oil produced in the Meknes region is made from olives grown outside the region. 104 IOC, “Table 1: [World] Production,” November 2012. 
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TABLE 7.3 Morocco: Olive oil supply, consumption, and trade, 2000/01, and 2007/08–2012/13 (1,000 mt) 

 2000/01 2007/08 2008/09 2009/10 2010/11 a

2011/12 b2012/13

Production 35.0 85.0 85.0 140.0 130.0 120.0 100.0

Imports 4.5 5.0 15.0 0 4.0 0 0

Consumption 45.0 65.0 70.0 90.0 100.0 90.0 85.0

Exports 0 2.0 3.0 21.0 30.5 11.0 30.0 

Source: IOC, “Tables 1–4: [World] Production, Imports, Exports, Consumption,” November 2012. 

Note: A marketing year spans October 1 to September 30 the following year. 

 aProvisional. aProjected. 

per ha, respectively, while during MY 2012/13, the summer months were unusually hot 

and dry so that yields fell to about 1.4 mt per ha.105 

In addition to the weather variability, output may be affected by a traditional method of 

harvesting known as “gaulage”—the practice of harvesting olives by beating the branches 

with a stick. This can damage the tree and exacerbate the problem of the alternate annual 

fruit-bearing cycle of the trees, as well as damage the fruit as it falls to the ground. 

Olive-Growing Sector 

Like Tunisia, the structure of the olive-growing industry in Morocco consists of many 

small-scale growers using traditional plantings and hand harvesting, and a few large 

growers using high-density or SHD plantings and mechanical harvesting. Nearly 

60 percent of olive plots are under 5 ha. 106 Approximately 90 percent of the olivegrowing area is in traditional plantings, with about 100 trees per ha or fewer and low 

yields of about 1.0–1.5 mt of olives per ha.107 In mountainous areas with poor soil, yields 

are typically even less at 500–700 kg per ha, running as low as 100 kg per ha in 

especially marginal areas. 108 Only about 2 percent of Morocco’s olive-growing area 

(about 15,000 ha) is planted in high-density or SHD groves, primarily because of a lack 

of water.109 Average yields for SHD plantings (150–400 trees per ha) that are irrigated are 

between 2–4 mt per ha.110 

 

The total area planted to olives has increased from about 750,000 ha in MY 2008/09 to 

nearly 1 million ha in 2011/12. Of this area, about 800,000 ha are currently in production 

because newly planted groves do not begin producing for several years. 

 105 Industry representatives, interviews by USITC staff, Meknes, Morocco, January 27–28, 2013; 

Government of Morocco, “Olive Sector Data,” data sheet compiled for and provided to USITC staff, Rabat, 

Morocco, January 29, 2013. 106 IOC, “Policies: Morocco,” 2012; Government of Morocco, “Olive Sector Data,” data sheet provided 

to USITC staff, Rabat, Morocco, January 29, 2013. 107 Industry representative, interview by USITC staff, Meknes, Morocco, January 27, 2013. 108 FAO, Olive GAP Manual, 2010, 36, 186; industry representatives, interviews by USITC staff, 

Meknes, Morocco, January 27–28, 2013; Government of Morocco, “Olive Sector Data,” data sheet compiled 

for and provided to USITC staff, Rabat, Morocco, January 29, 2013. 109 Industry representative, interviews by USITC staff, January 27 and January 28, 2013. High-density 

and SHD groves in Morocco typically have about 400 to 1,000 trees per hectare. 110 Government of Morocco, “Olive Sector Data,” data sheet compiled for and provided to USITC staff, 

Rabat, Morocco, January 29, 2013. 
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According to the United Nations Food and Agriculture Organization (FAO), 

approximately 38 percent of Morocco’s olive plantings are irrigated.111 Irrigation not only 

increases yields but also decreases the time needed for a grove to begin production. A 

grove with 300 trees per ha with irrigation can begin production in 4 years instead of 8–

10, and can produce 4–5 tons per ha in 8–10 years, compared with the average production 

of 1.0–1.5 tons per ha for traditional, rain-fed groves. After 25 years, irrigated groves 

without intensive plantings typically reach 8–9 mt per ha with proper farm 

management.112 Olives are harvested in Morocco between November and February. 

Unlike Tunisia, olive oil production in Morocco is largely from a single variety. Over 

90 percent of olive oil produced in Morocco is from the native Picholine olive variety.113

Picholine olives are not well adapted to SHD cultivation, but flourish in dry climates with 

little or no irrigation.114 This variety is also grown for table olives, leading to competition 

for olives between the table olive and oil segments of the industry. The table olive market 

is reportedly very stable, with prices for olives for canning higher than olives for 

production of oil. 115 Despite a 20 to 30 percent price premium for table olives in 

Morocco, most traditional growers are not able to sell into the segment because table 

olive production requires irrigation and intensive farm management practices. 116

Nonetheless, the table olive market limits the supply of olives available to produce olive 

oil, particularly in years with poor yields.117 However, the majority of table olives are 

produced for export, and only modern intensive growers have the ability to sell into this 

segment.118

Olive Oil Processing Sector 

The Moroccan olive oil processing sector consists of a large number of small mills, called 

“maasras,” that use traditional milling techniques, and several modern processing 

facilities, many of which are vertically integrated to include groves and bottling 

operations. The maasras produce approximately 30 percent of Moroccan olive oil, down 

from 60 percent a decade ago.119 Both maasras and Morocco’s other small producers, 

perhaps best described as “semi-modern,” have adopted modern crushing methods for the 

millstones or are separating water from the oil using a centrifuge.120 However, poor 

storage conditions and delays between harvest and processing lead to degraded fruit and 

lower-quality oil for most of these producers. The majority of olive oil produced by 

 111 FAO, Olive GAP Manual, 2010, 36. 112 Industry representative, interview by USITC staff, Meknes, Morocco, January 27, 2013. In 

comparison, yields from SHD plantings are typically 12–13 tons per hectare. 113 MCC, Morocco Ministry of Agriculture and Marine Fisheries, and Morocco Agency of Partnership 

for Progress, “Invest in Morocco,” 2010, 4. 114 Industry representatives, interviews by USITC staff, Washington, DC, December 20, 2012. 115 Industry representative, interview by USITC staff, Meknes, Morocco, January 28, 2013. 116 Industry representatives, interviews by USITC staff, Meknes, Morocco, January 28, 2013. 117 Morocco’s production of table olives shows much less variation than its production of olive oil. 

Over the 2007/08–2011/12 period, production of table olives has been 90,000 to 110,000 tons per year, while 

production of olive oil has varied between 85,000 and 140,000 tons per year (IOC). 118 Morocco is the world’s second-largest exporter of olives, after Spain. In 2011, Morocco exported 

76,744 mt of preserved olives valued at over $145 million. Spain is by far the largest exporter of preserved 

olives—over 234,000 mt in 2011. GTIS, Global Trade Atlas database (accessed June 19, 2012). 119 MCC, Morocco Ministry of Agriculture and Marine Fisheries, and Morocco Agency of Partnership 

for Progress, “Invest in Morocco,” 2010, 9; Hibler, “Improving Morocco’s Olive Industry,” 2003. A maasra 

is a traditional oil mill of the style introduced by the Romans. Traditional practices result in olive oil with a 

high level of acid. Humpal and Jacques, “Draft Report on Bumpers and Import Sensitivity Analysis,” 2003, 3. 120 Olive Oil Emporium. “Olive Oil Process.” n.d. 
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maasras and other small producers is “lampante” grade oil and would not meet IOC 

standards for virgin or extra virgin olive oil if tested.121

As most olive oil in Morocco is produced in maasras and other small traditional mills, 

only a small percentage of olive oil is produced using more modern practices. In 2008, 

there were 128 modern olive oil processing units in Morocco, with combined annual 

capacity of about 19,100 mt, roughly 20 percent of the total 90,000 mt of olive oil 

produced that year.122 Many of the modern mills are vertically integrated with growing, 

milling, and bottling operations, producing much higher-quality olive oil than traditional 

mills, partly because their higher milling capacity allows them to process the olives 

sooner after harvest. Firms producing for the export market where quality control is 

required are more likely to be vertically integrated. 

Consumption 

Per capita consumption of olive oil in Morocco is roughly 3 kilograms (kg) annually, 

quite low in comparison to other large producers, although it is projected to reach 5 kg by 

2020.123 The population of Morocco is slightly over 30 million, roughly three times that 

of Tunisia. Although most olive oil produced in Morocco is consumed domestically, 

olive oil accounts for only a small share of Morocco’s overall consumption of edible oils. 

The majority of edible oil consumed in Morocco is imported. In 2012, Morocco imported 

490,000 mt of edible oils (Harmonized System chapter 15) and exported 59,000 mt.124

The United States is the largest import supplier of edible oils to Morocco, at 136,000 mt 

in 2012 (predominately soybean oil). Reportedly, one goal of government support for 

olive oil production is to encourage domestic consumption of olive oil as a substitute for 

imported edible oils.125 

According to IOC data, Morocco’s annual domestic consumption of olive oil increased 

substantially between MY 2007/08 and MY 2010/11, from 65,000 mt to 100,000 mt, 

before declining to 90,000 mt in MY 2011/12. It is projected to drop further to 85,000 mt 

in MY 2012/13, as production is predicted to decline (table 7.3).126 About 18 percent of 

the olive oil consumed in Morocco is used by producing households, and 39 percent is 

bought directly from producing mills. Most of the rest is bought from local shops and 

grocery stores. Only 7.5 percent is purchased in supermarkets.127

Although it accounts for a relatively small part of domestic edible oil consumption, 

domestic demand for olive oil is strong, with prices that compare favorably with 

exports.128 In January 2013, the retail price for olive oil purchased from a maasra in rural 

 121 MCC representative, interview by USITC staff, Washington, DC, December 18, 2012; Azzouzi, 

Laytimi, and Abidar reported in 2006 that approximately 85 percent of olive oil produced in Morocco would 

not have met IOC quality standards, if tested. “Effect of Incentive Policy on Performance and International 

Competitiveness of Fruits, Vegetables, and Olive Oil in Morocco,” 2006, 6. 122 MCC, Morocco Ministry of Agriculture and Marine Fisheries, and Morocco Agency of Partnership 

for Progress, “Invest in Morocco,” 2010, 9. 123 Moroccan government official, interview by USITC staff, Rabat, Morocco, January 29, 2013. 124 GTIS, Global Trade Atlas database (accessed June 19, 2013). In addition to exports of olive oil, 

Morocco also exports fish oil and some soybean oil. 125 Industry representative, interview by USITC staff, Meknes, Morocco, January 27, 2013. 126 IOC, “Table 4: Consumption,” November 2012. Marketing year, for producers in the Northern 

Hemisphere, is October 1 through September 30. 127 Bennani, “Huile d’olive et olives de table” [Olive oil and table olives], October 2011. Only about 

20 percent of retail food sales in Morocco are in modern food distribution channels. There are approximately 

125 supermarkets with three or more registers, 200 self-service grocery stores with one or two registers, and 

thousands of small “mom-and-pop” stores. USDA, FAS, Morocco: Retail Foods, December 12, 2012, 5. 128 Industry representative, interview by USITC staff, Meknes, Morocco, January 27, 2013. 
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Morocco was approximately 40 dirhams per liter ($4.63 per liter).129 Average retail prices 

for a one-liter bottle range from 40 to 60 dirhams per liter ($4.63 to $6.94). 130

Additionally, many Moroccan brands have established strong brand recognition in the 

home market, relative to export markets.131 

Trade 

Moroccan exports of olive oil vary significantly from year to year (table 7.4), although 

they generally follow the pattern of domestic production. Most of the increased 

production volume over the past five years has gone to domestic consumption. In contrast 

to Tunisia, Moroccan producers generally supply the domestic market first and export the 

olive oil that is not consumed domestically.132 Morocco is not a major importer of olive 

oil, although a small volume is imported annually, mostly from the EU and Tunisia. 

The EU has traditionally been Morocco’s largest export market for olive oil. However, 

exports to the United States increased more than fivefold between 2007 and 2011, and in 

2011 the United States was Morocco’s largest export market by far.133 Morocco was the 

fourth-largest import supplier of olive oil to the U.S. market, and imports in 2011 more 

than doubled over 2010.134 Reasons for the shift toward the U.S. market and away from 

the EU include an affiliation between a Moroccan producer and a U.S. bottler and 

declining prices for olive oil in Spain. 

Additionally, U.S. imports of olive oil from Morocco are duty free under a free trade 

agreement. 135 In 2012, however, U.S. imports of olive oil from Morocco declined 

substantially, in line with the drop in domestic production. Morocco’s olive oil exports to 

the EU, specifically to Spain and Italy, increased in 2012 over 2011, as Spain’s olive oil 

production declined. 

Factors Affecting Competitiveness 

Most of Morocco’s olive oil production is by suppliers who use traditional growing and 

milling methods and who are focused on supplying the domestic market. Morocco also 

has some modern producers who can supply both the domestic olive oil market and the 

export olive oil market.136 In years when there is adequate and timely rainfall, Moroccan 

producers export a significant share of the olive oil produced, generally in bulk. Morocco 

is not a low-cost supplier of olive oil, but benefits from its proximity to and trade 

preferences with the EU. As noted above, some Moroccan producers also have 

established business relationships with bottlers in the United States. 

 129 Industry representatives, interviews by USITC staff, Meknes, Morocco, January 28, 2013, and email, 

February 6, 2013. 130 In comparison, the average unit value of U.S. olive oil imports from Morocco in 2012 (largely in 

bulk) was $2.66 per kg ($2.93 per liter). GTIS, Global Trade Atlas database (accessed June 19, 2013). 131 Industry representative, interview by USITC staff, Meknes, Morocco, January 28, 2013. 132 Industry representative, interview by USITC staff, Meknes, Morocco, January 26, 2013. 133 Industry representative, interview by USITC staff, Meknes, Morocco, January 27, 2013. 134 GTIS, Global Trade Atlas database (accessed June 19, 2013). According to data from the IOC, 

which reports on a MY basis, Morocco became the third-largest import supplier of olive oil to the U.S. 

market in 2011 (IOC, “U.S. Import Trends,” February 2012), overtaking Tunisia, but this is not supported by 

calendar year data from GTIS. U.S. imports from Morocco declined in 2012. 135 According to Moroccan officials, U.S. import duties on olive oil from all sources are low (about 

1 percent ad valorem equivalent), and the duty-free treatment given under the U.S.-Morocco free trade 

agreement in itself is unlikely to have had a significant impact on olive oil trade. Industry representative, 

interview by USITC staff, Meknes, Morocco, January 27, 2013. 136 Some of these producers also supply the table olive market. 
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TABLE 7.4 Morocco: Exports of olive oil (HS1509), 2008–12 

Country 2008 2009 2010 2011 2012

Value (thousand $) 

United States 3,533 1,676 27,967 46,424 13,282 

Spain 1,261 742 10,278 9,368 12,339 

Portugal 0 0 0 0 1,328 

Canada 454 891 655 821 915 

Belgium 172 251 7 942 861 

France 34 128 748 766 562 

China 758 0 34 1 309 

United Kingdom 0 7 16 176 164 

Italy 0 4,445 12,900 14,248 118 

Netherlands 1,516 1,657 1,776 1,282 106 

Equatorial Guinea 0 30 6 429 63 

United Arab Emirates 22 7 16 35 62 

All other 42 164 604 472 231

 Total 7,791 9,998 55,006 74,964 30,341 

 EU-27 2,983 7,247 25,732 26,785 15,478 

Quantity (metric tons) 

United States 890 466 9,706 18,221 5,296

Spain 441 391 4,273 4,271 4,888

Portugal 0 0 0 0 480

Canada 99 198 170 220 272

Belgium 35 62 2 291 245

France 7 29 213 239 151

China 249 0 4 0 77

United Kingdom 0 1 2 53 47

Italy 0 1,509 5,703 6,542 44

Netherlands 302 387 541 376 27

Equatorial Guinea 5 1 4 10 19

United Arab Emirates 0 7 2 148 15

All other 6 29 213 111 74

 Total 2,034 3,080 20,833 30,482 11,635

 EU-27 785 2,379 10,735 11,774 5,882

Source: GTIS, Global Trade Atlas database (accessed June 19, 2013). 

EU Proximity and Trade Preferences 

As is the case for Tunisia, Morocco benefits from its proximity to the EU, the largest 

olive oil market. Morocco is separated from Spain only by the Strait of Gibraltar. 

Additionally, in March 2000, as part of the Euro-Mediterranean Agreements, EU 

members and the Kingdom of Morocco began a process of gradual trade liberalization 

that, in 2012, culminated in the eventual elimination of duties on most EU imports of 

agricultural products from Morocco, including all imports of olive oil. 137 This is 

significant in that the EU most-favored-nation (MFN) duty rate of €1,250 per mt was 

equivalent to over half the producer price for Spanish extra virgin olive oil during 2010–

12.138 However, prior to 2012, almost all Moroccan olive oil entered the EU either under 

a duty-free tariff-rate quota (TRQ) or subject to an inward processing regime.139 

 137 Title II of the Euro-Mediterranean Agreement called for the establishment of a free trade area over a 

time period not to exceed 12 years. The agreement will also allow duty-free imports into Morocco of up to 

2,000 mt of olive oil from the EU (1,500 mt of extra virgin olive oil and 500 mt of virgin olive oil). 138 Between 2010 and 2012, the average price for extra virgin olive oil for in Jaén, Spain, was 

€2,004 per mt. 139 In 2011, EU imports of olive oil from Morocco totaled 12,936 mt: 3,920 mt within the quota, 

8,925 mt under the inward processing regime, and 91 mt that were apparently subject to MFN tariffs. See 

chapter 6 for a description of the EU inward processing regime. 
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The prospect of eliminating even these modest import duties on Moroccan olive oil led 

some Spanish producers to call the Euro-Mediterranean Agreement a “disaster.” 

However, producers in Morocco reportedly are focusing on the U.S. market, rather than 

the EU.140

Product Differentiation 

Most of Morocco’s olive oil exports are in bulk, either to the United States or to the EU 

under an inward processing regime. However, some Moroccan producers have 

established a reputation for quality, and a couple of these producers have successfully 

moved to bottling. In 2012, although U.S. imports of bulk olive oil from Morocco 

declined 50 percent from 2011, U.S. imports of bottled Moroccan olive oil increased 

70 percent, to the highest level since 2006. 

One way to distinguish a brand of olive oil is to register its name as a protected 

designation of origin (PDO). PDOs are issued by the European Commission’s 

Directorate-General for Agriculture and Rural Development in order to protect product 

names from misuse and imitation, and to provide a way for producers to differentiate 

their products.141 A PDO requires that the product be entirely produced and processed 

within the specified region, using traditional methods. Morocco has established a PDO 

for olive oil from the Meknes region, and has the potential to designate up to 11 

additional protected geographical indicators for olive oil from specific regions.142 PDO 

and protected geographical indication (PGI), offer producers not only a means of 

differentiation but also potentially higher returns. For example, during 2004–07, the 

prices of four Italian extra virgin olive oils produced under either a PDO or a PGI ranged 

from slightly higher to roughly twice as high compared with the prices of “other” extra 

virgin olive oil also produced in Italy.143 

Low Quality 

Much of the oil produced by traditional methods in Morocco is of poor quality and does 

not meet quality standards for export. Small-scale farmers have limited access to crushing 

equipment, and olives are often stored for long periods in poor conditions before 

processing. Much of the oil produced in Morocco by traditional methods for domestic 

consumption is not tested at all. 144 Data collected by the IOC indicates that in 

MY 2009/10, roughly 60 percent of Moroccan olive oil was lampante grade, and only 

5 percent was extra virgin grade.145 Therefore, most of the olive oil produced in Morocco 

is of too low a quality for export. 

In contrast to the traditional sector, modern mills employ quality control and testing 

procedures, and focus on producing extra virgin olive oil. Also, many modern mills are 

vertically integrated and better able to control storage conditions for olives and olive oil. 

As more of Morocco’s olive producers have moved into the export market and the formal 

domestic market, quality has improved. Oil destined for export is tested by a government 

 140 Butler, Olive Oil Times, “Spanish Producers Call,” February 29, 2012. 141 European Commission official, interview by USITC staff, Brussels, Belgium, February 27, 2013; 

Regulation (EU) No. 1151/2012 of the European Parliament and of the Council of 21 November 2012. 142 Thual and Lossy, Presentation of the Findings, October 21, 2010. 143 Dimitriou, “GIs from the Point of View of EU,” n.d., 18. 144 U.S. government officials, interviews by USITC staff, Washington, DC, December 18, 2012. 145 IOC, Morocco 2012, 8 (accessed May 6, 2013). Oil that would be graded lampante if tested is 

consumed domestically, much of it by producers’ households. 
7-22

entity (Maroc Export) to ensure compliance with IOC standards. 146 Government 

programs and international aid (discussed below) also seek to improve the quality of 

olive oil produced by traditional methods, through improvements in management 

practices and storage conditions. 

Efforts to improve quality have met with some success, and Moroccan olive oils 

increasingly compete in international competitions. Moroccan olive oils have won 

numerous awards for quality, including “Best of Class, Gold Medal” in the “robust” 

category at the 2012 Los Angeles International Northern Hemisphere Extra Virgin Olive 

Oil Competition.147

Costs of Production 

Average production costs in Morocco are generally high compared to those of other 

major producing countries. This makes it difficult for Moroccan exports to compete on 

price. Average production cost per mt of olive oil was estimated at $3,287 in 2010, of 

which olive purchases account for nearly two-thirds (61 percent) and bottling/packaging 

for over one-quarter (28 percent).148 Olive oil prices at the mill during the MY 2009/10 

were reported to be 18–25 Moroccan dirhams per kg ($2.08 to $2.89).149 For comparison, 

the average unit customs value of bulk U.S. imports of virgin olive oil from Morocco in 

2012 was $2.59 per kg. 150 Industry representatives reported that, because of high 

production costs, the price of Moroccan quality extra virgin oil from olives produced on 

SHD groves was over $4,000 per mt in late January 2013, with Spanish Arbequina and 

Greek Koroneiki oils selling at prices between 25 and 35 percent lower.151 

Olive production in Morocco is constrained by the terrain, the limited water supply, and 

the high cost of irrigation. The cost of land for a traditional olive grove in Morocco (on a 

hillside, with limited access to water and roads) is about 1,200 dirhams ($140) per ha, 

giving average yields of 1,000–1,500 kg of olives per ha. Labor costs are approximately 

1 dirham ($0.116) per kg of olives.152 Yields are much higher in irrigated groves (up to 

9 mt per ha) and labor costs lower per unit. However, most land does not have access to 

water, and installing a drip irrigation system costs 30,000-40,000 dirhams per ha 

($3,470–$4,630). Consequently, only about 15 percent of cultivated land in Morocco is 

irrigated.153 

 146 There have been some problems reported with certification of olive oil from olives grown under 

severe conditions of drought and high temperatures. Reportedly, olive oil from olives grown under severe 

conditions may fail a test (the “C183” test for linoleic acid) designed to test for adulteration with seed oil, 

such as canola oil. Industry representative and Moroccan government official, interviews by USITC staff, 

Meknes, Morocco, January 27–28, 2013. 147 Olive Oil Times, “Los Angeles Extra Virgin Olive Oil Awards by Medal,” 

http://static.oliveoiltimes.com/library/2012-LA-winners.pdf (accessed May 22, 2013). 148 MCC, Morocco Ministry of Agriculture and Marine Fisheries, and Morocco Agency of Partnership 

for Progress, “Invest in Morocco,” 2010, 16. Cost estimate by the Moroccan Ministry of Agriculture and 

Marine Fisheries. 149 IOC, Morocco 2012 (accessed May 6, 2013), 8. The 2012 annual average exchange rate of 8.645 

dirhams per U.S. dollar is used throughout this section. In 2000, the domestic price for extra virgin olive oil 

sold in Morocco averaged 95 percent of the export price, and input costs averaged 93 percent of the 

production value. Azzouzi, Laytimi, and Abidar, “Effect of Incentive Policy on Performance,” 2006. 150 GTIS, Global Trade Atlas database (accessed June 19, 2013). 151 Industry representatives, interviews by USITC staff, Meknes, Morocco, January 27, 2013. 152 Industry representatives, interviews by USITC staff, Meknes, Morocco, January 27, 2013. 

Harvesting costs account for the largest share of labor costs—approximately 75 dirhams per 100 kg. 153 Morocco Ministry of Agriculture and Maritime Fisheries, “L’irrigation au Maroc” [Irrigation in 

Morocco] (accessed February 11, 2013). 
7-23

Supportive Government Policies 

The government of Morocco has three primary programs designed to promote olive oil 

production: the Plan Maroc Vert (the Green Plan for Agriculture), the Plan Emergence, 

and Maroc Export. These plans are in addition to the poverty-reduction project funded by 

the Millennium Challenge Corporation (MCC), which also aims to increase cultivation of 

olives and production of olive oil. 

