United States 

Department of 

Agriculture

Animal and 

Plant Health 

Inspection 

Service

May 2012

Analysis in Support of Certification that the 

Rule will not have a Significant Economic 

Impact on a Substantial Number of Small 

Entities

Proposed Rule

APHIS 2012-0008

RIN 0579-AD70

Movement of mature green Sharwil 

avocados from Hawaii to the continental 

United States using a systems approach for 

pest mitigation

Policy & Program Development

Policy Analysis & Development
i

Summary

This proposed rule would allow the use of a systems approach for the movement of fresh, 

mature green Sharwil avocados from Hawaii to the continental United States. Avocados 

produced in the United States are principally grown in California, where nearly all of the fruit is 

of the small, dark-colored, rough-skinned Hass variety. Smaller volumes of avocados are 

produced in Florida and Hawaii, where varieties like the Sharwil that are larger and bright green 

in color are predominant.

The 2007 Census of Agriculture reported that there were a total of 8,245 avocado farms 

in the United States, with about 76 percent in California, 13 percent in Hawaii, and 11 percent in 

Florida. Average gross receipts for California avocado producers for the 2007-08 season was 

about $52,700, compared to average receipts of about $12,700 for Florida’s growers and about 

$750 for Hawaii’s growers. The Small Business Administration’s small-entity standard for 

avocado farms is annual receipts of not more than $750,000. While nearly all U.S. avocado

operations are small entities, it is evident that there is significant variation among the three States 

in average farm size.

We anticipate that Sharwil avocado consignments from Hawaii to the mainland would 

total about 180 metric tons per year, equivalent to about one-half of one percent of the U.S. 

supply of non-Hass avocados and to less than one-twentieth of one percent of the U.S. supply of 

all avocado varieties. They would be shipped between November and March, supplementing 

winter supplies. The APHIS Administrator has determined that this action, if promulgated, will

not have a significant economic impact on a substantial number of small entities.
ii

Table of Contents

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

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

Potential Impact on Small Entities...................................................................................... 1
1

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.

Hawaii has a history of quarantine treatment for Sharwil avocados due a variety of pests. 

APHIS conducted a pest risk analysis that found 11 quarantine significant pests that could be 

introduced with consignments of fresh, mature green Sharwil avocados into the continental 

United States. Currently, interstate movement is authorized if the avocados are fumigated with 

methyl bromide or fumigated in combination with cold treatment. However, both of these 

treatment regimes reduce the marketability of the avocados. The stand-alone fumigation causes 

fruit pitting and discoloration, resulting in a three- to four-day reduction in shelf life; methyl 

bromide combined with cold treatment also results in a significant reduction in shelf life due to 

the days the fruit is cold treated. 

The proposed rule would allow interstate movement of fresh, mature green Sharwil 

avocados from Hawaii under a systems approach. The proposed systems approach consists of 

orchard certification, trapping, orchard control and sanitation, harvest restrictions, post harvest 

safeguards, fruit culling, sampling, trace back requirements, limited distribution, and a limited 

harvest period. The proposed measures satisfy our commitment under the Plant Protection Act 

to allow interstate movement of plants and plant products subject to the least restrictive measures 

consistent with phytosanitary security.

Potential Impact on Small Entities

Avocado production in the United States largely takes place in California, where nearly 

all of the fruit grown is of the small, dark-colored, rough-skinned Hass variety. In Florida and 
2

Hawaii, varieties like the Sharwil, which is much larger and bright green in color, are 

predominant. Most avocado imports and exports by the United States are Hass. Given our 

limited understanding of the strength of consumers’ preferences for the various avocado varieties 

(that is, their degree of substitutability), we consider potential effects of the proposed rule for 

producers of non-Hass varieties as well as for all U.S. avocado farmers.

1

According to the 2007 Census of Agriculture, there were a total of 8,245 avocado farms 

in the United States that year, with about 76 percent (6,230 farms) in California, 13 percent 

(1,047 farms) in Hawaii, and 11 percent (951 farms) Florida.2 There were also 16 farms in Texas 

and 1 farm in Arizona producing avocados in 2007. Avocado farms in the three principal States 

differ significantly in size; in 2007, the average sizes ranged from about 12 acres in California, to 

7 acres in Florida, to 1 acre in Hawaii. 

