United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Importation of fresh avocado fruit (Persea americana

var. Hass) from Guatemala into the United States for
consumption

Risk Management Document

March 13, 2024

Pest Exclusion and Import Programs

Imports Regulations and Manuals

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Introduction

The importation of fruits and vegetables for consumption into the United States is regulated
under Title 7 of the Code of Federal Regulations, Part 319.56 (7 CFR § 319.56). Currently, fresh
Hass avocado fruit from Guatemala is not allowed importation into the United States (USDA,
2023). The National Plant Protection Organization (NPPO) of Guatemala, Ministerio de
Agricultura Ganadería y Alimentación, requested market access for fresh Hass avocado fruit,
Persea americana var. Hass (Lauraceae), for consumption from Guatemala into the United
States (MAGA, 2019). To support the request, the NPPO of Guatemala provided prerequisite
information that included field and industry practices commonly employed in the production of
fresh Hass avocado fruit (MAGA, 2020 and 2021).

Animal and Plant Health Inspection Service (APHIS) prepared a pest risk assessment titled
“Importation of avocado (Persea americana var. Hass) for consumption from Guatemala into the
United States: A Qualitative, Pathway-Initiated Pest Risk Assessment” (USDA, 2022) using
scientific literature, port-of-entry pest interception data, and information provided by the NPPO of
Guatemala. APHIS identified 11 quarantine pests (10 arthropod, 1 fungus) that could follow the
pathway as per the guidelines provided by the International Plant Protection Convention (IPPC)
in the International Standard for Phytosanitary Measures (ISPM) No. 11, “Pest Risk Analysis for
Quarantine Pests” (IPPC, 2021a). The use of biological and phytosanitary terms in that and this
document is consistent with ISPM No. 5, “Glossary of Phytosanitary Terms” (IPPC, 2023).

In this risk management document, APHIS proposes systems approach measures to support
the importation of fresh Hass avocado fruit for consumption from Guatemala into the
United States and provides evidence to conclude that these measures will effectively
prevent the introduction of the identified pests of concern into the United States. The
systems approach for Hass avocado fruit is based upon the establishment of pest-free places
of production for specific pests and obviates the need for post-harvest commodity
treatments to achieve phytosanitary security (IPPC, 2021c; NAPPO, 2003).

Findings of the Pest Risk Assessment

As per, “Importation of avocado (Persea americana var. Hass) for consumption from Guatemala
into the United States: A Qualitative, Pathway-Initiated Pest Risk Assessment” (USDA, 2022),
the following organisms are candidates for pest risk management because they have met the
threshold for unacceptable consequences of introduction and can follow the commodity import
pathway (Table 1):

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 Pest type Taxonomy Scientific name Likelihood of
Introduction

Arthropod Coleoptera: Curculionidae Conotrachelus aguacatae Medium

Barber

Arthropod Coleoptera: Curculionidae Conotrachelus perseae Barber Medium

Arthropod Coleoptera: Curculionidae Heilipus lauri Boheman Medium

Arthropod Lepidoptera: Holcocera plagatola Adamski Low

Coleophoridae

Arthropod Lepidoptera: Elachistidae Stenoma catenifer Walsingham Medium

Arthropod Lepidoptera: Noctuidae Euxoa sorella Schaus Low

Arthropod Lepidoptera: Tortricidae Amorbia santamaria Phillips Low

and Powell

Arthropod Lepidoptera: Tortricidae Cryptaspasma perseana Medium

Gilligan & Brown

Arthropod Lepidoptera: Tortricidae Histura perseavora Brown Low

Arthropod Lepidoptera: Tortricidae Netechma pyrrhodelta Low

(Meyrick)

Fungus Dothideomycetes: Elsinoë perseae (Jenkins) Low*

Myriangiales Rossman & W.C. Allen

* This risk rating applies only to Hawaii and Northern Mariana Islands.

