United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

November 

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-2013-0085

RIN 0579-AD87

Importation of Two Hybrids of Unshu 

Oranges from the Republic of Korea into the 

Continental United States, 7 CFR 319.28

Policy & Program Development

Policy Analysis & Development
Summary

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

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

Currently Unshu orange may be imported from the Republic of Korea into the continental 

United States as described in 7 CFR 319.28(c). Only one species of Unshu orange, Citrus

reticulata Blanco var. unshu, Swingle [Citrus unshiu Marcovitch, Tanaka], is allowed entry. In 

response to a market access request from the government of the Republic of Korea, we are 

proposing to amend the regulations to allow the importation of commercial consignments of two 

additional Unshu orange hybrids, Shiranuhi [(C. reticulata ssp. unshiu x (C. x sinensis)) x C. 

reticulata] and Setoka [(C. reticulata ssp. unshiu x (C.x sinensis)) x C. reticulata] x C. reticulata], 

utilizing the same import requirements currently listed in § 319.28(c). We would also modify 

those requirements by explicitly limiting shipments to commercial consignments.

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.

i
Korea and Japan are the principal exporters of Unshu oranges (Citrus reticulata Blanco 

var.) to the United States. In Korea, almost all Unshu oranges are produced on the southern 

island of Jeju.

1 Over 99 percent of Unshu oranges are consumed domestically, and only about 

0.6 percent of Korea’s Unshu orange, totaling 3,611 MT valued at $4.8 million, were exported in 

2012. The United Kingdom was the main destination of Korean Unshu oranges; the United 

States was the fourth largest importer of Korean Unshu oranges in 2012, totaling 743 MT, which 

were typically sold at a premium in ethnic specialty stores. 

The Pest Risk Analysis for this proposed rule assumes the upper range of annual Unshu

orange imports from Korea to the United States to be about 2,000 MT. Prior to administrative 

suspension of Unshu orange imports from Korea to the United States in 2003, imports of Unshu 

oranges from Korea to the United States averaged about 650 MT annually between 1995 and 

2002. Following the removal of the import suspension in 2010, imports of Unshu orange from

Korea totaled 412 MT in 2011 (valued at $0.5 million) and 743 MT in 2012 (valued at $0.9 

million). Given these import levels and Korea’s limited supply capacity and relatively stable 

domestic demand, projected exports of 2,000 MT may be high. Even if imports from Korea were 

to reach 2,000 MT, Korean Unshu orange share of the U.S. market for mandarin varieties is 

expected to remain negligible (about 1.4 percent of U.S. imports and 0.3 percent of U.S. 

domestic supply of all mandarin varieties based on the U.S. production and trade data for 2010-

2012). In addition, given the fact that fresh Unshu orange imports by the United States are 

predominantly supplied by Japan and Korea, we expect any product displacement would be 

largely borne by Japanese Unshu orange imports.

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 

1 Jeju was formerly translated as Cheju.

ii

 
rule, if promulgated, would 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

Korean production and trade of Unshu oranges ......................................................... 5

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

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

iv
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, would not have 

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

Currently Unshu orange may be imported into the continental United States from the 

Republic of Korea (Korea) as described in 7 CFR 319.28(c). Only one species of Unshu orange, 

Citrus reticulata Blanco var. unshiu, Swingle [Citrus unshiu Marcovitch, Tanaka], is allowed 

entry. In response to a market access request from the government of Korea to expand their 

authorized Unshu orange exports to include two additional hybrids, we are proposing to amend 

the regulations to allow the importation of commercial consignments of the Shiranuhi hybrid [(C. 

reticulata ssp. unshiu x (C. x sinensis)) x C. reticulata] and the Setoka hybrid [(C. reticulata ssp. 

unshiu x (C.x sinensis)) x C. reticulata] x C. reticulata], under the import requirements listed in §

319.28(c). We would also modify those requirements by explicitly limiting shipments to 

commercial consignments.2

The U.S. citrus industry does not produce Unshu oranges, but does produce many

substitute mandarin varieties.

3 We first present information on the production and worldwide 

trade of mandarin varieties by the United States and by Korea,

4 followed by information specific 

on the U.S. market for Unshu orange imports. We then address likely effects of the proposed rule 

for small entities.

