Rev. 4 1

United States Department of Agriculture 

Animal and Plant Health Inspection Service 

Plant Protection and Quarantine

 

 

Risk Management Document

Importation of Fresh Commercial Avocado (Persea americana 

Mill. var. Hass) Fruit in Bulk Shipments from Mexico into the 

United States. 

November 3, 2009 

Plant Health Programs (PHP) 

Risk Management and Plants for Planting Policy (RMPPP) 

Contact Person: David B Lamb 
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Introduction

 In conjunction with the expansion of market access for Mexican Hass avocados into the United 

States, Mexico requested procedures to be followed so that shipments may be sent in bulk to 

United States ports. Mexico has requested that the avocados be shipped in cardboard bins on 

pallets contained in ships holds. Mexico has also requested to be allowed to combine avocados 

from multiple packing houses that participate in the avocado export program into one 

consignment. This request applies to avocados moved overland to the United States border by 

refrigerated truck or refrigerated container. This also will apply to bulk maritime shipments to 

the United States ports of entry. Mexico is currently not authorized to comingle shipments from 

multiple packing houses.

Hass avocados may be imported into the United States from Michoacan, Mexico only after 

meeting the requirements of a systems approach listed in 7 CFR 319.56-30. These phytosanitary 

requirements include pest surveys and pest risk-reducing cultural practices, treatments, 

packinghouse procedures, inspection and shipping procedures. These requirements have been 

designed to prevent the importation of quarantine plant pests into the United States. 

Under the provisions of the operational workplan entitled “Workplan For the Exportation of 

Hass Avocados from Mexico to the United States of America” jointly developed between 

Mexico’s National Plant Protection Organization (NPPO) and Animal and Plant Health

Inspection Service (APHIS), a biometric sample of avocados is collected in Mexico at the 

packing house from a consignment to be exported. The sample is packaged, labeled, and shipped 

with the consignment so that inspectors from the U.S. Customs and Border Protection (CBP) can 

inspect it at the U.S. port of entry. Per 7 CFR 319.56-30, all boxes or plastic trays containing 

fruit in the consignment must be placed in a refrigerated truck or container and secured by a seal 

placed by the NPPO prior to leaving the packing house. Once sealed, the truck must remain 

unopened until it reaches the first U.S. port of arrival. 

History 

Between 1997 and 2006 more than 28 million Hass avocados imported from Mexico into the 

U.S. have been cut open and examined for pests. Of these, 20.2 million were examined in the 

orchards, 7.2 million in packing houses, and 602,490 at border inspection ports. No fruit flies 

were ever found. This includes fruit from wild trees, backyards, packing houses and border 

inspection. There have been only two incidents where any pests have been detected on Mexican 

avocados in nine years of fruit cutting and inspection. In both cases, Contrachelus perseae was 

found in backyard avocado trees (which were not Hass variety) in the municipalities of 

Tacambro and Tinguidin. Both municipalities were suspended from the program until 

eradication actions were completed, 

Risk Management Measures 

The avocados will be part of the Mexican Avocado program as described in 7 CFR 319.56-30(c). 

All safeguards currently in 7 CFR 319.56-30 will be applied to the import of bulk consignments. 
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c) Safeguards in Mexico.

(3) Packinghouse requirements. Each packinghouse must be registered with the Mexican 

NPPO’s avocado export program and must be listed as an approved packinghouse in the annual 

work plan provided to APHIS by the Mexican NPPO. The operations of the packinghouse must 

meet the following conditions: 

(i) During the time the packinghouse is used to prepare avocados for export to the United 

States, the packinghouse may accept fruit only from orchards certified by the Mexican NPPO for 

participation in the avocado export program. 

(ii) All openings to the outside must be covered by screening with openings of not more 

than 1.6 mm or by some other barrier that prevents insects from entering the packinghouse. 

(iii) The packinghouse must have double doors at the entrance to the facility and at the 

interior entrance to the area where the avocados are packed. 

(iv) Prior to the culling process, a biometric sample, at a rate determined by APHIS, of 

avocados per consignment must be selected, cut, and inspected by the Mexican NPPO and found 

free from pests. If the consignment originates from multiple packing houses, the biometric 

sample must proportionately represent each packinghouse contributing to the consignment and 

will be equivalent in size to the sample from a shipment from a single packinghouse. 