Risk Management Measures

APHIS proposes that fresh avocado fruit (Persea americana var. Hass L.) for consumption
from Guatemala may be imported into the United States under the following systems approach
conditions:

Oversight Requirements

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1. APHIS and the NPPO of Guatemala must jointly develop an operational workplan
(OWP) that details the activities and responsibilities that the NPPO of Guatemala will
carry out to meet the requirements of the systems approach. APHIS will be involved with
the NPPO of Guatemala in the implementation, monitoring, and supervising of those
activities.

2. The NPPO of Guatemala will provide oversight for all program activities. APHIS may
monitor places of production, packinghouses, and records if necessary.

3. If the NPPO of Guatemala finds that a place of production or packinghouse is not

complying with the requirements of the systems approach, no avocado fruit from the
place of production or packinghouse will be eligible for export into the United States
until APHIS and the NPPO of Guatemala investigate and implement remedial measures.

4. All Hass avocado fruit must be traceable to the place of production throughout the
production, packing, and export processes until arrival at eligible U.S. ports of entry.

5. Only commercial consignments are eligible for export as defined in 7 CFR section
319.56-2.

Place of Production Requirements

6. All places of production must be registered with the NPPO of Guatemala. If places of
production are sectioned into smaller managed units (i.e., production sites), then
production sites must also be registered with the NPPO of Guatemala.

7. The orchard and all contiguous orchards and properties must be surveyed semiannually
for a period of at least 5 years and found to be free of the moth and weevil avocado pests
listed in Table 1. Thereafter, the orchard and all contiguous orchards and properties must
be surveyed at least once per year provided the orchard and all contiguous orchards and
properties remain pest free. Specific trapping, pest survey, and buffer zone requirements
will be addressed in the OWP.

8. Personnel conducting trapping and pest surveys must be hired, trained, and supervised by
the NPPO of Guatemala.

9. As Guatemala produces Hass avocado fruits year-round, the NPPO of Guatemala will
visit and inspect places of production monthly, starting thirty days before harvest and
continuing until the end of harvest at each production site, to ensure growers are
following the systems approach measures.

10. All plant litter and fallen Hass avocado fruit must be removed from all places of
production to remove potential pest host material. Fallen avocado fruit must not be
included in field containers of avocado fruit brought to the packinghouse for export.

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11. The Hass avocado fruit must be free of leaves, twigs, and other plant parts.

12. All damaged or blemished Hass avocado fruit must be culled, as this measure was taken
into consideration as part of the pathway to determine the pest list and pest ratings
described in the Pest Risk Assessment.

13. Hass avocado fruit must be safeguarded by a pest-exclusionary material or plastic

tarpaulin while in transit to the packinghouse and while awaiting packing to prevent
infestation.

Packinghouse Requirements

14. All packinghouses must be registered with the NPPO of Guatemala.

15. All Hass avocado fruit must be packed within 24 hours of harvest in a pest-exclusionary
packinghouse or stored in a pest-exclusionary chamber to prevent infestation.

16. The packinghouse must have double doors at the entrance to the facility and at the
interior entrance to the area where Hass avocado fruits are packed, and other openings to
the outside of the packinghouse must be covered by pest-exclusionary material or barrier
to prevent pest entry.

17. All Hass avocado fruit must be dry-brushed and/or washed and waxed at packinghouse,
as this measure was taken into consideration as part of the pathway to determine the pest
list and pest ratings described in the Pest Risk Assessment.

18. Hass avocado fruit must be packed in pest proof packaging or covered with pest-
exclusionary material or plastic tarpaulin for transport to the United States. Until U.S.
Customs and Border Protection releases the consignment to commerce, the safeguarding
measures must remain in place to prevent infestation.

19. The NPPO of Guatemala must monitor and audit the harvesting system and ensure that
during the time the packinghouse is in use for exporting to eligible U.S. ports of entry,
the packinghouse may only accept Hass avocado fruit from registered, approved
production sites.

