United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

September 

2011

Analysis in Support of Certification That the 

Rule Will Not Have a Significant Economic 

Impact on a Substantial Number of Small 

Entities

Final Rule

2008-0085

RIN 0579-AD17

Importation of Fresh (Chilled or Frozen) 

Ovine Meat from Uruguay

Policy & Program Development

Policy Analysis & Development
1

Summary

This rule will allow the importation of fresh (chilled or frozen) lamb and mutton from 

Uruguay under certain conditions. U.S. production of lamb and mutton averaged 79,561 metric 

tons (MT) over the five years, 2006-2010. Over this same period, imports averaged almost 

75,100 MT (equivalent to about 94 percent of U.S. production). Uruguay expects its annual 

lamb and mutton exports to the United States not to exceed 2,000 MT. This quantity is 

equivalent to less than three percent of U.S. lamb and mutton imports and less than two percent 

of U.S. domestic supply of these commodities. A percentage of the imports from Uruguay are

likely to displace some of the lamb and mutton imported from existing foreign suppliers, further 

dampening any possible effects for U.S. businesses.

While most businesses that may be impacted by this rule, including U.S. sheep farms and 

meat processing establishments, are small entities, the APHIS Administrator has determined that 

this action will not have a significant economic impact on a substantial number of small entities.

 
2

Introduction 

This analysis provides the basis for certification by the APHIS Administrator that the

importation of fresh (chilled or frozen) ovine meat from Uruguay rule will not have a significant 

economic impact on a substantial number of small entities. We provide an overview of 

production and trade of lamb and mutton by the United States and Uruguay before discussing 

potential effects for small entities.

Sheep production in the United States has been marked by smaller inventories, fewer 

operations, and shrinking revenues during the last few decades. U.S. production of lamb and 

mutton averaged 79,561 metric tons (MT) over the five years, 2006-2010.1 Over this same 

period, imports averaged almost 75,100 MT (equivalent to about 94 percent of U.S. production), 

and were valued at $434.5 million (table 1). 

U.S. lamb and mutton imports dwarf U.S. exports of these commodities (table 1). By 

quantity, U.S. lamb and mutton exports, 2006-2010, were equivalent to only about eight percent 

of imports. In terms of value, U.S. lamb and mutton exports over this period were equivalent to 

only about four percent of imports, implying that the overall value of lamb and mutton products 

imported by the United States is of generally higher value than is the mix of U.S. lamb and 

mutton exports.

As shown in table 2, about two-thirds of U.S. lamb and mutton imports are supplied by 

Australia and about one-third by New Zealand, with negligible amounts coming from Canada, 

Iceland, and Mexico.

 

1 USDA ERS, “Livestock, Dairy, and Poultry Outlook,” LDP-M-204, June 15, 2011, p. 17. 

http://www.ers.usda.gov/publications/ldp/2011/06Jun/ldpm204.pdf

Lamb is defined as meat from sheep less than one year old, and mutton is defined as meat from sheep one year or 

older.
3

Table 1. Quantity and value of U.S. imports and exports of lamb and mutton, 2006-2010

Year Quantity in Metric Tons Value in Million Dollars

Imports Exports Net Imports Imports Exports Net Imports

2006 78,878.9 7,942.5 70,936.4 424.9 20.9 404.0

2007 83,421.3 3,955.2 79,466.1 453.4 11.2 442.2

2008 75,741.8 5,003.8 70,738.0 442.5 21.1 421.4

2009 69,585.4 6,975.0 62,610.4 431.1 21.5 409.6

2010 67,876.6 6,963.5 60,913.1 510.7 15.6 495.1

5-year 

average

75,100.8 6,168.0 68,932.8 452.5 18.1 434.5

Source: U.S. Census Bureau, as reported by USDA Foreign Agricultural Service. Sum of harmonized 

tariff schedule categories 020410, 020421, 020422, 020423, 020430, 020441, 020442, and 020443. 

 
4

Table 2. Percentage of U.S. lamb and mutton imports, 

by source country, 2006-2010

Quantity Value

Australia 66.8% 70.7%

New Zealand 33.0% 29.0%

Other 10.2% 0.3%

Source: Based on U.S. Census Bureau data, as reported by 

USDA Foreign Agricultural Service. Sum of harmonized 

tariff schedule categories 020410, 020421, 020422, 020423, 

020430, 020441, 020442, and 020443. 

1 Canada, Iceland, and Mexico.
5

Uruguay’s annual exports of lamb and mutton total between 20,000 MT and 25,000 MT.2 

The European Union and Brazil are the major destinations and account for about 50 percent of 

the quantity exported. The remainder is sold to 34 other countries. Uruguay expects its annual 

lamb and mutton exports to the United States not to exceed 2,000 MT. This quantity is 

equivalent to about 2.7 percent of U.S. lamb and mutton yearly imports, 2006-2010, and about 

1.3 percent of annual U.S. domestic supply over these five years.

Potential Impact on Small Entities

Entities that could be affected by this rule include sheep farmers, categorized within the 

North American Industry Classification System (NAICS) code 112410. The Small Business 

Administration (SBA) small-entity standard for this industry is annual receipts of not more than 

$750,000. The 2007 Census of Agriculture reports that there were 30,974 sheep farms that year, 

and the market value of the products sold by them totaled $435,107,000.

3

 Thus, average receipts 

per farm were about $14,050, well below the small-entity standard.

Establishments primarily engaged in processing meat and meat byproducts (except 

poultry and small game) from purchased meats could also be affected by this rule. They are 

classified within NAICS code 311612, for which the SBA small-entity standard is not more than 

500 employees. In 2007, 1,338 of the 1,381 establishments that comprised this industry (97 

percent) had fewer than 500 employees.4

Clearly, most U.S. businesses that may be affected by this rule are small. However, the 

impact of allowing fresh (chilled or frozen) ovine meat imports from Uruguay will be minor. As 

 

2

Information on Uruguay’s trade in ovine products and expected exports to the United States was provided in 

comment on the proposed rule by the Uruguayan Wool Secretariat (Secretariado Uruguayo de la Lama).

3

http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_1_US/st99_1_046_046.pdf

4 U.S. Census Bureau, 2007 Economic Census. http://factfinder.census.gov/servlet/IBQTable?_bm=y&-

geo_id=01000US&-fds_name=EC0700A1&-_skip=300&-ds_name=EC0731SA11&-_lang=en
6

indicated, expected imports from Uruguay are equivalent to less than three percent of U.S. lamb 

and mutton yearly imports in recent years and less than two percent of the U.S. domestic supply 

of these commodities. A percentage of the imports from Uruguay is likely to displace some of 

the lamb and mutton imported from existing suppliers, further dampening any possible effects 

for U.S. businesses. Under these circumstances, the APHIS Administrator has determined that 

this action will not have a significant economic impact on a substantial number of small entities.