United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

September

2013

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-2013-0059

RIN 0579-AD85

Importation of Fresh Unshu Oranges from 

Japan to the Continental United States, 

7 CFR 319.28

Policy & Program Development

Policy Analysis & Development
i

Summary

This analysis provides the basis for certification that the proposed rule, if promulgated,

will not have a significant economic impact on a substantial number of small entities.

APHIS received a request from the government of Japan to reassess the requirements for 

importing unshu oranges into the continental United States. The proposed rule would harmonize 

our regulations that allow importation of unshu oranges from Japan with our recently amended

domestic regulations to prevent the spread of citrus canker disease.

Easy-peel, sweet, juicy, seedless mandarin varieties, including unshu oranges, are gaining 

popularity in the United States. The United States does not commercially produce unshu oranges, 

but does produce various similar mandarin varieties. U.S. production of these mandarin varieties 

doubled in six years, from a quarter million metric tons (MT) in 2007, to almost half a million

MT in 2012. Production values of mandarin varieties more than doubled, from $141 million in 

2007 to $336 million in 2012. In general, harvesting and marketing activities are most active 

between January 1 and March 31 in California and between November 15 and March 15 in 

Florida. U.S. imports of mandarin varieties averaged about 142,000 MT per year, valued at $178 

million, between 2010 and 2012, with Chile, Spain, Peru and Morocco the main sources. Net 

imports (imports minus exports) averaged about 100,000 MT per year.

In 2012, Japan exported 2,400 MT of unshu oranges valued at $4.5 million. Canada was 

the main destination, accounting for 83 percent of Japan’s exports (2,000 MT). Unshu oranges 

have not been imported from Japan by the United States for the last three years. Between 1996

and 2009, the United States imported about 200 MT of unshu oranges from Japan annually, 

valued at about $340,000, only during the months of November and December. They were
ii

typically sold at a premium in ethnic specialty stores and through small-package direct delivery

to customers who celebrated the New Year’s holidays.

Reportedly, up to 500 MT of unshu oranges may be imported from Japan under the 

proposed rule. Given the much lower volumes and restricted seasonality of past unshu orange 

imports from Japan (about 200 MT annually imported, and only during the months of November 

and December), 500 MT may be an ambitious goal. The 500 MT would be equivalent to less 

than one-tenth of one percent of the U.S. supply of mandarin varieties in 2012. 

Korea is currently the principal source of unshu orange imports by the United States. 

Even if imports from Japan were to reach 500 MT, we expect any product displacement that 

would occur would be largely borne by Korean unshu orange suppliers. The extent to which U.S. 

producers of other mandarin varieties may be affected would depend upon the quantity imported, 

the degree to which consumers may substitute unshu oranges for the other mandarin varieties, 

and their price competitiveness. The Japanese unshu orange share of the U.S. market for 

mandarin varieties is expected to be negligible; past imports have served a specialty market 

during a limited time of the year; and they garner a premium price. Collectively, these conditions 

lead to the conclusion that any effect of the proposed rule for U.S. producers of other mandarin 

varieties would be small. 

Under these circumstances, the proposed rule, if promulgated, will not have a significant 

economic impact on a substantial number of small entities.
iii

Table of Contents

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

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

U.S. production and trade of mandarin varieties ........................................................ 2

Japanese production and trade of unshu oranges........................................................ 5

Relations of mandarin production and trade between the United States and Japan ... 8

Potential Impact on Small Entities.................................................................................... 10
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.

APHIS received a request from the government of Japan to reassess the requirements for 

importing unshu oranges1based on changes to our domestic regulations. The proposed rule 

would harmonize our import regulations for unshu oranges from Japan with recently changed 

domestic regulations for citrus canker, a disease caused by a complex of Xanthomonas spp. 

bacteria. The domestic regulations were amended based on research and a risk assessment that 

concluded commercially packed and disinfected fresh citrus fruits are not an epidemiologically

significant pathway for the spread of citrus canker. Therefore, interstate movement of citrus fruit 

grown in canker quarantine areas does not pose a risk of spreading citrus canker disease if the 

fruit is treated with an approved disinfectant and packed in a commercial packinghouse under a 

compliance agreement. 

