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United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Risk Management Document

Importation of Fresh Fruit of Tomato (Solanum lycopersicum) from the 

Economic Community of West African States

June 16, 2011

Plant Health Programs (PHP)

Regulations, Permits and Manuals (RPM)

Contact Person: Philip B. Grove
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Introduction:

The pest risk assessment (PRA) document, “Importation of Tomatoes, Solanum 

lycopersicum from the Economic Community of West African States (ECOWAS) into 

the Continental United States” (USDA, 2009) listed ten quarantine pests that may follow 

the pathway of commercial shipments of fresh tomatoes with the stem and calyx 

removed. Seven pests were rated as high risk. Three pests were rated as medium risk. 

APHIS has determined that measures beyond a standard port-of-entry inspection are 

required to mitigate the plant pest risk of these ten pests.

Pests rated High:

Bactrocera cucurbitae (Coquillet) (Diptera: Tephritidae)

Bactrocera invadens (Hendel) (Diptera: Tephritidae)

Ceratitis capitata (Wiedemann) (Diptera: Tephritidae)

Ceratitis rosa Karsh (Diptera: Tephritidae)

Helicoverpa armigera (Hübner) (Lepidoptera: Noctuidae)

Helicoverpa assulta (Guenée) (Lepidoptera: Noctuidae)

Leucinodes orbonalis (Guenée) (Lepidoptera: Pyralidae)

Pests rated Medium:

Chrysodeixis chalcites Esper (Lepidoptera: Noctuidae)

Maconellicoccus hirsutus (Green) (Hemiptera: Pseudococcidae)

Nipaecoccus viridis (Newstead) (Hemiptera: Pseudococcidae)

The Economic Community Of West African States is comprised of 15 member states: 

The Republic of Benin, Burkina Faso, The Republic of Cape Verde, The Republic of 

Cote D’Ivoire, The Republic of Gambia, The Republic of Ghana, The Republic of 

Guinea, The Republic of Guinea Bissau, The Republic of Liberia, The Republic of Mali, 

The Republic of Niger, The Federal Republic of Nigeria, The Republic of Senegal, The 

Republic of Sierra Leone, and the Togolese Republic.

Since 1997, APHIS has allowed the importation of tomatoes from various countries, 

including areas in Morocco and Western Sahara, using a systems approach to mitigate 

risks from Ceratitis capitata (Medfly). The tomatoes must be grown in registered 

production sites in accordance with the systems approach codified in 7 CFR § 319.56-28, 

(USDA, 2010). This systems approach has also been used effectively for tomato imports 

from other countries such as Spain, France, and Chile.

Due to the presence of Medfly, and other pests of concern in all countries comprising

ECOWAS, member states of ECOWAS wishing to export tomatoes to the continental 

United States must follow the conditions of the proposed systems approach with several 

mitigation measures, including production in pest exclusionary structures (PESs) within 

registered production sites. Production in PESs will prevent the introduction of fruit flies 
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(C. capitata, B. cucurbitae, B. invadens, and C. rosa), as well as the moths (C. chalcites, 

H. armigera, H. assulta, L. orbonalis) and the mealybugs (M. hirsutus, and N. viridis). 

The proposed importation of tomatoes from ECOWAS, if approved, would be regulated 

by an amendment to the existing fruit and vegetables Code of Federal Regulations (7 

CFR § 319.56). This document outlines the phytosanitary measures that APHIS will 

require if the proposed importation of tomatoes from ECOWAS is approved.

Issuance of permits for importation of tomato would be contingent on the receipt of a 

formal request for U.S. market access from the exporting country and approval by APHIS 

of an export program using a systems approach. A site visit by APHIS to approve the 

production sites and assure that they contain pest exclusionary structures would be 

required before final approval of the export program will be given. 

Risk Management Measures:

We are proposing the following set of mitigation measures:

• The fruit flies Bactrocera cucurbitae (melon fly), B. invadens, Ceratitis capitata 

(Medfly) and C. rosa (natal fruit fly) currently occur in ECOWAS and are listed 

as quarantine pests in the continental United States. Tomatoes must be grown in 

approved registered production sites. Initial approval of the production sites will 

be completed jointly by the NPPO of the requesting ECOWAS country and 

APHIS. The NPPO of the exporting country will visit and inspect the production 

sites monthly, beginning two months before harvest and continuing through the 

end of the shipping season. APHIS may monitor the production sites if necessary. 

• Tomato production sites must consist of a pest exclusionary structure(s) (PES), 

which must have self-closing double doors, and all openings, including vents, 

must be covered by screening with a mesh opening of 1.6mm or less. The PESs

will prevent the introduction of the four fruit flies of concern (B. cucurbitae, B. 

invadens, C. capitata and C. rosa), as well as the moths (C. chalcites, H.

armigera, H. assulta, L. orbonalis) and the mealybugs (M. hirsutus, and N. 

viridis).

• For the detection of four fruit flies of concern, traps with appropriate protein bait, 

must be placed inside the PES at a density of 8 traps/hectare (ha), with a 

minimum of 4 traps in each pest exclusionary structure. The traps will be 

monitored once a week.

