Statement of Thomas Dille
American Pistachio Growers Vice-Chairman
May 30, 2013
Before the U.S. Trade Representative
Trade Policy Staff Committee
Concerning the Proposed Transatlantic Trade and Investment Agreement
[Docket No. USTR–2013–0019]
On behalf of the growers, processors and affiliate members of the American Pistachio Growers,
we appreciate the opportunity to submit comments on the proposed Transatlantic Trade and
Investment Partnership (TTIP).
American Pistachio Growers (APG) is a voluntary agricultural trade association representing
pistachio growers, processors and industry partners in California, Arizona and New Mexico.
Governed by an 18-member Board of Directors, we are headquartered in Fresno, California. Our
organization has long served the industry by championing the interests of U.S. pistachio growers
and processors allowing their issues to remain front and center. Some of these issues include
pistachio nutrition research, government affairs, product development, food safety and market
development.
Negotiating Objectives for TTIP
The APG has several priorities for TTIP:
The immediate elimination of tariffs;
Harmonizing sanitary and phytosanitary standards; and
Export inspection in the exporting country
Economic Benefits in the Immediate Removal of Tariffs
The European tariff on pistachios is considerably low relative to most U.S. pistachio export
destinations.
(Table 1)
Tariff Schedule for Pistachios
HTS Number
0802.51.00
0802.52.00
2008.19.13
Description
Pistachios, fresh or dried, in shell
Pistachios, fresh or dried, shelled
Roasted almonds and pistachios
EU Rate
1.6%
1.6%
9.0%
U.S. Rate
0.9¢/kg
1.9¢/kg
1.0¢/kg
Prepare by Schramm, Williams & Associates Inc. using data from European Commission’s Common Customs Tariff Statistical
Nomenclature, Council Regulation (EU) No 927/2012 and the Harmonized Tariff Schedule of the United States (2013).
9 RIVER PARK PLACE EAST, SUITE 410 | FRESNO, CA 93720 | TEL: 559.475.0435 FAX: 559.475.0624 | AmericanPistachios.org
The tariff itself, however, still reflects an impediment to pistachio exports being shipped to
Europe. Pistachio production in Europe is in Spain, Italy, Greece and we suspect a little in
Portugal, and the Islands. We know the Italian pistachios being grown at the base of Mount Etna
are unique and sell for twice the price of U.S. As such, we are not competing against Italian
pistachios. We estimate the total European pistachio production to be 7,500 MT per year. The
attached APG’s 2012 World Pistachio Trade Report provides total U.S. exports to all the
European countries. As you will read, there is a great demand by European consumers for U.S.
pistachios.
As stated above, the current tariff on raw pistachios is relatively low compared to other crops.
The U.S. industry, as a result, has invested in the development of the market, and over the last 10
years has increased raw pistachio exports to Europe by a factor of almost five (see table 2
below). In 2012, the U.S. exported 43,000 tons of raw pistachios to Europe valued at $302
million. In terms of the tariff, this represents approximately $4.8 million. This $4.8 million cost
to imported pistachios could be used in a number of applications to increase exports to Europe,
including generic advertisements, the increased promotion of the product as a healthy alternative,
additional product research, or simply to lower the price of the product for consumers.
(Table 2)
U.S. Pistachio Export to Europe - 27
Units
$1,000
Metric Ton
2003
63,140
16,436
2004
108,457
26,184
2005
209,479
39,198
2006
194,163
37,603
2007
188,640
37,598
2008
292,173
60,313
2009
303,234
56,450
2010
305,904
49,314
2011
251,430
37,760
2012
302,076
43,044
Prepared by Schramm, Williams & Associates, Inc. using data from U.S. Department of Commerce.
In an analysis of costs to consumers, providing that the average consumer package is 1lb, the
current European tariff translates into $0.05 per bag for pistachio buyers. The industry estimates
that if the tariff on raw pistachios were removed, it would translated into increased exports to
Europe due to increased consumption spurred by lower costs to consumers and/or increased
promotion of the product as a health alternative to other snack foods.
Another justification for the immediate elimination of the tariff is Iran. Europe maintains a
Generalized System of Preferences (GSP) program. As is the case in the U.S., Europe’s GSP
helps developing countries by making it easier for them to export their products to the Europe
through the remove of tariff measures. Despite current financial transaction restrictions by the
U.S. and other nations applied sanctions that have been in place on Iran, Iran is a recipient of
European GSP. As such, Iran pays no duty when exporting to Europe and has a transportation
advantage to Europe due to its close proximity compared to the U.S. As stated above, the
European duty on raw pistachios is low. Despite this, Iran will continue to have a competitive
advantage on U.S. exporters and long as a tariff is imposed on U.S. exports to Europe.
