In order to export fruit to a foreign country, an agreement must be developed and approved by both the U.S. and the importing country. The agreement can be as simple as agreeing to have shipments inspected prior to shipping and a phytosanitary certificate issued. However, sometimes a more official work plan must be negotiated. A basic export work plan can include post-harvest handling protocols, inspection protocols, cold room and/or fumigation chamber certifications, as well as transporting restrictions. Work plans often cover postharvest treatments, if any, how many leaves are allowed, and even stem length rules. The basic plan may also list quarantine pests of specific concern and specify declarations for the phytosanitary certificate. But a basic work plan generally does not include orchard requirements for pest monitoring, sampling, or control methods.

A Systems Approach work plan is more extensive than a basic work plan and includes provisions for orchard pest management and pre-harvest risk evaluations for the pest of interest. Codling moth (Cydia pomonella (L.)) is the primary pest of concern for Taiwan. The Systems Approach work plan spells out expectations for controlling the pest in the orchard and states that orchards must maintain all records related to those controls. A special evaluation must also be done to determine if the control program has resulted in a low-risk orchard before that orchard lot can be considered a candidate for Taiwan export.


So why is there a systems approach work plan for Taiwan? Here is some background about how it came to be developed.

Prior to 2004, the U.S. had a basic work plan agreement with Taiwan that included Codling moth on the phytosanitary certificate list of quarantine pests. However, there were 3 separate findings (detections) of Codling moth in 2004 crop fruit during inspections in Taiwan. This led to a requirement for stricter pre-screening methods for the 2004 crop fruit to re-open the export market. The stricter pre-screening method increased the cull fruit to be examined from 300 to 600. It is estimated that the industry lost nearly $26M in sales during the 4-month period the market was closed for discussion on the proposed work plan changes. The discussions led to the adoption of a Systems Approach work plan beginning with the 2005 crop fruit, addressing orchard certification through orchard and/or bin sampling, in addition to the increased pre-screening at the packinghouse. There were still 2 detections of CM, or “Strikes” – for the 2005 fruit crop, even with the new plan in place, leading to a bigger push for training, including maintaining records.

For 2006, the USDA added the requirement for the training date to be written on the orchard sampling worksheet and bin sampling form to prove that the technician was trained. Two subsequent detections of codling moth in November 2006 resulted in the USDA changing the bin sampling requirement to a minimum of 150 bin fruit to be randomly sampled from within the bins, not taken off of the top, and cut and inspected.

In 2007, there was a double-strike in November. This meant that although there were 2 detections, the second occurred while the first was still under investigation, meaning it only counted as a single strike against the work plan. Basically, we got lucky given that the penalty for one strike is less severe.

In June of 2008, USDA and BAPHIQ (Taiwan’s Bureau of Animal and Plant Health Inspection and Quarantine) approved a revised work plan that moved some of the work plan parts around and clarified others. It also made changes to the portion of the plan dealing with the investigations into codling moth finds, by better defining the inspection service’s roll, and the timeline for submitting reports and lifting suspensions. The revised plan also clarified the use of fumigation in a new separate section of the plan. There have been no “strikes” since 2007, which led to the lessening of penalties for codling moth detection in the 2013 version of the work plan. The work plan is under constant scrutiny, however, and could be made stricter if the industry lets down their guard and ships fruit lots with live codling moth larvae.


As mentioned above, the work plan remains under constant scrutiny. Failures in the Systems Approach Work Plan, resulting in live codling moth larvae reaching Taiwan, could have a devastating effect on the Washington apple industry. There are other issues though, that could result in changes in the work plan, such as concerns about postharvest decays, or any newly discovered or invasive pest. Exporting apples to China requires extensive controls for specific postharvest decay organisms both in the orchard and during storage. There are also provisions in the China work plan dealing with various insect pests. So far, Taiwan has not followed suite by adding these measures to their work plan. Quarantine pests beyond those already listed in the phytosanitary certificate could be added to any work plan at any time, or ones already listed elevated to major concern status. The best way for the industry to guard against work plan changes is to ensure that they use the best control and monitoring practices in the orchard, maintain best practices at storage and packing facilities, and select only the best qualifying fruit for export markets.

MRL Issues

Taiwan instituted a pesticide residue program with MRL tolerances below those for the US. More information including a list of MRLs can be found on the NHC website. Note that Taiwan may add to the list at any time.

Information Resources

The subpage links under Quick Links give growers, fieldmen, packers, and shippers the necessary information for following the guidelines set forth by the current work plan and sampling protocols for exporting apples to Taiwan. Included here are web page links to the full Systems Approach Work Plan, instructions and forms required for the sampling protocol to document that fruit come from qualified supplying orchards with low risk for codling moth infestation (as required by Sec. 1 of the Work Plan), and codling moth identification information.

If you’d rather skip the web pages and download the files directly, links are provided in the column to the right for the relevant PDF files. These files are current as of July 2016. Updates will be posted if/when they are made available by USDA APHIS and NHC.

Work Plan Training

For information on training click on the “Training Events” link to the left or click here.

Quick Links

Export Contact:

Northwest Fruit Exporters
Fred Scarlett, Manager
Cell: 509-95-3045
Stacey Powell, Admin. Asst.
Office: 509-576-8004
Fax: 509-576-3646
105 South 18th Street, Suite 227
Yakima, WA 98901

Northwest Horticultural Council
105 South 18th Street,
Suite 105 Yakima, WA 98801
Phone: 509-453-3193
Fax: 509-457-7615
Email: general@nwhort.org
NHC Website

Judy Macias, Asst. Nat’l Trade Dir.
Office: 206-439-4548
Davin Potts, Export Trade Specialist – WA/OR/ID
Office: 509-925-1188

USDA APHIS/PPQ Certification
Mike Schell, Program Coordinator, PPQ Officer, Wenatchee, WA
Cell: 509-710-1119
Office: 509-667-8465
Daryl Petrey, Program Coordinator, PPQ Officer, Yakima, WA
Cell: 509-279-9453
Office: 509-925-1188
Evan Pace, Export Cert. Specialist, Portland, OR
Cell: 503-314-1039
Office: 503-820-2756

Maria Valle, SE Mgr.
Cell: 509-480-2265
Office: 509-249-6900
Mark Bechler, SW Mgr.
Cell: 509-571-0048
Office: 509-249-6900
Brenda Buckmiller, NE Mgr.
Cell: 509-885-4500
Office: 509-662-0457
Bill Walker, NW Mgr.
Cell: 509-885-6172
Office: 509-884-4259

Ron Pence, Asst. Program Mgr.
Office: 503-986-4620
Cell: 503-559-8694
Kathy Boland-Phelps, District Mgr.
Office: 541-386-204
Cell: 541-490-0360

Denise Hughes, Section Mgr.
Cell: 208-850-5885
Office: 208-722-7084
Jared Stuart, Section Mgr.
Cell: 208-334-2283
Office: 208-332-8622

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