We propose to remove the requirements in 7 CFR 319.28 that unshu oranges imported 

from Japan must be grown in specified canker-free export areas and be jointly inspected by the 

national plant protection organization (NPPO) of Japan and APHIS during harvest and 

packing.

2,3,4

 

1 Citrus reticulata Blanco var. unshu, Swingle [Citrus unshiu Marcovitch, Tanaka], also known as Satsuma 

mandarin.

2 Requirements for the movement of unshu oranges from Japan would also include: importation in commercial 

consignments only and practically free of leaves, twigs and other plant parts except for stems that are less than one

inch long and attached to the fruit; packing in a commercial packinghouse registered with the Japanese NPPO; 

standard packing house procedures including treatment with surface disinfectant listed in 7 CFR Part 305; and a 

phytosanitary certificate.

3

Shipments would still not be allowed to move from Kyushu Island into citrus-producing States due to a fruit fly 

that is found in Kyushu. Shipments from Honshu or Shikoku Islands would still require the approved treatment for 
2

Since the U.S. citrus industry produces many mandarin varieties which are substitutes for 

unshu oranges,

5 we first present information on the production and worldwide trade of mandarin 

varieties by the United States and by Japan,

6

followed by information specific to the U.S. market 

for unshu orange imports. We then address likely effects of the proposed rule for small entities. 

U.S. production and trade of mandarin varieties

Easy-peel, sweet, juicy, seedless mandarin varieties are gaining popularity in the United 

States. U.S. production of mandarin varieties doubled in six years, from 245,000 metric tons

(MT) in 2006/07, to 486,000 MT in 2011/12 (Table 1).

7 Active harvesting and marketing dates 

for tangerines are between January 1 and March 31 in California and between November 15 and 

March 15 in Florida.8 Imports of mandarin varieties have been relatively stable, ranging from 

121,000 to 149,000 MT between 2006/07 and 2011/12, except for a decline to 97,000 MT in 

2007/08. Considerably smaller quantities of mandarin varieties are exported by the United States, 

with quantities fluctuating between 8,000 and 51,000 MT over the six years, 2006/07 to 2011/12. 

U.S. net imports (imports minus exports) averaged 98,000 MT over this same period. Supported 

by the robust growth of domestic production and stable imports, per capita consumption of fresh 

mandarin varieties grew by 58 percent between 2006/07 (2.6 pounds) and 2011/12 (4.1 pounds). 

 

insect pests before they may move to citrus-producing States, and treatment would still be required for movement to 

any U.S. State if quarantine pests are found on inspection.

4

Japan and the Republic of Korea have been principal suppliers of unshu orange to the United States. The 

regulations concerning the importation of unshu oranges from Cheju Island of the Republic of Korea were amended 

in 2010. Federal Register (Vol. 75, No. 196 / Tuesday, October 12, 2010, [Page 62455]) Docket No. APHIS-2010-

0022, Final Rule: Importation of Fresh Unshu Oranges From the Republic of Korea Into the Continental United 

States, http://www.regulations.gov/#!docketDetail;D=APHIS-2010-0022

5 Cindy Fake, UC Davis Cooperative Extension, “A Mandarin by Any Other Name” 2004, 

http://www.mountainmandarins.com/documents/10Oct2005-MMGA.pdf

6

Include all tangerine hybrids, such as Fallglo, Sunburst, Honey, clementine, mandarin, Satsuma, as well as tangelos 

and tangors and other citrus hybrids.

7Mandarin variety season begins in November of first year shown.

