FTA recommendations:
 

1. RISK ASSESSMENT BY OVERSEAS WHOLESALE OPERATOR / MASTER LOADER - if the overseas wholesale operator / master loader can identify that all consignments are low risk or have been treated to prescribed standards, consignments can be consolidated and imported into Australia without restriction. This model would be used in particular for goods that cannot be treated. The risk of this model is whether the wholesale operator / master loader has the expertise and required detail to determine high from low risk commodities based on tariff assessment. It may only become obvious that a high risk item has been consolidated once an import declaration has been completed by the customs broker in Australia and this may only be after deconsolidation of the FAK in Australia. This is clearly a high biosecurity risk.

 
NOTE – FTA has sought advice that in the event that a high risk commodity is not treated and is consolidated / imported to Australia, who is deemed responsible and what is the penalty for such breach?
 

2. OFFSHORE TREATMENT AT THE CONTAINER LEVEL - based on the risk outlined in point 1, we recommend that where possible, all FAK containers are treated offshore at a container level.

3. ONSHORE TREATMENT AT THE CONTAINER LEVEL – in the event that an FAK container containing high risk goods is transported to Australia and has not been dealt with in accordance with either of the above 2 options, then these must be treated onshore at the container level, destroyed or re-exported. In these circumstances it is not an option to have the container deconsolidated due to the biosecurity risk. FAK containers should be allowed to move underbond and seals intact to approved premises for treatment.

4. RE-EXPORT - while the re-export policy addresses the domestic biosecurity risk, it would have dire impacts on the logistics sector including: waiting for export vessel availability, terminal congestion, management of refunds on duty / GST paid and failed receipt of stock for compliant importers.