United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

December 

2014

Initial Regulatory Flexibility Analysis

Proposed Rule

APHIS-2014-0088

RIN 0579-AE05

Mexican Hass avocado; comprehensive 

revision to authorize imports from beyond 

the State of Michoacán

Policy & Program Development

Policy Analysis & Development
i

Summary

Mexican officials have requested that additional States in Mexico be allowed to export 

Hass avocados to the United States under the same systems approach that was implemented for 

Michoacán and has successfully kept pest infestations out of the United States. U.S. imports of 

avocado from Mexico have increased significantly over the years, from 311 million pounds in 

2003 to over 1.2 billion pounds in 2013. U.S. avocado production over the 10 years, 2002/03 to 

2011/12, averaged 423 million pounds per year, of which California accounted for 87.5 percent 

or over 375 million pounds. Nearly all of California’s production is of the Hass variety. 

While APHIS does not have information on the size distribution of U.S. avocado 

producers, according to the Census of Agriculture, there were a total of 93,020 Fruit and Tree 

Nut farms (NAICS 1113) in the United States in 2012. The average value of agricultural 

products sold by these farms was less than $274,000, which is well below the SBA’s small-entity

standard of $750,000. It is reasonable to assume that most avocado farms qualify as small 

entities. Between 2002 and 2012, the number of avocado operations in California grew by 

approximately 17 percent, from 4,801 to 5,602 operations. 

Avocados produced in the State of Jalisco, north of Michoacán, are expected to be the 

first that would be exported to the United States under this rule. These imports would help meet 

the increasing year-round U.S. demand for avocado. Avocado per capita consumption in the 

United States grew from 1.1 pounds in 1989 to 4.5 pounds in 2011. A growing Hispanic 

population and greater awareness of the avocado’s health benefits have helped to spur demand. 

In 2012, Jalisco produced about 90 million pounds of Hass avocados. Given required 

phytosanitary safeguards, only a fraction of this quantity is expected to qualify for importation 

by the United States. But even if all of Jalisco’s avocado production were to meet the 
ii

requirements for U.S. entry, the total quantity would be equivalent to less than 8 percent of U.S. 

Hass avocado imports in 2013 of over 1.2 billion pounds. The proposed rule is not expected to 

have a large impact on the U.S. avocado market or California producers because of potential 

imports from Jalisco. Any market effects are as likely to be borne by other foreign suppliers, 

such as Chile and Peru, as by U.S. producers. 
iii

Table of Contents

Summary.............................................................................................................................. i

Introduction......................................................................................................................... 1

Reasons Action is Being Considered.................................................................................. 8

Objectives of and Legal Basis for the Rule ........................................................................ 8

Potentially Affected Small Entities..................................................................................... 8

Projected Reporting, Recordkeeping, and Other Compliance Requirements................... 10

Duplication, Overlap, or Conflict with Existing Rules and Regulations.......................... 10

Alternatives to minimize Significant Economic Impacts of the Rule............................... 10
1

Introduction

Michoacán is the only Mexican State from which Hass avocados are allowed to be 

imported into the United States. The proposed rule would allow importation of fresh Hass 

avocados from other regions of Mexico. The Regulatory Flexibility Act requires agencies to 

evaluate the potential effects of their proposed and final rules on small businesses, small 

organizations and small governmental jurisdictions. This initial regulatory flexibility analysis 

describes expected impacts of this proposed rule on small entities, as required by section 603 of 

the Act.

In this introduction, we briefly describe the history of avocado imports from Mexico, 

followed by an overview of U.S. production, consumption, and trade of Hass avocados. Likely 

effects of the rule in terms of U.S. avocado import volumes are also discussed. 

History of U.S. Imports of Mexican Hass Avocados

Fresh Hass avocados from Mexico were granted entry into the United States in stages due 

to concerns regarding the possible introduction of certain pests. In 1993, APHIS authorized the

entry of Mexican Hass avocados into Alaska. Then in November 1997, fresh Hass avocados 

from Mexico were allowed entry into 19 northeastern States and the District of Columbia during 

a four-month period, November through February. After four years, the area and period 

approved for fresh Hass avocado imports from Mexico were expanded to 31 eastern States and 

the District of Columbia, October 15 through April 15. In 2004, fresh Hass avocados from 

Mexico were allowed entry year-round into all States with access to California, Florida, and 

Hawaii delayed for two years. 

Throughout these years of expanded access, only commercial consignments of Hass 

avocados grown in approved municipalities in Michoacán were allowed entry. Ongoing pest 
2

mitigation measures include orchard and grower registration, surveys including trapping, orchard 

sanitation, registration of packing houses, biometric sampling and culling of fruit, and 

phytosanitary certification. The proposed rule would allow Hass avocado imports by the United 

States under the same systems approach that has successfully prevented the introduction of pests 

via avocado shipments from Michoacán. Jalisco would be the first additional Mexican State 

from which Hass avocados would be imported. 