8 USDA-NASS “Fruits and Tree Nuts: Blooming, Harvesting and Marketing Dates” December 2006.
3

Table 1. U.S. Fresh Mandarin Varieties: Productiona, Imports, Exports, Domestic Supply 

and Per Capita Use: Seasons 2006/07 through 2011/12b

Season ProductioncImports Exports Net 

Imports

Domestic 

Supplye

Per Capita 

Use

--- 1, 000 Metric Tons (MT) --- Pounds

2006/07 245 121 16 105 350 2.6

2007/08 360 97 32 65 425 3.1

2008/09 338 131 29 102 440 3.2

2009/10 435 128 8 120 556 4.0

2010/11 485 149 51 98 582 4.1

2011/12f486 136 37 99 585 4.1

Source: USDA-Economic Research Service (ERS) Fruit and Tree Nut Yearbook, 2012, Table G-19. (Pounds are 

converted to metric tons to be consistent with other data in this analysis.)

a

Includes all tangerine hybrids, such as Fallgio, Sunburst, Honey, clementine, mandarin, and Satsuma as well as 

tangelos and tangors.

b

Season begins in November of first year shown.

c Utilized production, excludes processed fruit.

d Net import equals imports minus exports.

e U.S. production (excluding processed utilization) plus net imports.

f

Preliminary.

Bearing acreages for mandarin varieties have also steadily increased, from 36,800 acres 

in 2006/07 to 52,600 acres in 2011/12 (Table 2). Production values have sharply increased by

138 percent, from $141 million in 2006/07 to $336 million in 2011/12, reflecting the expanding

demand for mandarin varieties in the United States.

Table 2. U.S. Fresh Tangerine aand Mandarin Acreage, Production, Price and Value: 

Seasons 2009/10 through 2011/12

Season

Bearing 

Acreage b

(1,000 acres)

Production

(million boxes c)

Price per box c

(dollars)

Value of 

Production 

(million dollars)

2006/07 36.8 5.9 23.44 141

2007/08 40.5 9.2 23.76 226

2008/09 44.2 8.6 23.05 205

2009/10 45.8 11.5 22.90 267

2010/11 48.3 12.3 25.70 320

2011/12 52.6 12.4 26.68 336

Source: USDA-National Agricultural Statistics Service (NASS) “Citrus Fruits Summary” September 2012, 2011, 

2010, and 2009.

a

Includes tangelos and tangors.
4

b Consists of three States: California, Florida and Arizona. In 2011/12, California accounted for the largest bearing 

area (38,000 acres), followed by Florida (12,100 acres) and Arizona (2,500 acres).

c Equivalent packinghouse-door returns. Box sizes vary by States, citrus type, and season. In 2011/12, the box 

weight for tangerines in California and Arizona was 80 pounds, whereas in Florida it was 95 pounds.

In 2012, the United States exported 36,500 MT of mandarin varieties, valued at $56 

million, F.A.S.

9

(Table 3).

10 Japan is the second largest importer of U.S. mandarin varieties – its

share substantially increased in 2011 to 36 percent, compared to the previous year’s 20 percent.

Canada consistently has been the largest importer of U.S. mandarins, with annual imports 

averaging 20,000 MT.

Table 3. U.S. Exports of Mandarin Varieties,

a

Fresh or Dried (HTS 080520), 

Calendar Year 2008-2012 (1,000 MT)

2008 2009 2010 2011 2012

World Totalb30.8 30.2 33.9 52.6 36.5

Japan 4.4 6.8 6.9 19.0 12.6

Market share: 14% 22% 20% 36% 35%

Canada 18.9 18.5 22.8 22.8 17.2

Netherlands 2.7 1.1 1.2 4.9 3.1

Australia 2.0 2.0 0.5 2.4 1.1

South Korea 0.7 0.2 - - 0.5

All other 2.1 1.6 2.5 3.5 2.0

Source: Global Trade Atlas, U.S. Department of Commerce – Bureau of Census.

a Mandarins (including tangerines and satsuma), clementine, Wilkings and similar citrus hybrids.

b Export data in Table 3 are based on calendar years and includes dried citrus. These data therefore do not 

correspond to export data reported in Table 1 that are based on crop season year and only include fresh mandarin 

varieties.