In 2008, the government of Morocco instituted its Green Plan for Agriculture. Because 

olive trees are less susceptible to variations in rainfall than cereal crops and because sales 

of both olives and olive oil provide cash income to farmers, the government offers 

incentives to farmers to diversify into the production of olives and other value-added 

products, and trains farmers in modern olive production methods. The primary goals of 

the Green Plan are to improve the efficiency of agriculture and to combat poverty among 

small farmers. The Green Plan provides incentives for farmers to shift their production to 

high-value crops, predominately olives (77 percent), and consists of two “pillars.” Pillar 1 

focuses on aggregating agricultural production where possible, allowing farmers to take 

advantage of economies of scale and vertical linkages. Support is given to groups of 

farmers to upgrade existing irrigation systems and construct new irrigation projects in 

suitable areas, and extension services provide information on good production practices 

and assistance with marketing. Pillar 2 focuses on developing higher-value agricultural 

production in zones that are not irrigated, receive little rainfall, and in mountainous areas. 

The plan aims to foster the shift of 400,000 ha on 200,000 farms to olive plantings and 

other high-value crops by 2020.154 

Under the Green Plan, specific regional plans are designed to foster the goals of these two 

pillars. In regions with large volumes of olive production, these include incentives to 

extend and intensify the cultivation of olives. A number of support programs are 

available to farmers under the Green Plan, including payments of 20 to 30 percent of the 

cost of installing irrigation systems. 

“Maroc Export,” the Moroccan Center for Export Promotion, is designed to promote 

exports of products that receive support from Moroccan government projects. Maroc 

Export has increased its advertising expenditures for the marketing of Moroccan olive oil 

in the EU and the United States.155 

International Assistance 

United Nations Industrial Development Organization 

The United Nations Industrial Development Organization (UNIDO) has carried out 

several programs in Morocco to improve production methods and marketing among 

small-scale producers. Programs undertaken with UNIDO support have included a 

project to improve the productive capacity of women entrepreneurs who trained members 

of seven associations/cooperatives in more efficient olive oil production and included 

provision of a mobile olive oil production unit (2001–2003).156 Other UNIDO efforts 

included a joint project with the Morocco Ministry of Industry, Trade, and Mines and 

Spain’s Agency for International Cooperation to develop manuals describing good 

 154 Government of Morocco, ADA, “Green Morocco Plan” (accessed November 21, 2012). 155 SpecialtyFood.com, “Category Spotlight: Emerging Olive Oils,” January 1, 2012. 156 UNIDO, “Moroccan Women’s Entrepreneurship Enhanced,” n.d (accessed March 1, 2013). 
7-24

agricultural practices for Morocco’s rural olive oil producers;157 a pilot project to fund 

two food-processing centers dealing with olive oil in Chefchauen, in 2002 and 2003;158

and an ongoing project in the Meknes-Tafilet region to market a regional branded olive 

oil.159 

Millennium Challenge Corporation 

The Millennium Challenge Account (MCA) implements the development programs of 

the Millennium Challenge Compact. The compact between the United States and 

Morocco was signed on August 13, 2007, and ran for five years. A large share of the 

funds ($328.7 million of the $697.5 million total) was for the Fruit Tree Productivity 

Project.160 Goals of the MCA project were to both improve irrigation in existing irrigated 

olive groves and increase plantings in rain-fed olive groves. The original plan called for 

planting 80,000 ha of new olive groves in areas without irrigation, although the project 

was scaled back to 62,000 ha. New groves are anticipated to begin producing 1–2 kg per 

tree within 5 years, and reach full production after 8-10 years.161 Seedlings are supplied 

by local nurseries that also provide technical assistance to the farmers for the first two 

years after planting. After two years, the Ministry of Agriculture provides technical 

assistance to growers.162 In addition to the aid provided for olive cultivation, funds have 

been approved to finance four producer-owned olive-processing plants.163 Although this 

MCC assistance has been a concern of the U.S. olive oil industry, these plantings have 

not yet impacted Morocco’s production levels and, when they come into production, 

almost all of the olive oil produced by these projects will be destined for domestic 

consumption.164 

Bumpers Amendment 

A provision in U.S. law, widely known as the Bumpers Amendment, prohibits U.S. 

government support for agricultural production in a foreign country if said production 

would compete with U.S. agricultural exports to third-country markets. However, the 

Bumpers Amendment does not apply to support for foreign agricultural production that 

may compete with U.S. producers in the U.S. domestic market. A 2003 report prepared 

for the U.S. Agency for International Development found that the only markets with 

imports of both U.S. and Moroccan olive oil were Canada, France, and the United 

Kingdom. The report found that imports of olive oil from Morocco had no impact on 

olive oil prices in France or the United Kingdom, and that “Moroccan olive oil exports 

should have no negative impact on U.S. exporters.” 165 The MCC assistance is not 

expected to have a significant impact on competition between U.S. and Moroccan olive 

oil exports to third-country markets, and therefore the Bumpers Amendment does not 

apply. 

 

 157 UNIDO, “Industrious Africa,” September 2008, 2007, 22. Phase 2 of the project began in 2008, 

aimed at disseminating the information to additional rural processors. 158 UNIDO, “Food Processing Pilot Centres,” 9 (accessed March 1, 2013). 159 UNIDO representative, email to USITC staff, March 11, 2013. 160 MCC, “Morocco Compact Quarterly Status Report,” September 2012. 161 MCC representative, interview by USITC staff, Meknes, Morocco, January 28, 2013. 162 Ibid. 163 MCC, “Morocco Compact Quarterly Status Report,” September 2012. 164 Industry representatives, interviews by USITC staff, California, November 13–14, 2012; MCC 

representative, interview by USITC staff, Meknes, Morocco, January 28, 2013; industry representative, 

interview by USITC staff, Meknes, Morocco, January 28, 2013. 165 Humpal and Jacques, Draft Report on Bumpers and Import Sensitivity, November 2003, 6-8. 
7-25

Bibliography 

Azzouzi Essaid, Ahmed Laytimi, and Ali Abidar. “Effect of Incentive Policy on Performance and 

International Competitiveness of Fruits, Vegetables, and Olive Oil in Morocco.” Presentation for 

98th Seminar, European Association of Agricultural Economists, Chania, Crete, Greece, June 29–

July 2, 2006. 

Bennani, Abdelhak Lahmam. “Huile d’olive et olives de table: Profil du consommateur marocain” [Olive 

oil and table olives: Profile of the Moroccan consumer]. Presentation at the IOC Advisory 

Committee on Olive Oil and Table Olives, October 2011. 

Butler, Julie. “Spanish Producers Call Moroccan Olive Oil Trade Deal a ‘Disaster.’” Olive Oil Times, 

February 29, 2012. 

CIA, see U.S. Central Intelligence Agency. 

Dimitriou. “GIs from the Point of View of EU.” European Commission Agriculture and Rural 

Development. 

Encyclopedia of the Earth. “Tunisia.” http://www.eoearth.org/article/Tunisia (accessed April 4, 2013). 

European Communities. Official Journal of the European Communities. Euro-Mediterranean Agreement. 

March 18, 2000. 

European Parliament. Regulation (EU) No. 1151/2012 of the European Parliament and of the Council of 

21 November 2012 on quality schemes for agricultural products and foodstuffs. 

European Union. Official Journal of the European Union. Agreement: in the form of an Exchange of 

Letters between the European Union and the Kingdom of Morocco concerning reciprocal 

liberalisation measures on agricultural products, processed agricultural products, fish and 

fishery products, the replacement of Protocols 1, 2 and 3 and their Annexes and amendments to 

the Euro-Mediterranean Agreement establishing an association between the European 

Communities and their Member States, of the one part, and the Kingdom of Morocco, of the other 

part. September 7, 2012. 

Food and Agricultural Organization of the United States (FAO). Aquastat: FAO’s Information System on 

Water and Agriculture. 

http://www.fao.org/nr/water/aquastat/data/cf/readPdf.html?f=CF_MAR_en.pdf (accessed August 

6, 2013). 

———. Olive GAP Manual, 2010. 

Ghanmi, Monia. “Tunisia Faces Labour Shortage.” Magharebia, March 14, 2013. 

http://magharebia.com/en_GB/articles/awi/features/2013/03/14/feature-04. 

Global Trade Information Service, Inc. (GTIS). Global Trade Atlas database (accessed various dates). 

http://www.gtis.com/english/GTIS_GTA.html (fee required). 

Government of Morocco. Agence pour le Développement Agricole (ADA). “Green Morocco Plan.”

http://www.ada.gov.ma/en/Plan_Maroc_Vert/plan-maroc-vert.php (accessed May 22, 2013). 
7-26

Government of Tunisia, Ministry of Industry and Technology. Tunisian Olive Oil website. “FOPROHOC 

Key Figures.” Promotion Program for Tunisian Olive Oil Newsletter 1, August 2010. 

http://www.accesstoebusiness.com/Newsletter-oil-olive-anglais/foprohoc.html. 

Government of the United Kingdom. Rural Payments Agency (RPA). Leaflet ET4. 

http://rpa.defra.gov.uk/rpa/index.nsf/15f3e119d8abcb5480256ef20049b53a/96f332aeb8d0043080

2572ff00505c37/%24FILE/ET4%20September%202009.pdf (accessed March 26, 2013). 

Hibler, Michelle. “Improving Morocco’s Olive Industry.” Science in Africa. 2003. 

Humpal, Don, and Kathleen Jacques. “Draft Report on Bumpers and Import Sensitivity Analysis for 

Moroccan Table Olives and Olive Oil.” Washington, DC: U.S. Agency for International 

Development, November 2003. 

International Monetary Fund (IMF). “Tunisia: Financial System Stability Assessment.” IMF Country 

Report No. 12/241, July 6, 2012. 

International Olive Council (IOC). Morocco 2012. IOC: Policies series, n.d. (accessed May 6, 2013). 

———. “Movements in Producer Prices.” Market Newsletter 67, December 2012. 

———. “Tables 1–4: [World] Production, Imports, Exports, Consumption.” World Olive Oil Figures, 

November 2012. http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures. 

———. Tunisia 2012. IOC: Policies series, n.d. (accessed May 6, 2013). 

———. “Tunisia Indicators.” E. 108/Doc. no. 4. Update no. 32, n.d. (accessed May 6, 2013). 

———. “U.S. Import Trends.” Market Newsletter 58, February 2012. 

Karray, Boubaker. “Olive Oil World Market Dynamics and Policy Reforms: Implications for Tunisia.” 

Institut Agronomique Méditerranéen de Montpellier, 2006. 

McEvoy, D.G., and E.E. Gomez. The Olive Industry: A Marketing Study. Rural Industries Research and 

Development Corporation Report No. 99/86, August 1999. 

Millennium Challenge Corporation (MCC). “Morocco Compact, Quarterly Status Report.” 

 September 2012. http://www.mcc.gov/documents/reports/qsr-2012002103301-morocco.pdf. 

———. Morocco Ministry of Agriculture and Marine Fisheries, and Morocco Agency of Partnership for 

Progress. “Invest in Morocco,” 2010. 

Morocco Ministry of Agriculture and Maritime Fisheries. “L’irrigation au Maroc.” ([Irrigation inof 

Morocco]). http://www.agriculture.gov.ma/pages/lirrigation-au-maroc (accessed February 11, 

2013). 

Olive Oil Emporium. “Olive Oil Process.” 

http://www.oliveoilemporium.com/OriginsoftheOlive/OliveOilProcess.aspx. n.d. (accessed 

June 19, 2013). 

Olive Oil Times. “Los Angeles Extra Virgin Olive Oil Awards by Medal,” 

http://static.oliveoiltimes.com/library/2012-LA-winners.pdf (accessed June 19, 2013). 
7-27

Regional Activity Centre for Cleaner Production. “Olive Oil Production and Processing Going ‘Green’ in 

Morocco,” March 28, 2011. 

Republic of Tunisia, Ministry of Agriculture, Office Nationale de l’Huile (ONH). “Organic Olive Oil.” 

http://www.onh.com.tn/index.php/en/huile-biologique (accessed various dates). 

———. “Production.” http://www.onh.com.tn/index.php/en/la-production (accessed various dates). 

Republic of Tunisia. Ministry of Industry and Technology. “Olive Growing in Tunisia.” 

 http://www.tunisia-oliveoil.com/template.php?code=32&langue=en (accessed various dates). 

Segrest, Susan, Nicole Potenza Denis, and Eva Meszaros. “Category Spotlight: Emerging Olive Oils from 

North Africa.” Specialty Food, January 1, 2012. 

SpecialtyFood.com. “Category Spotlight: Emerging Olive Oils from North Africa.” January 1, 2012. 

http://www.specialtyfood.com/news-trends/featured-articles/article/emerging-olive-oils-northafrica/. 

Thual, David, and Fanny Lossy. Presentation of the Findings of the IOC Commissioned Study on Existing 

and Potential GIs. Insight Consulting. Presentation to the International Olive Council Seminar, 

Villa San Giovanni, Italy, October 21, 2010. 

United Nations Industrial Development Organization (UNIDO). “Industrious Africa: Selected UNIDO 

Activities in Africa.” Vol. 2. Vienna: UNIDO, September 2008. 

 

———. “Food Processing Pilot Centres: An Approach to Productive Capacity-Building for Trade and 

Poverty Alleviation in Africa.” Vienna: UNIDO, 2007. 

———. “Moroccan Women’s Entrepreneurship Enhanced,” n.d. (accessed March 1, 2013). 

U.S. Central Intelligence Agency (CIA). “Tunisia.” CIA World Factbook, April 29, 2013. 

https://www.cia.gov/library/publications/the-world-factbook/geos/ts.html. 

U.S. Department of Agriculture (USDA). Foreign Agricultural Service (FAS). Morocco: Retail Foods, by 

Idriss El Honsali. GAIN Report No. MO1213, December 12, 2012. 

———. Tunisia: Oilseeds and Products Annual; 2013 Oilseeds and Products Annual, by Youssef 

Chahed. GAIN Report no. TS1301, March 1, 2013. 

———. Tunisia: Retail Foods; 2012 Tunisia Retail Foods, by Youssef Chahed. GAIN Report no. 

TS1210, December 19, 2012. 

University of California Cooperative Extension (UCCE). Sample Costs to Establish a Super-High Density 

Olive Orchard and Produce Olive Oil in the San Joaquin Valley, 2007. 

http://coststudies.ucdavis.edu/files/oliveoilsjv2007.pdf. 

———. Sample Costs to Establish a Super-High Density Olive Orchard and Produce Olive Oil in the 

Sacramento Valley, 2007. http://coststudies.ucdavis.edu/files/oliveoilsv2007.pdf. 

Williams, Daniel. “In Italy, Spanish Olive Oil Prices Too Good to Pass Up.” Olive Oil Times, June 14, 

2013.

8-1

CHAPTER 8

New World and Middle East

Overview 

Several countries outside the European Union (EU) and North Africa are also important 

global producers of olive oil. These producers can be split into two groups. The first 

consists of Chile, Australia, and Argentina, located in the Southern Hemisphere and 

producing relatively small, but increasing, quantities of olive oil with mostly modern and 

intensive production techniques. Due to their recent emergence, these countries are 

commonly referred to as New World producers. 1 The second group consists of two 

Middle Eastern countries, Turkey and Syria, that have been growing and milling olives 

for millennia.

2 Both Syria and Turkey produce large volumes of olive oil, generally 

relying on traditional production methods and lacking modern equipment. As a result, the 

volumes and quality of oil they produce are inconsistent.

This chapter will provide a production profile of each of the New World producers as 

well as a description of the distribution outlets and the factors affecting the 

competitiveness of producers in each New World country. The chapter will then provide 

an overview of the industries in both Turkey and Syria. 

Taken together, New World and Middle Eastern countries have historically accounted for 

about 15 percent of global production annually.3 However, they are not major players in 

the global market, accounting for less than 5 percent of global exports annually between 

2008 and 2012.4 While production in New World countries has been increasing rapidly, it 

is still small compared to production in the Mediterranean, and their exports tend to be 

concentrated in regional markets. Similarly, despite larger production volumes than the 

New World countries, Syria and Turkey export mostly within the Middle East. 

New World Producers

Overview 

Only in recent years have Chile, Australia, and Argentina emerged as actors in the global 

olive oil market. These countries mainly use modern growing and milling techniques and 

produce mostly high-quality extra virgin olive oil. While domestic consumption in Chile 

and Argentina is rising, these countries have excess supplies available for export. 

Australian exports have fluctuated depending on weather and the resulting harvest, but 

exports have been rising during good crop years. Located in the Southern Hemisphere, 

these countries can supply export markets with fresh olive oil with a unique flavor profile 

 1 The United States, covered in chapter 5, is also considered a New World producer. 

2 There are other olive oil-producing countries in the Middle East, such as Lebanon, Jordan, and Israel, 

but are not considered significant global producers. 3 IOC, “Table 1: [World] Production,” November 2012. 

4 GTIS, Global Trade Atlas database (accessed June 19, 2013).
8-2

during the months when producers around the Mediterranean have limited supplies and 

are using olive oil that has been stored since the previous harvest. The New World 

producers are also major exporters of wine. This provides marketing expertise and 

existing distribution networks through which to establish themselves as suppliers of highquality oil to the world.

Despite their recent production and export growth, New World producers must overcome 

several challenges if they are to expand further. First, they must compete with established 

European producers that benefit from scale, government support, and low costs of 

production. In addition, studies have found that some of the olive varieties grown in New 

World countries contain naturally occurring chemical traits that prevent their oil from 

meeting current International Olive Council (IOC) standards for extra virgin. This could 

restrict demand for their oils in IOC member countries. Another challenge for New 

World producers, like many producers in the United States, is differentiating their 

products based on quality. As discussed in chapter 3, some view the IOC standards as 

weak and lacking international enforcement, allowing large volumes of lower-quality oils 

to be labeled as extra virgin. 

Chile 

Chile has garnered global attention because of the high quality of the oils produced in the 

country and the rapid growth of its olive oil sector. Furthermore, as noted above, the 

country’s Southern Hemisphere location means that the oils produced there have a 

different freshness profile than their Northern Hemisphere competitors, which is an 

advantage both for the country’s bulk olive oil exports and for branded consumer 

products. Chilean firms have been able to use their marketing experience and networks 

from the country’s wine and other horticultural industries to break into the global market 

for the highest-quality olive oil. 

Production Profile 

Production overview

Historically, olives have been grown on a small scale in Chile since they were brought to 

the country by the Spanish in the 16th century. But it was not until the 1990s that

significant investment in the industry began. Area planted to olives grew substantially 

over the past decade, rising from an estimated 4,158 hectares (ha) (about 10,270 acres) in 

1999 to 24,000 ha (almost 60,000 acres) in 2010.5 This expansion in area triggered a 75-

fold increase in olive oil production, from 288 metric tons (mt) in 1999 to an estimated 

21,500 mt in marketing year (MY) 2011/12 (table 8.1). 6 Furthermore, the Chilean 

Association of Olive Oil Producers (ChileOliva) projects that olive-growing area may 

expand by an additional 9,000 ha (22,200 acres) by 2020, with total oil production 

volume estimated to reach 46,000 mt. 7 Such an increase would make

 5 The Chilean Ministry of Agriculture’s Office of Research and Agricultural Policy (ODEPA) estimates 

that 80 percent of this acreage is destined for olive oil use, with the remaining 20 percent producing table 

olives. See Sudy Bustamante and Cortés Tirado, Aceite de oliva [Olive oil], January 2012, 11, 12. 6 Sudy Bustamante and Cortés Tirado, Aceite de oliva [Olive oil], January 2012, 14; IOC, “Table 1: 

[World] Production,” November 2012. 7 This expansion would be equivalent to a 38 percent increase in area from 2010 and a 114 percent 

increase in production volume since 2011/12. See Sudy Bustamante and Cortés Tirado, Aceite de oliva [Olive 

oil], January 2012, 12. Industry representative, email to USITC staff, February 13, 2013. 
8-3

TABLE 8.1 Chile: Olive oil supply, consumption, and trade, 2000/01, and 2007/08–2012/13 (1,000 mt)

2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13 

Production (

c

) 6.5 8.5 12.0 16.0 21.5 21.5 

Imports (

c

) 0.5 1.0 0.5 0.5 0.5 0.5 

Consumption (

c

) 5.5 7.5 9.0 10.0 10.0 10.0

Exports (

c

) 1.5 2.0 3.0 6.5 11.5 11.5 

Source: IOC, “Tables 1–4: [World] Production, Imports, Exports, Consumption,” November 2012.

Note: A marketing year spans October 1 to September 30 the following year.

a

Provisional.

b

Projected.

c

Not available.

Chile the world’s seventh-largest olive oil producer, up from virtually no production at 

the beginning of the 2000s.8

Olive-growing sector 

As in the United States, most Chilean olive growers are small enterprises, but the bulk of 

the oil produced comes from a few large farms. In 2011, an estimated 10 firms accounted 

for approximately one-third of the country’s total harvested area.9 While there has not 

been an official census of the total number of olive growers in Chile, ChileOliva has 39 

members, which account for about 85 percent of the country’s total production volume.10

An estimated 60 percent of the total planted area is cultivated by producers with 500–

1500 ha (1,235–3,700 acres), while around 20 percent of planted area belongs to growers 

with 200–500 ha (500–1,235 acres), with small producers representing the remainder.11

Because the majority of olive groves were planted over the last decade, growers were 

able to use state-of-the-art production technology innovations. All acreage is irrigated, 

and even small producers are increasingly using mechanical harvesting to reduce their 

labor costs; around 80 percent of commercial groves are harvested mechanically.12 Many 

new plantings are using the super-high-density (SHD) production system, estimated to 

represent around 70 percent of planted area.13 The prevalence of the SHD system means 

that most olives grown in Chile are of varieties adapted to SHD production.

14

Olive oil processing sector 

In a 2012 inventory of the country’s horticultural food processors, the government of 

Chile identified 36 plants processing olives for olive oil.15 Most of these plants were 

 8 This counts the EU as one country, so that the EU, Tunisia, Syria, Turkey, Morocco, and Algeria 

would be the only countries producing more olive oil than Chile, were the forecast to be realized. 9 Portal Olivícola, “Chile: desafíos” [Chile: challenges], September 22, 2011. 10 Industry representative, email to USITC staff, February 13, 2013. 11 Ibid. 12 Orellana, “Industria olivícola” [Olive industry], August 29, 2012; industry representative, email to 

USITC staff, February 13, 2013. 13 Industry representative, email to USITC staff, February 13, 2013. 14 Just less than 50 percent of production is of the Arbequina variety, followed by Frantoio (18 percent), 

Arbosana (8 percent), Picual (8 percent), and Leccino (5 percent). ChileOliva, “Extra Virgin Journey,” n.d. 

(accessed March 18, 2013). 15 Ideaconsultora, Actualización del Catastro [Updating the registry], March 2012, 82.
8-4

located in the O’Higgins, Maule, Valparaíso, and Coquimbo regions, with the O’Higgins 

and Maule regions accounting for the majority of Chile’s production in MY 2010/11.16

The olive oil processing industry grew up alongside the olive-growing industry. For this 

reason, nearly all olive oil processing facilities were constructed after the year 2000; as a 

result, Chilean mills are equipped with the latest technology.17 The country’s total milling 

capacity is estimated at 159 mt per hour, with the greatest capacity in Coquimbo (52 mt 

per hour) followed by Maule (46 mt per hour).18 Even in the busiest milling months just 

after harvest, total plant utilization is estimated at just 70 percent of installed capacity, 

suggesting that there is room for future growth in production.19 In fact, most plants are 

either undergoing expansion or have new investments planned in anticipation of further 

growth in the sector.20

Vertical integration is more common in the Chilean olive oil sector than in most 

competitor countries. Slightly more than 55 percent of mills exclusively process olives 

that come from the company’s own olive-growing holdings.21 Additionally, 22 percent of 

mills derive a majority of their production from their own olives, but also source from 

intermediaries or contract with outside growers. This level of vertical integration means 

that most firms have complete oversight over their entire supply chain.

Distribution Outlets 

Domestic consumption 

In MY 2012/13, about 47 percent of Chilean olive oil production is expected to be sold 

into the domestic market. In 2011, 84 percent of domestic shipments were packaged for 

direct consumption and 16 percent was sold in bulk.22 Increased production has allowed 

Chile to substantially reduce imports, which now account for about 5 percent of domestic 

supplies.23 Although this small import share is largely a function of the country’s low 

consumption, this level of import penetration is drastically lower than that of many other 

New World producers.

