United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

August 2013

Analysis in Support of Certification that the 

Rule will not have a Significant Economic 

Impact on a Substantial Number of Small 

Entities

Final Rule

APHIS-2012-0002

RIN 0579- AD63

Avocado from Continental Spain

Policy & Program Development

Policy Analysis & Development
i

Summary

APHIS is going to allow imports from continental Spain of fresh avocado under a 

systems approach to pest risk mitigation. Over the three-year period, 2009-2011, annual U.S. 

avocado production averaged about 222,498 metric tons (MT). In comparison, U.S. net imports 

(imports minus exports) averaged about 397,350 MT per year over this same period, resulting in 

U.S. supply (production plus net imports) that averaged about 619,848 MT per year. Annual 

avocado imports from continental Spain are expected to total about 260 MT, that is, an amount 

equivalent to 0.12 percent of U.S. production, 0.06 percent of U.S. net imports, and 0.04 percent 

of U.S. supply, based on the 2009-2011 average annual quantities. 

U.S. avocado producers and avocado importers are predominantly small entities. Given 

the small quantity of avocado expected to be imported from continental Spain, no U.S. entity, 

large or small, is expected to be significantly affected by the proposed rule. The APHIS 

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

economic impact on a substantial number of small entities.
ii

Table of Contents

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

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

Potential Impact on Small Entities...................................................................................... 2
1

Introduction 

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

certification by the APHIS Administrator that the rule will not have a significant economic 

impact on a substantial number of small entities.

In response to a request from the Spanish national plant protection organization, APHIS 

is going to allow the importation into the United States of fresh avocado from continental Spain 

under a systems approach intended to prevent the introduction of quarantine pests. This analysis 

provides the basis, as required by the Regulatory Flexibility Act, for certification by the APHIS 

Administrator that the final rule will not have a significant economic impact on a substantial 

number of small entities. 

In 2011, the United States was the world’s fifth largest avocado producer and accounted 

for about 6 percent of the global production. The four leading avocado producing countries, with 

their production share inside the parenthesis, were: Mexico (30 percent), Chile (7 percent), 

Dominican Republic (6 percent), and Indonesia (6 percent) each, respectively (table 1). 

U.S. commercial production of avocado occurs in three States: California accounts for 

about 90 percent, followed by Florida with about 9 percent, and Hawaii with less than 1 percent. 

California grows mainly Hass avocado (characterized by purplish-black skin) in San Diego, 

Riverside, Ventura, and Santa Barbara counties. Florida-produced avocados are larger, greenskinned varieties grown mainly in Miami-Dade County. California’s avocado acreage (bearing 

and non-bearing) is more than 7 times that of Florida, but has declined since 2005 by about 20 

percent, while Florida’s avocado acreage has increased by about 14 percent. During this time, 

U.S. bearing acreage has remained steady at just over 68,700 acres. In 2010, U.S. utilized 
2

production of avocado totaled about 135,500 metric tons (MT), only one-half of the 271,000 MT 

produced in 2009, and indicative of the significant variability in yield from year to year (table 2).

In the last decade, U.S. per capita consumption of avocado has risen significantly, from 1 

kilogram in 2000 to 1.86 kilograms in 2010, representing an annual growth rate of about 6.4 

percent.1 Although the United States is a major producer of avocado, it is also the largest import 

market (since 2002) and has been a net importer since the late 1980s. During this time, the gap 

between U.S. imports and U.S. exports has widened substantially. The average annual value of 

U.S. avocado imports, 2009-2011, was nearly $622 million, compared to average annual exports 

valued at less than $16 million (table 2). 

Spanish avocado producers expect to export to the United States about 260 MT of fresh 

avocado annually, an amount equivalent to 0.15 percent of U.S. production, 0.07 percent of U.S. 

net imports (imports minus exports), and 0.05 percent of U.S. supply (production plus net 

imports), based on 2009-2011 average annual U.S. production and trade quantities (table 3).

Potential Impact on Small Entities

Entities that may be directly affected by the final rule are U.S. importers and producers of 

avocado. Avocado importers are classified in the North American Industry Classification 

System under Fresh Fruit and Vegetable Merchant Wholesalers (NAICS 424480). Avocado 

producers are classified under Other Noncitrus Fruit Farming (NAICS 111339).

2

The Small 

Business Administration (SBA) has established guidelines for determining which establishments 

are to be considered small. A firm primarily engaged in fresh fruit and vegetable wholesaling is 

 

1 USDA, Economic Research Service.

2 This industry comprises establishments primarily engaged in growing noncitrus fruits (except apples, grapes, 

berries, and fruit and nut combinations.
3

considered small if it employs not more than 100 persons. A firm primarily engaged in noncitrus 

fruit farming is considered small if it has annual sales of not more than $750,000.