U.S. Hass Avocado Production

U.S. avocado production over the 10 years, 2002/03 to 2011/12, averaged 211,600 tons

per year, and California accounted for 87.5 percent or 187,800 tons.

1 Nearly all of California’s

production is of the Hass variety. The value of U.S. avocado production over this period 

averaged $355.5 million, with California accounting for over 95 percent, or $339.9 million per 

year.

During development of the 2004 rule that removed regional and seasonal access 

restrictions for Mexican Hass avocados, the rule's expected effects on California avocado 

producers were the focus of much industry comment. A fear that significant losses would be 

suffered by California avocado growers, however, proved to be unwarranted. California avocado 

growers have not seen major changes in their volumes of production or the prices they receive. 

Notwithstanding significant season-to-season variation in production and prices, California 

avocado growers saw slight upward trends in production and nominal prices over the 10 years, 

2002/03 to 2011/12.

 

1 USDA National Agricultural Statistics Service, 2013 Agricultural Statistics Annual, Table 5-16. Seasons are from 

Nov 1 to Oct 31 for California and June 20 to March 1 for Florida. Tons are short tons (2,000 pounds). 

http://www.nass.usda.gov/Publications/Ag_Statistics/2013/chapter05.pdf
3

U.S. Imports of Hass Avocados

The United States is the largest importer of avocados in the world. Over the three years, 

2011 through 2013, the United States imported an average of 1.1 billion pounds of avocados per 

year, valued at $954 million ($0.87 per pound) (table 1).

2

 More than 84 percent of imported 

Hass avocados came from the Mexican State of Michoacán.

Table 1. Average annual U.S. imports of Hass avocados, by source country, 2011-2013

Value (millions) Pounds

(millions)

Price per

pound

Percentage

of Total 

Quantity

World $954.2 1,094.4 $0.87 100.0%

Mexico $841.5 924 $0.91 84.4%

Chile $59.5 97.9 $0.61 8.9%

Dominican 

Republic

$18.2 35.8 $0.51 3.3%

Peru $34.7 34.2 $1.02 3.1%

Source: U.S. Census Bureau, as reported by Global Trade Information Services, Inc.

The dramatic increase in U.S. demand for Hass avocados over the past decade has 

enabled domestic producers to maintain production levels while allowing for large increases in 

avocado imports. During 2003 and 2004, the United States imported an average of 316 million 

pounds of avocados per year, valued at $157 million ($0.50 per pound). In 2005 and 2006, the 

United States imported an average of 452 million pounds of avocados per year, valued at $292 

million ($0.65 per pound). Even greater growth was realized in subsequent years. The average 

annual quantity of avocados imported, 2007-2010, was 75 percent more than the average import 

 

2 All data in this section are from the U.S. Census Bureau, as reported by Global Trade Information Services, Inc. 

The data are for all avocados, fresh or dried. However, nearly all U.S. avocado imports are fresh and of the Hass 

variety. All prices and values reported are nominal, that is, they have not been adjusted for inflation. 
4

levels for 2005 and 2006, and the average value was greater by 107 percent. In 2013, Hass 

avocado imports exceeded 1.26 billion pounds, four times the 311 million pounds imported in 

2003.

The average nominal price increased from $0.50 per pound in 2003-2004 to $0.87 per 

pound in 2011-2013. The average rate of inflation according to the United States Department of 

Labor was approximately two percent per year over this period; based solely on the inflation rate, 

we would expect the price of Hass avocados to have increased to around $0.64 per pound. Hass 

avocado prices increased at a rate of about 5.7 percent per year, reflecting the strong consumer 

demand for this fruit. 

Mexico has significantly increased its market share as a foreign supplier. In 2004, when 

U.S. avocado imports totaled 320 million pounds, Chile accounted for 64 percent of those 

imports and Mexico 27 percent. From 2005 to 2010, these relative shares were approximately 

reversed, with Mexico supplying 67 percent of the total and Chile 29 percent. As shown in table 

1, Mexico supplied over 84 percent of U.S. Hass avocado imports, 2011-2013, followed by Chile 

with approximately 9 percent of the U.S. import market, and the Dominican Republic and Peru

together supplying the remaining 7 percent.

As Mexico’s market share has increased, the quantity supplied by Chile has continued to 

decline, from 257 million pounds valued at $122 million in 2009, to less than 52 million pounds 

valued at $34 million in 2013. Figures 1 and 2 show how the quantity and value of U.S. imports 

of Hass avocados from Mexico have been increasing since 2003, while imports from Chile have 

been in decline since 2009. 
5

 

0

200,000,000

400,000,000

600,000,000

800,000,000

1,000,000,000

1,200,000,000

1,400,000,000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Figure 1.

Quantity of Hass Avacado Imports, 2003-2013

(pounds)

World

Mexico

Chile

DR

$0

$200,000,000

$400,000,000

$600,000,000

$800,000,000

$1,000,000,000

$1,200,000,000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Figure 2.