24

Per capita olive oil consumption in Chile was estimated at 0.63 liters in MY 2011/12—

lower than in the United States, but greater than in neighboring Brazil and Argentina.25

At the same time, consumption is growing, with a 75 percent increase in per capita 

consumption from MY 2007/08 to MY 2010/11.26 This domestic consumption growth 

was driven by greater consumer awareness of olive oil’s health benefits.27 At the same 

time, olive oil is viewed as a gourmet product because of its price relative to other 

 16 Ibid., 8–84, 95. 17 Ibid., 83, 88. 18 Ibid., 86. 19 Ibid., 90. 20 Ibid., 91. 21 Ibid. 22 Ibid., 4. 23 Sudy Bustamante and Cortés Tirado, Aceite de oliva [Olive oil], January 2012, 14, 18. 24 Australia and the United States import about 73 percent and 97 percent, respectively, of their 

domestic consumption; IOC, “Tables 1–4: [World] Production, Imports, Consumption, Exports,” 

November 2012. 25 IOC, “Table 4: [World] Consumption,” November 2012; FAO, FAOSTAT database (accessed 

April 15, 2013).

26 IOC, “Table 4: [World] Consumption,” November 2012. 27 Industry representative, email to USITC staff, February 13, 2013.
8-5

cooking oil choices, and one of the challenges that the domestic industry faces is 

positioning itself as both high-quality and accessible to consumers of various income 

levels.28

Exports 

During MY 2012/13, about 53 percent of production is expected to be exported.29 An 

estimated 33 percent of exports by volume in 2012 were bottled for direct consumption,

and 67 percent were shipped in bulk.

30 Exports of virgin or extra virgin olive oil 

accounted for 94 percent of total Chilean exports between 2008 and 2012.31 Like the 

majority of the country’s production, most exports are reportedly extra virgin.

In 2012, Chilean olive oil exports reached 10,200 mt, valued at $36 million, making 

Chile the fifth-largest exporter in the world by value.32 Chile’s primary export markets 

are the United States, Italy, Spain, and Brazil. Despite Chile’s focus on those markets, 

their market share in each of those countries is limited—Chilean olive oils account for 2 

percent of U.S. imports, 1 percent of Brazil’s imports, and less than that for Italy and 

Spain.33 But Chile’s strategy is not one of dominating markets on a volume basis. Rather, 

the industry is concentrated on strengthening the high quality reputation of its oils. For 

this reason, the industry has focused its marketing efforts on the high-value food sectors 

both in high-income countries, like the United States and Japan, as well as in certain 

rapidly developing countries, like Brazil and China.34

Factors Affecting Competitiveness

Chile has emerged as a small, but notable producer of olive oil over the past decade. It 

has been able to rapidly expand production because its costs are competitive with other 

origins. Chilean producers also have a small marketing advantage as a Southern 

Hemisphere producer with a different harvesting window than most large olive oilproducing countries. Moreover, Chile has an established reputation as a producer of highquality horticultural products, and olive oil producers have been able to take advantage of 

these previously established distribution channels. Chilean producers have made strides

at marketing themselves as a high-quality olive oil source, but the rapid growth of their 

olive-growing sector may present challenges in finding sufficient marketing outlets for 

their products. Since their domestic market is small, Chilean producers must move their 

product into the global market, in contrast with other New World producers who may 

have more sales opportunities in their own domestic market.

 28 Industry representative, email to USITC staff, February 13, 2013; Portal Olivícola. “Arturo Leiva,” 

January 19, 2012. 29 IOC, “Table 1 and 3: [World] Production and Exports,” November 2012; FAO, FAOSTAT database 

(accessed April 15, 2013). 30 In this instance, bottled for direct consumption is used to convey that the product was shipped in 

containers of 5 liters or less, with bulk shipments denoting product shipped in containers of greater than 5 

liters. See Servicio Nacional de Aduanas Chile, Arancel aduanero vigente [Current customs duties], August 

10, 2011; GTIS, Global Trade Atlas database (accessed June 19, 2013). 31 GTIS, Global Trade Atlas database (accessed June 19, 2013). 32 This figure counts the EU as one country, making the top four exporters the EU, Tunisia, Turkey, 

and Argentina. GTIS, Global Trade Atlas database (accessed June 19, 2013). 33 GTIS, Global Trade Atlas database (accessed June 19, 2013). 34 Industry representative, email to USITC staff, February 13, 2013.
8-6

Production costs 

On both a per hectare and a per kilogram (kg) of oil produced basis, Chile is a costcompetitive producer of high-quality olive oil. Chilean planting costs for SHD olive 

groves are similar to those found in the United States.35 Operating costs for SHD growers 

in Chile were estimated at $1.04–$1.18 per kg in 2010, or approximately $2,492 per ha, 

which are competitive with even the lowest-cost European producer. 36 Chile’s 

competitive cost structure is due to several factors. First, the high percentage of SHD 

producers means that average labor costs are low because of the prevalence of 

mechanized harvesting. Chile’s geographic isolation (surrounded by desert, mountains, 

and ocean) also reduces agrichemical costs because these natural barriers form 

boundaries against pests and diseases.

37 The country also offers good access to financing 

at low rates, which helps new producers get started and aids established producers in 

upgrading their operations.38

Southern Hemisphere location 

Owing to its location in the Southern Hemisphere, Chile harvests its olives between midMay and mid-July, whereas the Northern Hemisphere harvest occurs from October 

through February.39 For this reason, Chilean oil has a different freshness window than 

oils from Europe, North Africa, and the United States. This is an advantage for both 

single-origin niche oils whose “best before” dates fall into a different window, and also 

for bulk oil that may be purchased by North American or European blenders looking for a 

certain freshness and taste profile.40 When Southern Hemisphere oils become available, 

blenders combine them with older Northern Hemisphere oils for balance and to achieve 

their desired chemical and taste profiles. 

Reputation for high quality 

The Chilean olive oil sector has always focused on producing a high-quality olive oil, 

partly because the industry felt that it would be a struggle to compete on the basis of 

quantity while trying to remain profitable. 41 Chile has a reputation as a high-quality 

producer of food products (including wine, berries, and other fruit) and growers in the 

country were able to use both their reputation and their previously established marketing 

channels to get their products into high-value gourmet food markets.42

Chilean-produced olive oil is able to maintain its position or expand further into these 

markets because it is a high-quality product. An estimated 90 percent of Chilean olive 

oils are extra virgin, and they have some of the lowest acidity levels in the world, which 

 35 SHD planting costs in Maule, Chile, were estimated at $9,590 per ha (about $3,880 per acre) in 2010. 

This estimate includes agricultural investments (trees, irrigation systems, trellising, labor for planting the 

orchard, etc.), which are similar to the U.S. costs outlined in UCCE, “Sample Costs to Establish: Sacramento 

Valley,” 2007. See Navarette Bustamente et al., “Informe Centro de Competitividad del Maule” [Maule 

Competitiveness Center report], August 2010, 54–55. 36 USITC staff calculcation based on Navarette Bustamente et al., “Informe Centro de Competitividad 

del Maule” [Maule Competitiveness Center report], August 2010, 56–57; AEMO, “Aproximación a los 

Costes del Cultivo del Olivo” [Approximation of the costs of olive growing], June 2010. 37 Sudy Bustamante and Cortés Tirado, Aceite de oliva [Olive oil], January 2012, 11. 38 Industry representative, email to USITC staff, February 13, 2013. 39 Ediciones Especiales, “Calidad que conquista” [Quality that is conquering], April 26, 2012, 2. 40 Industry representative, interview by USITC staff, Maryland, December 20, 2012. 41 Industry representative, email to USITC staff, February 13, 2013. 42 Olint, “2001: Chile, an Opportunity,” n.d. (accessed October 15, 2012); industry representative, 

email to USITC staff, February 13, 2013.
8-7

is one indicator of oil quality and freshness. 43 Also, Chilean oils have captured 

international notice in recent years by placing well at some highly visible olive oil 

competitions.44

Opening sufficient marketing channels to keep pace with production 

Since Chile is not a traditional producer of olive oil, many foreign consumers do not yet 

recognize the country as a source of olive oil of any kind, let alone one of quality.45 At 

the same time, production is rapidly growing, and finding enough marketing outlets for 

increased supply will be one of Chile’s main challenges.46 This will require both opening 

new markets and increasing consumer awareness of Chilean oils in established ones, and 

Chilean producers are focusing on both strategies.47 Regarding the first goal, ChileOliva 

plans to increase Chilean olive oil’s presence in certain developing-country markets (such 

as Brazil, China, and Russia) by participating in food shows and hosting promotional 

events for potential buyers.48 Like producers in the United States, Chilean producers are 

concerned about being crowded out of domestic and international markets by lowerquality producers.49

In an effort to strengthen its U.S. market position, ChileOliva has undertaken a new U.S.-

focused marketing campaign targeting specific high-income cities where consumers are 

already purchasing olive oil: New York, Miami, and Boston.50 The campaign, consisting

of tastings, a social media presence, and prominent advertisement buys, is designed to 

attract consumers looking for gourmet, high-quality products and who are less price 

sensitive than typical consumers.51

Australia 

Australia started producing olive oil in significant quantities only over the last decade. 

However, in a relatively short time, the oil olive industry has developed rapidly, 

employing intensive layouts of olive groves, modern irrigation and farm management 

practices, mechanized harvesting, and advanced milling technologies. Australia’s olive 

oil producers benefit not only from an established base of domestic consumers, but also 

from ready access to export markets in the rapidly growing Asian economies.52 But the 

Australian olive oil sector faces several challenges, including severe weather that has

harmed yields in recent years and imports that capture a large share of domestic 

consumption while offering lower prices than domestically produced oils.

 43 Portal Olivícola, “Chile lanza campaña” [Chile launches a campaign], April 16, 2012. 44 In March 2012, a Chilean oil took first prize at the Sol de Oro competition in Verona, Italy. Similarly, 

at the 2012 Los Angeles International Extra Virgin Olive Oil Competition, two Chilean oils won “Best of 

Class” Gold Medal designations. See Higgins, “Chile’s TerraMater,” March 7, 2012; Los Angeles, “Awards 

by Country,” n.d. (accessed December 19, 2012). 45 Portal Olivícola, “Chile: desafíos” [Chile: challenges], September 22, 2011. 46 Tapia Mayer, “La sorprendente campaña” [The surprising campaign], November 19, 2012, 4; 

Moraga Vásquez, “El Ambicioso Plan” [The ambitious plan], August 1, 2011, 1. 47 Portal Olivícola. “Arturo Leiva,” January 19, 2012. 48 Tapia Mayer, “La Sorprendente Campaña” [The surprising campaign], November 19, 2012, 4; 

ProChile, “Alimentos chilenos” [Chilean foods], May 9, 2012; ProChile, “Empresarios chilenos” [Chilean 

entrepreneurs], September 13, 2012; industry representative, email to USITC staff, February 13, 2013. 49 Moraga Vásquez, “El Ambicioso Plan” [The ambitious plan], August 1, 2011, 3. 50 Portal Olivícola, “Chile lanza campaña” [Chile launches a campaign], April 16, 2012. 51 Tapia Mayer, “La sorprendente campaña” [The surprising campaign], November 19, 2012, 1–2. 52 Government of Australia, Australia Olive Oil Industry Research, August 2010, 6.
8-8

Australia and the United States share many similarities as producers and consumers of 

olive oil. Both countries have modern industries that produce high-quality olive oil, yet 

account for only a small portion of domestic consumption.53 And, as in the United States, 

there is concern among both consumers and producers that many imported extra virgin 

olive oils sold in Australia do not meet international standards for extra virgin. 

Reportedly, Australian consumer confidence in olive oil has declined in no small part 

because current international standards for olive oil are viewed as weak and often not 

enforced. 54 As a result, Australian producers advocate the use of various new testing 

methods to measure the quality of olive oil, similar to the position of producers in 

California. The two industries commonly work together on research to develop and 

measure the effectiveness of new chemical tests for defining the extra virgin grade.

55

Production Profile 

Australia is a relatively new producer in the global olive oil market. Rapid expansion of 

olive grove plantings in the 1990s allowed rapid increases of olive oil production in the 

first decade of the 2000s.56 Starting around MY 2003/04, Australian olive oil producers 

began to increase their share in the domestic market at the expense of imports, while at 

the same time establishing an export distribution chain. Because of the late development

of the olive oil industry compared with traditional Mediterranean suppliers, Australia 

employed modern production technologies in establishing its olive groves.

57 Australia’s 

olive oil production is very concentrated—one company produces half of the country’s 

olive oil—and growers are typically vertically integrated with mills and bottlers using 

their own marketing labels.

Production overview 

Australia is projected to produce 19,000 mt of olive oil in MY 2012/13, a 27 percent 

increase from MY 2008/0958 and part of a decade-long growth trend (table 8.2). Strong 

olive oil production growth occurred in spite of severe droughts and extreme 

temperatures during 2006–09 that constrained olive grove yields and output.

59 According 

to industry representatives, extreme weather conditions also exacerbated normal interyear 

fluctuations in production in certain regions of Australia.

60

 53 USITC, hearing transcript, December 5, 2012, 148–49 (testimony of Leandro Ravetti, Boundary 

Bend Limited).

54 Ibid. 55 Both countries jointly strive to improve the current international standards for extra virgin olive oil 

by incorporating what they view as the most modern chemical tests, such as those that use pyropheophytins 

(PPPs) and 1,2-diacylglycerol (DAGs). 56 Industry representative, email to USITC staff, February 4, 2013. 57 Rabobank, New World versus Old World Olive Oil, August 2012, 5. 58 IOC, “Table 1: [World] Production,” November 2012. 59 Industry representative, email to USITC staff, February 4, 2013. 60 The members of the Australian Olive Association (AOA) represent about 85 percent of national 

production. In constructing its 2013 projections, the AOA has incorporated production estimates starting with 

2009 that vary dramatically from year to year. The variation is caused by the after effects of the droughts and 

relatively low water supplies affecting Australia, which causes more prominent fluctuations in yields during 

alternating years. The AOA production figures are based on their marketing calendar, which differs from the 

IOC marketing year. Harvests in Australia begin in April and run through July. Marketing typically begins in 

June for the year’s harvest. There are additional disparities between IOC production levels and trends and the 

AOA’s estimates. Industry representative, emails to USITC staff, February 4, 2013, and March 10, 2013. 
8-9

TABLE 8.2 Australia: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt)

2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 1.0 12.0 15.0 18.0 18.0 19.0 19.0 

Imports 30.0 27.0 28.5 35.0 32.0 31.5 31.0 

Consumption 31.0 35.0 37.0 44.0 44.0 44.5 42.5

Exports (

c

) 4.0 6.5 8.0 6.0 7.0 8.0 

Source: IOC, “Tables 1–4: [World] Production, Imports, Exports, Consumption,” November 2012.

Note: A marketing year spans October 1 to September 30 the following year.

a

Provisional.

b

Projected. 

c

Not available.

Olive growing sector 

In Australia, there are about 16,200 commercial hectares (approximately 40,000 acres) of 

olive trees for oil production. 61 Most Australian commercial groves use intensive 

production methods, although only about 3 percent are the SHD groves typically found in 

the United States.

62 Yields in Australia fluctuate depending on location, olive varieties,

weather, and production method. For intensive groves, yields range from 8 mt to 14 mt 

per ha (3.25 to 4.25 mt of olives per acre),

63 rates that typically exceed those in Europe

(including intensive European groves) and are similar to those of the intensive and SHD 

operations in the United States and Chile.64 Oil yields vary between 12 and 20 percent, 

slightly higher than in California but lower than in Spain. 65

The olive-growing industry structure is very concentrated, with an estimated 85 percent

of production controlled by about 40 large-scale producers.66 One company, Boundary 

Bend Limited, accounts for about half of Australia’s production. In addition, there are 

about 1,500 smaller olive growers, with groves typically ranging from 2 to 4 ha (5 to 10 

acres). Maintaining the profitability of these smaller producers is a challenge for the 

industry because of high input costs and downward pressure on prices from imported 

oil.67

Olive oil processing sector

Like the olive growing sector, the olive oil processing sector in Australia is highly 

concentrated. There are about 230 mills in Australia, most using modern, continuous twophase extraction systems. Much of the industry is vertically integrated: many of the larger 

growers own their own mills and bottling plants and market their own commercial brands 

of bottled oil.68 When mills source olives off-site they tend to reward suppliers who meet 

 61 Initial plantings during the period of expansion are estimated to be about 74,000 to 82,000 acres 

based on sales of trees from nurseries in 2002, from which most current production is believed to be derived. 

However, many groves went out of production due to harsh weather or unsuitable terrain or are maintained as 

noncommercial hobby farms. Government of Australia, Australia Olive Oil Industry Research, August 2010, 

4; industry representative, email to USITC staff, February 4, 2013. 62 Industry representative, email to USITC staff, February 4, 2013. 63 Ibid. 64 Rabobank, New World versus Old World Olive Oil, August 2012, 6. 65 Industry representatives, email to USITC staff, March 10, 2013. 66 Industry representative, email to USITC staff, February 4, 2013. 67 Government of Australia, Australia Olive Oil Industry Research, August 2010, 11. 68 Industry representative, email to USITC staff, March 14, 2013.
8-10

their unique quality specifications by paying premiums of up to 50 percent above 

international prices. Premiums are based on the results of extensive testing. Testing takes 

place on the olives’ arrival and later on the oil, which is tested independently before 

being blended with oil from other sources. 

Distribution Outlets 

Domestic consumption 

Australian olive oil consumption has grown dramatically since MY 2000/01. In the four 

years between MY 2007/08 and MY 2011/12, consumption rose from 35,000 mt to 

44,500 mt, an increase of 27 percent (table 8.2).

69 While the United States and Brazil 

report higher overall consumption levels, the only two non-Mediterranean countries to do 

so, Australians actually consumed between 1.8 and 2.2 liters per capita annually during 

MY 2007/08–MY 2011/12, about twice as much as per capita consumption in the United 

States. 70 Although domestic production is increasingly displacing imported olive oil, 

imports still account for about 70 to 80 percent of annual consumption. Nearly threequarters of olive oil is purchased through grocery stores, with the remainder marketed 

through food service, manufacturing, and boutique stores.71

Exports 

Australia exported approximately 3,300 mt of olive oil worth $15 million in 2012, 

primarily of higher grades of olive oil.

72 Between 90 and 95 percent of the value of 

Australian exports is virgin or extra virgin olive oil.73 Major markets for Australian olive 

oil are China, the United States, and Italy. Historically, the United States was Australia’s 

largest overseas market, taking, on average, 38 percent of its exports (both volume and 

value) between 2008 and 2012. However, in 2012 China surpassed the United States as 

Australia’s top market by value,

74 as Chinese consumers have continued to develop an 

interest in the product and as Australian producers take advantage of their geographical 

location vis-à-vis their Mediterranean competitors.

75

Factors Affecting Competitiveness 

Australia is an efficient producer of high-quality olive oil and is geographically well 

situated to service several rapidly growing markets in Asia. The industry is also focused 

on developing domestic demand by educating consumers and by differentiating its 

product from lower-priced imports through certifications designed to capture value in 

premium olive oil markets.

 69 IOC, “Table 4: [World] Consumption,” November 2012. 70 IOC, “Table 4: [World] Consumption,” November 2012. 71 Industry representative, email to USITC staff, February 4, 2013. 72 GTIS, Global Trade Atlas database (accessed June 19, 2013). Trade data described here differ from 

the data presented in table 8.2 due to the difference in sources and because the data in table 8.2 are presented 

on a marketing year basis instead of a calendar year basis. 73 GTIS, Global Trade Atlas database (accessed June 19, 2013). 74 GTIS, Global Trade Atlas database (accessed June 19, 2013). 75 Rabobank, New World versus Old World Olive Oil, August 2012, 6.
8-11

Production volumes 

Over the past 10 years, Australia quickly developed its olive oil industry using modern, 

efficient production practices.76 However, going forward, production growth is likely to 

level off, as new plantings have declined and yields continue to be lowered by the 

aftereffects of extreme weather. Rapidly changing weather conditions have been a 

challenge in recent years, as olive producers have alternately contended with too much 

rain after years of too little. Australia’s current production capacity is likely to stabilize at

25,000 to 30,000 mt annually over the next few years.77

Location 

Australia is geographically well situated to take advantage of increasing demand in

emerging markets, such as China and India.78 China has already become Australia’s most 

important export market, and recent steps by India to reduce its olive oil tariffs offer 

additional market access opportunities for Australian producers.

79 Rising per capita 

incomes in several Asian markets has led to rapidly growing demand for higher-quality, 

higher-valued foods (e.g., beef, dairy products, wine, and other horticultural products) 

from reliable suppliers. With its proximity to Asian markets, Australia is well positioned 

to be a preferred supplier of high-quality olive oil.

Reputation for high quality

Australia has an international reputation for producing high-quality extra virgin olive 

oils.80 The use of intensive grove management means Australian olive oil is mostly extra 

virgin grade. Most olive oil producers are fully integrated, owning some, if not all, of the 

groves from which their olives are sourced. This level of vertical integration allows 

producers to constantly monitor the progress of the crop and to have strict quality 

oversight throughout the growing and milling processes.

81 The Australian olive oil 

sector’s level of integration, quality oversight, and a payment structure that incentivizes 

quality has resulted in fruity oils that have competed and won in olive oil competitions 

around the world.82

Policies and certifications 

Linked to Australia’s reputation for high quality is its role as a pioneer in the field of 

olive oil standards and testing. One way Australian oil is distinguished from other sources 

is through the Australian Code of Practice, a voluntary set of standards developed by the 

Australian Olive Association (AOA).

83 Producers that are signatories to the code abide by 

 76 Government of Australia, Australia Olive Oil Industry Research, August 2010, 6. 77 Industry representative, email to USITC staff, February 4, 2013. 78 Government of Australia, Australia Olive Oil Industry Research, August 2010, 10. 79 Indian tariffs have been reduced from 40 or 45 percent, depending on the grade of olive oil, down to 

7.5 percent. Embassy of India, “Government of India announces reduction in Duty Rates on Olive Oil,” n.d. 80 Rabobank, New World versus Old World Olive Oil, August 2012, 6. 81 Industry representative, email to USITC staff, February 4, 2013; industry representatives, interview 

by USITC staff, California, November 14, 2012. 82 Australian olive oils have scored well at various competitions, including the 2013 New York 

International Olive Oil Competition and the 2011 Los Angeles International Extra Virgin Olive Oil 

Competition. Butler, “Australia and New Zealand Shine,” April 26, 2013; Zanteson, “Los Angeles Olive Oil 

Competition,” June 9, 2011. 83 Australian Olive Association website, http://www.australianolives.com.au/content/code-of-practice

(accessed May 3, 2013).
8-12

a certain set of business and quality standards, which allows them to display a 

certification logo prominently on their labels at retail stores. Olive oils are periodically 

taken from retail outlets and tested by independent government laboratories to ensure that 

the product meets the standards. In addition to the Code of Practice, Australian olive oils 

are subject to the Australian Standards for Olive Oil and Olive Pomace Oils (AS5264-

2011), which were developed in parallel to the Code of Practice. 84

The goal of both the Australian Code of Practice and the standards is to better inform the 

consumer and to protect the integrity of the product for producers. The code and 

standards establish unique grading standards (differing slightly from those of the IOC and 

Codex Alimentarius) and testing requirements that help domestic producers to 

differentiate their products as high quality and thereby capture price premiums in the 

market. The standards are intended to better inform consumers by preventing retail labels 

from using terms deemed to be misleading, such as “extra light” and “pure.” 85

Educational efforts are also directed toward consumers and members of the supply chain 

to improve the understanding of the characteristics and value of the different grading 

specifications.86 The Australian standards also require testing to detect deodorized and 

old oil, in addition to other tests for quality.87 A further distinguishing feature of the code 

is that oils are tested for compliance at the retail level, whereas in Europe testing takes 

place at the time of bottling. For more information on the Australian standards, see 

chapter 3. 

Argentina 

Argentine olive oil production has experienced substantial growth over the past 20 years, 

propelling the country to become the world’s largest exporter of olive oil outside of the 

Mediterranean region. It is the only New World olive oil producing country with 

membership in the IOC. Domestic per capita consumption in Argentina is low, however,

and most production is exported. Similar to Australia and Chile, Argentine oil has a 

different freshness window than Northern Hemisphere oils, which is attractive for 

Northern Hemisphere blenders. However, rising delivered costs are hurting the sector’s 

competitiveness in overseas markets, causing great uncertainty about the future of the 

industry.

