United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Commodity Import Evaluation Document

Garlic Allium sativum L. (dry bulb, no green leaves) Imported from EU and Other 

Countries into the Continental United States

County of Origin: EU and Other Countries 

Date of Request: May 12, 2010

Commodity:

Scientific name: Allium sativum L. Common name(s): Garlic

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Current Status:

Many countries that are currently authorized to export garlic (dry bulbs, no green leaves) 

to the United States may do so only if the commodity undergoes vacuum fumigation for 

two pests, Brachycerus sp. and Dyspessa ulula. These countries include Algeria, 

Armenia, Austria, Azerbaijan, Belarus, Bosnia and Herzegovina, Bulgaria, Croatia, 

Czech Republic, Egypt, Estonia, Georgia, Germany, Greece, Hungary, Israel, 

Kazakhstan, Kyrgyzstan, Latvia, Lebanon, Lithuania, Macedonia, the former Yugoslav 

Republic of, Moldova, Montenegro, Morocco, Palestine Authority, Portugal, Romania, 

Russian Federation, Serbia, Slovakia, Slovenia, Switzerland, Syria, Tajikistan, Turkey, 

Turkmenistan, Ukraine and Uzbekistan. Imports from these countries are authorized by 

the regulations in 319.56-4, and all applicable requirements are listed in the fruit and 

vegetable manual and the fruits and vegetable import requirement database (FAVIR).

Imports of garlic from France are also allowed under the provisions of 319.56-4, with a 

phytosanitary certificate (PC) containing an additional declaration that the garlic was 

inspected and found free from Brachycerus sp. and Dyspessa ulula. Similarly, the 

regulations in 319.56-13 provide that imports of garlic from Italy and Spain are approved 

if the garlic is accompanied by a PC which contains an additional declaration that the 

garlic has been inspected by the exporting NPPO and found free of Brachycerus sp. and 

Dyspessa ulula, based on field inspection and reexamination at the port of export. For 

the countries of Canada, Philippines and the Republic of South Korea, no PC is required 

in order to ship fresh garlic to the United States. No PC is required for these countries 

because historically, no reportable interceptions have been found in fresh garlic from

Canada, China, Philippines and the Republic of South Korea. 
Version 2 2 October 6, 2010

Previous Decision sheets:

Decision sheets dated from 1923 to 1928 allow entry of Allium from France and many of

the countries of Europe (USDA, 1922-present). Federal Plant Quarantine Memo #24, 

Aug. 1, 1935, allows Allium into the United States from all countries in the world. There 

is a 1988 decision sheet (memo) on Leek moth and diseases which recommended that 

Allium with green leaves be prohibited. The memo references numerous interceptions of 

Allium pests in ships stores. A 1996 APHIS pest risk assessment on European Allium

listed a number of pests and rated them medium risk. 

Treatment Quality Assurance Unit (TQAU) consultation and treatment manual:

The entry in the treatment manual allowing entry of Allium from Spain and Italy with PC 

and Additional Declaration “found free of pests” is present in the earliest version of the 

treatment manual available (1972 version) at the Treatment Quality Assurance Unit 

(TQAU) and they have no other documentation on this issue. An older version of the 

treatment manual dated 1950 from the APHIS library has a page describing vacuum 

fumigation of garlic, and indicates that the treatment is to be used when garlic is infested 

with Brachycerus sp. or Dyspessa sp (USDA, 1950).

Summary of entry status: Sometime between 1935 and 1957 APHIS made a decision 

to treat garlic from a number of countries with mandatory vacuum fumigation for two 

pests, most likely in response to interceptions. Spain and Italy, and later, France, were 

exempted from the required fumigation. 