2 The Pest Risk Assessment (PRA) identified two pests: Xanthomonas citri subsp. citri and Elsinoë australis

(the causal agents of citrus canker and sweet orange scab, respectively), as quarantine pests associated with the two 

Unshu orange hybrids. APHIS determined that the requirements specified in 7 CFR part 305 for phytosanitary 

treatments and 7 CFR 319.28(c) for importation would provide an appropriate level of phytosanitary protection 

against these pests. 3 Cindy Fake, UC Davis Cooperative Extension, “A Mandarin by Any Other Name” 2004, 

http://www.mountainmandarins.com/documents/10Oct2005-MMGA.pdf 4 Include all tangerine hybrids, such as Fallglo, Sunburst, Honey, clementine, mandarin, Satsuma, as well 

as tangelos and tangors and other citrus hybrids.

1

 
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).

5 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.6 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-year period from 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). 

Table 1. U.S. Fresh Mandarin Varieties: Productiona

, Imports, Exports, Domestic Supply 

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

Season Productionc Imports 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

2011/12f 486 136 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.

5

Mandarin variety season begins in November of first year shown. 6 USDA-NASS “Fruits and Tree Nuts: Blooming, Harvesting and Marketing Dates” December 2006.

2

 
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 a and 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.

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 36,513 MT of mandarin varieties, valued at $56 

million, F.A.S.

7 (Table 3).8 Canada consistently has been the largest importer of U.S. mandarins, 

with annual imports averaging 20,000 MT valued $30 million. The United States exported 475 

MT of mandarin varieties to Korea, valued at $0.6 million.

7 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. 8 See note b in Table 3. 

3

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

a Fresh or Dried (HTS 080520), 

Calendar Year 2008-2012 (metric tons)

2008 2009 2010 2011 2012

World Totalb 30,810 30,166 33,895 52,597 36,513

Canada 18,850 18,500 22,828 22,782 17,180

Japan 4,442 6,778 6,895 18,956 12,649

Netherlands 2,726 1,128 1,152 4,878 3,125

Australia 1,996 2,027 507 2,438 1,122

South Korea 732 166 6 - 475

 Market share 2.4% 0.6% 0.0% - 1.3%

All other 2,064 1,568 2,508 3,542 1,961

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.).

9 Principal sources were Chile, Spain, Peru and Morocco

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

exports to the United States increasing from 16,300 MT in 2008, to 53,500 MT in 2012.10

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

was the ninth largest exporter of mandarin varieties to the United States in 2012; the United 

States imported 743 MT Unshu oranges from Korea, valued at about $0.9 million. Korea’s share 

of Unshu orange imports by the United States was only 0.5% in 2012.

11

9 Custom Import Value – The price actually paid, excluding import duties, freight, insurance, and other 

charges. 10 In 2012, Spain still kept the top place in terms of import value ($65 million), compared to Chile ($50 

million). 11 The United States began importing Unshu oranges from Korea in 1995 but the importation was 

suspended in 2002 due to interceptions of citrus canker during pre-clearance inspections and subsequent detections 

of citrus canker at U.S. ports of entry. In 2007, in response to a request from Korea, APHIS allowed the importation 

of Unshu oranges produced on the Jeju Island (formerly translated as Cheju) to resume, but only to the State of 

Alaska, then in 2010, APHIS allowed importation of Unshu oranges into the continental United States.

4

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

a Fresh or Dried (HTS 080520), Calendar 

Year 2008-2012 (metric tons)

2008 2009 2010 2011 2012

World Totalb 110,767 120,803 141,016 140,805 143,936

Chile 16,291 27,335 35,478 43,285 53,480

Spain 53,559 48,335 53,541 54,031 44,202

Peru 8,753 10,634 14,649 14,264 17,239

Morocco 14,580 15,607 20,293 16,206 14,290

South Africa 4,763 5,969 7,780 4,476 6,968

Mexico 7,726 5,797 4,104 3,640 2,340

Israel 399 1,244 1,631 1,137 1,978

Australia 3,752 4,325 3,072 2,167 1,852

South Korea 18 - - 412 743

All other 944 1,556 469 1,598 1,586

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.