U.S. imports of mandarin varieties averaged 142,000 MT per year between 2010 and 

2012, valued at $178 million (C.V.).

11 Principal sources were Chile, Spain, Peru and Morocco

(Table 4). Chile has swiftly displaced Spain as the dominant supplier of mandarin varieties, with 

 

9

Free Along Ship Export Value – The value of exports at port of export, excluding the costs of loading, freight, 

insurance and other transportation charges incurred beyond the port of exportation.

10 See note b in Table 3. 

11 Custom Import Value – The price actually paid, excluding import duties, freight, insurance, and other charges.
5

exports to the United States increasing from 16,300 MT in 2008, to 53,500 MT in 2012.12

Imports from Peru also sharply increased, from 8,800 MT in 2008 to 17,200 MT in 2012.

Mandarin imports from Japan, however, did not materialize between 2010 and 2012. The 

United States imported 114 MT of unshu oranges from Japan in 2009 valued at about $143,000. 

Prior to 2009, the United States imported on average about 200 MT of unshu oranges annually

from Japan, valued at about $340,000, only during the months of November and December. 

Table 4. U.S. Imports of Mandarin Varieties,

a

Fresh or Dried (HTS 080520), Calendar 

Year 2008-2012 (1,000 MT)

Metric Ton 2008 2009 2010 2011 2012

World 110.8 120.8 141.0 140.8 143.9

Japan 0.07 0.11 - - -

Market share: 0.06% 0.09% 0% 0% 0%

Chile 16.3 27.3 35.5 43.3 53.5

Spain 53.6 48.3 53.5 54.0 44.2

Peru 8.8 10.6 14.6 14.3 17.2

Morocco 14.6 15.6 20.3 16.2 14.3

All other 17.5 18.8 17.1 13.0 14.7

Source: Global Trade Atlas, U.S. Department of Commerce – Bureau of Census.

a Mandarins (including tangerines and satsuma), clementine, Wilkings and similar citrus hybrids.

b

Import data in Table 4 are based on calendar years and includes dried citrus. These data therefore do not 

correspond to export data reported in Table 1 that are based on crop season year and only include fresh mandarin 

varieties.

Japanese production and trade of unshu oranges

Japan has a long history of unshu orange production dating back about 500 years. In 

recent decades, production and acreage have contracted to about 900,000 MT and 110,000 acres 

in 2012, from its peak of 3.6 million MT and 390,000 acres in 1972 – a 75 percent reduction in

40 years (

Figure 1).

13 Nonetheless, unshu oranges still accounted for 27 percent, by value, of all 

fruit produced in Japan in 2010, the largest single share.

14 Many cultivars of unshu orange exist

in Japan, which are typically classified according to the time of harvest. 

 

12 In 2012, Spain still kept the top place in terms of import value ($65 million), compared to Chile ($50 million). 
6

Figure 1. Japan: Unshu Orange Production and Acreage: 1973-2012

Source: USDA-Foreign Agricultural Service (FAS) GAIN Report “Japan, Citrus Annual” December 2012,

Japanese Ministry of Agriculture, Forestry and Fisheries (MAFF), Fruits Production and Shipment Statistics

Japan’s unshu orange exports are relatively small (Table 5). In 2012, Japan exported 

2,424 MT of unshu oranges, valued at $4.5 million (F.O.B.),

15 with Canada by far the largest 

importer. No unshu oranges were exported to the United States in 2011 or 2012; however, Japan 

exported about 100 MT per year to the United States between 2008 and 2010. 16 The 2012 

average price worldwide was $1.87 per kilogram (KG). The unit value of exports to the United 

States closely aligns with the world average.