Pest Findings/interceptions:

There are two pests of concern listed in the Fruit and Vegetable manual and FAVIR: the 

moth larvae Dyspessa ulula and weevils in the genus Brachycerus. Both of these pests 

have stages that may feed internally in the garlic cloves. A search of the APHIS pest 

interception database including all sources, commercial permit cargo, ships stores, 

passenger baggage, etc. gave the following interceptions (AQAS-PestID, 2010):

Pest Interception Records (all sources including passenger baggage):

Country Pest intercepted Number of pests 

intercepted

Egypt Phycitinae, species of (Pyralidae) 1

France Parmena balteatus (Linnaeus) (Cerambycidae) 1

Greece Brachycerus albidentatus Gyllenhal (Curculionidae) 1

Greece Brachycerus sp. (Curculionidae) 1

Hungary Sitona sp. (Curculionidae) 1

Israel Dyspessa sp. (Cossidae) 1

Israel Helicella sp. (Hygromiidae) 1

Israel Lepidoptera, species of 1

Italy Brachycerus albidentatus Gyllenhal (Curculionidae) 2

Italy Brachycerus algirus (Fabricius) (Curculionidae) 2

Italy Brachycerus sp. (Curculionidae) 4
Version 2 3 October 6, 2010

Italy Diptera, species of 1

Italy Mycterothrips sp. (Thripidae) 1

Italy Parmena balteatus (Linnaeus) (Cerambycidae) 1

Italy Parmena sp. (Cerambycidae) 3

Italy Pyralidae, species of 1

Italy Tortricidae, species of 1

Jordon Chrysomelidae, species of 1

Morocco Lepidoptera, species of 1

Portugal Cydia sp. (Tortricidae) 1

Portugal Geometridae, species of 1

Portugal Opogona sacchari (Bojer) (Tineidae) 1

Portugal Pseudococcus sp. (Pseudococcidae) 2

Portugal Pyralidae, species of 1

Russia Frankliniella sp. (Thripidae) 1

Spain Brachycerus albidentatus Gyllenhal (Curculionidae) 1

Spain Brachycerus algirus (Fabricius) (Curculionidae) 1

Spain Brachycerus pradieri Fairmaire (Curculionidae) 1

Spain Brachycerus sp. (Curculionidae) 3

Spain Bruchidius atrolineatus (Pic) (Bruchidae) 1

Spain Centrocoris sp. (Coreidae) 1

Spain Dyspessa sp. (Cossidae) 1

Spain Dyspessa ulula (Borkhausen) (Cossidae) 6

Spain Gryllus sp. (Gryllidae) 1

Spain Noctuidae, species of 1

Spain Pyralidae, species of 3

Spain Thripidae, species of 1

Switzerland Thripidae, species of 1

Syria Cossidae, species of 1

Turkey Dyspessa ulula (Borkhausen) (Cossidae) 1

Turkey Sitona sp. (Curculionidae) 1

Turkey Tarsonemus sp. (Tarsonemidae) 1

Pests intercepted in permit cargo from France do not include any of the internal feeders. 

There is one interception of Brachycerus (a weevil) in permit cargo from Italy and 6 from 

Spain including permit cargo, and 2 from Greece. Dyspessa ulula or Dyspessa sp. was 

intercepted 7 times from Spain including permit cargo, and once from Israel, Syria 

(probable) and Turkey. Many of the interceptions are not identified to the species level,

or are hitchhikers such as snails or thrips. The number of interceptions APHIS has made 

over a 26-year period is relatively low. 

Summary:

No documentation could be found on the decision to allow Spain and Italy to import 

without fumigation based on a PC and an inspection free of pests. The pest interceptions 

are infrequent according to APHIS records.

There is no technical or scientific reason to exclude any country in the EU or 

countries with market access from this same entry status for Garlic (Allium sativum)

that Spain, Italy and France currently have.
Version 2 4 October 6, 2010

Allium sativum for consumption from these countries should be enterable with a PC with 

an AD that shows the commodity was inspected and is free of pests. This would 

specifically include only commercial shipments for consumption. The Allium would 

be required to be a dry bulb free of leaves. The garlic consignments must be 

accompanied by a Phytosanitary Certificate (PC) with an Additional Declaration (AD) 

attesting freedom from Brachycerus spp. or Dyspessa ulula. Each consignment is subject 

to inspection. If inspection reveals the target pests (Brachycerus spp. or D. ulula), the 

required fumigation, T101-e-2, is a fumigation under vacuum. However, as of October

2008, there are no APHIS-approved commercial vacuum chambers in the US. 