Production Profile 

Production overview 

Unlike many other New World producers, Argentina has a history of large-scale olive oil 

production and consumption, though sustained success and growth has proven elusive in 

the past. In the early 1990s, olive oil production became profitable in Argentina, thanks 

to increasing world prices and a revision in Argentina’s tax policy that gave incentives to 

plant new olive orchards outside traditional production areas and into the northwestern 

 84 These standards were adopted and published in July 2011 by Standards Australia, an independent 

nongovernmental Australian standards organization. 85 USITC, hearing transcript, December 5, 2012, 151 (testimony of Leandro Ravetti, Boundary Bend 

Limited).

86 Industry representative, email to USITC staff, February 4, 2013. 87 The Australian standards require both the DAGs and PPP chemical tests, which may detect olive oil 

that is not fresh, olive oil produced from poor-quality olives, or extra virgin oil blended with soft deodorized 

olive oil. For information on the debate around the DAGs and PPP chemical tests, see chapter 3. 
8-13

part of the country.88 In 2012, Argentina’s total area planted to olives was estimated at 

105,000 ha (about 260,000 acres), with roughly half for olive oil production, 30 percent 

for table olives, and the remaining 20 percent identified as dual-use.89 In MY 2011/12, 

Argentina’s olive oil production was 32,000 mt—eight times greater than production in 

MY 2000/01 (table 8.3).

90

TABLE 8.3 Argentina: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt)

2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 4.0 27.0 23.0 17.0 20.0 32.0 17.0 

Imports 5.5 (

c

) (

c

) (

c

) (

c

) (

c

) (

c

)

Consumption 6.0 7.0 5.0 5.0 5.5 6.0 6.0

Exports 4.0 18.5 14.0 19.0 12.0 23.5 17.5

Source: IOC, “Tables 1–4: [World] Production, Imports, Exports, Consumption,” November 2012.

Note: A marketing year spans October 1 to September 30 the following year.

a

Provisional.

b

Projected.

c

Not available.

Olive growing sector 

Argentina’s olive growing areas are mainly concentrated in a series of valleys at the foot 

of the Andes Mountains in the western part of the country. These valleys are extremely 

arid, but groves are irrigated from aquifers that are recharged by the Andean snowmelt.91

The Argentine olive-growing sector underwent a major structural change in the early 

1990s after the passage of the country’s Tax Deferral Acts, resulting in a split of the 

industry into two types of olive-growing operations—traditional groves planted before 

the implementation of the law, and more modern groves planted afterward.

Approximately 70 percent (75,000 ha or 185,300 acres) of the country’s total olive area

are planted in high-density (HD) systems of monovarietals, designed for mechanical 

harvesting and drip irrigation.92 These new groves typically range in size between 100 

and 1,000 ha (about 250–2,500 acres), 93 and use more sophisticated production 

techniques. Yields on these operations can reach 10–12 mt per ha (25–30 mt per acre)—

twice the level achieved under traditional systems, which account for the remaining 30 

percent of Argentina’s planted acreage.

94 The growth in operations of this type has 

shifted the bulk of production to the country’s northwestern provinces of Catamarca and 

La Rioja, accounting for 52 percent of the country’s total planted area.

95

 88 Gobbee, “El olivo en Argentina” [Olives in Argentina] (accessed April 30, 2013); Matías et al., 

“Olivicultura Argentina y regional” [Argentinian and regional olive oil growing], March 2012, 1–2. 89 An additional 10,000 ha (25,000 acres) of olive groves have yet to reach bearing age. IOC, “Policies: 

Argentina,” 2012, 5. Production area shares come from 2010, but total acreage has not changed substantially 

since that time. See Tagarelli, “Olivo” [Olives], January 2010, 33. 90 IOC, “Table 1: [World] Production,” November 2012. 91 Gobbee, “Argentina: Born to Be Extra Virgin,” January 16, 2012, 17. 92 Palma, “Olivo” [Olives], May 2010, 41; Gobbee, “Seminario de Herramientas” [Seminar on tools], 

September 13, 2010, 31. 93 Gómez del Campo et al., “Olive Growing in the Arid Valleys,” 2010, 25. 94 Ibid. 95 Other major producing provinces include San Juan (20 percent), Mendoza (16 percent), and Córdoba 

(9 percent). Gobbee and Gusman, “Argentina: Born to Be Extra Virgin,” July 2–6, 2012, 4.
8-14

Olive oil processing sector

Historically, Argentina’s olive oil mills produced mostly lower-quality olive oils because 

their primary consumers (both domestic and in Brazil, the primary export market) were 

price sensitive.

96 Producers were paid strictly on the amount of oil yielded from their 

olives, which provided an incentive to harvest late to increase oil yields, to the detriment 

of product quality.97

Today, Argentina’s olive oil processing sector has an increased focus on quality. Over the 

past 15 years, several new mills and processing facilities have sprung up in regions of 

olive grove expansion.

98 Many of these new mills are located adjacent to olive groves, 

minimizing the distance and time between harvest and milling.99 These new mills were 

built with modern technologies, have higher capacities than traditional mills, and rely 

largely on two-phase extraction systems.100 Partly because of these modernization efforts, 

more than 90 percent of Argentine olive oil is now reported to be extra virgin.101

There are an estimated 90 olive oil processing facilities in Argentina.102 Moreover, many 

new mills have up to 30 percent excess capacity to allow for the future maturation of 

recently planted trees that have not yet reached full bearing age.103 Despite the large 

number of olive oil processing facilities, the industry is highly concentrated; four 

processors account for approximately 70 percent of the country’s total production.104

Distribution Outlets 

Domestic consumption 

In MY 2011/12, only 19 percent of Argentina’s olive oil production was projected to be 

consumed domestically.105 Historically, Argentina has consumed olive oil as a result of 

its heritage of large Spanish and Italian immigrant populations. However, consumption 

has declined from historical highs because of the popularity and affordability of cheaper 

substitutes, such as sunflower oil, which reportedly cost one-tenth as much as olive oil.

106

Per capita consumption of olive oil is estimated at 0.16 liters annually, compared with 

about one liter in the United States.107 However, efforts to promote domestic olive oil and 

increase its consumption are underway. In November 2012, olive oil was declared a 

“national food,” and a Federal Program for the Promotion of Argentine Olive Oil was 

established.108

 96 SAGPyA-DNA, “Informe del Sector Olivarero” [Report on the industrialized food sector], May 2004, 

3–4. 97 Ibid. 98 Pardo et al., “Propuestas de mejoras” [Proposals for improvements], April 2010, 4. 99 MRECIC, “Informe sector alimentos industrializados” [Report on the industrialized food sector], 

2010, 17. 100 Pardo et al., “Propuestas de mejoras” [Proposals for improvements], April 2010, 3. 101 Gobbee and Gusman, “Argentina: Born to Be Extra Virgin,” July 2–6, 2012, 33. 102 IOC, “Policies: Argentina,” 2012, 7. 103 Gobbee and Gusman, “Argentina: Born to Be Extra Virgin,” July 2–6, 2012, 18. 104 IOC, “Policies: Argentina,” 2012, 7. 105 IOC, “Tables 1 and 4: [World] Production and Consumption,” November 2012. 106 FOA, “The Local Olive Growing Industry in Argentina,” 2011, 36; Gobbee and Gusman, 

“Argentina: Born to Be Extra Virgin,” July 2–6, 2012, 12. 107 IOC, “Table 4: [World] Consumption,” November 2012; FAO, FAOSTAT database (accessed 

April 15, 2013).

108 ANDigital, “El aceite de oliva” [Olive oil], November 22, 2012.
8-15

Imports represent an insignificant fraction of total domestic consumption.109 Argentine 

olive oil imports fell substantially after the country imposed countervailing duties on 

olive oil shipments from the EU in 1998.110 Additionally, the country raised the applied 

most-favored-nation (MFN) tariff rate on olive oil from 10 percent to 31.5 percent in 

October 2006.111

Exports 

In MY 2011/12, Argentina exported 73 percent of its production.112 Argentina’s principal 

export markets in 2012 were Brazil (45 percent of total exports by volume), the United 

States (32 percent), and Spain (10 percent).113 Between 2008 and 2012, 92 percent of the 

country’s olive oil exports were of at least virgin grade, while refined olive oil products 

made up the remaining 8 percent. 114 In contrast to some other New World olive oil 

exporters, Argentina depends heavily on bulk exports—from 2006 to 2010 about twothirds of export volumes were in bulk.115 Exports bottled for direct consumption have 

grown over the last 5 years, but have yet to overtake bulk sales. 

Factors Affecting Competitiveness 

Argentina is the largest olive oil exporter outside of the Mediterranean. However, the 

sector is currently struggling to remain globally competitive owing to an appreciating 

currency, stagnating global olive oil prices, and rising internal costs. The country does 

enjoy a production niche because of its position in the Southern Hemisphere, but the 

location of its groves in mountain valleys creates production challenges, with both high 

average temperatures and a tendency for some production areas to experience hard 

freezes that damage the olive trees.

Rising delivered cost 

Rising costs of delivery for Argentinian oil producers, at a time when the global industry 

experienced a period of depressed prices, led the Secretary of Agriculture for the 

province of Rioja to declare that 2012 was the worst year for the country’s olive growers 

in the past half century.116 Costs of nearly all factors of production have risen, in part due 

to high overall domestic inflation. 117 In September 2012, the Regional Agricultural 

Experimentation Consortium of Argentina (CREA) calculated that average labor costs in

 109 GTIS, Global Trade Atlas database (accessed June 19, 2013); Tagarelli, “La Olivicultura en 

Argentina” [Olive growing in Argentina], June 2011, 5. 110 Argentina applied a $1.00 per kg countervailing duty to imports of packaged olive oil from the EU, 

and a countervailing duty of $0.80 per kg for olive oil in bulk from the EU at that time. These measures were 

revoked in July of 2006. See WTO, “Semi-Annual Report: Argentina,” February 25, 1999; WTO, “SemiAnnual Report: Argentina,” February 5, 2007; Tagarelli, “Olivo” [Olives], August 2007, 48–49. 111 According to the WTO’s Tariff Analysis Online database, this was still the applied tariff rate in 

2010, the last year for which applied rates were available. See WTO, TAO database (accessed April 24, 

2013); Tagarelli, “Olivo” [Olives], August 2007, 48–49. 112 IOC, “Tables 1 and 3: [World] Production and Exports,” November 2012. 113 GTIS, Global Trade Atlas database (accessed June 19, 2013). 114 Ibid. 115 Staff calculation based on FOA, “The Local Olive Growing Industry in Argentina,” 2011, 37. 116 Portal Olivícola, “Argentina: la crisis olivícola” [Argentina: Olive sector crisis], January 3, 2013. 117 Higgins, “Argentina’s Olive Oil Industry,” March 16, 2011.
8-16

the country rose 25 percent just from 2011 to 2012.118 As a result, the costs of manual 

harvesting (a system which many Argentine olive groves still use) have more than 

doubled from 2008 to 2012.119 Labor is not only expensive but scarce, with some in the 

industry forecasting that there will not be enough seasonal workers to harvest this year’s 

crop.120 Some growers have attempted to convert their groves to mechanical harvesting to 

reduce costs and avoid labor uncertainty, but this conversion is costly and further 

complicated by the difficulty of importing both harvesters and the parts to repair them.121

Other costs, including energy prices and fertilizer, more than doubled between 2005 and 

2012.122

Cost increases have not been limited to factors of production. High internal transportation 

costs have also hurt the competitiveness of the export sector, particularly since most olive 

groves and processing plants are far from the coastal ports.123 Export taxes further hinder 

the competitiveness of the Argentine olive sector.124

Stagnant to declining global olive oil prices over the past five years further exacerbated 

the negative financial position of Argentine olive oil producers.125 In 2012, many growers 

chose not to harvest their olives because the market price for a kilo of olives was lower 

than the cost to harvest them.126 Moreover, several consecutive years of poor returns have 

jeopardized the 2013 harvest. Many farms are reportedly unable to access credit because 

of their history of recent losses, so they may be unable to finance harvesting 

operations. 127 In at least one Argentine province in 2013, the regional government 

disbursed emergency loans to finance the region’s olive harvest.128 Other growers have 

abandoned olive farming completely, shifting to almonds or pistachios.129

Location 

The location of Argentina’s olive oil industry presents both an advantage and a challenge. 

On one hand, Argentina’s location in the Southern Hemisphere means that the country’s 

olive harvest takes place at a different time of year than in the Mediterranean.130 This 

harvest schedule shifts the freshness window of Argentina’s oils, creating unique 

marketing opportunities for the country’s growers. For this reason, Argentina’s olive oils 

are important to Northern Hemisphere blenders trying to reach a certain freshness and 

 118 CREA, “Situación de la olivicultura argentina” [The situation of Argentinian olive farming], 

September 2012, 5–6. General inflation was not the only factor that contributed to high labor costs; other 

factors may have been government work programs and wage requirements. Saieg, “Emergencia en el sector 

olivícola” [Emergency in the olive-growing sector], March 24, 2012. 119 CREA, “Situación de la olivicultura argentina” [The situation of Argentinian olive farming], 

September 2012, 6. 120 Portal Olivícola, “Argentina: se agudizan” [Argentina: The olive sector’s problems], February 21, 

2013. 121 CREA, “Situación de la olivicultura argentina” [The situation of Argentinian olive farming], 

September 2012, 6. 122 CREA, “Alerta roja” [Red alert], October 22, 2012. 123 Portal Olivícola, “Argentina: se agudizan” [Argentina: The olive sector’s problems], February 21, 

2013. 124 Higgins, “Argentina’s Olive Oil Industry,” March 16, 2011. The export tax is 5 percent. 125 CAME, “Reclamo del sector olivícola” [Demands of the olive sector], December 7, 2012. 126 Saieg, “Emergencia en el sector olivícola” [Emergency in the olive sector], March 24, 2012. 127 Boyadjián, “Olivicultura: una buena cosecha” [Olive farming: A good harvest], January 27, 2013. 128 Portal Olivícola, “Argentina: aguardan los créditos” [Argentina: Growers are holding on to their 

credits], April 25, 2013. 129 CREA, “Alerta roja” [Red alert], October 22, 2012. 130 FOA, “The Local Olive Growing Industry in Argentina,” 2011, 32.
8-17

chemical profile in their oils.131 Additionally, because Argentine growers can plant olives 

in a variety of different soils and microclimates, the country can produce oils with a wide 

range of organoleptic (sensory) attributes.132

Location also creates challenges for Argentina’s olive oil industry. Most of the country’s 

olive groves are located in arid mountain valleys with higher average temperatures than 

in traditional European growing areas.133 Higher temperatures during oil synthesis likely 

worsen both oil yields and fatty acid compositions of many Argentine oils, leading to 

instability in oils of some varieties.134 Also, the higher temperatures during harvest can 

cause the olives to degrade before they even reach the mill (which in some cases are 100–

500 kilometers away from the farms where the olives were harvested), lowering oil

quality.135 On the other hand, a 2013 preliminary investigation by Argentina’s National 

Institute of Agricultural Technology (INTA) found that 65 percent of the olive groves in 

San Juan province (the province with about 20 percent of Argentina’s total olive area) 

were located in zones that experienced low temperatures far below the tolerance level of 

olive trees, calling into question the long-term viability of the industry in those areas.136

Middle Eastern Producers

Overview

Olive oil is produced throughout the Middle East, but Turkey and Syria are by far the 

largest producing countries. Together they account for more than 60 percent of annual 

Middle Eastern olive oil production and approximately 10 percent of global production.

Both Turkey and Syria rely mostly on traditional production methods and lack modern 

equipment, resulting in variable olive oil production volumes and qualities.

The main sales outlets for both Syrian and Turkish olive oil are their respective domestic 

markets. Exports are limited primarily to neighboring countries within the Middle Eastern 

region, although the potential to expand exports is much greater for Turkey than Syria. In 

Turkey, planted acreage and production continue to expand, potentially providing surplus 

product for increased exports. In contrast, after years of expansion aided by government 

support, Syrian production and exports have declined as a result of the civil war that 

began in early 2011. Both future production volumes and integration into the global 

market will depend on ending the political unrest in Syria.

Turkey

Turkey is a significant producer of olive oil. With most of its oil destined for domestic 

consumption, Turkey has not played a major role in the global export market in recent 

years. In MY 2011/12, exports of olive oil from Turkey accounted for only 2.6 percent of 

 131 In 2013, for example, several Italian companies expressed interest in sourcing supplies from 

Argentina in response to supply shortages in Europe. See Portal Olivícola, “Italianos buscan comprar” 

[Italians are looking to buy], February 13, 2013. 132 FOA, “The Local Olive Growing Industry in Argentina,” 2011, 32. 133 Gómez del Campo et al., “Olive Growing in the Arid Valleys,” 2010, 28–29. 134 Ibid., 43. 135 Ibid., 30, 41–42. 136 Portal Olivícola, “Argentina: Afirman que el 65%” [Argentina: 65% of San Juan olives], April 22, 

2013.
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global trade. 137 However, recent plantings and planned expansion of olive groves are 

expected to permit increased exports of olive oil in the future. The area under olive 

cultivation has expanded steadily—about 11 percent between 2007 and 2011—and 

improvements in harvesting methods have decreased the variation in annual production. 

As a result, Turkey’s production of olive oil has increased in each of the last five years

(table 8.4).

138

TABLE 8.4 Turkey: Olive oil supply, consumption, and trade, 2000/01, 2007/08–12/13 (1,000 mt)

2000/01 2007/08 2008/09 2009/10 2010/11 a2011/12 b2012/13

Production 175.0 72.0 130.0 147.0 160.0 191.0 195.0 

Imports 0 0 0 0 0 0 0 

Consumption 72.5 85.0 108.0 110.0 131.0 150.0 160.0

Exports 92.0 15.0 31.0 29.5 12.0 20.0 30.0 

Source: IOC, “Tables 1–4: [World] Production, Imports, Exports, Consumption,” November 2012.

Note: A marketing year spans October 1 to September 30 the following year.

a

Provisional.

b

Projected.

Government support for the olive oil industry has spurred production growth in recent 

years. Between 1998 and 2011, the government allocated Turkish lira (TL) 169 million 

(about $92.8 million at 2012 exchange rates) to the olive oil sector, with the goal of 

increasing production in order to become the world’s second-largest olive oil producer by 

2014.139 In December 2004, the second National Olive Summit, a partnership between 

the Ministry of Agriculture and public and private stakeholders, established a target of 

650,000 mt of olive oil production within a decade, compared to only 195,000 mt in 

MY 2012/13.

140 The Organisation for Economic Co-operation and Development (OECD)

reports that the government provided direct payments of TL 19.11 million in 2011, or TL

1.0 ($0.55) per kg.141 As well as incentives to plant trees, olive producers are eligible for 

reimbursement of up to 50 percent of the costs of mechanization for cultivation and 

processing. 142 Partly as a result of this support, the number of olive trees in Turkey 

increased from 100 million in 2004 to 165 million in 2012.143 Once these trees come into 

production, output is forecast to increase to 300,000 mt by 2016. 144 As Turkey’s 

production increases, exports are also expected to grow substantially over the coming 

decade.

145

Despite Turkey’s relatively low annual per capita olive oil consumption, domestic 

consumption is the primary marketing outlet for Turkish producers, accounting for more 

than 80 percent of production during MY 2007/08–MY 2011/12.

146 Turkish exports of 

olive oil fluctuated widely between 2008 and 2012, ranging from $49 million in 2011 to 

$96 million in 2009. The United States was the leading export market in 2012, followed 

 137 IOC “Table 3: [World] Exports,” November 2012. 138 Anatolia News Agency, “Periodicity No Longer Plagues Olive Sector,” October 9, 2012; Turkish 

government official, email to USITC staff, December 21, 2012. 139 Today’s Zaman, “Financial Incentives for Olive Oil Producers,” June 20, 2012. 140 IOC, “Policies: Turkey,” 2012, 10. 141 OECD, PSE Database for Turkey, Agricultural Support Estimate (accessed December 19, 2012). 142 Today’s Zaman, “Financial Incentives for Olive Oil Producers,” June 20, 2012. 143 Tan, “Actions de promotion de l’huile d’olive” (Actions to promote olive oil), July 2, 2012. 144 IOC, Market Newsletter no. 50, May 2011. 145 Olives101.com, “Turkey’s Olive Oil Exports,” October 17, 2011. 146 Turkey’s per capita consumption of olive oil is between 1.5 and 2 liters. Tan, “Actions de promotion 

de l’huile d’olive” (Actions to promote olive oil), July 2, 2012.
8-19

by Saudi Arabia and Japan. Despite its Mediterranean location, Turkey is not a major 

supplier to the EU, although in 2012 Spain was Turkey’s fourth-largest export market. 

Turkish exporters face high EU tariffs and strong competition from other suppliers, 

specifically Tunisia and Morocco, that receive preferential market access (see box 2.3).147

Turkey’s largest markets for olive oil in 2012 have very low import duties on olive oil—

5 percent ad valorem in Saudi Arabia, zero in Japan, and 3.4 to 5 cents per kg in the 

United States.148

Up until 2007, 70 percent of Turkey’s olive oil exports were in bulk. In 2007, Turkey’s 

Promotional Committee for Olive and Olive Oil was established, with the aim of 

expanding Turkey’s exports of olives and olive oil in target markets, as well as promoting

the brand and image of Turkish olives and olive oil.149 Since 2008, U.S. imports of olive 

oil from Turkey have predominately been in bottles (i.e., containers of less than 18 kg).

Through 2007, most of Turkey’s exports of both virgin and refined olive oil to the EU 

were through the EU inward processing regime described in chapter 2. Since 2007, 

Turkish producers have continued to export refined olive oil to the EU through this 

program, but have shifted exports of virgin olive oil away from the inward processing 

regime or to other markets.150

Although Turkey’s competitiveness in global markets is strengthened by government 

support and the recent emphasis on marketing, it continues to face challenges. The 

growing sector consists mostly of many small producers, using traditional methods of 

growing and milling. Small operators are not able to invest in new production methods 

(such as mechanized cultivation) and marketing, and are not able to benefit from scale 

economies. As a result, Turkey is considered a relatively high-cost producer in global 

markets.151

Syria 

Before the outbreak of its civil war in March 2011, Syria was the world’s fourth-largest 

olive oil producer.152 Production of olive oil was estimated by the IOC to have reached an 

all-time high of 198,000 mt in MY 2011/12.153 While current information about the state 

of the Syrian olive oil sector is limited because of the political unrest, production levels 

have declined dramatically since the outbreak of the war, and Syria’s role in the global 

olive oil market is now limited.154

Before the war, rising production was the direct result of government policies in the late 

1990s and early 2000s. The Syrian government reclaimed large tracts of land owned by 

the private sector, and then provided subsidized seedlings and loans to boost olive tree 

acreage.155 Production did grow, but few growers use modern equipment and production 

 147 Green Prophet, “Turkey Aims to Become World’s Second Largest,” December 27, 2009; Narrayani, 

“Turkish Olive Oil Aims for Asia,” March 1, 2011. 148 Turkey does have access to a small EU import quota of 100 mt at 7.5 percent ad valorem, as well as 

a preferential tariff rate of €112.05 per 100 kg for virgin olive oil and €127.87 per kg for other olive oil. The 

U.S. tariff ad valorem equivalent on imports is around 1 percent. 149 Promotional Committee for Olive and Olive Oil (OOPC), “About Us” (accessed December 19, 

2012). 

150 EU Commission, COMEXT, http://epp.eurostat.ec.europa.eu/portal/page/portal/eurostat/home/

(accessed May 29, 2013). 151 Turkekul et al., “The Competitiveness of Turkish Olive Oil,” April 2010, 72. 152 IOC, “Table 1: [World] Production,” November 2012. 153 Vij,“Syria Expects Record Olive Oil Production,” November 6, 2011. 154 Industry representatives, interview by USITC staff, Meknes, Morocco, January 28, 2013. 155 Mohammad, “Trade in Olive Oil in Syria,” December 2006, 9.
8-20

techniques, leading to inconsistent production volumes and qualities. As a result, Syrian 

oil has not been preferred by major global purchasers, and exports have been limited 

largely to other Middle Eastern countries (e.g., Saudi Arabia and the United Arab 

Emirates) and China.156 The civil war has further limited Syria’s ability to compete in a 

variety of export markets. Production volumes have declined, and many mills are no 

longer operating. Moreover, many buyers who traditionally sourced oil from Syria are 

unable or unwilling to do so now.157 Exports are now limited to buyers in neighboring 

countries, because shipping goods across borders has become more difficult, more 

dangerous, and more costly.158

 156 O’Sullivan, “Bumper Olive Crop Expected in Syria,” November 5, 2011. 157 Industry representative, interview by USITC staff, Meknes, Morocco, January 28, 2013. 158 Vij, “Producers in Lebanon Benefit from Reduced Syrian Imports,” November 27, 2012. 
8-21

Bibliography

AEMO. See Spanish Association of Olive Municipalities.

