United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

October 2011

Analysis in Support of Certification that the 

Rule will not have a Significant Economic 

Impact on a Substantial Number of Small 

Entities

Proposed Rule 

2011-0028

RIN 0579-AD61

Importation of Fresh Bananas from the 

Philippines into the Continental United 

States

Policy & Program Development

Policy Analysis & Development
1

Summary

This analysis examines impacts for U.S. small entities of a rule that would allow fresh 

banana imports from the Philippines into the continental United States. Commercial production 

of bananas in the United States takes place in Hawaii, where most if not all of the banana farms

are small entities. These producers would be little affected by the proposed rule given the large 

quantity of bananas already imported by the United States and the relatively small quantity

expected to be imported from the Philippines. Bananas from the Philippines would not be 

allowed entry into Hawaii.

In 2009, Hawaii’s banana harvest totaled about 8,392 metric tons (MT), compared to U.S. 

imports of about 3.6 million MT. The volume of bananas expected to be imported from the 

Philippines is not more than 100 containers per year at most, or approximately 1,814 MT per 

year, an amount equivalent to about 0.05 percent of U.S. imports. 

The United States is clearly a minor producer but a major importer of bananas. 

Compared to the volume of current imports, the quantity of bananas expected to be imported 

from the Philippines is negligible. In addition, bananas from the Philippines would not be 

allowed entry into Hawaii. For these reasons, any impact of the rule for U.S. banana producers 

in Hawaii would be small. The APHIS Administrator has determined that this action, if 

promulgated, will not have a significant economic impact on a substantial number of small 

entities.
2

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, will not have a 

significant economic impact on a substantial number of small entities. The analysis examines 

impacts for U.S. small entities of a rule that would allow fresh banana imports from the 

Philippines into the continental United States. The rule would amend 7 CFR 319.5, and is part of 

a continuing program to allow the importation of foreign agricultural products that APHIS has 

determined are without significant risk of introducing exotic plant pests into the United States. 

The Regulatory Flexibility Act requires agencies to evaluate potential effects of their 

proposed and final rules on small businesses, small organizations and small governmental 

jurisdictions. Section 603 of the Act requires an agency to prepare an initial regulatory

flexibility analysis (IRFA) that describes the expected impact of a proposed rule on small 

entities. In place of the IRFA, the head of the agency may certify that a rule will not have a 

significant economic impact on a substantial number of small entities. This analysis provides 

factual basis for certification of this rule.

Potential Impact on Small Entities

U.S. commercial production of bananas takes place in Hawaii. In 2009, that State’s 

banana harvest totaled about 8,392 metric tons (MT), harvested on 240 farms.1 A banana farm is 

considered to be small according to the Small Business Administration’s standard for Other 

Noncitrus Fruit Farming (North American Industry Classification System category 111339) if its 

 

1 Hawaii Farm Facts, May 2010. 

http://www.nass.usda.gov/Statistics_by_State/Hawaii/Publications/Fruits_and_Nuts/annbanFF.pdf
3

annual receipts are not more than $750,000. Average annual receipts for the Hawaiian producers 

in 2009 was about $42,400, indicating that most if not all of these farms are small entities. 

Banana farms in Hawaii are small, but they would be little affected by the proposed rule,

given the very large quantity of bananas already imported by the United States and the relatively 

insignificant quantity expected to be imported from the Philippines. Moreover, bananas from the 

Philippines would only be allowed entry into the continental United States.

The international banana market is highly regional, and the United States imports

bananas from Central America, South America and the Caribbean.

2

 In 2009, the United States 

imported 3.6 million MT of fresh bananas, with Guatemala, Ecuador, and Costa Rica, 

respectively, the top three sources.

3

 Similarly, banana exports by the Philippines are principally

to Asian markets, with Japan, Iran, China, and Korea its major customers. This action will allow 

the importation of fresh bananas by the United States from the Eastern Hemisphere for the first 

time.

Banana imports from the Philippines will compete against existing U.S. banana imports 

from other countries. The volume of bananas expected to be imported from the Philippines is 

not more than 100 containers per year at most, or approximately 1,814 MT annually. This 

quantity is equivalent to about 0.05 percent of U.S. imports. 

In sum, the United States is a minor producer but a major importer of bananas. 

Compared to the volume of current imports, the quantity of bananas expected to be imported 

from the Philippines is negligible. Moreover, bananas from the Philippines will be allowed only

into the continental United States, not into Hawaii. For these reasons, any impact of the rule for 

 

2

http://www.unctad.org/infocomm/anglais/banana/market.htm

3 Hawaii Farm Facts, May 2010. 

http://www.nass.usda.gov/Statistics_by_State/Hawaii/Publications/Fruits_and_Nuts/annbanFF.pdf
4

U.S. banana producers in Hawaii would be small. The APHIS Administrator has determined that 

this action, if promulgated, will not have a significant economic impact on a substantial number 

of small entities.