Consignments found to have the target pests therefore must be re-exported, destroyed, or 

returned to the country of origin.

CABI (CABI, 2007) has a section indicating that inspection for, and detection of,

Dyspessa ulula is feasible: “D. ulula may be detected in storage, before packing and transportation. 

The garlic heads should be examined carefully, affected heads may be crushed easily.

“Symptoms shown in garlic heads damaged by D. ulula are unmistakable: large galleries and 

darkened holes often with secondary mold. Sometimes cloves are completely eaten, remaining 

only the outer coverings of the garlic head with the larval excrements. A strongly attacked batch of 

garlics can be detected by a weight shortage (between 40% and 80% of the normal 

weight). Transport of larvae inside damaged bulbs is the only known way of accidental 

introduction of this pest and their detection is very easy.”

Brachycerus is rarely intercepted even in passenger baggage, with only 16 interceptions 

from all countries, all sources, over a 27 year period (AQAS-PestID, 2010). Adult 

females lay clusters of eggs in holes chewed in the bulb (Espinosa et al., 1990). The 

larvae bore into the garlic bulb, leaving bulging lumps, holes, frass, and fungal decay. 

Mature larvae are often visible externally. These symptoms can be readily inspected for 

by the NPPO in the originating country, and at the port of entry into the United States. 

Infested bulbs would also be unlikely to be included in shipments; they would be culled 

during packing processes.

Treatment if pests are found:

Currently, if target pests Brachycerus spp. or Dyspessa ulula are found on inspection of 

French, Spanish or Italian Allium, a vacuum fumigation with methyl bromide would be 

required. Since vacuum fumigation facilities are currently not available, the

consignments would have to be destroyed or re-exported. If externally feeding pests are 

found, standard MB fumigation for hitchhikers can be used. This same treatment status 

should be accorded other countries in the EU and Asia Minor.

FAVIR and Manual change:

APHIS should change FAVIR and the treatment manual immediately to add the other 

countries of the EU and countries currently with market access to the continental United 

States to the same status of entry as France, Spain and Italy.

APHIS should publish a notice in the Federal Register and notify our stakeholders.
Version 2 5 October 6, 2010

Recommendations:

I recommend that countries of the EU and countries currently with market access to the 

continental United States be given the same status of entry as France, Spain and Italy for 

commercial shipments of garlic, Allium sativum.

References

AQAS-PestID. 2010. Agricultural Quarantine Activity System Pest Interception 

Database. USDA-APHIS-PPQ. Last accessed May 2010.

CABI, 2007. Crop Protection Compendium. CAB International (CABI), Wallingford, 

UK.

Espinosa, B., A. Balbiana and L. Sannino. 1990. Osservazioni biologiche su

Brachycerus algirus (Fabricius, 1787) dannoso all'aglio in Campania e 

panoramica dei Brachycerus italiana (Coleoptera Curculionidae). Memorie della 

Società Entomologica Italiana Vol. 69 No. Supplement pp. 79-96 

USDA. 1922-present. Decision sheets on Allium.

USDA. 1935. Foreign Plant Quarantines Memorandum #24. Quarantine No. 56. – List 

of approved fruits and vegetables by countries of origin. 

USDA. 1950. Methyl Bromide fumigation of garlic. 

USDA. 2009. Treatment Manual. USDA-APHIS, PPQ;

http://www.aphis.usda.gov/ppq/manuals/port/Treatment_Chapters.htm [accessed 

May 2010].

.

________________________________________________________________________

__X___ APPROVED

_____ DISAPPROVED

Walter P. Gould, Ph.D.

Senior Risk Manager __10/06/2010_____

Signature (name) Date