Agencia Noticias Digital (ANDigital). “El aceite de oliva fue declarado ‘alimento nacional’” [Olive oil 

declared “national food”], November 22, 2012. 

http://www.andigital.com.ar/noticia.php?noticia_id=26275. 

Anatolia News Agency. “Periodicity No Longer Plagues Olive Sector,” October 9, 2012. 

Boyadjián, Carlos. “Olivicultura: una buena cosecha con altos costos y precios en baja” [Olive farming: A 

good harvest with high costs and falling prices]. iEco Clarín Online, January 27, 2013. 

http://www.ieco.clarin.com/economia/Olivicultura-cosecha-altos-costosprecios_0_854914711.html. 

Butler, Julie. “Argentina to IOC: Campesterol Level Must Change.” Olive Oil Times, July 12, 2012. 

http://www.oliveoiltimes.com/olive-oil-basics/olive-oil-grades/argentina-tells-ioc-campesterollevel-must-change/27334.

———. “Australia and New Zealand Shine at International Olive Oil Competition.” Olive Oil Times,

April 26, 2013. http://www.oliveoiltimes.com/olive-oil-basics/australia-new-zealand-shine-atolive-oil-competition/34153.

———. “New World Fails in Push to Raise Campesterol Limit for Olive Oil.” Olive Oil Times, March 22, 

2013. http://www.oliveoiltimes.com/olive-oil-basics/new-world-fails-in-push-to-raisecampesterol-limit/33512.

ChileOliva. “Extra Virgin Journey,” n.d. http://www.chileoliveoil.cl/extra-virgin-journey/ (accessed 

March 18, 2013).

Confederación Argentina de la Mediana Empresa (CAME). “Reclamo del sector olivícola [Olive sector 

demands].” Circular no. 432, December 7, 2012. 

http://www.redcame.org.ar/contenidos/circular/Reclamo-del-sector-Olivicola.2446.html.

Consorcios Regionales de Experimentación Agrícola (CREA). “Alerta roja para la olivicultura” [Red alert 

for olive farming], October 22, 2012. http://www.aacrea.org.ar/index.php/alerta-roja-para-laolivicultura. 

———. “Situación de la Olivicultura Argentina: una visión desde Nodos y la zona CREA Valles 

Cordilleranos” [The situation of Argentinian olive farming: An overview from Nodos and the 

CREA Valles Cordilleranos zone], September 2012. 

http://www.aacrea.org.ar/images/documentos/compromiso/olivoseptiembre2012.pdf. 

Ediciones Especiales. “Calidad que conquista valiosos mercados” [Quality that is conquering valuable 

markets]. In La Tercera Edición Especial: Aceite de Oliva; Innovación y Calidad, April 26, 2012. 

http://papeldigital.info/eespecialesal/index.html?2012042601#. 

Embassy of India. “Government of India announces reduction in Duty Rates on Olive Oil.” News Release. 

http://www.indianembassy.gr/reduction.php.
8-22

Federacion Olivicola Argentina (FOA). “The Local Olive Growing Industry in Argentina: Development, 

Prospects and Potential.” OLIVÆ no. 116, 2011. 

http://www.internationaloliveoil.org/store/view/54-olivae-116-english. 

Food and Agriculture Organization of the United Nations (FAO). FAOSTAT database. 

http:///faostat.fao.org (accessed April 15, 2013). 

Global Trade Information Service, Inc. (GTIS). Global Trade Atlas database (accessed various dates). 

http://www.gtis.com/english/GTIS_GTA.html (fee required).

Gobbee, Frankie, and Alfredo Gusman. “Argentina: Born to Be Extra Virgin.” Presentation for the 18th

Extraordinary Session of the IOC Council of Members, Buenos Aires, Argentina, July 2–6, 2012. 

http://www.internationaloliveoil.org/documents/viewfile/6464-argentina-born-to-be-extravirgin/1. 

Gobbee, Frankie. “Argentina: Born to Be Extra Virgin.” NASFT Seminar, California, January 16, 2012. 

http://www.slideshare.net/latinberries/aceite-de-oliva-extra-virgen-argentina.

———. “El Olivo en Argentina: Un Poco de Historia y Cultura” [The olive in Argentina: A little history 

and culture]. Olivid Viveros Newsletter no. 83, n.d. 

http://www.olivid.com.ar/noticias/noticia329.html.

———. “Seminario de Herramientas para la Exportación de Aceituna de Mesa y Aceite de Oliva Prosap” 

[Seminar on tools for exporting table olives and olive oil]. Presentation organized by the 

Government of the Province of Rioja and PROARGEX, September 13, 2010. 

http://www.proargex.gov.ar/capacitaciones/presentaciones/13092010lr.pdf.

Gómez del Campo, M., A. Morales-Sillero, F. Vita Serman, M.C. Rousseaux, and P.S. Searles. “Olive 

Growing in the Arid Valleys of Northwest Argentina (Provinces of Catamarca, La Rioja and San 

Juan).” OLIVÆ no. 114, 2010. http://www.internationaloliveoil.org/store/view/40-olivae-114-

english. 

Government of Australia. Australia Olive Oil Industry Research, Development and Extension Plan 2010–

2015, August 2010.

Green Prophet. “Turkey Aims to Become World’s Second Largest Olive Oil Producer,” December 27, 

2009. 

Higgins, Charlie. “Argentina’s Olive Oil Industry Continues to Face Challenges.” Olive Oil Times,

March 16, 2011. http://www.oliveoiltimes.com/olive-oil-business/south-america/argentina-oliveoil-industry-challenges/13897. 

———. “Chile’s TerraMater Wins Gold.” Olive Oil Times, March 7, 2012. 

http://www.oliveoiltimes.com/reviews-opinions/extra-virgin-olive-oil-competitions/terramaterwins-gold/25279. 

———. “In Argentina, a Push to Make Olive Oil a ‘National Food’.” Olive Oil Times, October 14, 2012. 

http://www.oliveoiltimes.com/olive-oil-business/south-america/argentina-make-olive-oilnational-food/29545. 
8-23

Ideaconsultora Ltda. Actualización del Catastro de la Agroindustria Hortofrutícola Chilena, Informe 

Final [Updating the registry of the fruit and vegetable agroindustry in Chile: Final report]. 

Santiago, Chile: March 2012. http://www.odepa.gob.cl/odepaweb/serviciosinformacion/publica/Catastro_Agroindustrial_Informe_final.pdf. 

International Olive Council (IOC). Argentina 2012. IOC: Policies series, n.d. (accessed May 6, 2013).

———. “List of IOC Members,” December 2010. 

http://www.internationaloliveoil.org/estaticos/view/103-list-of-ioc-members.

———. Market Newsletter no. 50, May 2011.

———. “Tables 1–4: [World] Production, Imports, Exports, Consumption.” World Olive Oil Figures, 

November 2012. http://www.internationaloliveoil.org/estaticos/view/131-world-olive-oil-figures.

———. Turkey 2012. IOC: Policies series, n.d. (accessed May 6, 2013).

Leiva Dimter, Arturo. “Negocio mundial del aceite de oliva: oportunidades de inversión en Chile” [World 

trade in olive oil: Opportunities for investment in Chile]. Presentation for Expo Corfo, Santiago, 

Chile, May 2009. 

Los Angeles Extra Virgin Olive Oil Competition. “Awards by Country,” n.d. 

http://www.fairplex.com/wos/olive_oil_competition/AwardsCelebration/documents/2012%20AL

LFINALEVOOResults%20By%20Country.pdf (accessed December 19, 2012).

Matías, A., S. Molina, V. Aybar, J. Ladux, and J. Ortiz. “Olivicultura Argentina y Regional” [Argentinian 

and regional olive growing]. Instituto Nacional de Tecnología Agropecuario (INTA) Catamarca,

March 2012. http://inta.gob.ar/documentos/olivicultura-argentina-yregional/at_multi_download/file/Olivicultura%20argentina%20y%20regional.pdf.

Ministerio de Relaciones Exteriores, Comercio Internacional y Culto (MRECIC). Dirección de Oferta 

Exportable. Dirección General de Estrategias de Comercio Exterior. Subsecretaría de Comercio 

Internacional. “Informe sector alimentos industrializados: aceite de oliva y aceitunas” [Report on 

the industrialized food sector: Olive oil and table olives], 2010. 

http://www.argentinatradenet.gov.ar/sitio/estrategias/Informe%20Sectorial%20Aceite%20de%20

Oliva%20y%20Aceitunas.pdf. 

Mohammad, Mohammad Ali. “Trade in Olive Oil in Syria.” Commodity Brief No. 9, Government of 

Syria, Ministry of Agriculture and Agrarian Reform, National Agricultural Policy Center, 

December 2006.

Moraga Vásquez, Eduardo. “El ambicioso plan del aceite de oliva” [The ambitious plan for olive oil]. 

ChileOliva, August 1, 2011. 

http://www.chileoliva.cl/files/noticia%20emol%20revista%20del%20campo.pdf. 

Narrayani, Gita. “Turkish Olive Oil Aims for Asia.” Olive Oil Times, March 1, 2011. 

Navarrette Bustamante, Jorge, Ruth Soto Rivas, Roemil Jorquera Cornejo, Carolina Rojas Aguilar, 

Andrés Astorga, and Eddie Guerra Morales. “Informe Centro de Competitividad del Maule: 

aceite de oliva” [Maule Competitiveness Center report: Olive oil]. Centro de Competitividad del 

Maule in conjunction with the University of Talca, August 2010. 

http://www.centrodecompetitividaddelmaule.cl/files/aceite_oliva.pdf. 
8-24

Oléicole International. Thirty-ninth meeting of the Advisory Committee of the Olive Oil and Table Olives 

International Olive Council. Buenos Aires, July 2, 2012.

Olint Olive Trees. “2001: Chile, an Opportunity That Can’t Be Missed,” n.d. 

http://www.olint.com/en/2001-chile-opportunity-can%E2%80%99t-be-missed (accessed 

October 15, 2012).

Olives101.com, “Turkey’s Olive Oil Exports Expected to Reach $5 Billion by 2023,” October 17, 2011.

http://www.olives101.com/2011/10/17/turkeys-olive-oil-exports-expected-to-reach-5-bln-by2023/.

Orellana L., Francisca. “Industria olivícola reduce costos en 40% con mayor tecnología en cosecha” 

[Olive industry cuts costs 40% with better harvest technology]. Diario Financiero de Chile, 

August 29, 2012. http://w2.df.cl/industria-olivicola-reduce-costos-en-40-con-mayor-tecnologiaen-cosecha/prontus_df/2012-08-28/220649.html. 

Organisation for Economic Co-operation and Development (OECD). Agricultural Support Estimate. PSE 

Database for Turkey (accessed December 19, 2012). 

O’Sullivan, Arieh. “Bumper Olive Crop Expected in Syria.” Jerusalem Post, November 5, 2011. 

http://www.jpost.com/Middle-East/Bumper-olive-crop-expected-in-Syria.

Palma, Lelia. “Olivo” [Olives]. Revista Alimentos Argentinos, no. 48. Secretaría de Agricultura, 

Ganadería, Pesca y Alimentos (SGPyA) de Argentina, May 2010. 

http://www.alimentosargentinos.gov.ar/contenido/revista/ediciones/pdf/revista_AA_48.pdf.

Pardo, J.E., M. M. Bauzá, E.V. Araniti, J.D. Granel, and A. Silvestre. “Propuestas de mejoras para 

fábricas de aceite de oliva virgen de la provincia de Mendoza (Argentina)” [Proposals for 

improvements to virgin olive oil mills in Mendoza province, Argentina], April 2010. 

http://portalolivicola.com/descargas/propuestas_mejoras_fabricas_Mendoza1.pdf.

Portal Olivícola. “Argentina: afirman que el 65% de los olivos de San Juan se cultivan en zonas no aptas”

[Argentina: 65% of San Juan olives are said to be grown in unsuitable areas], April 22, 2013. 

http://www.portalolivicola.com/2013/04/22/argentina-afirman-que-el-65-de-los-olivos-de-sanjuan-se-cultivan-en-zonas-no-aptas/.

———. “Argentina: aguardan los créditos para cubrir los costos de la cosecha” [Argentina: Growers are 

holding on to their credits to cover harvest costs], April 25, 2013. 

http://www.portalolivicola.com/2013/04/25/argentina-aguardan-los-creditos-para-cubrir-loscostos-de-la-cosecha/.

———. “Argentina: la crisis olivícola es la peor en los últimos 50 años” [Argentina: This is the worst 

olive sector crisis in the last 50 years], January 3, 2013. 

http://www.portalolivicola.com/2013/01/03/argentina-la-crisis-olivicola-es-la-peor-en-losultimos-50-anos/. 

———. “Argentina: Se agudizan los problemas del sector olivícola” [Argentina: The olive sector’s 

problems are getting worse], February 21, 2013. 

http://www.portalolivicola.com/2013/02/21/argentina-se-agudizan-los-problemas-del-sectorolivicola/. 
8-25

———. “Arturo Leiva: ‘Tenemos una industria que aumentará su oferta, llegando en el 2015 a producir 

más de 43.000 toneladas de extravirgen’” [Argentina: Arturo Leiva: “We have an industry that 

will expand its production, reaching more than 43 000 tons of extra virgin by 2015”], January 19, 

2012. http://www.portalolivicola.com/2012/01/19/arturo-leiva-%e2%80%9ctenemos-unaindustria-que-aumentara-su-oferta-llegando-el-2015-a-producir-mas-de-43-000-toneladas-deextravirgen%e2%80%9d/.

———. “Chile: desafíos para la comercialización del aceite de oliva” [Chile: Challenges in marketing 

olive oil], September 22, 2011. http://www.portalolivicola.com/2011/09/22/chile-desafios-parala-comercializacion-del-aceite-de-oliva/. 

———. “Chile lanza campaña ‘Extra virgen de verdad’” [Chile launches its “Truly extra virgin” 

campaign], April 16, 2012. http://www.portalolivicola.com/2012/04/16/chile-lanza-campanaextra-virgen-de-verdad/. 

———. “Italianos buscan comprar aceite de oliva en Mendoza” [Italians are looking to buy olive oil in 

Mendoza], February 14, 2013. http://www.portalolivicola.com/2013/02/14/italianos-buscancomprar-aceite-de-oliva-en-mendoza/. 

ProChile. “Alimentos chilenos buscan expandirse desde Sao Paulo al interior de Brasil” [Chilean foods 

are seeking to expand into São Paulo in the Brazilian interior], May 9, 2012. 

http://www.prochile.gob.cl/noticias/alimentos-chilenos-buscan-expandirse-desde-sao-paulo-alinterior-de-brasil/. 

———. “Empresarios chilenos a la conquista de los mercados asiáticos” [Chilean entrepreneurs seek to 

conquer Asian markets], September 13, 2012. http://www.prochile.gob.cl/noticias/empresarioschilenos-a-la-conquista-de-los-mercados-asiaticos/. 

Promotional Committee for Olive and Olive Oil (OOPC). “About Us,” accessed December 19, 2012. 

http://www.olivetolive.com/Asp/Content.AspMS=1&Content=1&MN01=2&MN02=1&MN03=0&MN04=0&MN05=0&ID=36.htm. 

Rabobank. New World versus Old World Olive Oil, August 2012.

Saieg, Laura. “Emergencia en el sector olivícola” [Emergency in the olive sector]. Los Andes Noticias 

Online. March 24, 2012. http://losandes.com.ar/notas/2012/3/24/emergencia-sector-olivicola631549.asp. 

Secretaría de Agricultura, Ganadería, Pesca y Alimentos (SAGPyA). Dirección Nacional de Alimentos 

(DNA). “Informe del sector olivarero: subsector productor de aceite de oliva” [Report on the 

olive sector: Olive oil-producing subsector], May 2004. 

http://64.76.123.202/SAGPYA/economias_regionales/_olivo/_informes/informe_del_sector_oliv

arero.pdf. 

Servicio Nacional de Aduanas Chile. Arancel Aduanero Vigente [Current customs duties], August 10, 

2011. 

http://normativa.aduana.cl/prontus_normativa/site/artic/20111222/pags/20111222114144.html. 

Spanish Association of Olive Municipalities (AEMO). “Aproximación a los Costes del Cultivo del Olivo.” 

[Approximation of the costs of olive cultivation]. Presentation prepared for AEMO seminar, 

June 2010.
8-26

Sudy Bustamante, Ana X., and Pablo Cortés Tirado. Aceite de oliva [Olive oil]. Oficina de Estudios y 

Políticas Agrarias (ODEPA), January 2012. 

http://www.odepa.gob.cl/odepaweb/publicaciones/doc/4878.pdf. 

Tagarelli, Sofía. “La Olivicultura en Argentina” [Olive growing in Argentina]. Secretaría de Agricultura, 

Ganadería, Pesca y Alimentos (SGPyA) de Argentina, Subsecretaría de Desarrollo de las 

Economías Regionales, Dirección de Competitividad e Inclusión de Pequeños Productores, June 

2011. http://64.76.123.202/SAGPYA/economias_regionales/_olivo/_informes/Informe_olivo.pdf. 

———. “Olivo” [Olives]. Revista Alimentos Argentinos, no. 38. Secretaría de Agricultura, Ganadería, 

Pesca y Alimentos (SGPyA) de Argentina, August 2007. 

http://www.alimentosargentinos.gov.ar/contenido/revista/ediciones/pdf/revista_AA_38.pdf. 

———. “Olivo” [Olives]. Revista Alimentos Argentinos, no. 47. Secretaría de Agricultura, Ganadería, 

Pesca y Alimentos (SGPyA) de Argentina, January 2010. 

http://www.alimentosargentinos.gov.ar/contenido/revista/ediciones/pdf/revista_AA_47.pdf.

Tapia Mayer, Andrea. “La sorprendente campaña del aceite de oliva en U.S.A” [The surprising olive oil 

campaign in the United States]. ChileOliva, November 19, 2012. 

http://www.chileoliva.cl/files/reportaje_campo.pdf. 

Tan, Mustafa. “Actions de promotion de l’huile d’olive et des olives de table menées en Turquie”

[Actions to Promote Olive Oil and Table Oil Consumption in Turkey]. Presentation to the 39th

meeting of the Comité consultatif de l’huile d’olive et des olives de table du Conseil.

Today’s Zaman. “Financial Incentives for Olive Oil Producers,” June 20, 2012.

http://www.todayszaman.com/newsDetail_getNewsById.action?newsId=284083.

Turkekul, B., C. Günden, C. Abay, and B. Miran. “The Competitiveness of Turkish Olive Oil on the 

World Market.” Journal of Food, Agriculture and Environment 8, no. 2 (April 2010): 68–73.

Turkish Statistical Institute (TurkStat). Crop Production Statistics database (accessed May16, 2013).

http://www.turkstat.gov.tr/VeriBilgi.do?alt_id=45. 

University of California Cooperative Extension (UCCE). “Sample Costs to Establish a Super-High 

Density Olive Orchard and Produce Olive Oil in the Sacramento Valley,” 2007. 

http://coststudies.ucdavis.edu/files/oliveoilsv2007.pdf.

U.S. International Trade Commission (USITC). Hearing transcript in connection with inv. no. 332-537, 

Olive Oil: Conditions of Competition between U.S. Major Foreign Supplier Industries. 

December 5, 2012.

Vij, Vikas. “Producers in Lebanon Benefit from Reduced Syrian Imports.” Olive Oil Times, November 27, 

2012. http://www.oliveoiltimes.com/olive-oil-business/africa-middle-east/lebanon-benefitreduced-syrian-imports/31032.

———. “Syria Expects Record Olive Oil Production amid Political Unrest.” Olive Oil Times, 

November 6, 2011. http://www.oliveoiltimes.com/olive-oil-business/africa-middle-east/syriaexpects-record-olive-harvest-amid-political-unrest/21366.

World Trade Organization (WTO). “Semi-Annual Report under Article 25.11 of the Agreement: 

Argentina.” Committee on Subsidies and Countervailing Measures, no. G/SCM/N/47/ARG, no. 

99-0746, February 25, 1999. https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S001.aspx. 
8-27

———. “Semi-Annual Report under Article 25.11 of the Agreement: Argentina.” Committee on 

Subsidies and Countervailing Measures, G/SCM/N/153/ARG, no. 07-0473, February 5, 2007. 

https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S001.aspx. 

———. “Tariff Analysis Online.” http://tariffanalysis.wto.org/?ui=1 (accessed April 24, 2013).

Zanteson, Lori. “Los Angeles Olive Oil Competition Picks Cobram, Sciabica.” Olive Oil Times, June 9, 

2011. http://www.oliveoiltimes.com/reviews-opinions/extra-virgin-olive-oil-competitions/losangeles-olive-oil-competition-crowns-cobram-sciabica/16899. 

APPENDIX A 

Request Letter

   

DOCK?

" Nefliii

COMMITTEE ON WAYS AND MEANS

The Honorable Irving A. Williamson

Chairman

U.S. International Trade Commission

500 E Street, SW

Washington, DC 20436

Dear Chairman Williamson:

The Committee on Ways and Means is interested in obtaining current information on the

global competitiveness of the U.S. commercial olive oil industry. The U.S. commercial olive oil

industry has grown rapidly over the last decade, employing modern agriculture technologies and

research to capture the growing domestic demand for olive oil. The United States is the fourth

largest market in terms of olive oil consmnption. U.S. consumption of olive oil has increased

approximately 40 percent in the past ten years. Although domestic production has increased, the

vast majority of U.S. consumption is satisfied by imports.

In order to better assess the current market conditions confronting the U.S. industry, we

request that the U.S. International Trade Commission conduct an investigation under section

332(g) of the Tariff Act of 1930 (19 U.S.C. §l332(g)) and provide a report setting forth the

results of the investigation. The report should include, to the extent practicable, information and

analysis regarding the major suppliers of olive oil, particularly Spain, Italy, and North African

countries, in addition to the United States. A significant problem is the lack of information about

the commercial olive oil industry of certain major supplier countries to the U.S. market. Special

effort should be made to collect data about the major supplier countries of olive oil that have

little published historical data.

To the extent that information is publicly available, the report should contain:

I an overview of the commercial olive oil industry in the United States and major supplier

countries, including production of olives for olive oil processing, planted acreage and

new plantings, processing volumes, processing capacity, carry-over inventory, and

consumption;

0 information on the international market for olive oil, including U.S. and foreign supplier

imports and exports of olive oil in its various forms, olive oil trade between the European

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Union and North African countries, and a history of the tariff treatment and classification

of olive oil in the United States and major supplier countries;

I a qualitative and, to the extent possible, quantitative assessment of the role of imports,

standards and grading, prices, and other factors on olive oil consumption in the U.S.

market; and

I a comparison of the competitive strengths and weaknesses of the commercial olive

production and olive oil processing industries in the major producing countries and the

United States, including factors such as industry structure, input production costs and

availability, processing technology, product innovation, govemment support and other

government intervention, exchange rates, and pricing and marketing regimes, plus the

steps each respective industry is taking to increase its competitiveness.

The report should focus primarily on the 2008-2012 time period. The Committee

requests that the Commission transmit its report to Congress no later than 11 months following

the receipt of this request. It is the C0mmittee’s intent to make the Commission’s report

available to the public in its entirety. Therefore, the report should not include any confidential

business information.

Thank you for your attention to this request.

incerely,

l/\/\£/

Dave Camp

Cc: Rep. Sandy Levin, Ranking Member

A-4
APPENDIX B 

Federal Register Notice

   

61026 Federal Register / Vol. 77, No. 194 / Friday, October 5, 2012 / Notices 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 332–537] 

Olive Oil: Conditions of Competition 

Between U.S. and Major Foreign 

Supplier Industries 

AGENCY: United States International 

Trade Commission. 

ACTION: Institution of investigation and 

scheduling of hearing. 

SUMMARY: Following receipt on 

September 12, 2012, of a request from 

the Committee on Ways and Means 

(Committee) of the House of 

Representatives under section 332(g) of 

the Tariff Act of 1930 (19 U.S.C. 

1332(g)), the U.S. International Trade 

Commission (Commission) instituted 

investigation No. 332–537, Olive Oil: 

Conditions of Competition between U.S. 

and Major Foreign Supplier Industries. 

DATES: 

November 14, 2012: Deadline for 

filing requests to appear at the public 

hearing. 

November 21, 2012: Deadline for 

filing prehearing briefs and statements. 

December 5, 2012: Public hearing. 

December 12, 2012: Deadline for filing 

posthearing briefs and statements. 

