United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

November 

2014

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-2014-0085

RIN 0579-AE04

Importation of Fresh Andean Blackberry and 

Raspberry from Ecuador into the Continental 

United States

Policy & Program Development

Policy Analysis & Development
i

Summary

The proposed rule is in response to a market access request from the Ecuadorian 

Government for APHIS’s authorization to allow the importation into the continental United 

States of fresh Andean raspberries (Rubus idaeus) and blackberries (Rubus occidentalis) under a 

systems approach. Generally, APHIS allows the importation of fresh fruits and vegetables when 

requested by a foreign government, and when sound science and an analysis of the risks show 

that it is appropriate to do so. 

U.S. entities that may be impacted by the proposed rule are U.S. producers of fresh 

raspberries, blackberries, and loganberries, the majority of which are produced in Oregon (98 

percent of U.S. blackberries and almost all of loganberries), Washington (95 percent of U.S. red 

raspberries) and California (84 percent of all color raspberries). As a species, Andean raspberries 

and blackberries are very similar to loganberries.

Impacts of the proposed rule on U.S. entities would be dependent upon the quantity of 

fresh Andean raspberries and blackberries from Ecuador. In 2005, Ecuador had approximately

10,564 acres of Andean blackberry and raspberry crops with a potential production output of 

6,840 metric tons (about 15 million pounds) of fruit. Between 2000 and 2006, Ecuador exported 

an average of 13 metric tons (about 28,660 pounds) of Andean blackberries and raspberries. In 

2007, exports of fresh Andean raspberries and Andean blackberries from Ecuador reached 90 

metric tons (about 198,416 pounds). According to an Ecuadorian government estimate, the 

maximum quantity of fresh Andean raspberries and blackberries that could be exported to the 

United States is less than 182 metric tons per year or 401.24 thousand pounds. 

On average between 2008 and 2012, the United States imported 37.22 million pounds of 

fresh raspberries and between 2011 and 2013 imported 63 million pounds of fresh blackberries. 
ii

Comparing the volume level of these imports with the proposed maximum level of imports from 

Ecuador, the Ecuadorian import share would be less than 0.5 percent of the U.S. import share for 

these fruits.
iii

Table of Contents

Summary.............................................................................................................................. i

Introduction......................................................................................................................... 1

Potential Impact on Small Entities...................................................................................... 4
1

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.

Table 1. U.S. Crop Harvested (Area, Volume, Value) by Crop Category in 2012

Source: USDA, NASS, AMS Report, Noncitrus fruit production by State 2013 and the North American Raspberry 

and Blackberry Association at http://www.raspberryblackberry.com/

Table 1 presents the U.S. raspberry, blackberry, loganberry, and boysenberry production 

in 2012 by crop category. The majority of red raspberry production occurs in California and 

Washington. California produced 97.2 million pounds of raspberries valued at $240 million and 

Washington 62.7 million pounds of raspberries valued at $37.9 million (tables 2 and 3). Oregon 

produced 2.2 million pounds of black raspberries valued at $5.7 million and 2.3 million pounds 

of loganberries and boysenberries valued at over 2 million dollars (table 1).

Table 2. Volume of U.S. Raspberry Production, 2008-2012

California Oregon Washington

 Sum of all raspberries 

In the 3 States

Year

Red 

Raspberries

(1,000 pounds) 

Red

Raspberries

(1,000 pounds)

 Black 

Raspberries

(1,000 pounds)

Red

Raspberries

(1,000 pounds)

Total Volume

(1,000 pounds)

2008 86,400 5,050 3,120 55,000 149,570

2009 123,200 5,400 3,130 65,700 197,430

2010 81,000 5,120 1,740 61,010 148,870

2011 108,000 6,000 2,230 72,300 188,530

2012 97,200 6,600 2,150 62,700 168,650

5 year 

Average 99,160 5,634 2,474 63,342 170,610

Source: USDA, National Agricultural Statistics Service, Noncitrus Fruits and Nuts Summary, Tables: D-4, D-5, D-6 

