United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

November 

2010

Analysis in Support of Certification that the 

Rule will not have a Significant Economic 

Impact on a Substantial Number of Small 

Entities

Proposed Rule 

APHIS- 2009-0093

CSF Status of Switzerland and 

Liechtenstein; FMD and SVD Status of 

Liechtenstein

Policy & Program Development

Policy Analysis & Development
1

Summary

This rulemaking would add Switzerland and Liechtenstein to the APHIS-defined 

European classical swine fever region, and Liechtenstein to the lists of regions free of foot-andmouth disease, rinderpest, and swine vesicular disease. The impact of the rule in terms of pork 

and pork product imports from Switzerland and Liechtenstein would be inconsequential. U.S. 

net exports (exports minus imports) of pork and pork products averaged more than 1.17 million 

metric tons (MT) over the five-year period, 2005-2009. During this same period, Switzerland’s 

exports of swine meat averaged only 201 MT, and its net imports (imports minus exports) 

averaged about 8,650 MT.

While most U.S. swine farms are small entities, the potential effect of this rule for these 

operations would be negligible, given the very small volume of pork and pork products exported 

by Switzerland and that country’s status as a net importer of these commodities, in contrast to the 

United States’ role as a major world supplier. Under these circumstances, the Administrator of 

the Animal and Plant Health Inspection Service has determined that this action will not have a 

significant economic impact on a substantial number of small entities.
2

Introduction 

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

certification by the APHIS Administrator that the proposed rule, if promulgated, will not have a 

significant economic impact on a substantial number of small entities. We examine expected 

impacts for U.S. small entities of adding Switzerland and Liechtenstein to the APHIS-defined 

European classical swine fever region, and Liechtenstein to the lists of regions free of foot-andmouth disease, rinderpest, and swine vesicular disease. 

Potential Impact on Small Entities

We address potential impacts of this rule by first describing the significance of small 

entities to U.S. production of pork and pork products and then comparing U.S. and Swiss trade in 

these commodities.

1

 Information on Liechtenstein’s trade in pork and pork products is not 

available, but is presumed to be relatively insignificant. Liechtenstein’s total area is only 160 

square kilometers, less than 2 percent of the country’s employment is engaged in agriculture, and 

its gross domestic product in 2007 was the equivalent of about 1/94 of the Swiss GDP.2

Size and other characteristics of U.S. swine operations

Most swine operations in the United States are small, based on the Small Business 

Administration’s small-entity standard of annual receipts of less than $750,000 (North American 

Industry Classification System category 112210). According to the 2007 Census of Agriculture, 

that year there were 74,789 swine operations in the United States. They sold 207 million swine 

valued at $18 billion. Nearly 90 percent of swine farms are small entities. Based on inventory 

 

1

In 1924, Switzerland and Liechtenstein established a customs union, under which Switzerland formulates trade 

policy measures for the two countries. On January 2009, all border veterinary controls between Switzerland/ 

Liechtenstein and the EU were abolished. Trade in live animals and animal products takes place under the same 

conditions as intra-EU trade. 

2 http://www.liechtenstein.li/en/pdf-fl-multimedia-information-bilateral-schweiz-praesentation.pdf
3

share in 2007, small operations had annual total sales of $3 billion and average sales of about 

$44,700, while large operations had annual total sales of $15 billion and average sales of about

$1,886,200.

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

operations, namely, small family farms and farms having operators who belong to socially 

disadvantaged groups.3 Over 65 percent of swine farms qualified as small family farms (gross 

farm sales of less than $250,000), and many of these small family farms also qualified as limited 

resource farms (gross farm sales of not more than $100,000 and low household income). In 

2007, almost 10 percent of swine farms had a woman as the principal operator. Swine farms 

with Hispanic, African American, and American Indian or Alaskan Native operators each 

comprised about 2 percent of all U.S. swine farms.

According to the 2008 Organic Production Survey, that year 8,748 swine were certified 

organic on 169 farms. These operations had sales that totaled approximately $4 million. Most 

organic farms are relatively small in comparison to conventional swine operations.

U.S. and Swiss pork trade

The pork industry plays an important role in the U.S. economy. Cash receipts from 

marketing swine for meat totaled about $14.4 billion in 2009.4 U.S. pork production increased 

from 9.4 million MT in 2005 to 10.4 million MT in 2009. U.S. consumption of pork and pork 

products increased from 8.7 million MT to 9.0 million MT during this same five-year period, and 

net exports (exports minus imports) increased from 0.7 million MT to 1.5 million MT, an annual 

growth rate in net exports of over 16 percent. Total U.S. exports of pork and pork products in 

 

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

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

4 http://usda.mannlib.cornell.edu/usda/current/MeatAnimPr/MeatAnimPr-04-29-2010.pdf
4

FY 2011 are forecast to reach $4.5 billion, due mostly to larger sales to the major markets of 

Japan and Mexico.5,6

In contrast, over the five-year period 2005-2009, Switzerland’s annual net imports of

swine meat averaged 8,646 MT (imports of 8,847 MT minus exports of 201 MT) and were 

valued at $28.5 million (imports of $29.8 million minus exports of $1.3 million). Nearly all 

Swiss exports of pork and pork products are destined for EU countries. 

While most U.S. swine farms are small entities, the potential effect of this rule for these 

operations would be negligible, given the very small volume of pork and pork products exported

by Switzerland and that country’s status as a net importer of these commodities, in contrast to the 

United States’ role as a major world supplier. Under these circumstances, the Administrator of 

the Animal and Plant Health Inspection Service has determined that this action will not have a 

significant economic impact on a substantial number of small entities.

 

5 http://usda.mannlib.cornell.edu/usda/current/AES/AES-08-31-2010.pdf. 

6 While the United States is a net exporter of pork and pork products, it is a net importer of live swine, all of which 

were imported from Canada in 2008 and 2009. 
5

References

USDA/APHIS/ Veterinary Services, APHIS Evaluation of the Classical Swine Fever Status of 

Switzerland and Liechtenstein, August 2009.

Organic Survey, 2008. The Census of Agriculture, National Agriculture Statistical Service, 

USDA, 2010.

SBA, Small business Size Standards matched to North American Industry Classification System 

2002, Effective July 2006, (http://www.sba.gov/size/sizetable2002.html). 

The Global Trade Atlas: Global Trade Information Services, Inc., Country Edition 

(http://ww.gtis.com/gta/login.cfm).

UN/FAO, FAOSTAT data (http://faostat.fao.org).

USDA/ERS, Livestock, Dairy, and Poultry Outlook, August 2010.

USDA/FAS, Production, Supply and Distribution (ps&d) database

(http://www.fas.usda.gov/psdonline/psdquery.aspx).

USDA/NASS, Meat Animal Production, Disposition, and Income

(http://usda.mannlib.cornell.edu/usda/current/MeatAnimPr/MeatAnimPr-08-31-2010.pdf)