United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine



## Commodity Import Evaluation Document

G arlic Allium sativum L. (dry bulb, no green leaves) Im ported from EU and Other

Countries int o the Continental United States



### County of Origin : EU and Other C ountries



### Date of Request : May 12 , 20 1 0



### Commodity :

Scientific name : Allium sativum L. Common name (s ) : Ga rlic

________________________________________________________________________

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 pest s, 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, La tvia, 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 Uz bekistan

. I mports 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 Fra nce 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 , b ased on field inspection and reexamination at the port of export. F or

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

becaus e h istorically

, n o reportable interceptions have been found in fresh garlic from

Canada, China

, Philippines and the Republic of South Korea

.Version 2 October 6, 2010 2 Previous Decision sheets:

Decision sheets d ated from 192 3 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 (m emo) on Leek moth and diseases which recommend ed that

A llium with green leaves be prohibited . The memo r eference s 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. A n older version of t he

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

fumigation of garlic, and indicates that t he 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 fumigatio n 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 Dyspess a 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 st ores,

passenger baggage, etc. gave the following interceptions ( AQAS

- PestID , 2010) :

Pest Interception Records (all sources including passenger baggage) :

Country Pest intercepted N umber of pests

intercepted

Egypt Phycitinae, species of (Pyralidae) 1

Fra nce 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. (Hygromii dae) 1

Israel Lepidoptera, species of 1

Italy Brachycerus albidentatus Gyllenhal (Curculionidae) 2

Italy Brachycerus algirus (Fabricius) (Curculionidae) 2

Italy Brachycerus sp. (Curculionidae) 4Version 2 October 6, 2010 3 Italy Diptera, species of 1

Italy Mycterothrips sp. (Th ripidae) 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 Gylle nhal (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. (Core idae) 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

Syr ia 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

(probab le) and Turkey

. Many of the interceptions are not identified to the species level,

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

over a 26

- year period is relatively low.

Summary:

N o documentation could be f oun d 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 exclud e any country in the EU or

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

that Spain, Italy and France currently have

.Version 2 October 6, 2010 4 Allium sativum for consumption from these countries should be enterable with a PC with

an AD that shows the commodi ty 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. T he garlic consignment s must be

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

attesting freedom from Brachycerus spp. or Dyspessa ulula

. Each c onsignment is subject

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

required fumigation, T101

- e

- 2, is a fumi gation 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, 2 007) 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 s trongly 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.”

Br achycerus 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 Uni ted 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

c onsignments would have to be destroyed or re

- exported. If externally feeding pests are

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

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

F AVI R 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 October 6, 2010 5 Recommendations :

I recommend th at 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 . 20 1 0 . Agricultural Quarantine Activity System Pest Interception

Database. U SDA

- APHIS

- PPQ. Last access ed May 20 1 0.

CABI, 200 7

. 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

Societ à Entomologica Italiana Vol. 69 No. Supplement pp. 79

- 96

USDA. 1922

- present. Decision sheets on Al lium

. 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 20 1 0].

.

________________________________________________________________________



### __ X ___ APPROVED

_____ DISA P PROVED

Walter P. Gould, Ph. D

. Senior Risk Manager

__ 10 / 06 /20 1 0

_____ Signature (name) Date