Crop Category Commercial 

Acres 

Production

(in 1,000 pounds) 

Value

(in 1,000 dollars)

Blackberries

Marion 3,500 25,500 $13,700

Evergreen 500 4,100 $2,400

Other 2,800 23,900 $5,800

Sum of All Blackberries 6,800 53,500 $21,900

Raspberries

Red 11,000 69,300 $44,500

Black 900 2,200 $5,700

Other 5,400 97,200 $239,800

Sum of All Raspberries 17,300 168,700 $290,000

Boysenberries & Loganberries 500 2,300 $2,044
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Table 3. Value of U.S. Raspberry Production, (2008-2012)

In 1,000 US dollars Sum of all raspberries

California Oregon Washington in these 3 States

Year Red 

Raspberries

Red 

Raspberries

Black 

Raspberries Red Raspberries

2008 $259,200 $8,084 $5,815 $92,093 $365,192 

2009 $357,055 $6,956 $1,181 $57,154 $422,346 

2010 $200,288 $6,172 $2,185 $50,254 $787,538 

2011 $223,200 $6,400 $5,510 $44,336 $279,446 

2012 $239,820 $6,644 $5,689 $37,871 $290,024 

5-Year 

Average $255,913 $6,400 $5,510 $44,336 $491,341

Source: USDA, National Agricultural Statistics Service, Noncitrus Fruits and Nuts Summary, Tables: D-4,-5,-6 

U.S. fresh raspberry consumption ranks as the third most popular berry after strawberries 

and blueberries. Nearly 90 percent of U.S. blackberries are consumed in the frozen product form.

Even though the United States is a net exporter of fresh raspberries, U.S. consumers demand 

different varieties of fresh berries to satisfy domestic demand and Andean blackberries and 

raspberries are distinct species, more closely resembling the loganberry than U.S. raspberries and 

blackberries, and are not likely to be substitutes for U.S. commercially produced raspberries and 

blackberries. In addition, most U.S. blackberries are destined for U.S. processed market 

products.

Table 4. US Fresh Raspberries: Supply and Utilization (in 1,000 pounds), 2008-2012 

Year

SUPPLY UTILIZATION Imports as a share 

of Domestic fresh 

consumption Production 1/ Imports Total 

Supply Exports 2/ Domestic Per Capita Use

2008 83,700 25,900 109,600 62,400 47,200 0.15 54.9%

2009 118,800 27,400 146,300 64,300 82,000 0.27 33.4%

2010 78,700 32,100 110,800 47,700 63,100 0.20 50.8%

2011 104,000 42,400 146,400 48,300 98,100 0.31 43.2%

2012 93,600 58,300 15,200 51,500 100,500 0.32 58.0%

Average 95,760 37,220 37,220 105,660 105,660 54,840 54,840 78,181 54,840 78,181 0.25 48.1 %

1/ Based on production in Oregon, Washington, and California, using the assumption that 95 percent of California’s raspberry 

crop is for fresh use. 2/ Exports also, include blackberries, mulberries, and loganberries.

Raspberries, Fresh (HSC-0810.20.1020), Import Statistics US Department of Commerce, Bureau of Census.

Source: USDA, Economic Research Service calculations

Oregon also produces more than 98 percent of U.S. blackberries, making this State the 

predominant geographic source for U.S. blackberries (table 5). In 2013, 51 million pounds of 

blackberries were produced on 7,300 acres, of which 4 million pounds were sold as fresh berries 
3

and the remaining 47 million pounds sold as processed product. The 2008-12 average U.S. 

production of fresh blackberries was valued at 37 million dollars (table 5). During 2008 and 

2013, Mexico was the United States’ major supplier of fresh blackberries and raspberries,

holding a 93 percent share of imports, followed by Guatemala with 4 percent, Canada with 2 

percent, and Chile with 1 percent.