 

13 Unshu orange originated in Kagoshima Prefecture, formerly called Satsuma. It is said that seeds came from 

Zhejiang Province in China approximately 500 years ago, from which chance seedlings grew.

14 Ministry of Agriculture, Forestry and Fisheries (MAFF) Agricultural Statistics 

http://www.maff.go.jp/j/tokei/kouhyou/sakumotu/sakkyou_kazyu/index.html#y

15 Free On Board – A standard reference to the price of merchandise on the border or at a national port. In F.O.B. 

contracts, the seller is obliged to have the goods packaged and ready for shipment at the place agreed upon, and 

purchaser agrees to cover all ground transport costs and to assure all risks in the exporting country, together with 

subsequent transport costs and expenses incurred in loading the goods onto the chosen means of transport.

16 We note that there are differences in reporting periods and other discrepancies between the trade data for the 

United States and Japan.

0

50

100

150

200

250

300

350

400

450

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

19731975197719791981198319851987198919911993199519971999200120032005200720092011

Thousand Acre

T

s

housand M

T

Japanese Unshu Orange Production and Acreage

Production ('000 MT) Acreage ('000 acre)
7

Table 5. Japan: Exports of Mandarin Varieties, Fresh or Dried (HTS 080520), Calendar 

Year 2008-2012 (1,000 MT)

2008 2009 2010 2011 2012

World 3.4 2.6 2.2 2.6 2.4

Unit Value/KG $1.38 $1.48 $1.82 $1.85 $1.87

United Statesb0.1 0.1 0.1 - -

Market share: 3% 4% 2% 0% 0%

Unit Value/KG $1.48 $1.40 $1.82 - -

Canada 2.9 2.1 1.6 2.2 2.0

Hong Kong 0.2 0.2 0.2 0.1 0.2

Taiwan 0.1 0.1 0.2 0.1 0.1

Singapore 0.0 0.1 0.1 0.1 0.1

All other 0.0 0.1 0.1 0.1 0.1

Source: Global Trade Atlas, Japan Customs.

a Primarily consisted by unshu oranges.

b The export quantities to the United States shown in this table are not equal to the U.S. import quantities from Japan 

shown in Table 4 due to differences in reporting periods and other discrepancies.

Exports of unshu orange from Japan to the United States have been highly seasonal, 

occurring only during the months of November and December (Figure 2). These unshu oranges 

were typically sold at premium prices in ethnic specialty stores and through small-package direct

delivery to customers who celebrated the New Year’s holidays.

17

Figure 2. Monthly Imports of Unshu Orange from Japan to U.S.: Oct. 2004 – Sept. 2009 

(1,000 MT)

Source: Global Trade Atlas, U.S. Department of Commerce – Bureau of Census

 

17 We do not have the information on retail prices for unshu oranges imported from Japan. USDA-Agricultural 

Marketing Service Custom Average Price shows that the terminal market prices for Satsuma oranges averaged about 

$2.09/KG from California and Florida, and $2.61/KG from Peru in 2012, suggesting imports are generally sold with 

premiums. No other imported prices of mandarin varieties are available at either terminal market or retail levels.

 -

 50

 100

 150

 200

Thousand M

T

Monthly Imports of Unshu Orange from Japan to U.S.

Oct 2004 - Sept 2009 (1,000 metric tons)
8

Japan is a net importer of mandarin varieties.

18 In 2012, Japan imported 20,309 MT of 

mandarin varieties, valued at $31 million (C.I.F.) (Table 6). The United States has consistently

supplied the largest share, accounting for 82 percent in 2012, valued at $22 million (C.I.F.). Unit 

values for mandarin varieties imported from the United States have been consistently lower than 

the average unit values of imports from all sources, for example, by 21 cents/KG in 2012 and by

8 cents/KG in 2008.