February 12, 2013: Deadline for filing 

all other written submissions. 

August 12, 2013: Transmittal of 

Commission report to the Committee. 

ADDRESSES: All Commission offices, 

including the Commission’s hearing 

rooms, are located in the United States 

International Trade Commission 

Building, 500 E Street SW., Washington, 

DC. All written submissions should be 

addressed to the Secretary, United 

States International Trade Commission, 

500 E Street SW., Washington, DC 

20436. The public record for this 

investigation may be viewed on the 

Commission’s electronic docket (EDIS) 

at http://www.usitc.gov/secretary/ 

edis.htm. 

FOR FURTHER INFORMATION CONTACT: 

Project leader Brendan Lynch (202–205– 

3313 or brendan.lynch@usitc.gov) or 

deputy project leader Alison Rozema 

(202–205–3458 or 

alison.rozema@usitc.gov) for 

information specific to this 

investigation. For information on the 

legal aspects of this investigation, 

contact William Gearhart of the 

Commission’s Office of the General 

Counsel (202–205–3091 or 

william.gearhart@usitc.gov). The media 

should contact Margaret O’Laughlin, 

Office of External Relations (202–205– 

1819 or margaret.olaughlin@usitc.gov). 

Hearing-impaired individuals may 

obtain information on this matter by 

contacting the Commission’s TDD 

terminal at 202–205–1810. General 

information concerning the Commission 

may also be obtained by accessing its 

Internet server (http://www.usitc.gov). 

Persons with mobility impairments who 

will need special assistance in gaining 

access to the Commission should 

contact the Office of the Secretary at 

202–205–2000. 

Background: As requested by the 

Committee, the Commission will 

conduct an investigation and prepare a 

report on the conditions of competition 

between U.S. and major foreign supplier 

industries. As requested and to the 

extent that information is publicly 

available, the report will include the 

following— 

1. An overview of the commercial 

olive oil industry in the United States 

and major supplier countries, including 

production of olives for olive oil 

processing, planted acreage and new 

plantings, processing volumes, 

processing capacity, carry-over 

inventory, and consumption; 

2. Information on the international 

market for olive oil, including U.S. and 

foreign supplier imports and exports of 

olive oil in its various forms, olive oil 

trade between the European Union and 

North African countries, and a history of 

the tariff treatment and classification of 

olive oil in the United States and major 

supplier countries; 

3. A qualitative and, to the extent 

possible, quantitative assessment of the 

role of imports, standards and grading, 

prices, and other factors on olive oil 

consumption in the U.S. market; and 

4. A comparison of the competitive 

strengths and weaknesses of the 

commercial olive production and olive 

oil processing industries in the major 

producing countries and the United 

States, including factors such as 

industry structure, input production 

costs and availability, processing 

technology, product innovation, 

government support and other 

government intervention, exchange 

rates, and pricing and marketing 

regimes, plus the steps each respective 

industry is taking to increase its 

competitiveness. 

The Committee asked that the report 

focus primarily on the period 2008– 

2012 and that the Commission deliver 

its report by August 12, 2013. The 

Committee also stated that it intends to 

make the Commission’s report public. 

Public Hearing: The Commission will 

hold a public hearing in connection 

with this investigation at the U.S. 

International Trade Commission 

Building, 500 E Street SW., Washington, 

DC, beginning at 10:30 a.m. on 

Wednesday, December 5, 2012. Requests 

to appear at the public hearing should 

be filed with the Secretary not later than 

5:15 p.m., November 14, 2012, in 

accordance with the requirements in the 

‘‘Submissions’’ section below. All 

prehearing briefs and statements should 

be filed with the Secretary not later than 

5:15 p.m., November 21, 2012; and all 

posthearing briefs and statements 

responding to matters raised at the 

hearing should be filed with the 

Secretary not later than 5:15 p.m., 

December 12, 2012. All hearing-related 

briefs and statements should be filed in 

accordance with the requirements for 

filing written submissions set out below. 

In the event that, as of the close of 

business on November 14, 2012, no 

witnesses are scheduled to appear at the 

hearing, the hearing will be canceled. 

Any person interested in attending the 

hearing as an observer or nonparticipant 

may call the Office of the Secretary 

(202–205–2000) after November 14, 

2012, for information concerning 

whether the hearing will be held. 

Written Submissions: In lieu of or in 

addition to participating in the hearing, 

interested parties are invited to file 

written submissions concerning this 

investigation. All written submissions 

should be addressed to the Secretary, 

and all such submissions (other than 

prehearing and posthearing briefs and 

statements) should be received not later 

than 5:15 p.m., February 12, 2013. All 

written submissions must conform with 

the provisions of section 201.8 of the 

Commission’s Rules of Practice and 

Procedure (19 CFR 201.8). Section 201.8 

and the Commission’s Handbook on 

Filing Procedures require that interested 

parties file documents electronically on 

or before the filing deadline and submit 

eight (8) true paper copies by 12:00 p.m. 

eastern time on the next business day. 

In the event that confidential treatment 

of a document is requested, interested 

parties must file, at the same time as the 

eight paper copies, at least four (4) 

additional true paper copies in which 

the confidential information must be 

deleted (see the following paragraph for 

further information regarding 

confidential business information). 

Persons with questions regarding 

electronic filing should contact the 

Secretary (202–205–2000). 

Any submissions that contain 

confidential business information must 

also conform with the requirements of 

section 201.6 of the Commission’s Rules 

of Practice and Procedure (19 CFR 

201.6). Section 201.6 of the rules 

requires that the cover of the document 

and the individual pages be clearly 

marked as to whether they are the 

‘‘confidential’’ or ‘‘nonconfidential’’ 


pmangrum on DSK3VPTVN1PROD with NOTICES

B-3
Federal Register / Vol. 77, No. 194 / Friday, October 5, 2012 / Notices 61027 

version, and that the confidential 

business information be clearly 

identified by means of brackets. All 

written submissions, except for 

confidential business information, will 

be made available for inspection by 

interested parties. 

In the request letter, the Committee 

stated that it intends to make the 

Commission’s report available to the 

public in its entirety, and asked that the 

Commission not include any 

confidential business information in the 

report it sends to the Committee. Any 

confidential business information 

received by the Commission in this 

investigation and used in preparing this 

report will not be published in a manner 

that would reveal the operations of the 

firm supplying the information. 

By order of the Commission. 

Issued: October 1, 2012. 

William R. Bishop, 

Hearings and Meetings Coordinator. 

[FR Doc. 2012–24529 Filed 10–4–12; 8:45 am] 

BILLING CODE 7020–02–P 

DEPARTMENT OF JUSTICE 

Notice of Lodging Proposed Consent 

Decree Clean Air Act 

On October 1, 2012, the Department 

of Justice lodged a proposed Consent 

Decree with the United States District 

Court for the District of New Jersey in 

the lawsuit entitled United States and 

State of New Jersey v. Durand Glass 

Manufacturing Company, Inc., Civil 

Action No. 1:12–cv–06115–RBK–JS. 

The action involves alleged violations 

of the Clean Air Act, 42 U.S.C. 7401, et 

seq., and N.J.A.C. 7:27–22.1, et seq., at 

Durand Glass Manufacturing Company, 

Inc.’s facility located in Millville, New 

Jersey, in regard to Durand’s failure to 

comply with prevention of significant 

deterioration, new source review, and 

permit requirements. The action seeks 

civil penalties and injunctive relief. 

Pursuant to the Decree, Durand will pay 

a civil penalty of $300,000 (based on 

Durand’s inability to pay a larger 

penalty), and agreed to install advanced 

emission control devices on the three 

glass furnaces at the facility. 

The publication of this notice opens 

a period for public comment on the 

Consent Decree. Comments should be 

addressed to the Assistant Attorney 

General, Environment and Natural 

Resources Division, and should refer to 

United States, et al. v. Durand Glass 

Manufacturing Company, Inc., D.J. Ref. 

No. 90–5–2–1–09182. All comments 

must be submitted no later than thirty 

(30) days after the publication date of 

this notice. Comments may be 

submitted either by email or by mail: 

To submit 

comments: Send them to: 

By email .... pubcommentees.enrd@usdoj.gov. 

By mail ...... Assistant Attorney General, 

U.S. DOJ—ENRD, P.O. Box 

7611, Washington, DC 

20044–7611. 

During the public comment period, 

the Consent Decree may be examined 

and downloaded at this Justice 

Department Web site: http:// 

www.usdoj.gov/enrd/ 

Consent_Decrees.html. We will provide 

a paper copy of the Consent Decree 

upon written request and payment of 

reproduction costs. Please mail your 

request and payment to: Consent Decree 

Library, U.S. DOJ—ENRD, P.O. Box 

7611, Washington, DC 20044–7611. 

Please enclose a check or money order 

for $18.75 (25 cents per page 

reproduction cost) payable to the United 

States Treasury. 

Ronald Gluck, 

Assistant Section Chief, Environmental 

Enforcement Section, Environment and 

Natural Resources Division. 

[FR Doc. 2012–24562 Filed 10–4–12; 8:45 am] 

BILLING CODE 4410–15–P 

DEPARTMENT OF JUSTICE 

Notice of Lodging of Proposed 

Consent Decree Under the Clean Water 

Act and Safe Drinking Water Act 

On September 28, 2012, the 

Department of Justice lodged a proposed 

Consent Decree with the United States 

District Court for the Eastern District of 

Pennsylvania in the lawsuit entitled 

United States et al. v. GSP Management 

Company, et al., Civil Action No. 12– 

5553. 

The Consent Decree resolves alleged 

violations of the Clean Water Act and 

Safe Drinking Water Act at mobile home 

parks operated by defendants in 

Pennsylvania, Delaware and Virginia. 

The defendants treat sewage and 

provide drinking water at a number of 

its mobile home parks and illegally 

discharged sewage, failed to properly 

operate and maintain treatment 

facilities, exceeded federal drinking 

water standards for certain pollutants 

and failed to notify residents about 

drinking water problems. The Consent 

Decree requires payment of a civil 

penalty of $1,339,000, hiring a third 

party environmental consultant to 

perform environmental audits at each 

mobile home park, implementing 

corrective measures, conducting regular 

inspections, and developing a companywide environmental management 

system. 

The publication of this notice opens 

a period for public comment on the 

Consent Decree. Comments should be 

addressed to the Assistant Attorney 

General, Environment and Natural 

Resources Division, and should refer to 

United States et al. v. GSP Management 

Company, et al. D.J. Ref. No. 90–5–1–1– 

10286. All comments must be submitted 

no later than thirty (30) days after the 

publication date of this notice. 

Comments may be submitted either by 

email or by mail: 

To submit 

comments: Send them to: 

By email ... pubcommentees.enrd@usdoj.gov. 

By mail ..... Assistant Attorney General, 

U.S. DOJ—ENRD, 

P.O. Box 7611, 

Washington, DC 20044–7611. 

During the public comment period, 

the Consent Decree may be examined 

and downloaded at this Justice 

Department Web site: http:// 

www.usdoj.gov/enrd/ 

Consent_Decrees.html. We will provide 

a paper copy of the Consent Decree 

upon written request and payment of 

reproduction costs. Please mail your 

request and payment to: Consent Decree 

Library, U.S. DOJ—ENRD, P.O. Box 

7611, Washington, DC 20044–7611. 

Please enclose a check or money order 

for $15.25 for a paper copy of the 

Consent Decree without the exhibits, 

and $52.00 for a paper copy of the 

Consent Decree and all exhibits (25 

cents per page reproduction cost) 

payable to the United States Treasury. 

Robert Brook, 

Assistant Section Chief, Environmental 

Enforcement Section, Environment and 

Natural Resources Division. 

[FR Doc. 2012–24537 Filed 10–4–12; 8:45 am] 

BILLING CODE 4410–15–P 

DEPARTMENT OF JUSTICE 

Office of Justice Programs 

[OMB Number 1121–0140] 

Agency Information Collection 

Activities; Proposed Collection; 

Comments Requested: OJP Standard 

Assurances Form 

ACTION: 60-Day Notice. 

The Department of Justice, Office of 

Justice Programs will be submitting the 

following information collection request 


pmangrum on DSK3VPTVN1PROD with NOTICES

B-4
APPENDIX C 

Calendar of Hearing

   

C-3
C-4
C-5
C-6
APPENDIX D 

Summary of Position of Interested Parties

 

D-3

Summary of Views of Interested Parties 

The U.S. International Trade Commission (Commission or USITC) held a public hearing 

in relation to its investigation on global olive oil trade on December 5, 2012, in 

Washington, DC. Interested persons were also invited to file written submissions for the 

investigation. This appendix summarizes the views expressed to the Commission via 

testimony, written submissions, or both, and reflects the principal points made by the 

particular party. The views expressed in the summarized materials should be considered 

to be those of the submitting parties and not the Commission. In preparing this summary, 

Commission staff did not undertake to confirm the accuracy of, or otherwise correct, the 

information summarized. For the full text of hearing testimony, written submissions, and 

exhibits, see entries associated with investigation no. 332-537 at the Commission’s 

Electronic Docket Information System (https://edis.usitc.gov/edis3-internal/app). 

American Olive Oil Producers Association1

The American Olive Oil Producers Association (AOOPA) is a federation of U.S. olive oil 

growers, processors, and state associations that represents over 90 percent of U.S. olive 

oil production. In testimony before the USITC and in written submissions, AOOPA 

stated that the growing domestic olive oil industry faces major obstacles to its further 

expansion. Principal among these were (1) improving the image of olive oil by adopting 

quality standards to prohibit fraud, and (2) persuading foreign governments to stop 

policies and practices that distort the economics of the olive oil industry. 

Regarding the first point, AOOPA pointed to several studies that found numerous 

instances where olive oil labeled as extra virgin was found to be of a lower grade. This 

may be due to fraud in which oils are mixed into higher-quality oils and labeled as extra 

virgin, or to mislabeling, in which lower-grade olive oil is marketed as extra virgin. In 

order to ensure the integrity of the industry, AOOPA contends that olive oil must be 

correctly labeled. Toward this end, the organization is considering all mechanisms 

whereby a mandatory standard may be enforced, including the potential implementation 

of a U.S. Department of Agriculture (USDA) marketing order. The organization stressed 

that although it is exploring this possibility, no draft has been submitted to USDA, and 

there are multiple additional steps and opportunities for public comment before such an 

order could be implemented. AOOPA stated that the goal of such an order would not be 

to stop olive oil imports, but to ensure that all producers selling olive oil in the U.S. 

market adhere to the same standards for the benefit of the U.S. consumer. 

In reference to the second point, several of AOOPA’s submissions to the USITC detailed 

the various support programs and levels of support received by producers in European 

countries. AOOPA contends that these support policies reduce prices in the U.S. and 

global marketplace, which greatly affects domestic olive oil growers. 

 1

 American Olive Oil Producers Association, written submissions to the USITC, November 28, 2012; 

December 13, 2012; and February 12, 2013; USITC, hearing transcript, December 5, 2012, 144–148 

(testimony of Alexander Ott, American Olive Oil Producers Association).
D-4

Bari Olive Oil Company2

According to Mr. Kyle Sawatzky, co-owner and sales manager of Bari Olive Oil 

Company, Bari is a California olive oil producer that produced an estimated 

50,000 gallons of olive oil in the 2012/13 marketing year, using olives supplied by 

32 growers. Mr. Sawatzky testified that Bari’s olive oil sales has doubled or tripled its 

olive oil sales each year since 2008. Mr. Sawatzky asserted that Bari had grown to the 

point where it can not sell all of its oil as a niche product, but is unable to compete on 

price with imported olive oil in mainstream grocery stores. In response, he said Bari 

Olive Oil has developed a line of organic olive oil and infused olive oils. Mr. Sawatzky 

asserted that some producers of imported olive oil receive subsidies that allow them to 

sell olive oil in the U.S. market at prices below costs for producers like Bari, but stated 

that what U.S. olive oil producers need to compete in the U.S. market is an enforceable 

set of standards for both imported and domestic olive oil. 

Boundary Bend Limited3

Leandro Ravetti provided testimony on behalf of Boundary Bend Limited, the largest 

olive oil producer in Australia; he is the company’s technical director. Mr. Ravetti states 

that the United States and Australia have similar positions in the global olive oil market 

in that they are home to significant olive oil consumers and to modern olive oil industries, 

which account for only a minority of domestic consumption. Mr. Ravetti stated that the 

most widely accepted grading standards for olive oil are the Codex Standard and the IOC 

standard. He pointed out that IOC’s voting membership consists only of producing and 

exporting countries, while importing countries are not able to participate in voting. Mr. 

Ravetti also said that chemical limits imposed by European standards that utilize data 

from European oils fail to accommodate many high-quality olive oils from around the 

world, due to differences in varieties and growing conditions. Mr. Ravetti also stated that 

the Australian testing procedure is less expensive that the current IOC testing. 

Mr. Ravetti noted that there are other standards developed for grading olive oil, notably 

those from the European Commission, the United States, and Australia. He stated that 

the Australian standard is the clearest example of an alternative and that differs from the 

IOC in several areas. Mr. Ravetti noted that the Australian standard bans the use of terms 

such as “Extra Light” and “Pure” from being used on labels, as they are considered 

misleading to consumers. Finally, Mr. Ravetti pointed out that Australia’s is the only 

standard to incorporate a “best before” date policy. He noted that many producers of 

product that is found to be substandard claim that the product was within legal limits at 

the time of bottling, but that this position takes complete disregard for the consumer. 

 2

 USITC, hearing transcript, December 5, 2012, 21–24 (testimony of Kyle Sawatzky, Bari Olive Oil 

Company). 3

 USITC, hearing transcript, December 5, 2012, 148–154 (testimony of Leandro Ravetti, Boundary 

Bend Limited); Leandro Ravetti, written submission to the USITC, November 29, 2012. 
D-5

California Olive Oil Council4

The California Olive Oil Council (COOC) is a trade and marketing nonprofit association, 

dedicated to promoting fresh, quality extra virgin olive oils made in California. 

According to the hearing testimony of Ms. Patricia Darragh, the COOC was founded in 

1992, and today has 400 members that produce 90 percent of the state’s olive oil output. 

In their submission, the COOC detailed its primary activities, which include conducting 

educational programs (for growers, retailers, and consumers), establishing sensory 

protocols and panels, and operating a certification program for California oils. The 

submission noted that the sensory panel not only tests and certifies California olive oils, 

but also carries out blind taste tests on random samples of oils pulled from retail shelves, 

including both imported and domestic oils. The submission emphasized that the COOC’s 

panels found that from two-thirds to three-quarters of imported olive oils labeled as extra 

virgin were less than extra virgin grade, which indicates that these products are 

mislabeled or adulterated. The COOC submission also detailed other ways in which they 

believe that olive oil consumers are being misled, including the use on the front label of 

confusing terms such as “lite” or misleading country of origin assertions such as 

“imported from Italy” when the oil inside the bottle in reality comes from a variety of 

countries. 

The COOC emphasized that it seeks to level the playing field by ensuring that imported 

olive oils are properly labeled and identified by their actual grade, which will help 

consumers regain confidence in the segment. During the Commission’s hearing, a COOC 

representative noted that retailers are increasingly trying to ensure that the olive oils that 

they are selling are in fact true extra virgin grade. She reported that some retailers have 

specifically sought out COOC-certified oils because they are guaranteed to be extra 

virgin. 

California Olive Ranch5

California Olive Ranch (COR) stated to the Commission that it is a domestic olive oil 

firm that is involved in all stages of the marketing chain, from growing the olives to 

marketing olive oil to the end consumer, both for retail and food service uses. In 

testimony before the Commission and in written submissions, representatives of the firm 

expressed their belief that ineffectual quality standards, rampant fraud and mislabeling, 

and substantial government subsidies to EU producers has prevented U.S. olive oil 

producers from realizing their full potential. 

In its testimony, COR stressed that its business model—based on mechanically 

harvesting olives at the peak of ripeness and processing them within hours, making COR 

an efficient, high-technology enterprise—is disruptive to entrenched market players 

because it produces high-quality extra virgin olive oil at a competitive cost. The firm 

 4

 California Olive Oil Council, written submission to the USITC, November 28, 2012; USITC, hearing 

transcript, December 5, 2012, 13–16 (testimony of Patricia Darragh, California Olive Oil Council). 5

 California Olive Ranch, written submissions to the USITC, November 30, 2012; USITC, hearing 

transcript, December 5, 2012, 8–13 (testimony of Adam Englehardt and Gregory Kelley, California Olive 

Ranch).
D-6

feels that the lack of grading standards means that its product is being sold alongside 

lower-quality oils marketed under the same “extra virgin” label to a consumer that is 

uneducated about differences in olive oil quality. COR feels that questions about olive oil 

quality are retarding the growth of the category in the United States, and that mandatory 

enforcement of grades by a U.S. government entity would improve consumer confidence 

in the category and actually increase overall purchases of olive oil. 

At the same time, COR pointed out that government aid represents a significant share of 

the income of European growers, allowing them to offer their product for lower prices. 

They assert that these levels of support depress U.S. olive oil prices and contribute to an 

olive oil surplus in Europe. COR also noted that European tariffs on imports of olive oil 

are significantly higher than U.S. olive oil tariffs, which hampers the ability of U.S. firms 

to compete in the European market as well. The firm expressed hope that quality and 

fraud problems in the industry could be resolved by U.S. government agencies, not with 

the intent of hindering imports, but in order to let the market determine competitiveness. 

California State University, Fresno Center for Agricultural 

Business6

Dr. Mechel Paggi testified on behalf of the California State University, Fresno Center for 

Agricultural Business. Dr. Paggi states that U.S. producers face challenging competition 

from foreign producers, which currently have a 98 percent market share in the United 

States. However, according to Dr. Paggi, the industry in California has the potential to 

grow substantially, primarily from innovative production techniques and marketing 

practices. He stated that California olive oil producers have become more efficient and 

productive through the use of high-density groves, mechanized harvesting, and advanced 

irrigation and input management, adding that entrepreneurial marketing programs have 

increased the public awareness of California producers in particular. Dr. Paggi also 

stated that U.S. olive growers do not have the benefit of receiving as much government 

support as their competitors in Europe. Dr. Paggi pointed out that EU producers, 

particularly in Italy and Spain, receive direct government support and that the EU 

provides additional storage programs for olive oil to address oversupply. 

Central Texas Olive Ranch7

In his testimony, Central Texas Olive Ranch Executive Vice President Joshua Swafford 

outlined the operations of his family’s olive groves near Georgetown, Texas. To provide 

context on his family’s decision to grow olives, Mr. Swafford explained that the other 

options on their land would be to graze cattle or to grow annual crops, such as cotton, 

vegetables, or field crops. After considering these options, according to Mr. Swafford, he 

and his family decided instead to plant olive trees, which are a permanent crop and 

 6

 USITC, hearing transcript, December 5, 2012, 31–34 (testimony of Dr. Mechel Paggi, Center for 

Agricultural Science and Technology, California State University, Fresno); Dr. Mechel Paggi, written 

submission to the USITC, November 28, 2012. 7

 USITC, hearing transcript, December 5, 2012, 240–242 (testimony of Joshua Swafford, Central Texas 

Olive Ranch); Joshua Swafford, written testimony to the USITC, December 5, 2012. 
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require less water. Mr. Swafford pointed out that there are a number of crop maintenance 

practices and equipment needed to grow olives successfully. Central Texas Olive Ranch, 

he said, has found success growing olives with its 23,000 olive trees—Mr. Swafford 

attributed part of this success to support from university extension research and advice—

and installed its own mill in 2012. He stated that their olive oil is distributed throughout 

the state of Texas and that Central Texas Olive Ranch has recently been joined by a few 

new olive growers in the area. 

Charles Sturt University, Australia, Graham Center for 

Agricultural Innovation8

Dr. Rodney Mailer of the New South Wales Department of Agriculture testified on behalf 

of the Graham Centre for Agricultural Innovation at Charles Sturt University in Australia. 

According to Dr. Mailer, the International Olive Council (IOC) was a critical resource for 

Australia’s laboratory testing capacity when the country first began commercial 

production. However, Dr. Mailer stated that the IOC’s testing standards do not fairly 

assess olive oil from production outside of the Mediterranean production regions due to 

differences in environment, a problem that is particularly significant since more 

production is taking place in nontraditional regions. In response, Australia developed 

two new tests based on the diacylglycerol and the pyropheophytin levels, which he 

claimed identify old and poorly stored olive oil more accurately; however, these tests 

have been rejected by the IOC. Dr. Mailer said they have not been addressed by the IOC 

because its membership is predominantly Mediterranean producers. 

