1

United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Importation of fresh litchi (Litchi chinensis) fruit 

from the Republic of South Africa into the 

continental United States

Risk Management Document

January 06, 2011

Ver. 1.0

Plant Health Programs (PHP)

Regulations, Permits and Manuals (RPM)

Contact Person: Marc.Phillips@aphis.usda.gov
2

A. Introduction

The Government of the Republic of South Africa (RSA) requested permission to import 

Litchi chinensis Sonn. (litchi) fruit into the United States. Litchis have not been imported 

from RSA before, so a pathway-initiated risk assessment (PRA) was conducted. A list of 

litchi pests in RSA was prepared based on United States Department of Agriculture 

(USDA)’s Animal and Plant Health Inspection Service (APHIS) records of intercepted pests, 

and scientific literature. The pest risk assessment document, “Importation of Fresh Litchi,

Litchi chinensis Sonn., Fruit from the Republic of South Africa into the Continental United 

States: A Qualitative, Pathway-initiated Pest Risk Assessment” (USDA, 2009), identified the 

following eight quarantine insect pests that could follow the pathway of commercial 

consignments of fresh litchi fruit. 

Ceratitis capitata Wiedemann (Diptera: Tephritidae)

Ceratitis rosa Karsch (Diptera: Tephritidae)

Ceroplastes rubens Maskell (Homiptera: Coccidae)

Ceroplastes rusci (Linnaeus) (Hemiptera: Coccidae)

Coccus viridis (Green) (Hemiptera: Coccidae)

Cryptophlebia peltastica (Meyrick) (Lepidoptera: Tortricidae)

Nipaecoccus viridis (Newstead) (Hemiptera: Pseudococcidae)

Thaumatotibia leucotreta (Meyrick) (Lepidoptera: Tortricidae)

All pests were rated to have high risk potential. The Animal and Plant Health Inspection 

Service, Plant Protection and Quarantine (PPQ) commodity Pest Risk Assessment (PRA) 

guidelines state that for pests rated as high risk, phytosanitary measures beyond port-of-entry

inspections are strongly recommended (USDA, 2000). 

The proposed importation of litchi from RSA, if approved, would be regulated by an 

amendment to the APHIS’ Fruits and Vegetables Import Requirements (FAVIR) database 

available on-line. This risk management document outlines the phytosanitary measures that 

APHIS will require if the proposed importation of this commodity from RSA is approved and 

documents the evidence used by APHIS to conclude that these measures will effectively 

prevent the introduction of quarantine pests. 

B. Risk Management Measures

APHIS proposes to allow the importation of the fresh fruit of litchi from RSA into the 

continental United States under the following conditions: 

(a) The litchi fruit must be irradiated with a minimum absorbed dose of 400 Gy and follow 

the requirements of 7CFR parts 305 and 319.

(b) Prior to departure from RSA, each consignment must be inspected and found to be free 

from pupae of Cryptophlebia peltastica. Using a biometric sampling procedure mutually

agreed upon by APHIS and the National Plant Protection Organization (NPPO) of RSA, a 
3

representative sample of fruit must be drawn from each lot, cut open and inspected for the 

presence of any pupae of this pest. 

(c) If irradiation is applied outside the United States, each consignment of fruit must be 

inspected jointly by inspectors from APHIS and the NPPO of RSA prior to departure and 

accompanied by a Phytosanitary Certificate (PC) issued by the NPPO of RSA certifying that 

the fruit received the required irradiation treatment, and with an Additional Declaration 

stating that the consignment was inspected by RSA inspectors and found to be free from

pupae of Cryptophlebia peltastica. If irradiation is to be applied upon arrival in the United 

States, each consignment of fruit must be inspected by RSA inspectors prior to departure and 

accompanied by a PC issued by the NPPO of RSA with an Additional Declaration stating 

that the consignment was inspected by RSA inspectors and found to be free from pupae of

Cryptophlebia peltastica.

(d) Each consignment is subject to inspection at the United States ports-of-entry. 