Table 5. US Fresh Blackberry Production, 2008-2013

U.S. Producing State: Oregon US Imports 

Year Volume

(1,000 pounds)

Volume

(metric tons)

Value

(1,000 US$) 

Value

(1,000 US$) 

Volume

(metric tons)

2008 45,100 20,457 $27,773 0 0

2009 54,900 24,902 $30,842 0 0

2010 43,660 19,804 $33,291 0 0

2011 52,680 23,895 $42,783 $45,522 15,343

2012 53,520 24,276 $44,520 $80,288 26,713

2013 51,020 23,142 $42,268 $133,800 43,763

Average 50,147 22,746 $36,913 $43,268 14,303

Source: USDA, National Agricultural Statistics Service, Noncitrus Fruits and Nuts Summary, 

Tables: D-4, D-5, D-6; HTC: 0810209030 Commerce Department, Bureau of the Census 

. 

Overview of the Ecuadorian Raspberry and Blackberry Market

In 2005, Ecuador had approximately 4,275 hectares of Andean blackberry and raspberry

crops with a potential production of 6,840 metric tons of fruit1. Between 2000 and 2006, 

Ecuador exported an average of 13 metric tons of Andean blackberries and raspberries. The 

reason for Ecuador’s relatively small amount of exports is due to the high domestic demand for 

these fruits (0.82 pounds/capita/ year). In 2007, exports of fresh raspberries and blackberries 

from Ecuador reached 90 metric tons. The sea shipping containers that are typically used for 

estimating the volume of fresh fruit shipments are 40 feet long and each holds approximately 40 

thousand pounds or 18.18 metric tons of fruit. According to an estimate given to APHIS by

Ecuador’s Government (PROFIAGRO), the maximum quantity that Ecuador can export annually 

 

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Source of the data are the Ecuadorian Phytosanitary and Sanitary Services (SESA) and the PROFIAGRO 

Program which work in cooperation with APHIS, International Development Bank and International Monetary 

Fund, in compliance of the Andean Trade Preferential Agreement (ATPDEA).
4

of fresh Andean raspberries and blackberries will be less than 10 shipping containers per year or 

less than 181.8 metric tons. 

On average between 2008 and 2012, the United States imported 37.22 million pounds of 

fresh raspberries (table 4) and between 2011 and 2013 U.S. imported 63 million pounds of fresh 

blackberries (table 5).

In comparison with the total U.S. volume of imports of fresh raspberries and blackberries 

the last five years of available data, the potential maximum amount of a given Ecuadorian import 

share would be less than 0.5 percent.

The majority of fresh raspberry, blackberry, and loganberry producers are small entities. 

APHIS welcomes informed public comment in order to better determine the extent to which U.S.

small entities may be affected by this proposed rule.

Potential Impact on Small Entities

Generally, APHIS allows the importation of fresh fruits and vegetables when requested 

by a foreign government, and when sound science and an analysis of the risks show that it is 

appropriate to do so. Although raspberries and blackberries are grown in at least 37 states, only

three states--Oregon, Washington, and California--account for most of the U.S. production for 

both fresh and processing markets of raspberries, blackberries, and loganberries.

Blackberry, raspberry, and loganberry species derive from the genus Rubus. In general, 

U.S. berry growers in cooler climates concentrate on raising raspberries, while blackberries and 

loganberries are mostly grown in the Pacific Northwest and the South. About 90 percent of all 

blackberries are consumed in frozen product form, given the delicate nature and limited shelf life 

of this fruit. Farms producing raspberries and blackberries are classified within the North 

American Industry Classification System under Berry (except Strawberry) Farming (NAICS 

111334). For this industry classification, a business is considered to be a small entity if its 
5

annual receipts are not more than $750,000. The average 2012 market value of crops sold by

farms classified under this category was less than $135,000. We infer that the majority of farms 

producing fresh raspberries and blackberries are small entities. 

The APHIS Administrator has determined that this action, if promulgated, will not have a 

significant economic impact on a substantial number of small entities.