Dr. Mailer suggested that the current IOC and Codex standards are inadequate for the 

market. He stated that tests performed under his laboratory’s direction on imported olive 

oil from supermarkets in the United States and Australia found that 75 percent of product 

tested were found to be unacceptable under their labeled grade. He added that at the 

same time, certain IOC and Codex standards are so restrictive that often high-quality 

olive oil from Australia, New Zealand, Argentina, Chile, and the United States fails to 

meet them. Dr. Mailer also stated that surveillance and enforcement of regulations 

targeting adulterated product needs to be improved, as his laboratory has found evidence 

of canola and olive pomace oil blended in product that was labeled extra virgin olive oil. 

He added that, nonetheless, there is a much smaller incidence of adulteration than failure 

to meet quality standards. 

Cowgirl Brands, LLC9

Karen Lee, President of Cowgirl Brands, LLC, a bottler, marketer, and distributor of 

Texas-grown olive oil, testified about competition between domestic and imported olive 

oil, as well as perceived fraud in the labeling of imports. Ms. Lee testified that the 

production cost of Texas olive oil was currently approximately $40 per gallon, but was 

 8

 USITC, hearing transcript, December 5, 2012, 154–158 (testimony of Rodney Mailer, New South 

Wales Department of Agriculture). 9

 USITC, hearing transcript, December 5, 2012, 247–251 (testimony of Karen Lee, Cowgirl Brands, 

LLC). 
D-8

expected to fall with increases in volume, to be competitive with olive oil produced in 

California. Ms. Lee asserted that lower-priced imported olive oil was often of lower 

quality, but that without adequate labeling and standards, consumers are unable to 

distinguish between inferior olive oil and a quality product. Ms. Lee testified that the 

Texas Olive Oil Council had established a standard that is more rigorous than the IOC 

standard, and that more rigorous standards and labeling would help consumers make 

better choices. 

Enzo Olive Oil Company10

According to Mr. Pat Ricchuiti, a representative of the firm, Enzo Olive Oil Company is 

an olive grower and producer of olive oil in California. Mr. Ricchuiti compared olive 

production in California to the production of almonds and walnuts in the state. He 

asserted that the reason California olive production has not experienced the growth levels 

of California almonds and walnuts is because of competition from subsidized imports of 

olive oil from the European Union. He asserted that if EU subsidies to its olive producers 

were to stop, California olive production would follow an expansion path similar to that 

experienced by the state’s almond and walnut growers. He argued that EU subsidies to its 

olive producers are keeping the U.S. olive oil industry from reaching its potential. 

European Union11

In a written submission, the European Union (EU) (via the European Commission) 

provided information on olive oil production in member states and outlined the EU 

regulations and policies pertaining to the sector. The EU reported that olive oil 

production is concentrated in Spain, Italy, and Greece, and that while both traditional and 

modern olive-growing methods are in use in these countries, production generally 

remains characterized by small holdings on marginal or steeply sloped land. The EU also 

provided data on member countries’ share of world olive oil production, consumption, 

and exports, showing that, when taken together, EU countries account for a majority of 

all three. 

The submission also discussed EU regulations and policies for the olive oil industry, 

summarizing key measures related to marketing and quality standards, designation of 

origin, and agricultural support payments: 

 On quality standards, the EU works closely with the IOC and aims to support and 

enhance the role of the IOC through the EU Action Plan for the olive oil sector; 

 EU marketing standards establish grades of olive oil and labeling requirements 

for products sold in member states; 

 10 USITC, hearing transcript, December 5, 2012, 24–26 (testimony of Pat Ricchuiti, Enzo Olive Oil 

Company). 11 European Commission, written submission to the USITC, February 11, 2013.
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 The EU program on designation of origin allows producers to register and protect 

names of agricultural products. 

 

 Finally, the EU provides direct support payments to olive and other farmers 

through its agricultural policy. 

 In its submission, the EU emphasized that direct payments to olive farmers have 

been decoupled from production levels since 2006 and that, under the rules of the 

World Trade Organization (WTO), its support payments have been determined to 

be non-trade-distorting. The EU provides additional support to the olive oil 

industry in the form of a private storage aid system, which gives the European 

Commission the option of subsidizing private storage of olive oil when prices 

drop below set triggers. 

Florida Olive Council12

In his hearing testimony, Mr. Michael O’Hara Garcia, president of the Florida Olive 

Council, stated that the Council is a not-for-profit organization promoting the cultivation 

and marketing of olives and olive oil in the state of Florida. Mr. O’Hara Garcia provided 

an overview of olive-growing activities in Florida and of potential challenges to the 

industry’s competitiveness as it grows. Mr. O’Hara Garcia stated that there are three 

commercial-scale olive growers at present in Florida, and about 15 small-scale growers. 

He reported that there is interest from citrus growers in converting land to olive 

production because a pathogen called HLB disease is destroying citrus groves, spurring 

the need for alternative crops that can be grown in the Florida climate. Olives are one 

such crop. Mr. Garcia expressed his hope that the olive industry in Florida (and 

throughout the U.S.) will grow and follow a path to success in export markets like that of 

the U.S. wine and nut industries. He stated, however, that high European tariffs and EU 

support payments to olive growers are obstacles to the growth of the U.S. industry, 

especially in export markets. 

Georgia Department of Agriculture13

Ms. Synde Smith, of the Department of Agriculture of Georgia state, testified on behalf 

of Commissioner Gary W. Black that, like other agricultural crops such as blueberries, 

olive production in Georgia has the potential for significant expansion. Ms. Smith stated 

that olive growers in Georgia receive little assistance from government programs other 

than extension assistance for research and development. Ms. Smith also reported that 

olive growers in the state had been able to meet environmental regulations. She also 

predicted that consumer preference for domestic or locally grown olive oil could be an 

important factor in U.S. demand. 

 12 USITC, hearing transcript, December 5, 2012, 245–249 (testimony of Michael Garcia, Florida Olive 

Council); Michael Garcia, written testimony to the USITC, December 5, 2012. 13 USITC, hearing transcript, December 5, 2012, 243–247 (testimony of Synde Smith, Georgia 

Department of Agriculture). 
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Georgia Olive Farms14

According to Mr. Jason Shaw, president of Georgia Olive Farms, the company is a 

producer of olives and olive oil in the Lakeland, Georgia area. Mr. Shaw reported that 

Georgia Olive Farms first planted olive trees in 2009 and first produced olive oil in 2011. 

Mr. Shaw estimated that within five years, a dozen olive growers in Georgia were 

expected to be growing olives on over 500 acres. He stated that an expansion of olive 

production similar to the expansion for pecans and blueberries could result in an increase 

of 100,000 to 150,000 acres in olive production, but testified to his belief that U.S. olive 

production was constrained by European support programs for olive oil, estimated at over 

two billion euros annually. 

Golden Olive Ranch15

In a written submission to the USITC, Golden Olive Ranch of Hughson, California, 

detailed the firm’s decision to first plant olives in 2009, and its subsequent decision to 

remove its olive trees due to low prices caused by a combination of low-cost imports and 

fraudulence in olive oil labeling. The submission noted that when the firm made the 

decision to first plant olives, it was offered a price of $18 per gallon for its oil. It stated 

that two years later, prices had dropped below $10, imports had risen, and import prices 

had declined to a level that appeared to be below the cost of production. The submission 

stated that the situation was exacerbated by the presence of fraudulent and adulterated 

olive oils being misrepresented to the American consumer by mislabeling and false 

advertising—a direct result of the lack of enforcement of grade standards for olive oil. 

The submission emphasized that sales of domestic olive oil will never be able to compete 

fairly with fraudulent imported oils sold at below-market prices. The firm noted that its 

$5 million investment in 500 acres of olive trees was a total loss, and that it made the 

decision to exit the market in the absence of a level playing field for U.S. olive oil 

growers. 

JCS Tradecom16

John Sessler testified on behalf of JCS Tradecom, a family-owned olive oil importer. Mr. 

Sessler is also the current chairman of the North American Olive Oil Association 

(NAOOA). He stated that JCS Tradecom has developed a retail brand, ZOE, that 

includes a number of different olive oil products with different flavor profiles, production 

practices, and price points. The company sources its oil from many different regions, 

including Greece, Spain, and California, although its blends do not mix olive oils from 

different countries. According to Mr. Sessler, JCS Tradecom participates in the 

NAOOA’s Seal Certification program, and it markets its products at independent gourmet 

 14 USITC, hearing transcript, December 5, 2012, 235–238 (testmimony of Jason Shaw, Georgia Olive 

Farms). 15 Golden Olive Ranch, written submission to the USITC, February 11, 2013. 16 USTIC, hearing transcript, December 5, 2012, 126–133 (testimony of John Sessler, JCS Tradecom).
D-11

shops, high-end retail grocery stores, and online retailers, in addition to supplying private 

label and foodservice companies. 

Mr. Sessler stated that the company observes increasing market segmentation and product 

differentiation in the U.S. olive oil market. He explained that having the ability to offer a 

broad range of products is one reason the company sources from many different regions 

and countries. While there are many price points and quality options for olive oil, Mr. 

Sessler stated that olive oil should not be a luxury or elite product, but one that all 

consumers can enjoy for its flavor, versatility, and health benefits. Mr. Sessler pointed 

out that JCS Tradecom’s business depends on integrity and maintaining customers’ trust. 

According to Mr. Sessler, the firm works with producers in Spain, Greece, and California 

to ensure internal quality requirements, and each shipment is accompanied by the 

appropriate IOC tests to ensure the authenticity and quality of the product. Mr. Sessler 

said that a federal marketing order would not be effective in enhancing standards or 

stemming fraudulent activity. 

Next Door Pantry, LLC17

Next Door Pantry is a marketer of Texas-grown olive oil, according to Abigail Rutledge, 

president of the company. Ms. Rutledge testified about market competition with imported 

olive oil and perceived fraud in the labeling of imported olive oil. Ms. Rutledge asserted 

that most U.S. consumers do not have much experience with the taste of extra virgin 

olive oil, and without that experience, have only price as a criterion. She also asserted 

that U.S. olive oil producers lack the advantages of the government support and 

established infrastructure enjoyed by olive oil producers in the Mediterranean region. She 

compared the current situation facing U.S. olive oil producers today to the situation 

facing U.S. wine producers 40 years ago. She also reported that the Texas Olive Oil 

Council had adopted technical standards that are equivalent to those of the California 

Olive Oil Council. 

North American Olive Oil Association18

The North American Olive Oil Association (NAOOA) stated that it represents the 

companies that account for the majority of the olive oil sold in the United States, through 

membership of importers, purchasers, and distributors. The NAOOA said that it is 

concerned with maintaining the availability of olive oil in the U.S. market and providing 

consumers with all grades of olive oil; it also focuses on consumer education and the 

promotion of the health benefits of all grades of olive oil. 

According to written submissions by the NAOOA, one of their priorities is the 

establishment of “universal, objective, and mandatory grade standards” for olive oil, as 

well as a testing regime to enforce such standards. The group believes the best path is 

 17 USITC, hearing transcript, December 5, 2012, 251–254 (testimony of Abigail Rutledge, Next Door 

Pantry). 18 North American Olive Oil Association, written submissions to the USITC, November 21, 2012; 

December 17, 2012; and February 12, 2013; USITC, hearing transcript, December 5, 2012, 126–133 

(testimony of Eryn Balch, North American Olive Oil Association). 
D-12

through a Food and Drug Administration (FDA) standard of identity, which would make 

current USDA standards mandatory and allow for both government and private company 

testing and enforcement. Ms. Eryn Balch, the executive vice president of NAOOA, 

makes it clear in the hearing testimony that the USDA standards—which are largely 

based on the IOC standard—should be adopted as they currently stand. The NAOOA 

asserts that the IOC standards govern most of the olive oil produced globally and have 

scientific backing, while still being dynamic enough to work well in the United States. In 

the absence of mandatory standards, the NAOOA explained in the hearing testimony that 

it takes it upon itself to test the oils of both members and nonmembers, alerting each 

offender if there is something amiss with either the oil or the bottle label. The NAOOA 

has also established a Certified Quality Seal Program, where companies are subject to 

more frequent testing, including random chemical tests straight from bottles bought off 

supermarket shelves. 

In written submissions to the USITC, the NAOOA stated that a USDA marketing order is 

not the best and most efficient way to monitor the U.S. olive oil market for many reasons. 

The NAOOA pointed out that first, the United States imports the vast majority of its 

domestically consumed olive oil; if a USDA marketing order were to apply to imports, 

very large quantities of imported oil would be subject to not only increased testing costs, 

but also delays at the port while testing occurs. The NAOOA, in written submissions, 

asserts that since olive oil is a highly perishable product, these delays would result in 

diminished olive oil quality for consumers. Second, the NAOOA estimates that a 

marketing order would likely target every import lot, while an FDA standard of identity 

would take a more risk-based approach and therefore be more efficient. Third, the 

NAOOA added that a marketing order would only test olive oil at the port of entry, and, 

according to Ms. Balch’s hearing testimony, would not prevent fraudulent activity from 

taking place once inside the United States. Lastly, in response to suggestions that new 

chemical tests, such as the pyropheophytins (PPPs) and 1,2-diacylglycerol (DAGs), 

should be included in order to make the standards more stringent, NAOOA argued that 

these tests are unreliable, are inconsistent, and do not accurately measure the purity or 

quality of olive oil. 

The NAOOA also asserted in its written submissions that the growth of the domestic 

olive oil industry is not being stunted by imports. According to the NAOOA, the 

domestic industry targets different consumer segments and therefore faces little direct 

competition from imports. In addition, the NAOOA stated that the decoupled support 

given to olive growers through the EU is not passed downstream to bottling companies, 

meaning it does not suppress prices of imports in the U.S. market. 

Pompeian, Inc.19

Pompeian, Inc., is a U.S. importer of olive oil and other Mediterranean foods. Frank 

Patton, CFO and president of Pompeian Olive Oil Company, noted that Pompeian had 

been importing olive oil in bulk, blending and bottling the oil at its facility in Baltimore, 

Maryland, since 1906. Mr. Patton testified that in order to ensure a consistent, unique 

flavor profile and other factors, such as the stability of the product, Pompeian’s extra 

virgin olive oil is blended from extra virgin olive oil from a variety of sources, including 

 19 USITC, hearing transcript, December 5, 2012, 28–31 (testimony of Frank Patton, Pompeian Inc.). 
D-13

from California, and from different varieties of olives. He explained that in order to 

ensure the shelf life of its extra virgin olive oil, the oil is packaged in bottles designed to 

limit exposure to ultra-violet light. 

Mr. Patton testified that Pompeian conducts chemical and sensory tests of oil samples 

before purchase, and continues to test the oil at various stages of processing, including 

testing of oil purchased from retail establishments. Mr. Patton testified that in addition to 

its own internal testing regime, Pompeian is the first U.S. olive oil company to participate 

in the USDA voluntary quality monitoring program, and also participates in the North 

American Olive Oil Association Quality Seal Program in order to ensure that the extra 

virgin oil meets applicable quality standards. Mr. Patton testified that Pompeian decided 

to participate in the USDA quality monitoring program because other government agency 

regulations, such as those of the FDA, are concerned with safety, but do not address 

product quality. 

Santa Cruz Olive Tree Nursery20

Santa Cruz Olive Tree Nursery is a commercial producer of olive trees for planting in 

both super-high-density (SHD) and traditional production systems located in Watsonville, 

CA. In a written submission to the USITC, Santa Cruz Olive Tree Nursery provided 

comments about the need for standards in the U.S. olive oil market. The submission 

noted that existing olive oil standards from the IOC and USDA cover both purity and 

quality of olive oil. However, the submission states that current quality standard limits 

are easy to meet so that even were these standards to be enforced in the U.S. market, 

American consumers would still lack assurance that the quality of oil they intended to 

purchase was what they actually received. The submission noted that newer chemical 

tests are available to test for quality which would address some of the deficiencies in the 

current testing regime. Furthermore, the submission states that IOC tests for olive oil 

purity discriminate against producers based on area and climate, which make them 

useless as scientific tools to screen out adulteration. In hearing testimony given at the 

USITC, the party noted that the IOC has demonstrated considerable resistance to 

changing any of its standards. 

The submission emphasizes that the industry would be better served by a standard that 

focuses on measures of quality and diminishes the use of purity criteria, and states that a 

USDA marketing order would be the proper vehicle for developing a new framework that 

promotes clear and cost effective grading standards for the benefit of the entire olive oil 

sector and for U.S. consumers. In testimony given at the USITC, the firm noted that 

confusion of the consumer regarding olive oil quality is a major hurdle for the California 

industry, and this confusion is driven by the current system of grades and labeling. It 

added that if this confusion were alleviated, then the industry could move forward based 

on quality. 

 20 Santa Cruz Olive Tree Nursery, written submission to the USITC, November 28, 2012; USITC, 

hearing transcript, December 5, 2012, 27–31 (testimony of Bruce Golino, Santa Cruz Olive Tree Nursery).
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Senator Lois Wolk21

In a written submission to the USITC, California State Senator Lois Wolk, chair of the 

California Senate Subcommittee on Olive Oil Production and Emerging Products, noted 

the work of the Subcommittee in assisting the olive oil industry in meeting the challenges 

of a healthy and growing industry. One of the actions of the subcommittee highlighted in 

the submission was the convening of an informational hearing on January 26, 2012, 

entitled Challenges Facing California’s Olive Oil Industry, and the submission includes a 

transcript of this hearing. 

This hearing investigated the competitive, quality, and authenticity issues of olive oil and 

included three panels of witnesses: the first panel was dedicated to the topic of extra 

virgin olive oil fraud, the second panel related the California olive oil industry 

perspective, and the third panel highlighted the world view of the industry from the 

perspective of both North American importers and Australian olive oil producers. 

Recurring themes presented throughout the hearing included issues of olive oil quality 

and authenticity. Domestic producers emphasized that a lack of enforcement of standards 

makes it difficult for producers of true extra virgin olive oil to compete in this market. 

There was some disagreement at the hearing, however, as to the pervasiveness of olive oil 

adulteration in the U.S. market. 

Aside from the hearing, Senator Wolk’s submission noted that California was the first 

state to establish quality standards for extra virgin olive oil. The submission concluded by 

emphasizing the potential of California’s olive oil industry to produce a healthy product 

that is ideally suited to the state’s climate and growing conditions. The submission warns, 

however, that continuing to allow mislabeled, fraudulent, and corrupt product to be sold 

as extra virgin olive oil does a disservice to growers, producers, and consumers in this 

growing market. 

Texas Olive Ranch22

In written and oral testimony, Mr. Jim Henry, who owns Texas Olive Ranch and is also 

the founding director of the Texas Olive Oil Council, described the expansion of the 

Texas olive oil industry and the challenges to its growth. Mr. Henry explained that he 

started growing olives in Texas on an experimental basis in 1993 and began commercial 

production in 2007. At present, he is in the process of investing in expanded olive 

growing in the Victoria, Texas, area, which offers a more suitable climate than that found 

around his existing groves, which are located further southwest. According to Mr. Henry, 

his expansion is part of an overall expansion of Texas olive growing and milling 

capabilities in recent years. He said he believes the industry in Texas offers significant 

potential, especially for sales in channels like farmers’ markets, where customers can see 

and taste the product. 

 21 Senator Lois Wolk, written submission to the USITC, January 15, 2013.

22 USITC, hearing transcript, December 5, 2012, 242–245 (testimony of Jim Henry, Texas Olive 

Ranch); Jim Henry, written testimony to the USITC, December 5, 2012.
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Despite this growth potential, according to Mr. Henry, there are numerous challenges to 

the olive oil industry in Texas. He said that among these are lack of consumer awareness 

of the availability of locally produced olive oil and of the differences in flavor between 

the local product and imports; unavailability of crop insurance and financing due to the 

nascent status of the industry in Texas; lack of sufficient economies of scale; and 

competition from lower-priced imports from Europe, which, in Mr. Henry’s view, are 

able to sell at low prices due to government assistance provided by the European Union 

and national governments in Europe. 

Tom Mueller23

Tom Mueller stated that he is a freelance journalist and author based out of Italy who has 

extensively covered the olive oil industry worldwide. Mr. Mueller pointed out that fraud 

has plagued the olive oil industry going back to the Roman Empire, as it is a valuable and 

expensive vegetable oil that can easily be mixed with less expensive oils. Mr. Mueller 

stated that U.S. consumers usually buy extra virgin olive oil for its flavor and for health 

reasons and that inferior olive oil undermines the consumer in this regard. According to 

Mr. Mueller, quality is the key component on which consumer should base their buying 

habits, rather than specific geographic or other labels. 

Mr. Mueller stated that olive oil quality is not a matter of nationality, as high- and lowquality oils are produced all over the world. He said he believes that responsibility for 

fraudulent sales and marketing lie with U.S. authorities that do not properly enforce 

existing laws, with international olive oil organizations that look after the interests of 

members at the expense of the market’s reputation, and with the International Olive 

Council, which has been too slow to respond to the need for quality standards. 

University of California at Davis, Olive Center24

The University of California at Davis Olive Center (Olive Center) stated that it is a selffunded university-industry coalition that promotes olive research and education, 

addressing the needs of California olive growers and processors. In addition, the Olive 

Center noted that it provides fee-based laboratory analysis of olive oil for the public. 

The Olive Center said that it conducted three recent studies on olive oil, funded in part by 

the California olive oil industry, which found that a large share of olive oil sold in U.S. 

supermarkets did not meet the IOC minimum standards or were adulterated. It stated that 

the three studies on olive oil quality analyzed 207 samples purchased from U.S. 

supermarkets and foodservice distributors and found that 65 percent of Mediterranean 

olive oil samples did not meet the IOC’s minimal sensory standards for extra virgin, and 

that two of the samples were adulterated with canola oil. 

 23 USITC, hearing transcript, December 5, 2012, 37–42 (testimony of Tom Mueller); Thomas B. 

Mueller, written submission to the USITC, November 29, 2013. 24 University of California (UC) Davis, written testimony to the USITC, December 5, 2012, 34–37 

(testimony of Selina Wang, UC Davis); UC Davis, written submission to the USITC, February 12, 2013; 

December 5, 2012. 
D-16

Olive Center researchers reported that the studies they conducted used DAGs and PPP 

tests, which, they noted, the IOC claims to be unreliable. The Olive Center stated that it 

has been unable to review the scientific basis for the IOC claim, however, because the 

IOC has not released its scientific justification to the public. The Olive Center states, 

however, that the International Organization for Standardization (ISO) has recognized the 

DAGs and PPP tests after years of scientific review. In its support for the tests, the Olive 

Center notes that although these tests are not perfect, they are preferable to the current 

loose IOC chemical standards. Olive Center researchers state that the DAGs and PPPs 

levels in olive oil are directly related to the age of the olives used to produce it, so the 

results of testing their levels are very closely related to the age and the freshness of the oil 

and correlate best with sensory characteristics. The Olive Center has recommended that 

the USDA add the DAGs and PPP tests to U.S. standards. 

The UC Davis Olive Center noted that it currently offers DAGs and PPP testing as a 

service to the California olive oil industry and reports that currently there are no other 

U.S. labs offering such testing. Olive Center staff asserted that in view of the university’s 

overhead expenses, the Olive Center does not view testing as a moneymaking activity; 

rather, the Olive Center provides this testing with the goal that other labs will start doing 

this type of testing and drive down its costs in the future. 

Researchers from the Olive Center state that they are also working with Spanish 

researchers, who, they note, have vast experience in olive oil research, as well as 

chemical manufacturers, to develop specific instruments for olive oil testing—ones that 

can identify other chemical markers that would correlate to organoleptic flaws in olive 

oil. Researchers at the Olive Center, along with lipid scientists around the world, believe 

that modern chemical testing techniques, including chromatography and spectrography, 

can be used to correlate and identify chemical markers that identify a threshold level for a 

flaw. The researchers stated that these flaws include rancidity, fustiness, and mustiness, 

which are all indicators of problems either with the olives that were used to produce the 

olive oil, the way it was produced, or the way it was stored. 

In response to questions about the subjective and objective nature of olive oil sensory 

analysis, the Olive Center stated that objective sensory testing is a valid scientific method 

used to measure thr intrinsic sensory attributes of a sample and confirm and quantify the 

presence of sensory defects. The Olive Center said that sensory evaluation has been 

endorsed and accepted by various professional organizations, such as the Institute of 

Food Technologists and the American Society for Testing and Materials. The Olive 

Center stated that objective sensory testing is endorsed as well by the IOC. The Olive 

Center explained that the IOC provides written standards for objective sensory 

evaluation, including definitions for the vocabulary of sensory properties and defects, a 

point system for assigning grades or classifications, methods for panel training, and 

certification of laboratories evaluating olive oil. By contrast, according to the Olive 

Center, subjective sensory evaluation measures an assessor’s feelings toward a sample 

and is clearly not appropriate for olive oil assessments. 
D-17

University of Georgia, Center for Agribusiness and 

Economic Development25

Dr. Kent Wolfe, of the University of Georgia’s Center for Agribusiness and Economic 

Development, presented a comparison of olive oil production costs in the state of Georgia 

with those in Spain. He testified that the subsidy provided by the European Commission 

to olive producers in Spain lowers these producers’ ongoing costs for olive production 

from slightly below those of producers in Georgia to “substantially” below those of 

producers in Georgia. He testified that, as a result, Georgia’s olive oil industry was 

retarded in its growth from a niche market to a mature industry. 