Table 6. Japan: Imports of Mandarin Varieties, Fresh or Dried (HTS 080520), Calendar 

Year 2008-2012 (1, 000 MT)

2008 2009 2010 2011 2012

World 10.2 9.0 10.9 21.3 20.3

Unit Value/KG $1.29 $1.49 $1.46 $1.55 $1.53

United Statesa

7.8 7.1 9.2 17.6 16.6

Market share 76% 79% 84% 83% 82%

Unit Value/KG $1.21 $1.39 $1.31 $1.43 $1.32

Australia 1.5 1.2 1.0 2.3 2.1

New Zealand 0.4 0.5 0.3 0.9 1.0

Chile 0.2 0.2 0.3 0.5 0.3

All other 0.4 0.1 0.1 0.1 0.3

Source: Global Trade Atlas, Japan Customs.

a Quantities imported from the United States are not equal to U.S. export quantities to Japan shown in Table 3 due to 

differences in reporting periods and other discrepancies..

Relations of mandarin production and trade between the United States and Japan

As discussed previously, annual U.S. production of mandarin varieties doubled over six 

years, to 0.5 million MT in 2011/12. With steady net imports of about 0.1 million MT annually, 

U.S. per capita consumption of mandarin varieties increased to 4.1 pounds in 2011/12, from 2.6 

pounds in 2006/07. Per capita consumption in Japan, 13.4 pounds in 2011, is still much higher

than in the United States.

19 However, it has declined almost 80 percent from its peak of 60 

 

18 Mainly mandarin varieties other than unshu oranges.

19 Per capita consumption of unshu orange in Japan was 10.1 pounds in 2011.
9

pounds in 1972.

20 As shown in Figure 3, the decrease in unshu orange production in Japan and

the increase in U.S. production of mandarin varieties are resulting in their respective production 

trend lines to converge.

Figure 3. Unshu Orange Production in Japan and Mandarin and Mandarin Hybrid 

Production in the United States: 1981 – 2012 (in thousand metric tons)

Sources: USDA-ERS Fruit and Tree Nut Yearbook 2012

Ministry of Agriculture, Forestry and Fisheries (MAFF), Japan, Fruits Production and Shipment Statistics

Korea and Japan have been the principal suppliers of unshu oranges to the United States. 

Imports of unshu oranges from Korea averaged about 650 MT annually between 1995 and 2002, 

prior to administrative suspension of unshu orange imports from Korea to the United States. 

Following removal of the import suspension in 2010, imports of unshu orange from Korea

totaled 445 MT in 2011 (valued at $0.6 million) and 447 MT in 2012 (valued at $1 million).

The Pathway-initiated Risk Analysis for this proposed rule assumes the upper range of

annual unshu orange imports from Japan would be about 500 MT. Unshu orange imports from 

 

20 MAFF statistics. Per capita consumption of unshu orange was 42 pounds in 1972 and declined to 10 pounds in 

2011.

0

500

1,000

1,500

2,000

2,500

3,000

3,500

19811982198319841985198619871988198919901991199219931994199519961997199819992000200120022003200420052006200720082009201020112012

Unshu Orange Production in Japan and Mandarin and 

Mandarin Hybrid Production in the United States

(in Thousand Metric Tons)

Japan: Unshu Orange U.S.: Tangerine Varieties and Hybrids
10

Japan to the United States had been historically lower than imports from Korea; imports from 

Japan averaged about 200 MT between 1996 and 2010 with an average value of $0.34 million

(Figure 4). Considering this historical information, an increase of 500 MT may be a challenge.

Even if the imports from Japan were to reach 500 MT, given the fact that fresh unshu oranges are

predominantly supplied by Korea and Japan, we expect any product displacement that may occur 

because of the proposed rule would be largely borne by Korean suppliers. 