Inspection Requirements

20. Hass avocado fruit from each place of production must be inspected by the NPPO of
Guatemala or personnel authorized by the NPPO of Guatemala, following post-harvest
processing. At a rate to be jointly determined by APHIS and the NPPO of Guatemala, a
sample will be visually inspected for all quarantine pests, and a portion of the avocado
fruit will be cut open to detect internal pests.

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 21. If any pests from Table 1 are detected, the consignment from which the sample was taken
is prohibited from being shipped to the United States. Additionally, no avocado fruit from
the place of production or packinghouse will be eligible for export into the United States
until APHIS and the NPPO of Guatemala investigate and implement remedial measures.

22. The NPPO of Guatemala will issue a phytosanitary certificate (PC) for all consignments
of avocado fruit to verify that all Hass avocado fruit were produced in accordance with
the systems approach requirements and are free from quarantine pests.

23. All consignments are subject to inspection by U.S. Customs and Border Protection at the
U.S. port of entry.

Justification of risk mitigation measures

A systems approach provides an alternative to single measure import requirements (e.g.,

quarantine treatment) to meet the appropriate level of phytosanitary protection. They can also be
developed to provide phytosanitary protection in situations where no single measure is available
(IPPC, 2021b). The systems approach for Hass avocados is based upon the establishment of pest-
free places of production for specific pests and obviates the need for post-harvest commodity
treatments to achieve phytosanitary security (IPPC, 2021c; NAPPO, 2003). Pest free places of
production have been used successfully to prevent infestation by weevils of Heilipus spp. and
Copterus sp. and the seed moth S. catenifer of Hass avocados in Mexico and S. catenifer in Peru.
As agreed by the NPPOs, the specific trapping, pest survey, and buffer zone requirements to
ensure pest free places of production are addressed in the OWP (MAGA, 2020 and 2021; USDA,
2021). Finally, the use of pest-exclusionary packaging and structures (packinghouses or storage)
will prevent infestation until consignments are released to commerce by U.S. Customs and
Border Protection at the port of entry.

APHIS determined five of the 10 arthropod pests listed in Table 1, Co. aguacatae, Co. perseae,
He. lauri, S. catenifer, and Cr. perseana, have a medium likelihood of introduction to the United
States. Infestation of the avocado seed weevils, Co. aguacatae, Co. perseae, and He. lauri, may
cause premature fruit drop and discolored pulp from the frass of the internally feeding stages
(Francia Rico, 2008a; Segrera, 2019). Field culling will remove avocado seed weevil-infested
fruit exhibiting premature fruit drop from the pathway. At the packinghouse, discolored pulp or
frass on avocado seed weevil-infested fruit will be identified and removed from the pathway
during post-harvest processing or inspection by the NPPO of Guatemala. Similarly, infestation of
S. catenifer may cause premature fruit drop, and often, larvae penetrate the surface of the
avocado fruit, leaving visible, darkened holes (Cervantes Peredo et al., 1999; Hoddle and
Hoddle, 2008b). Field culling will remove S. catenifer-infested fruit exhibiting premature fruit
drop from the pathway. At the packinghouse, discoloration or holes on the surface of S.
catenifer-infested fruit will be identified during post-harvest processing or inspection by the
NPPO of Guatemala and removed from the pathway. Cr. perseana mainly infests fallen fruit and

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is not a serious pest of commercial orchards (Hoddle and Hoddle, 2008b; Mancilla-Brindis et al.,
2021). Field culling will remove Cr. perseana-infested fruit exhibiting premature fruit drop from
the pathway.