Harmonizing sanitary and phytosanitary standards – Maximum Residue
Exporting crops is risky because of all the problems associated with exports, such as quality
standards, different and changing regulations, strikes, piracy, etc. The U.S. has implemented the
National Export Initiative that urges small and medium business to export. One of the frequent
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problems for all exporters is pesticides residues. Pistachios cannot be grown according to each
country’s pesticide tolerance so the growers’ pesticide practice is to follow California, federal or
Codex levels. We urge our U.S. negotiators to make the harmonization of pesticide maximum
residue levels a major trade objective rather than create a committee to work on the problem after
the implementation of the TTIP agreement. Improving regulatory coherence and transparency
in regulatory rule-making is always desirable to reduce the potential for cross-border issues.
Export inspection in the exporting country
The U.S. pistachio industry continues to improve its ability to eliminate aflatoxin to a level of
success unmatched by other pistachio producing countries. The industry strives to ensure that all
U.S. exporters export the cleanest and safest product in the world. As a result, there were no
findings of aflatoxin on any U.S. product in 2012 in excess of European allowable levels. The
U.S. has developed new technologies for aflatoxin control, and expects these approaches to
further reduce the minimal levels sometimes found in U.S. pistachios. As such, the industry has
requested that our government propose to European a program in which aflatoxin testing could
be conducted in the U.S. before it is exported to Europe. APG supports our trade negotiators
finding a suitable agreement to this end. We believe that if a pilot program were to be
implemented, U.S. exporters would easily prove that pre-shipment inspection for aflatoxin would
produce the same quality product that is currently being shipped.
The purpose of a pre-clearance program would be to eliminate unnecessary costs and, at times,
administrative delays. These delays often result in delivery challenges to bulk purchasers,
demurrage fees and potentially re-exportation costs. Providing this enhanced cooperation would
save millions of dollars for the industry, as well as further the effort to ensure predictability when
receiving a product from the U.S.
Conclusion
TTIP negotiations have the potential to be among the most beneficial trade agreements since the
North American Free Trade Agreement. APG believes that although negotiations will be
difficult, the agreement will ultimately spur the expansion of domestic and European businesses
that will in turn increase U.S. and European purchasing power. APG requests that the USTR
Trade Policy Staff Committee carefully consider the comments above. We appreciate this
opportunity to provide the committee with our comments.
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Attachment
WORLD PISTACHIO TRADE
2013
Schramm, Williams & Associates, Inc.
March 2013, First Edition
Attachment
European Union 27 - Imports from U.S.
(in metric tons)
Country
2003
2004
2005
2006
23007
2008
2009
2010
2011
Luxembourg
5,635
7,746
10,607
8,017
8,245
6,501
9,672
19,092
11,264
The Netherlands
4,343
4,064
7,170
10,707
12,496
12,660
11,951
9,683
7,381
Belgium
3,133
3,396
4,379
2,514
6,420
12,922
9,562
5,619
6,131
Germany
2,203
2,287
1,896
2,121
4,349
7,637
4,171
3,831
4,142
France
3,882
4,791
4,649
3,368
4,228
4,514
3,827
4,408
3,219
Italy
2,417
2,297
3,570
2,227
2,843
2,336
2,796
1,898
2,701
Spain
521
246
1,895
2
1,537
2,895
3,342
2,456
1,766
U.K.
245
659
2,279
1,178
1,824
1,805
1,684
1,482
1,328
Greece
45
342
2,618
1,647
1,526
1,385
1,872
1,912
517
Sweden
0
0
8
20
82
146
152
152
472
Poland
0
62
108
20
40
174
77
59
217
Cyprus
0
38
82
242
283
438
191
274
186
Portugal
119
141
248
248
258
369
206
113
186
Bulgaria
0
0
0
2
105
268
172
173
150
Romania
0
13
20
96
186
416
240
97
38
Slovenia
0
0
0
0
0
0
0
0
20
Lithuania
0
1
20
0
217
214
59
80
20
Finland
0
0
0
0
0
0
1
3
0
Estonia
12
13
0
0
0
96
39
0
0
Latvia
0
20
117
4
179
325
20
0
0
Czech Republic
0
140
493
10
21
80
20
0
0
Hungary
0
0
0
0
12
54
0
0
0
Slovakia
0
112
198
1,474
201
0
0
0
0
Denmark
39
75
57
122
5
0
0
0
0
Other
1
0
0
0
0
0
1
1
0
Total
12,617
14,633
22,637
15,295
24,316
36,074
28,432
22,558
39,738
Source: Eurostat.
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