(e) The fruit must be commercially produced and be part of a commercial consignment as

defined in Section 319.56-2. 

C. Historical Performance of Importing Irradiated Fruits

Current regulations (7 CFR 305.9) allow the use of irradiation to treat fruit for importation 

into the United States. In April 2007, India began shipping mangoes irradiated with 400 Gy

to the United States and has continued shipping irradiated mangoes each year since. This 

was followed by Thailand, which started shipping mangoes and five other fruits all treated 

with 400 Gy irradiation dose to the United States beginning November 1, 2007. Thereafter 

commodities irradiated with 400 Gy have also been imported from Vietnam (dragon fruit) 

and Mexico (guava and mango). No pests of quarantine significance have been reported 

from the irradiated fruit imported from all these countries (Pest ID, 2010). 

Current domestic regulations (7 CFR318.13-4f) allow the interstate movement of fifteen 

different fruit, including mango, from Hawaii, using a minimum absorbed dose of from 150 

Gy to 400 Gy. For example, the dose of 300 Gy is adequate to mitigate the risk from mango 

seed weevil in mango fruit, while all fruit flies require a dose of 150 Gy (USDA, 2006b). No 

live pests of quarantine significance have been intercepted from fruits and vegetables treated 

with irradiation in Hawaii and moved to the mainland United States (Uyeda, 2005). In 

Addition, there have been no records of pest interceptions on Australian mangoes irradiated 

with 150 Gy dose and imported into New Zealand since 2004 (Edwards, 2005). 

D. Evidence for the Effective Removal of Pests of Concern from the Pathway

The measures described in Section B would effectively remove the pests of concern from the 

stated pathway. 
4

All the pests of concern for the importation of litchi from RSA are insects. Irradiation of 

fruits and vegetables with a minimum absorbed dose of 400 Gy is a treatment approved by

APHIS for mitigating risks from all insect pests except for adults and pupae of the order 

Lepidoptera (USDA, 2006). Two of the litchi quarantine pests belong to the order 

Lepidoptera: Thaumatotibia leucotreta (false codling moth) and Cryptophlebia peltastica

(litchi moth). The adult and pupal stages of T. leucotreta are external feeders; adults are 

mobile and, because of their size, are easily detectable during inspection. Treatment with a 

minimum absorbed dose of 400 Gy is also approved by APHIS to successfully neutralize 

eggs and larval stages of this pest1. 

In case of Cryptophlebia peltasica, there is evidence that the larvae may occasionally pupate 

inside the fruit (Grové, 1999; de Villiers, 2001). Although irradiation with a generic dose of 

400 Gy dose is not an approved treatment for pupae of Lepidoptera, evidence suggests that 

the dose may be sufficient to neutralize the pupae of this pest and thereby mitigate the

pathway risks. Research by Follett and Lower (2000) has shown that a dose as low as 250 

Gy was sufficient to cause a complete sterility among the pupae or the resulting progeny of a

closely related species, Cryptophlebia illepida, which lead the authors to believe that the 

dose would likely have similar effects on other species of Cryptophlebia as well. However,

in the absence of a comparative study involving C. peltastica or large scale confirmatory

tests performed on members of the genus Cryptophlebia, a measure of confidence could not 

be established. Therefore additional measures are required to supplement the irradiation 

treatment. C. peltastica produces visible holes on the fruit skin, leaving brown frass on the 

surface, which are easily detectable during inspection. Biometric sampling, fruit cutting and 

inspection during the preclearance activities is considered adequate to detect the internal

pupae. This sampling regime may be adjusted to provide 95% of confidence for the 

detection of 3% or less infestation rate as may be agreed upon by APHIS and the NPPO. 

Other life stages such as eggs and larvae are effectively managed by the irradiation dose of

400 Gy (USDA 2006). 

The requirement for a Phytosanitary Certificate provides quality control and rigor by

requiring RSA officials to conduct phytosanitary inspections for the pests not targeted 

by the treatment. This along with port of entry inspection effectively doubles the 

inspections the fruit receives. Furthermore, specifically listing the pest of concern on 

the Additional Declaration alerts U.S. inspectors to the specific pest. 