(v) The identity of the avocados must be maintained from field boxes or containers to the 

shipping boxes or bulk shipping bins so the avocados can be traced back to the orchard in which 

they were grown if pests are found at the packinghouse or the port of first arrival in the United 

States. 

(vi) Prior to being packed for shipping , each avocado fruit must be cleaned of all stems, 

leaves, and other portions of plants and labeled with a sticker that bears the official registration 

number of the packinghouse. 

(vii) The avocados must be packed in clean, new boxes, or clean plastic reusable crates, 

or bulk shipping bins. The boxes, crates or bulk shipping bins must be clearly marked with the 

identity of the grower, packinghouse, and exporter, and with the statement “Not for importation 

or distribution in Puerto Rico or U.S. Territories. 

(viii) Prior to leaving each packinghouse, the refrigerated truck or refrigerated container 

must be secured by the Mexican NPPO with a seal that will be broken by the Mexican NPPO if 

the truck or container is opened to have more avocados added from another approved 

packinghouse. The refrigerated truck or refrigerated container must be resealed by the Mexican 

NPPO at each packinghouse that contributes to the shipment and then remain unopened until it 

reaches the port of first arrival in the United States or to the port of export for bulk shipments 

(ix) Any avocados that have not been packed or loaded into a refrigerated truck or 

refrigerated container by the end of the workday must be kept in the screened packing area. 

(x) For bulk consignments arriving at the maritime port of export, the fruit must be 

transferred from the refrigerated truck or refrigerated container to large clean boxes or cardboard 

bins on pallets and not sealed for shipment by sea.. After transfer into these boxes or bins, the 

fruit must be safeguarded from insects by screening with openings of not more than 1.6 mm or 

by some other barrier that prevents insects from entering the boxes or bins. 

(i) Repackaging. If any avocados are removed from their original shipping boxes or bulk 
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shipping bins and repackaged, the stickers required by paragraph (c)(3)(vi) of this section may 

not be removed or obscured and the new boxes must be clearly marked with all the information 

required by paragraph (c)(3)(vii) of this section. 

Evidence for removal of pests from the pathway 

For bulk consignments, the fruit will be shipped from the maritime port of export in clean large 

boxes or cardboard bins on pallets and not sealed in containers. The boxes or bins must be 

protected by screening with openings of not more than 1.6 mm or by some other barrier that 

prevents insects from entering. Avocados that have been removed from the tree may become 

susceptible to fruit flies, however in packinghouse and port situations, fruit fly attack on bulk 

fruit is not likely to occur since fruit fly populations are not normally present in those areas. 

Packinghouses are currently required to be screened and have double entry doors under the 

Mexican Hass avocado export program. Screening would be important for fruit shipped in boxes 

or bins on pallets for maritime shipments. However, the port environment is not ecologically 

suited to fruit flies and populations are generally not present. The larger boxes or bins will 

continue to be labeled with the identity of the grower, packinghouse and exporter as agreed to in 

the operational workplan so that the same track-back capability to the place of production is 

maintained. 

Sampling from the larger bins at the U.S. port of entry may present inspectors more difficulty 

than the smaller boxes in containerized shipments in ensuring that no commingling of 

unauthorized fruits or contraband is present. If samples collected at the packing house in Mexico 

could not be associated with the individual units comprising the bulk shipment so that track back 

is possible, then the fruit must be resampled. This is to ensure that a representative sample from 

all areas of large bins or boxes is taken when sampling fruits. A biometric sample, with the rate 

to be determined by APHIS, will be inspected and cut for the presence of actionable pests. If 

quarantine pests of concern are found, fruit in that consignment will be rejected. 

Summary: 

If the components of the Mexican avocado program as outlined in 7 CFR 319.56-30 are 

maintained, there is no additional pest risk to allowing the import of Mexican Hass avocado in 

bulk to the United States. Authorizing Mexico’s request to combine loads from multiple 

participating packing houses will not increase pest risk since all packing facilities participating in 

the program are required to meet the safeguards as outlined in this document and the operational 

workplan entitled “Workplan for the Exportation of Hass Avocados from Mexico to the United 

States. 

Authors 

Walter Gould, Senior Risk Manager 

David B Lamb, Import Specialist 
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