Korean production and trade of Unshu oranges

Korea produces few orange varieties such as navel and Valencia, but harvests a large 

crop of other citrus, mainly Unshu oranges, almost all from the southern island of Jeju.12, 13 In

the 2011/2012 marketing year (MY), Unshu orange production was forecast at 580,000 MT.

14,15

Unshu oranges were first introduced into Jeju Province in 1911 from Japan, and their

production saw significant growth in the 1970s and 1980s. In recent years, production volumes 

have fluctuated at around 600,000 MT, while planted acreage has shown a gradual decline 

towards 50,000 acres (Figure 1).

12 USDA Economic Research Service, South Korea – Fruits, Nuts, and Vegetables 

http://www.ers.usda.gov/topics/international-markets-trade/countries-regions/south-korea/specialty-processedproduct-markets.aspx

13 Jeju Province is situated on Korea’s largest island of Jeju (or Jeju-do), a size of 714 sq. miles with 

population of about 583,000 people in 2011. 

14 USDA Foreign Agriculture Service, GAIN Report “Republic of Korea – Citrus Annual” December 18, 

2013. http://gain.fas.usda.gov/Recent%20GAIN%20Publications/Citrus%20Annual_Seoul_Korea%20-

%20Republic%20of_12-18-2012.pdf 15 Ibid. “Korea’s citrus production is predominantly unshu oranges with an 85 percent share, followed by 

winter unshu and late season varieties.”

5

 
Figure 1. Korea: Unshu Orange Production and Acreage: 2003-2012

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

Jeju Provincial Government & Korea Rural Economic Institute

One noticeable trend is that citrus production patterns in Jeju have been shifting gradually 

from open-field grown Unshu oranges to greenhouse facility production for the past 10 years, in 

addition, organic Unshu orange production is increasing. With the help of the Free Trade 

Agreement (FTA) transition fund, the Jeju government projects its acreage for winter Unshu and 

late varieties to increase from 1,180 acres to 1,620 acres by 2014.16

Korea’s Unshu orange exports have been relatively small, but grew to 3,611 MT in 2012, 

valued at $4.8 million (Table 5). Exports to the United Kingdom sharply increased in 2012, when

the United Kingdom became the largest import of Korean Unshu oranges, accounting for 42 

percent of Korea’s exports (1,501 MT). After Canada and Russia, the United States was the

fourth largest importer of Korean Unshu oranges (477 MT) in 2012.17 The average unit price 

worldwide was $1.33 per kilogram (KG) in 2012. The unit prices of Unshu orange exports to the 

United States are higher than the average price worldwide. In the United States, these Unshu

16 Ibid. 17 The trade information are primarily based on MY2011/12 (Oct.11-Sept.12) and do not equal to the data 

shown in Table 4.

44

46

48

50

52

54

56

58

60

62

0

100

200

300

400

500

600

700

800

2003 2005 2007 2009 2011

Thousand Acres

Thousand MT

Korean Unshu Orange Production and Acreage

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

6

 
oranges were typically sold at premium prices in ethnic grocery stores and through smallpackage direct delivery to customers for holidays.

18

Table 5. Korea: Exports of Mandarin Varieties,

a Fresh or Dried (HTS 080520), Year 2008-

2012 (metric tons)

2008 2009 2010 2011 2012

World Total 2,536 2,783 1,724 2,930 3,611

 Unit Value/KG $0.78 $1.09 $0.99 $0.97 $1.33

United Kingdom 3 19 99 360 1,501

Canada 465 828 157 541 723

Russia 1,785 1,475 1,130 1,264 480

United Statesb 39 10 10 445 477

 Unit Value/KG $0.98 $1.30 $1.34 $1.32 $2.00

Hong Kong 25 44 12 73 158

All other 219 408 315 247 272

Source: Korea Customs and Trade Development Institution, Global Trade Atlas 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 Korea

shown in Table 4 due to differences in reporting periods and other discrepancies. Korean export data are based on 

exports for marketing year, for example MY 2010/11 (Oct.10 – Sept.11) and MY 2011/12 (Oct.11 – Sept. 12).

Korea’s imports of mandarin varieties in recent years have been limited. Trade data 

indicate that Korea imported only one kilogram of mandarin varieties in 2012, valued at $12, and 

that was from the United States (Table 6).