Value of Hass Avocado Imports, 2003-2013

(dollars)

World

Mexico

Chile

DR
6

Expected Impact of the Rule on Hass Avocado Imports from Mexico

The proposed rule would allow fresh Mexican Hass avocado imports from regions in 

Mexico beyond the State of Michoacán. Avocados produced in the State of Jalisco, north of 

Michoacán, are expected to be the first that would be exported to the United States under this 

rule (figure 3). In 2012, Jalisco produced about 90 million pounds of Hass avocados valued at 

$38 million. Given required phytosanitary safeguards, only a fraction of this quantity is expected 

to qualify for importation by the United States. But even if all of Jalisco’s production met the 

import requirements for U.S. entry, the total quantity would be equivalent to less than 8 percent 

of U.S. Hass avocado imports in 2013 of over 1.2 billion pounds. The proposed rule is not 

expected to have a large impact on the U.S. avocado market because of potential imports from 

Jalisco. Any market effects are as likely to be borne by other foreign suppliers, such as Chile and 

Peru, as by U.S. producers. 
7

Figure 3. Map of Mexico

 
8

Reasons Action is Being Considered

The action is being considered because Mexico has demonstrated that it can meet 

phytosanitary requirements for the export of fresh Hass avocados to the United States. 

Objectives of and Legal Basis for the Rule

The objective of the rule is to allow the importation of fresh Hass avocados from regions 

in Mexico beyond Michoacán, starting with the State of Jalisco. This action is based on a pest 

risk assessment and risk management document prepared by APHIS. The Plant Protection Act 

authorizes the Secretary to prohibit or restrict the importation of plants and plant products only 

when it is necessary to prevent the introduction of plant pests or noxious weeds into the United 

States. The systems approach in place, with the exception of the proposed removal of mandatory 

fruit cutting at land and maritime borders, will continue to satisfy our commitment under the 

International Plant Protection Convention to allow the importation of plants and plant products 

subject to the least restrictive measures consistent with ensuring phytosanitary security.

Potentially Affected Small Entities

The number of avocado farms in California increased by nearly 17 percent between 2002 

and 2012, from 4,801 to 5,602 operations.3 Total acreage, however, decreased by 20 percent 

during the same time period, from 75,570 acres to 59,814 acres. Despite the decrease in acreage, 

higher yields have allowed producers to maintain overall production levels. In 2012, nearly onehalf of California’s avocado farms were in San Diego County (2,778 operations and 20,506 

acres), followed by Ventura County (1,129 operations and 17,053 acres), Riverside County (670 

 

3 National Agricultural Statistics Service (NASS), United States Department of Agriculture (USDA), “California: 

State and County Data, Census of Agriculture.”
9

operations and 6,883 acres), Santa Barbara County (466 operations and 7,171 acres), and San 

Luis Obispo County (216 operations and 5,141 acres) (figure 4). 

According to the Census of Agriculture, there were a total of 7,495 avocado farms in the 

United States in 2012, of which 75 percent were in California. 4 Nearly all U.S. production of 

Hass avocados takes place in California, where Hass is the dominant variety grown. 

APHIS does not have information on the size distribution of U.S. avocado producers, but 

according to the 2012 Census of Agriculture, there were a total of 93,020 Fruit and Tree Nut 

farms (NAICS 1113) in the United States in 2012. Of this number, nearly 92 percent had annual 

sales in 2012 of less than $500,000, which is well below the SBA’s small-entity threshold of 

$750,000.5 While cash receipts by size for avocado farms were not reported in the 2012 Census 

of Agriculture, it is reasonable to assume that most avocado farms qualify as small entities. 

 

4 NASS, USDA, “United States: Summary and State Data, Volume 1,” 2012 Census of Agriculture.

5 Source: SBA and 2012 Census of Agriculture.

0

500

1000

1500

2000

2500

3000

3500

San Diego Ventura Riverside Santa

Barbara

San Luis

Obispo

Figure 4.

Number of Avocado Operations by 

County, 2002, 2007, and 2012

2002

2007

2012
10

Projected Reporting, Recordkeeping, and Other Compliance 

Requirements

Reporting and recordkeeping requirements associated with the proposed rule are 

discussed in the rule under the heading "Paperwork Reduction Act."

Duplication, Overlap, or Conflict with Existing Rules and 

Regulations

APHIS has not identified any duplication, overlap, or conflict of the proposed rule with 

other Federal rules.

Alternatives to minimize Significant Economic Impacts of 

the Rule

We have prepared this initial regulatory flexibility analysis because of our limited 

understanding of the potential additional quantity of Hass avocados that may be imported from 

Mexico over the longer term, as more States in Mexico meet the import requirements. In the 

absence of apparent significant economic impacts in the near term, we have not identified 

alternatives that would minimize such impacts.