While cash receipts by size of avocado farm were not reported in the 2007 Census of 

Agriculture, value-of-production data for the 2007-08 season can be combined with the number 

of farms reported in the 2007 Census of Agriculture for an indication of average sales per farm

by State.

3

 Average gross receipts for California avocado producers for the 2007-08 season was 

about $52,700, compared to average receipts of about $12,700 for Florida’s growers and about 

$750 for Hawaii’s growers. Avocado producers are included within the North American 

Industry Classification System category of Other Non-Citrus Fruit Farming (NAICS 111339). 

The Small Business Administration’s small-entity standard for this industry is annual receipts of 

 

1 One indicator of distinct markets is sizable price differences. For the four production years, 2006-07 through 

2009-10, California avocados had an average wholesale price of 96 cents per pound, compared to 70 cents per 

pound for Hawaii avocados and 30 cents per pound for Florida avocados. (2011 Agricultural Statistics Annual, 

Table 5-16. http://www.nass.usda.gov/Publications/Ag_Statistics/2011/Chapter05.pdf)

2 NASS, USDA, “United States: Summary and State Data, Volume 1,” 2007 Census of Agriculture, issued February 

2009 and updated December 2009. http://www.agcensus.usda.gov/Publications/2007/Full_Report/CenV1US1.txt

3

2011 Agricultural Statistics Annual, Table 5-16. 

http://www.nass.usda.gov/Publications/Ag_Statistics/2011/Chapter05.pdf
3

not more than $750,000. While clearly most U.S. avocado producers are small entities, there is 

significant variation among the three States in average farm size.

U.S. avocado production and trade over the four-year period, 2007-2010, are shown in 

table 1. Notwithstanding the generalizing assumptions noted in the table with respect to 

California production and U.S. exports, it is evident that the Hass variety dominates the U.S. 

avocado market. 

Table 1. Average annual avocado production, imports, and exports, and 

supply of all avocado varieties and of non-Hass varieties, 2007-2010, 

metric tons

All avocado varieties

Production 171,020

Imports 360,130

Exports 7,340

Supply 523,810

Non-Hass avocado varieties

Production 21,380

Imports 12,120

Exports 0

Supply 33,500

Sources: Production quantities, 2011 Agricultural Statistics Annual; trade quantities, 

U.S. Census Bureau.

Note: Production averages are for the seasonal years, 2006-07 through 2009-10. We 

assume that all Hass avocado production in the United States takes place in California 

and other varieties are not grown in California. We also assume that all U.S. avocado 

exports are Hass variety. Production quantities include avocado that is processed. 

As noted, we have little knowledge of the extent to which the Sharwil variety substitutes 

for the more prevalent Hass variety. We therefore compare the size of anticipated annual 

Sharwil consignments from Hawaii to U.S. supplies of both non-Hass avocados and all varieties 

of avocados.

The pest risk management document for this proposed rule notes that the volume of 

avocados that would be moved from Hawaii to the continental United States is unknown. 
4

However, given current production levels, the volume is anticipated to be fewer than 10 standard 

shipping containers per year. This is an amount equivalent to about 180 metric tons. When 

compared to the levels of supply shown in table 1, annual Sharwil avocado consignments of 180 

metric tons would be equivalent to about one-half of one percent of the U.S. supply of non-Hass 

avocados and to less than one-twentieth of one percent of the U.S. supply of all avocado 

varieties. 

While the proposed rule would benefit Hawaiian avocado producers by allowing them to 

use a systems approach to mitigate pest risk, making the sale of Sharwil avocados to the 

continental United States more economically feasible, the quantity that is expected to be shipped 

would not significantly affect the mainland avocado market overall or the more limited market 

for non-Hass varieties. With imports providing one-third of the U.S. supply of non-Hass 

avocados and two-thirds of the U.S. supply of all avocados, any effects of the proposed rule for 

U.S. mainland producers would be further muted. Moreover, the Sharwil avocados from Hawaii 

would be shipped between November and March, when there is increased reliance on foreign 

suppliers. Any market effects of the proposed rule could be expected to be borne proportionately 

by avocados supplied from abroad during the winter months. Based on these factors, the APHIS 

Administrator has determined that this action, if promulgated, will not have a significant 

economic impact on a substantial number of small entities.