Figure 4. Mandarin Exports by U.S. to Japan, Japan to U.S. and Korea to U.S.: 1994-2012

Source: Global Trade Atlas, U.S. Department of Commerce – Bureau of Census

Potential Impact on Small Entities

The United States is not a commercial producer of unshu oranges (Citrus reticulata

Blanco var. Unshu) but produces other mandarin varieties of Citrus reticulata in Alabama, 

Arizona, California, Florida, Hawaii, Louisiana and Texas. As a result, the proposed rule may

affect domestic mandarin, and other mandarin variety growers, and wholesalers and distributors 

of these mandarin varieties, to the extent that unshu oranges can substitute for the other mandarin 

 -

 2,000

 4,000

 6,000

 8,000

 10,000

 12,000

 14,000

 16,000

 18,000

 20,000

Metric T

on

Mandarin Exports by U.S., Japan and South Korea

1994-2012 (Metric Ton)

U.S. Export to Japan Japan Export to U.S. Korea export to U.S.
11

varieties. Nonetheless, given the relatively low level of unshu orange imports expected from 

Japan, this proposed rule is likely to have minimal economic impacts on small U.S. entities.

Following the Small Business Administration (SBA) guidelines, the entities potentially

affected by the proposed rule are classified within the following industries: Citrus (except 

Orange) Groves (NAICS 111320), and Fresh Fruit and Vegetable Merchant Wholesalers 

(NAICS 424480).21,22

Establishments classified within Citrus (except Orange) Groves are considered small by

SBA standards if annual sales are not more than $750,000. APHIS does not have information on 

the size distribution of non-orange citrus producers, but according to the 2007 Census of 

Agriculture there were 9,659 other orange growers, a category that includes all orange growers 

except those producing Valencia oranges, as well as 1,976 tangerine growers. Average annual 

sales per “other orange” grower is estimated to have been about $121,715 in 2007,

23 well below 

the SBA small-entity threshold of $750,000. We infer that most if not all U.S. “other orange”

growers, including tangerine growers, are small entities. 

Establishments classified within Fresh Fruit and Vegetable Merchant Wholesalers are 

considered small by the SBA standards if they employ not more than 100 persons. According to 

the 2007 Survey of Business Owners, 97 percent of the 5,074 establishments in this category

employed fewer than 100 people.24

 

21 NAICS refers North American Industry Classification System.

22 U.S. Small Business Administration, Table of Small Business Size Standards http://www.sba.gov/content/tablesmall-business-size-standards 

23 Average sales per entity is based on the number of non-Valencia orange growers recorded in the 2007 

Agricultural Census, i.e., 9,659 operations, and the total value of fresh and processed non-Valencia oranges reported 

in the USDA-NASS Citrus fruits 2008 Summary, i.e., $1.2 billion. 

http://usda01.library.cornell.edu/usda/nass/CitrFrui//2000s/2008/CitrFrui-09-25-2008.pdf

24 U.S. Census Bureau, Survey of Business Owners, 2007 Survey Results. 

http://www.census.gov/econ/sbo/07menu.html
12

Clearly, the industries that could be affected by the proposed rule are overwhelmingly 

composed of small entities. However, as described, we expect any effects to be insignificant. 

Even if imports from Japan were to reach 500 MT, it is likely that any product displacement that 

would occur would be largely borne by Korean suppliers. The extent to which U.S. producers of 

other mandarin varieties may be affected would depend upon the quantity imported, the degree 

to which consumers may substitute unshu oranges for the other mandarin varieties, and their 

price competitiveness. The Japanese unshu orange share of the U.S. market for mandarin 

varieties is expected to be negligible. The 500 MT would be equivalent to less than one-tenth of 

one percent of the U.S. supply of mandarin varieties in 2012. Past imports, which garnered a 

premium price, served a specialty niche market during a limited time of the year prior to peak 

harvesting and marketing activities of U.S. mandarin varieties. Collectively, these conditions 

lead to the conclusion that any effect of the proposed rule for U.S. producers of other mandarin 

varieties would be small. 

Under these circumstances, the proposed rule, if promulgated, will not have a significant 

economic impact on a substantial number of small entities.