APHIS determined the remaining 5 arthropod pests listed in Table 1, Eu. sorella, Ho. plagatola,
N. pyrrhodelta, A. santamaria, and Hi. perseavora, have a low likelihood of introduction to the
United States. As for all pests listed in Table 1, pest surveys and trapping to establish a pest free
place of production will minimize the risks associated with Eu. sorella, Ho. plagatola, and N.
pyrrhodelta. Little is known about pest damage and host suitability for Eu. sorella, Ho.
plagatola, and N. pyrrhodelta, but all three pests were reared from avocado fruit collected from a
commercial orchard (Adamski and Hoddle, 2009). A. santamaria mainly feeds on foliage (Téliz
and Mora, 2007) but has been known to internally feed on large mature fruit (Brown and Hoddle,
2010). However, common industry practice is to harvest before an internal infestation is likely to
occur (MAGA, 2021). The recently described Hi. perseavora has been found in both managed
and unmanaged avocado orchards (Brown and Hoddle, 2010) but is most likely to infest fallen
avocado fruits (Arévalo and Bonilla, 2019). Field culling all fallen avocado fruit will remove Hi.
perseavora-infested fruit from the pathway.

APHIS determined the fungus listed in Table 1, El. perseae, has a low likelihood of introduction
to the United States. El. perseae -infected avocado fruits are misshapen and subject to premature
fruit drop, and visible purple and brown lesions develop on the surface of the fruit (McMillan,
1976; Palmateer et al., 2006). Fruit drop occurs before harvesting of avocado fruits, which occurs
at ¾ ripeness as per common industry practice (MAGA, 2021). Field culling will remove
infected fruit exhibiting premature fruit drop from the pathway. At the packing house, any
remaining misshapen or discolored fruit will be removed from the pathway during post-harvest
processing or inspection by the NPPO of Guatemala.

APHIS considered culling, brushing or washing, and waxing as part of commodity pathway in
the PRA (USDA, 2022). These measures remove external feeders from commercial
consignments, and subsequently, APHIS does not list external feeders on the PRA pest list
(Table 1) and does not address external pests in the RMD. Commercially produced Hass avocado
fruit is not considered a fruit fly host (Aluja et al., 2004; Willink and Villigran, 2007). Similarly,
APHIS does not list any fruit flies on the PRA pest list (Table 1) and does not address fruit fly
pests in the RMD. Thus, the requirements for varietal restriction (Hass avocado only), brushing
or washing of fruit, and waxing of fruit are important measures in the systems approach for
removing quarantine pests from the pathway.

Commercially produced Hass avocado fruit is usually of high quality and subject to advanced
pest control measures throughout the production cycle to maintain marketability. Cultural,
chemical, or mechanical means (e.g., pre-harvest application of pesticides, resistant cultivars,
and sanitation, such as removing and discarding damaged avocado) are mainstays of commercial

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crop production, ensuring pest-free avocado fruit (Kirk et al., 2001). Commercially produced
Hass avocado practices are effective to reduce the risk of all pests listed in Table 1 from entering
commerce.

The intended use (for consumption) reduces the risk of all pests listed in Table 1 from
establishing in the United States because the commodity is less likely to come into contact with
host material. Hass avocado fruit is likely to be consumed and debris disposed through normal
disposal channels limiting the opportunities for avocado fruit to encounter hosts in the United
States (USDA, 2022).

Inspection is considered effective at finding externally feeding pests or accidental hitchhikers

and preventing infested consignment from entering commerce (Cavey, 2003; Wittenberg &
Cock, 2001). The NPPO of Guatemala will inspect Hass avocado fruit for export to the United
States and issue a phytosanitary certificate which certifies that the consignment is free of pests.
In addition, Hass avocado fruit will be subject to inspection at United States ports of entry by
U.S. Customs and Border Protection.

Summary

The NPPO of Guatemala requested new market access for fresh Hass avocado fruit for
consumption from Guatemala into the United States (MAGA, 2019). An APHIS pest risk
assessment identified 11 quarantine pests that could follow the pathway. APHIS has determined
that the proposed systems approach based on pest-free places of production, orchard sanitation,
packinghouse measures, and commercial consignments, in conjunction with inspection and the
issuance of a phytosanitary certificate by the NPPO of Guatemala, will effectively mitigate the
10 arthropod pests and 1 fungus associated with fresh Hass avocado fruit imports from
Guatemala to the United States.

Author

Laura A. Jeffers. Ph.D.

Senior Risk Manager – Entomology

Contact Person

Esther Serrano
Regulatory Policy Specialist

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