APHIS regulations on irradiation require that the treatment be monitored where applied and 

the consignment examined for pests of concern not targeted by the treatment. Although the 

400 Gy dose is effective for all pests except the adults and pupae of Lepidoptera, fruit cutting

and inspections by the United States and RSA NPPOs should ensure that the consignments

are free of the two Lepidopteran stages of concern that irradiation is not considered effective 

against.

 

1 For irradiation treatment, neutralizing a pest generally refers to either sterilizing the pest or preventing it from 

achieving sexual maturity, although irradiation treatment can in some cases kill pests that may be present. 
5

By allowing only commercial consignments of litchis into the United States, it is assumed

that the fruits would undergo standard post harvest commercial handling (e.g. culling, 

packing, and sanitation). By requiring that irradiation must follow requirements of 305.9 and 

that packages containing irradiated fruit be labeled as per 305.9(g)(3)(iii) ensures the

integrity of the shipment and the capability to trace back to origin.

E. Conclusion

The phytosanitary requirements described above include irradiation treatment for quarantine 

pests of litchi from RSA using a minimum absorbed dose of 400 Gy, and inspections for the 

pests or pest stages not targeted by the irradiation treatment. 

APHIS concludes that based on the evaluation of effectiveness of these mitigation measures 

directed against the pests of concern, the safeguards of 7 CFR § 319.56 and the Phytosanitary

Certificate with an Additional Declaration described in this Risk Management Document, 

these measures will result in the effective removal from the pathway of the pests of concern 

identified by the PRA for the importation of fresh litchi fruit from RSA into the continental 

United States.

F. Authors:

Marina Zlotina

Risk Manager - TDY

Inder Paul S. Gadh

Senior Risk Manager
6

G. Literature Cited:

de Villiers, E.A. 2001. Cryptophlebia peltastica (Meyrick). Litchi moth. In: A. van den 

Berg, E.A. de Villiers and P.H. Joubert (Eds.) Pests and Beneficial Arthropods of Tropical 

and Non-Citrus Subtropical Crops in South Africa, pp. 325– 328. Institute for Tropical and 

Subtropical Crops, South Africa, Nelspruit.

Edwards, G. 2005. Personal Communication from G. Edwards of NZ Department of 

Agriculture & Fisheries to Karen Ackerman of USDA, APHIS, PPQ, Phytosanitary Issues 

Management, Riverdale, MD.

Follett, P.A. and R. A. Lower. 2000. Irradiation to Ensure Quarantine Security for 

Cryptophlebia spp. (Lepidoptera: Tortricidae) in Sapindaceous Fruits from Hawaii. J. Econn. 

Entomol. 93(6): 1848-1854.

Grové, T. 1999. The litchi moth – a literature review. Cryptophlebia peltastica (Meyrick) 

(Lepidoptera: Tortricidae). Neltropika Bull. 305: 30-31.

Pest ID. 2010. USDA, APHIS, Plant Protection and Quarantine, Pest Interception 

Dadabase. Last checked May 2010.

USDA. 2000. Guidelines for Pathway-Initiated Pest Risk Assessments. Version 5.02. October 

17, 2000.

USDA. 2006. Treatments for Fruits and Vegetables. January 27, 2006 issue of Federal 

Register 71(18): 4451-4464

USDA. 2009. Importation of Fresh Litchi, Litchi chinensis Sonn., Fruit from the Republic of 

South Africa into the Continental United States: A Qualitative, Pathway-initiated Pest Risk 

Assessment. USDA, APHIS, Plant Protection and Quarantine, Center for Plant 

Health Science and Technology, Raleigh, North Carolina. 2009. pp 40.

Uyeda, E. 2005. Personal communication from E. Uyeda, Port Director, US Department of 

Agriculture, USDA, APHIS, PPQ, Hilo, HI.