Yocha Dehe Wintun Nation26

Chairman Marshall McKay testified on behalf of the Yocha Dehe Wintun Nation. 

Chairman McKay stated that he is the elected tribal chairman of the sovereign, federally 

recognized tribal nation. He noted that the nation is located in California and is a 

producer of olive oil, managing over 11,000 acres of land that grow over a dozen crops 

and 300 head of cattle. Chairman McKay stated that the nation is committed to 

preserving the land for future generations with a focus on responsible stewardship and 

sustainability. According to Chairman McKay, the Yocha Dehe planted 82 acres of highdensity Arbequina olive trees in 2008; additionally, since the closest mill was two and a 

half hours away and freshness is essential to their olive oil production, the Yocha Dehe 

built their own state-of-the art mill to produce their oil, as well as oil made from the 

olives of many other local olive producers. 

Chairman McKay reported that the Yocha Dehe believe that the U.S. olive oil market 

should be fair for producers and consumers, pointing to recent studies indicating that 

some product on the market does not meet quality standards. The Yocha Dehe support 

the recommendations proposed by the University of California at Davis report that would 

raise standards, improve and increase testing, and conduct research to improve packaging 

in order to preserve freshness. Chairman McKay noted that the Yocha Dehe product 

marketed at several small retail stores competes against lower-priced imported extra 

virgin olive oil, but that these products should be more expensive due to import costs 

alone. According to the Chairman, this indicates that something in the market is not 

right. Chairman McKay stated that U.S. consumers suffer because they are buying 

products that are mislabeled in the marketplace. 

 25 USITC, hearing transcript, December 5, 2012, 240–244 (testimony of Kent Wolfe, University of 

Georgia). 26 USITC, hearing transcript, December 5, 2012, 158–163 (testimony of Chairman Marshall McKay, 

Yocha Dehe Wintun Nation).

APPENDIX E 

Consumer Demand for Olive Oil: 

Econometric Results from Retail Scanning 

Data

E-3 

This appendix provides detail on the econometric estimates of demand reported in 

chapter 4. These estimates are based on retail scanning data provided by Nielsen. The 

analysis estimates consumer preferences for olive oil using the geographic splits in the 

data to control for unobservable factors, using panel data methods. 

Data 

The Nielsen data contain revenue and units sold information for olive oil products at the 

universal product code (UPC) level. These data are reported at different geographic 

aggregations. Panels are formed by using data for nine U.S. Census divisions over three 

years at a weekly frequency (156 weeks). The observed sales correspond to the period 

February 2010–February 2013. 

As many as 2,275 different UPCs were observed in the data. Many of the UPCs, 

however, represent different presentations of the same product, with variations by size or 

type of packaging.1

 These UPCs were aggregated for each brand, oil grade and oil source 

combination. For instance, STAR Extra Virgin and STAR Extra Virgin California stand 

as two product choices. Product prices were harmonized to dollars per liter. 

These data are further aggregated into five product groups for which their demand is 

estimated.2

 The first three groups split the extra virgin oils, which together account for 

the majority (63.7 percent) of the observed sales, according to whether the products are 

domestic or foreign, and if foreign, whether they are branded or unbranded. The fourth 

group comprises the flavored olive oils, and the fifth group includes other refined olive 

oils that are virgin, light taste, etc. The specific 5 groups are listed in table E.1, along with 

their respective market shares by value. 

TABLE E.1 Defined product groups and market shares

Group Abbreviation Description Market share

1 BRA_EV_F Branded extra virgin foreign 45.2

2 UNB_EV_F Unbranded extra virgin foreign 17.5

3 BRA_EV_D Branded extra virgin domestic 1.1

4 ___FL__ Flavored oils, whether or not branded, whether or not foreign 1.1

5 ___OT_F Other refined oils, all of which are foreign, whether or not branded 35.1

Expenditure shares for the product groups are further explored by division and over time 

in figures E.1–E.5. These figures show substantial differences in market share trends by 

product group and divisions. Figure E.3 shows the small market share for the domestic 

olive oil, in many divisions very close to zero. It also shows a growing trend, but mainly 

in the West (Pacific and Mountain). In contrast, foreign branded extra virgin oils, with 

the largest market share levels overall, have maintained market shares in the Northeast 

(Mid Atlantic and New England), while lost market shares in the West (figure E.1). 

 1

 For instance, a popular product, Bertolli Extra Virgin, is identified in the data with 12 UPCs, 

depending on bottle size and material. 2

 Consumers may exhibit preferences over brands and demand analyses at the brand level are common 

in demand estimation for differentiated products. See, e.g., Hausman et al., “Competitive Analysis with 

Differentiated Products,” 1994; Hausman, “The Valuation of New Goods under Perfect and Imperfect 

Competition,” 1996. The large number of brands in the data, however, renders such analysis unfeasible. 
E-4 

.3 .4 .5 .6 .3 .4 .5 .6 .3 .4 .5 .6

0 50 100 150 0 50 100 150 0 50 100 150

Pacific Mountain W N Central

E N Central Mid Atlantic New England

W S Central E S Central S Atlantic

w1

week

Graphs by division .1 .15 .2 .25 .3 .1 .15 .2 .25 .3 .1 .15 .2 .25 .3

0 50 100 150 0 50 100 150 0 50 100 150

Pacific Mountain W N Central

E N Central Mid Atlantic New England

W S Central E S Central S Atlantic

w2

week

Graphs by division

FIGURE E.1 Expenditure shares for product group 1 (branded, extra virgin, foreign) 

Sources: Nielsen, U.S. Retail Market Data, 2013; USITC staff estimates. 

FIGURE E.2 Expenditure shares for product group 2 (unbranded, extra virgin, foreign) 

Sources: Nielsen, U.S. Retail Market Data, 2013; USITC staff estimates.
E-5 

0 .01 .02 .03.04 0 .01 .02 .03.04 0 .01 .02 .03 .04

0 50 100 150 0 50 100 150 0 50 100 150

Pacific Mountain W N Central

E N Central Mid Atlantic New England

W S Central E S Central S Atlantic

w4

week

Graphs by division

0 .02.04.06.08 0 .02.04.06.08 0 .02.04.06.08

0 50 100 150 0 50 100 150 0 50 100 150

Pacific Mountain W N Central

E N Central Mid Atlantic New England

W S Central E S Central S Atlantic

w3

week

Graphs by division

FIGURE E.3 Expenditure shares for product group 3 (branded, extra virgin, domestic) 

Sources: Nielsen, U.S. Retail Market Data, 2013; USITC staff estimates. 

FIGURE E.4 Expenditure shares for product group 4 (flavored olive oil) 

Sources: Nielsen, U.S. Retail Market Data, 2013; USITC staff estimates. 
E-6 

.2 .3 .4 .5 .2 .3 .4 .5 .2 .3 .4 .5

0 50 100 150 0 50 100 150 0 50 100 150

Pacific Mountain W N Central

E N Central Mid Atlantic New England

W S Central E S Central S Atlantic

w5

week

Graphs by division

FIGURE E.5 Expenditure shares for product group 5 (other refined olive oil) 

Sources: Nielsen, U.S. Retail Market Data, 2013; USITC staff estimates. 

Base Model 

The analysis is conducted at the product-group level and demand is estimated using an 

Almost Ideal Demand System (AIDS) model.3

 In its basic form, the model specifies the 

system of equations 

 , for i = 1,..., J (1)

(2) 

where the dependent variableswidt are the expenditure shares of olive oil product group i

in division d at time t. These shares are modeled in terms of price indices for each of the 

product groups p jdt and total expenditure on olive oil (i.e., across the five olive oil 

groups) mdt . Pdt , in turn, is the exact price index for the system, as defined in equation 

(2). 

 3

 Deaton and Muelbauer, “An Almost Ideal Demand System,” 1980. 

idt

j

widt i i mdt Pdt ij p jdt     ln( / )  ln  

   

i j

idt ij i j

i

Pdt i p ln p ln p 2

1 ln 0  ln 
E-7 

A linearized version of the AIDS model (LA-AIDS), also suggested by Deaton and 

Muellbauer, uses the Stone price index jdt j

ln Pdt   wjdt ln p in place of the nonlinear 

index in (2). This version is widely applied in the empirical literature because of its 

computational convenience. To reduce potential bias from endogeneity, fixed-weights 

are often used 

(3) 

where wjd are the average expenditure shares over the whole data period by product 

group and division. 

Estimated Demand 

The demand system in (1) is estimated with the inclusion of product-division fixed 

effects id and product-division trends t id . The former are included to account for 

time-invariant differences in demographics or preferences, and the latter to account for 

changes in demographics or preferences, possibly at varying rates, across the country. 

Thus, the model that is fitted to the data becomes 

, for i = 1,..., J (4)

which is estimated both as an AIDS and LA-AIDS by seemingly unrelated regressions 

(SUR), after imposing the typical restrictions from consumer maximization:   1

i

 i , 

ij ji    for all i and j,   0

j ij  for all product i, and   0

i

 i

Similar to the price index for the system, price indices for each of the product groups 

p jdt were approximated from the product-level data using a Stone index, 

kdt k

ln p jdt   wkd ln p , where pkdt are the prices of all products k in group j. Alternate 

approximations were used and the results reported for robustness.4

 

Estimated model parameters, which cannot be interpreted directly as elasticities, are 

shown in table E.2.5

 Parameter estimates and reported mean values in the table, however, 

can be used to form elasticities. Results in table E.2, especially derived elasticity 

estimates, are robust to the choice of an AIDS or LA-AIDS model, so further analyses 

rely on the linear model. 

 

4

 A similar analysis in the literature uses proxy kdt k p jdt   wkdt p and instrumental variables to 

address the potential endogeneity bias from this index. See Chaudhuri et al., “Estimating the Effects of 

Global Patent Protection in Pharmaceuticals,” 2006. 5

 Parameters not shown (e.g., for group 5 in table E.1) can be easily retrieved by the imposed 

restrictions on symmetry and homogeneity of degree zero in prices and total expenditures. 

jdt

j

ln Pdt  wjd ln p

idt

j

idt i id id i mdt Pdt ij p jdt w      t   ln( / )  ln  
E-8 

TABLE E.2 Estimated parameters for 5 product group model 

 AIDS LA-AIDS 

i = 1 i = 2 i = 3 i = 4 i = 1 i = 2 i = 3 i = 4 

i1 

 -0.340 -0.337 

(0.121) (0.114) 

i2 

 0.109 -0.220 0.105 -0.213 

(0.038) (0.028) (0.032) (0.027) 

i3 

 0.005 -0.006 0.000 0.004 -0.005 0.000 

(0.007) (0.004) (0.001) (0.005) (0.004) (0.001) 

i4 

 -0.014 0.007 -0.001 0.017 -0.015 0.009 -0.001 0.018 

(0.012) (0.006) (0.000) (0.010) (0.012) (0.007) (0.000) (0.010) 

 i



0.013 -0.025 -0.004 -0.008 0.013 -0.025 -0.004 -0.008 

(0.029) (0.016) (0.001) (0.002) (0.030) (0.016) (0.001) (0.002) 

Own price elast. -1.778 -2.103 -0.992 0.380 -1.778 -2.106 -0.993 0.377 

 (0.281) (0.148) (0.095) (0.776) (0.281) (0.147) (0.095) (0.773) 

 

Mean values 

w1 0.441 

w2 0.188 

w3 0.012 

w4 0.013 

w5 0.346 

lnm P 12.499 

Note: Estimated by SUR. Regressions also include product fixed effects, product-division fixed effects, and productdivision trends. Robust standard errors with clustering in parenthesis. N = 1,092. 

All estimated own-price, cross-price, and expenditure elasticities for the five product 

groups are in table E.3. For the most part estimated elasticities show the expected sign. 

All own-price elasticitites are negative, except for the flavored olive oils. For that 

category, its own-price elasticity flips from a positive to a negative value depending on 

the choice of index used to aggregate the product prices. This sensitivity to the price 

index is consistent with considerable product churning in this category. Cross-price 

elasticities in the fourth column also show that the price of flavored olive oil does not 

have a significant effect on the demand for any of the other product categories in the 

system. Based on these results, the flavored olive oils were excluded from the analysis 

and the demand system re-estimated for all non-flavored olive oils. Estimated elasticities 

for this model are shown in table E.4. Table E.5 provides standard errors for the 

benchmark specification. 

 
E-9 

TABLE E.3 Estimated price and expenditure elasticities (all olive oil) 

Product-group price index p1 p2 p3 p4 p5 m 

Benchmark: 

kdt

k

ln pˆ jdt   wkd ln p q1: BRA_EV_F -1.778 0.233 0.010 -0.035 0.540 1.030 

q2: UNB_EV_F 0.617 -2.106 -0.023 0.049 0.595 0.869 

q3: BRA_EV_D 0.529 -0.333 -0.993 -0.057 0.202 0.652 

q4: ____FL__ -0.878 0.789 -0.048 0.377 -0.633 0.392 

q5: ____OT_F 0.672 0.287 0.002 -0.033 -1.997 1.069 

 

Robustness checks: 

kdt

k

pˆ jdt   wkdt p q1: BRA_EV_F -1.833 0.231 0.015 -0.005 0.604 0.988 

q2: UNB_EV_F 0.538 -2.093 -0.048 0.041 0.565 0.997 

q3: BRA_EV_D 0.660 -0.721 -1.091 0.054 0.325 0.774 

q4: ____FL__ 0.038 0.688 0.052 -0.757 -0.510 0.489 

q5: ____OT_F 0.746 0.299 0.008 -0.027 -2.070 1.043 

kdt

k

pˆ jdt   wkd p q1: BRA_EV_F -1.631 0.218 0.015 -0.041 0.402 1.036 

q2: UNB_EV_F 0.590 -2.100 -0.037 0.064 0.627 0.856 

q3: BRA_EV_D 0.741 -0.546 -1.031 -0.050 0.233 0.652 

q4: ____FL__ -1.107 0.989 -0.043 0.369 -0.663 0.455 

q5: ____OT_F 0.500 0.302 0.003 -0.033 -1.837 1.066 

kdt

k

ln pˆ jdt   wkdt ln p q1: BRA_EV_F -1.796 0.257 0.012 -0.010 0.545 0.993 

q2: UNB_EV_F 0.591 -2.080 -0.037 0.051 0.459 1.015 

q3: BRA_EV_D 0.545 -0.539 -1.049 0.045 0.226 0.772 

q4: ____FL__ -0.081 0.856 0.045 -0.601 -0.599 0.380 

 q5: ____OT_F 0.677 0.247 0.005 -0.031 -1.930 1.033 

Note: Elasticities are conditional on total expenditures on olive oil. Elasticities evaluated at mean values. 

 
E-10 

TABLE E.4 Estimated price and expenditure elasticities (all nonflavored olive oil) 

Product-group price index p1 p2 p3 p4 m 

Benchmark: 

kdt

k

ln pˆ jdt   wkd ln p q1: BRA_EV_F -1.792 0.235 0.009 0.528 1.020 

q2: UNB_EV_F 0.619 -2.058 -0.025 0.598 0.865 

q3: BRA_EV_D 0.495 -0.350 -1.002 0.226 0.630 

q4: ____OT_F 0.656 0.289 0.003 -2.008 1.060 

Robustness checks: 

kdt

k

pˆ jdt   wkdt p q1: BRA_EV_F -1.833 0.234 0.015 0.601 0.983 

q2: UNB_EV_F 0.548 -2.038 -0.046 0.553 0.983 

q3: BRA_EV_D 0.636 -0.688 -1.113 0.398 0.767 

q4: ____OT_F 0.742 0.291 0.010 -2.082 1.039 

kdt

k

pˆ jdt   wkd p q1: BRA_EV_F -1.655 0.224 0.014 0.391 1.027 

q2: UNB_EV_F 0.602 -2.049 -0.037 0.633 0.852 

q3: BRA_EV_D 0.678 -0.552 -1.052 0.292 0.635 

q4: ____OT_F 0.485 0.305 0.005 -1.854 1.058 

kdt

k

ln pˆ jdt   wkdt ln p q1: BRA_EV_F -1.796 0.257 0.011 0.542 0.987 

q2: UNB_EV_F 0.593 -2.018 -0.035 0.454 1.006 

q3: BRA_EV_D 0.508 -0.514 -1.065 0.298 0.772 

 q4: ____OT_F 0.676 0.245 0.007 -1.949 1.022 

Note: Elasticities are conditional on total expenditures in non-flavored olive oil. Elasticities evaluated at mean 

values. 

 
E-11 

TABLE E.5 Price and expenditure elasticities (all nonflavored olive oil), national and Pacific 

 National 

 p1 p2 p3 p4 m 

q1: BRA_EV_F -1.792 *** 0.235 *** 0.009 0.528 *** 1.020 *** 

(0.274) (0.065) (0.011) (0.199) (0.067) 

q2: UNB_EV_F 0.619 *** -2.058 *** -0.025 0.598 *** 0.865 *** 

(0.180) (0.187) (0.023) (0.107) (0.081) 

q3: BRA_EV_D 0.495 -0.350 -1.002 *** 0.226 0.630 *** 

(0.427) (0.377) (0.098) (0.199 ) (0.116) 

q4: ____OT_F 0.656 ** 0.289 *** 0.003 -2.008 *** 1.060 *** 

(0.279) (0.071) (0.007) (0.217) (0.061) 

 

 Pacific Division 

 p1 p2 p3 p4 m 

q1: BRA_EV_F -1.743 *** 0.220 *** 0.007 0.496 *** 1.019 *** 

 (0.258) (0.061) (0.009) (0.189) (0.062) 

q2: UNB_EV_F 0.615 *** -2.043 *** -0.020 0.581 *** 0.867 *** 

 (0.179) (0.184) (0.022) (0.108) (0.080) 

q3: BRA_EV_D 0.129 -0.089 -0.997 *** 0.051 0.906 *** 

 (0.109) (0.096) (0.025) (0.051) (0.029) 

q4: ____OT_F 0.811 ** 0.358 *** 0.001 -2.245 *** 1.075 *** 

 (0.346) (0.088) (0.009) (0.270) (0.075) 

Note: Elasticities are conditional on total expenditures in non-flavored olive oil. Elasticities evaluated at mean 

values. Robust standard errors with clustering in parenthesis. Significant at the 10 percent (*), 5 percent (**), 

and 1 percent (***) level. 

Expenditure elasticities are all larger than zero, indicating that olive oil is a normal good. 

All own-price elasticities are negative and significant at the 1 percent level, consistent 

with expectations. All foreign product categories show comparable own-price elasticities 

in the range of 1.8–2. The demand for the domestic variety, however, is significantly less 

sensitive to its own price, with an elasticity of about 1. Consistent with this last point, the 

demand for the domestic extra virgin olive oil shows significantly lower response to the 

prices of all other olive oils in the system. In fact these cross-price elasticities are not 

statistically different from zero. 

Looking at the cross-price elasticities for the other product groups shows significant 

substitutability across all types of imported olive oils. Although these cross-price 

elasticities among the imported oils are not statistically different, the point estimates 

suggest some perceived quality from product branding that may be at least as important 

as the perceived quality from the oil grade. 
E-12 

Nested Demand 

An alternative demand system using a nested structure was briefly considered. At the top 

level, this model captures demand for olive oil grade (extra virgin versus other). The next 

level considers preference among foreign branded, foreign unbranded and domestic 

branded extra virgin oils (i.e., groups 1–3 in table E.1). 

The lower-level system is estimated using an AIDS specification as in equation (4). That 

estimation yields elasticities conditional on expenditures on extra virgin oil that are 

shown in the top panel in table E.6. These results are not too different from the results 

obtained when demand for non-flavored olive oil is modeled using a single level (nonnested results discussed in table E.5). 

TABLE E.6 Extra virgin elasticities from a nested model 

 Conditional elasticities 

P1 P2 P3 

q1: BRA_EV_F -1.459 0.366 0.011 

q2: UNB_EV_F 1.044 -1.833 -0.027 

q3: BRA_EV_D 0.601 -0.452 -0.983 

 Unconditional elasticities 

P1 P2 P3 

q1: BRA_EV_F -1.138 0.077 -0.006 

q2: UNB_EV_F 0.532 -1.051 -0.040 

q3: BRA_EV_D 0.078 -0.674 0.004 

 Unconditional elasticities, alternative specification 

P1 P2 P3 

q1: BRA_EV_F -0.603 0.305 0.007 

q2: UNB_EV_F 0.936 -0.879 -0.029 

q3: BRA_EV_D 0.490 -0.499 0.014 

Note: Elasticities evaluated at mean values. Table panels described in text. 

The conditional elasticities, which hold expenditures on extra virgin oil constant, can be 

adjusted to account for the effect that expenditures may switch to other olive oils in 

response to changes in the price of extra virgin oil. This adjustment is derived from the 

parameter estimates in the upper-level demand. In estimating this upper-level demand an 

AIDS specification is first considered. The resulting unconditional elasticities are shown 

in the middle panel of table E.6. The bottom panel in the table shows an alternate 

estimation, where the upper-level demand has been estimated using a simpler log-log 

demand specification.6

 

The “unconditional” elasticities in table E.6, particularly the own-price elasticity for the 

domestic variety, differ from the non-nested results discussed before. This difference may 

reflect different substitution patterns between each extra virgin category and the “other” 

category (non-extra virgin) that may be better handled in a single-level demand system. 

 6

 For a multi-level demand system that follows this structure, see Hausman, “The Valuation of New 

Goods under Perfect and Imperfect Competition,” 1996. 
E-13 

The more flexible structure used to derive the elasticities in table E.5 is taken as the 

preferred specification. 

Endogenous Prices 

An identification challenge in demand estimations relates to the endogeneity of prices, in 

the sense that prices are simultaneously determined by demand and supply. For instance, 

while prices determine product demand (as in equation 1), suppliers are likely to also set 

prices in response to demand conditions. In the estimations above, product prices and 

thus product group price indices p jdt in equation (4) are treated as predetermined. One 

rationalization of this treatment is that, while prices are not exogenous, to the extent that 

suppliers do not revise prices in the short run, this stickiness attenuates the simultaneity 

concerns. 

A more corrective approach would involve the use of instrumental variables, given 

appropriate instruments, to account for the possible endogeneity of prices. Ideal 

instruments would include cost shifters (e.g., input prices) that would vary by the 

different product groups and that can be observed at the data frequency. In practice, such 

instruments are difficult to obtain. A possible instrumental variable approach in the 

literature, of using prices in other divisions as instruments, was tried but it did not 

produce reasonable results.7

 

 

 7

 The idea behind this approach is that prices for product j can be modeled as 

( , , ) jdt jd jt jdt p  f  c  that includes a division fixed effect, underlying costs and demand shocks. Note 

that jt c does not vary across divisions. Thus, prices in other divisions would signal common cost shocks. 

For these instruments to be valid, however, demand shocks  jdt should be uncorrelated across divisions, 

which is an untestable assumption. See Hausman et al., “Competitive Analysis with Differentiated Products,” 

1994; Nevo, “Measuring Market Power in the Ready-to-Eat Cereal Industry,” 2001. 
E-14 

Bibliography 

Chaudhuri, Shubham, Pinelopi Goldberg, and Panle Jia. “Estimating the Effects of Global Patent 

Protection in Pharmaceuticals: A Case Study of Quinolones in India.” American Economic 

Review 96, no. 5, (2006): 1477–1514. 

Deaton, Angus and John Muellbauer. “An Almost Ideal Demand System.” American Economic Review

70, no. 3, (1980): 312–26. 

Hausman, Jerry. “The Valuation of New Goods under Perfect and Imperfect Competition.” In The 

Economics of New Goods, edited by Timothy F. Bresnahan and Robert J. Gordon, 207–48. 

Chicago: University of Chicago Press, 1997. 

 

Hausman, Jerry, Gregory Leonard, and J. Douglas Zona. “Competitive Analysis with Differentiated 

Products.” Annals of Economics and Statistics 34 (1994): 159–80. 

Nevo, Aviv. “Measuring Market Power in the Ready-to-Eat Cereal Industry.” Econometrica 69, no. 2, 

(2001): 307–42.