• Detection of a single fruit fly of concern inside a PES during two months prior to 

export and continuing through the duration of the harvest, or detection of a fruit 

fly of concern in a consignment at port of entry inspection which is traced back to 

a PES will result in immediate cancellation of exports from that production site

until APHIS and NPPO of the exporting country mutually determine that risk 

mitigation is achieved.

• There may be no shade trees within 10 meters of the entry door of the PES and 

no fruit fly host material within 50 meters of entry door of the PES . A 3 to 10 

meter vegetation-free zone around the outside perimeter of the PES is 

recommended but not required. 
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• Trapping will be conducted by the NPPO of the exporting country. The NPPO of 

the exporting country must maintain records of trap placement, trap maintenance, 

and any captures of the fruit flies of concern. The NPPO of the exporting country 

must maintain an APHIS approved quality control program to monitor or audit the 

trapping program. The trapping records must be maintained for one year for 

APHIS review. 

• Tomatoes for export to the United States must have the stem and calyx removed. 

The tomatoes may be in any stage of ripeness.

• The tomatoes must be packed within 24 hours of harvest. The tomatoes must be 

safeguarded by an insect-proof mesh screen or plastic tarpaulin while in transit to 

the packing house and while awaiting packing. Tomatoes must be packed in 

insect proof cartons or containers or covered with insect-proof mesh or plastic 

tarpaulin for transit to the airport and export to the United States. These 

safeguards must remain intact upon arrival in the United States or they will be 

refused entry. 

• For shipments by sea: Tomatoes must be safeguarded by an insect-proof mesh 

screen or plastic tarpaulins while in transit to the packing house and while 

awaiting packing. Tomatoes must be packed in insect proof cartons or containers 

or covered with insect-proof mesh or plastic tarpaulin, and these safeguards must 

be intact upon arrival in the United States. Sea containers must be kept closed if 

stored within 20 meters of fruit fly host prior to loading.

• During the time the packing house is packing fruit for export to the United States, 

the packing house may only accept fruit from registered production sites.

• Each shipment of tomatoes must be accompanied by a phytosanitary certificate 

issued by the NPPO of the ECOWAS member country and bearing the 

Additional Declaration (AD), “These tomatoes were grown in registered 

production sites in (Insert ECOWAS member country) and the consignment has 

been inspected and found free of the pests of concern.”

Efficacy of Risk Management Measures:

The mitigation measures described in this document are necessary to achieve 

phytosanitary security for ECOWAS tomatoes that are consistent with those for tomatoes 

currently allowed entry into the United States under 7 CFR §319.56-28. Use of 

registered production sites, including PESs equipped with double self-closing doors, and 

covering of vents or openings in the PES (other than the double closing doors) with 1.6 

mm or less screening in order to prevent the entry of quarantine pests is also consistent 

with the requirements for importation of tomatoes from other countries under 7 CFR 

§319.56-28.

A search of records on tomato imports since 1997, revealed no records of interception of

either fruit flies or major lepidopteran quarantine pests (US Pest ID 2008) thereby 

suggesting the effectiveness of the systems approach.
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Requiring an Additional Declaration (AD) specifically requires the NPPO to inspect the 

tomatoes for presence of all quarantine pests. 

Summary:

By themselves, registered production sites that include PESs provide the level of 

phytosanitary security required by the United States. A systems approach, employing a 

combination of measures acting independently, if properly implemented, also mitigates 

risk and provides an acceptable level of phytosanitary protection.

The requirement for production in a PES diminishes the likelihood of quarantine pests 

following the pathway. Therefore, the importation of tomatoes from ECOWAS would be 

restricted to commercial shipments only.

The requirement of a Phytosanitary Certificate from the NPPO of the exporting member 

country of ECOWAS would document that the importation is a product of that ECOWAS

member country. A Phytosanitary Certificate also provides phytosanitary security by 

requiring the NPPO to conduct inspections for pests of concern. Therefore, APHIS will 

require each consignment to be accompanied by a Phytosanitary Certificate with an AD

verifying that the consignment has been produced in registered production sites.

These inspections double the number of inspections each tomato receives by requiring 

phytosanitary inspections in addition to the normal packinghouse quality inspections. 

Importations of tomato from ECOWAS member countries would also be subject to 

inspection at the port of entry into the United States.

Author:

Devaiah A. Muruvanda, Ph.D. 

Senior Risk Manager-Entomology

References:

USDA, 2010. Code of Federal Regulations, Title 7, Part 319 (7 CFR § 319 Foreign 

Quarantine Notices) Subpart 56 (Fruits and Vegetable). United States Government.

USDA, 2009. APHIS, Center for Plant Health Science and Technology. Importation of 

Tomatoes, Solanum lycopersicum, from the Economic Community of West African 

States (ECOWAS) into the Continental United States, A Qualitative, Pathway-Initiated 

Pest Risk Assessment, 82 pp.

US Pest ID Database, 2008. (Accessed May 14, 2008), United States Department of 

Agriculture, Animal and Plant Health Inspection Service, Plant Protection and 

Quarantine, Riverdale, MD.