In 2007, nearly 95 percent of fruit and vegetable wholesale establishments (4,207 of 

4,437 businesses) that operated the entire year were small by the SBA’s small-entity threshold of 

not more than 100 employees.

3

 That same year, nearly 93 percent of farms that sold fruits, tree 

nuts, or berries (104,424 of 112,690 operations) had annual sales of less than $500,000, well 

below the SBA’s small-entity threshold of $750,000.4 The subset of these farms that comprise 

the industry Other Non-citrus Fruit Farming numbered 23,641, and can be assumed to be also 

primarily composed of small entities.5 Of these Other Non-citrus Fruit Farming establishments, 

there were 8,245 avocado farms in 2007, also presumed to be principally small operations. 

While most entities that may be affected by the final rule are small, any effects would be 

insignificant because of the small quantity of avocado expected to be imported from continental 

Spain. Under these circumstances, the APHIS Administrator has determined that this action will 

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

 

3 U.S. Census Bureau, 2007 Economic Census. Wholesale Trade: Subject Series—Establishment & Firm Size: 

Summary Statistics by Employment size of establishments for the United States. .

4 USDA NASS, Census of Agriculture, Volume 1, Table 59. Summary by Market Value of Agricultural Products 

Sold: 2007.

5 USDA NASS, Census of Agriculture, Volume 1, Table 46. Selected Characteristics of Farms by North American 

Industry Classification System: 2007.
4

Table 1. World’s Top 5 Avocado Producers, 2002-2011 (thousand metric tons)

Countries 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Average

(2002 –

11)

10 year

Share

(%)

Mexico 901 905 987 1,022 1,134 1,143 1,125 1,231 1,107 1,269 

(1,082)

30

Chile 140 140 160 160 205 260 331 328 330 369 (241) 7

Indonesia 238 256 222 228 240 202 225 258 224 276 (237) 7

Dominic. 

Republic 148 274 219 114 216 184 187 184 289 295 (211) 6

USA 181 212 163 283 247 193 116 269 158 239 (206) 6

Others 1,406 1,450 1,511 1,649 1,591 1,671 1,662 1,789 1,912 2,040 (1,668) 46

World 

Total 3,014 3,237 3,262 3,456 3,633 3,653 3,646 4,059 4,020 4,488 (3,647) 100

Source: FAOSTAT 2013. Numbers are rounded so they may not always match.

Table 2. Annual U.S. Production and U.S. and Spanish Avocado Trade, 2009-2011 (quantities in metric tons) 

2009 2010 2011

Quantity Value Quantity Value Quantity Value

U.S. utilized avocado 

production

270,799 $429,586,000 158,150 $376,103,808 238,544 $492,100,00

U.S. avocado exports 2,455 $4,515,437 18,502 $31,340,087 7,341 $25,043,810

U.S. avocado imports 431,734 $711,176,603 345,010 $574,698,302 415,306 $912,998,844

U.S. net imports 429,279 $706,661,166 326,508 $543,358,215 407,965 $887,955,034

Spain’s avocado 

exports

53,053 $119,044,669 54,422 $117,026,309 70,888 $172,648,154

Spain’s avocado 

imports

30,275 $63,981,049 32,822 $62,630,100 29,848 $62,014,060

Spain’s net exports 22,778 $55,063,620 21,600 $54,396,209 41,040 $110,634,094

Source: USDA NASS; U.S. Census Bureau, as reported by Global Trade Information Services, Inc.
5

Table 3. Average Annual Volume of U.S. Avocado Production and of expected U.S. & Spanish Trade, 2009-2011

US Avocado Production and Spain’s 

Avocado Trade

3-Year Average Quantity

(metric tons)

Comparative Size with respect to the 

volume (260 metric tons/year) of expected 

US avocado imports from Spain 

U.S. utilized production in avocados 222,498 0.12 percent

U.S. avocado exports 9,433 2.76 percent

U.S. avocado imports 397,350 0.07 percent

U.S. net imports of avocados 387,917 0.07 percent

U.S. avocado supply 619,848 0.04 percent

Spain’s exports of avocados 59,454 0.42 percent

Spain’s imports of avocados 30,982 0.84 percent

Spain’s net exports of avocados 28,473 0.91 percent

Sources: USDA NASS; U.S Census Bureau, as reported by Global Trade Information Services, Inc.; Spanish 

Government, SGAISV.

The APHIS Administrator has determined that this action will not have a significant 

economic impact on a substantial number of small entities.