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

Year 2008-2012 (metric tons)

2008 2009 2010 2011 2012

World Total 0.05 0.005 0 0.828 0.001

 Unit Price/KG $1.46 $28.20 - $6.00 $12.00

United Statesa 0 0 0 0 0.001

 Unit Price/KG - - - - $12.00

Japan 0.05 0.005 0 0 0

 Unit Price/KG $1.46 $28.20 - - -

Taiwan 0 0 0 0.828 0

 Unit Price/KG - - - $6.00 -

Source: Korea Customs and Trade Development Institution, Global Trade Atlas

18 We do not have the information on retail prices for Unshu oranges imported from Korea. 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 at 

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

levels.

7

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

differences in reporting periods and other discrepancies.

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

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

years, to 0.5 million MT in 2011/12 (Table 1). 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. Korea’s per capita consumption of domestically produced citrus, 31

pounds in 2011,19 is still much higher than that of the United States. To meet its domestic 

demand for Unshu oranges with limited production capacity, most of domestic Unshu orange 

supply (over 99 percent) is consumed domestically. Korea’s relatively stable production and the 

increase in U.S. production are resulting in convergence of their respective production trend lines

(Figure 2).

Figure 2. Unshu Orange Production in Korea 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,

Jeju Provincial Government & Korea Rural Economic Institute, USDA-FAS GAIN report “Korea Citrus Annual”

19 USDA Foreign Agriculture Service, GAIN Report “Republic of Korea – Citrus Annual” December 18, 

2013.

0

200

400

600

800

1,000

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Unshu Orange Production in Korea and Mandarin 

Variety Production in the United States

(thousand MT)

Korea Unshu Orange U.S.: Mandarin Varieties and Hybrids

8

 
Korea and Japan are the principal suppliers of Unshu oranges to the United States. The 

Pest Risk Analysisfor this proposed rule assumes the upper range of annual Unshu orange 

imports from Korea would be about 2,000 MT (about 1.4 percent of U.S. imports and 0.3 percent 

of U.S. domestic supply of all mandarin varieties based on the U.S. production and trade data for 

2010-2012). Prior to administrative suspension of Unshu orange imports from Korea to the 

United States, imports of Unshu oranges from Korea to the United States averaged about 650 

MT annually between 1995 and 2002. Following removal of the import suspension in 2010, 

imports of Unshu orange from Korea totaled 412 MT in 2011 (valued at $0.5 million) and 743

MT in 2012 (valued at $0.9 million) (Table 4). Given these import levels and Korea’s limited 

supply capacity and relatively stable domestic demand for Unshu oranges, projected exports to 

the United States of 2,000 MT may be a challenge (Figure 3). Even if the imports from Korea

were to reach 2,000 MT, given the fact that fresh Unshu orange imports by the United States are

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

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

Figure 3. Mandarin Exports by U.S. to Korea, Korea to U.S. and Japan to U.S.: 1994-2012

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

 -

 2,000

 4,000

 6,000

 8,000

 10,000

 12,000

 14,000

Metric Ton

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

1994-2012 (Metric Ton)

U.S. Export to Korea Japan Export to U.S. Korea Export to U.S.

9
Potential Impact on Small Entities

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

Blanco var. unshiu) 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 variety growers, wholesalers and distributors to the extent that the 

Unshu orange is a substitute for the other mandarin varieties. Nonetheless, given the relatively 

low level of Unshu orange imports expected from Korea, 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).20,21

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,

22 well below 

20 NAICS refers to the North American Industry Classification System. 21 U.S. Small Business Administration, Table of Small Business Size Standards http://www.sba.gov/content/tablesmall-business-size-standards 22 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

10

 
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.23

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

composed of small entities. However, we expect any effects on U.S. small entities of allowing 

importation of the two additional Korean Unshu orange hybrids to be insignificant. 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 Korean Unshu orange share of the U.S. 

market for mandarin varieties is expected to remain negligible, since the highest import target of 

2,000 MT would be equivalent to less than one percent of the U.S. supply of mandarin varieties. 

Even if imports from Korea were to reach 2,000 MT, it is likely that any product displacement 

that would occur would be largely borne by Japanese Unshu orange imports. 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.

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

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

11