FTA / APSA SUBMISSION TO SENATE COMMITTEE - BIOSECURITY PROTECTION LEVY & TERMINAL ACCESS CHARGES

Thursday, April 11, 2024
Building on the momentum of our "Three-point plan" as outlined in our member notice from 19 February 2024, the following submission focusses on a revised model for the controversial Biosecurity Protection Levy and the need for a mandatory code to control the rate of increase of stevedore-imposed Terminal Access Charges.
SUBMISSION

Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA) have provided a formal submission to the Rural and Regional Affairs and Transport Legislation Committee examining the Agriculture (Biosecurity Protection) Levies Bill 2024 [Provisions] and Related Bills.

SUBMISSION AVAILABLE HERE


SUMMARY
The Department of Agriculture, Fisheries and Forestry (DAFF) use labour intensive processes with biosecurity officers physically assessing import documentation and selecting consignments for further treatment or inspection on a set criterion for inspection. It is an outdated system unable to keep pace with increases and changing patterns of international trade.

As became evident in Senate Estimates 13 March 2024, DAFF are unable to recruit and train staff quick enough to keep up with demand. Despite the best efforts of management and existing frontline officers, industry is paying a heavy price.

This is causing significant delays for importers to gain release of cargo resulting in breaches to commercial contractual arrangements, adding to storage costs and generating exorbitant container detention fees administered by and payable to foreign owned shipping lines.

Making matters worse, stevedores and empty container parks are ramping up their 'ransom model' forcing transport operators to pay designated fees or be denied access to container collection and dispatch facilities. It is not sustainable for our exporters and importers to absorb this rapidly increasing impost of hundreds of millions of dollars annually whereby they cannot influence service or price.

The scourge of these Terminal Access Charges (TACs), combined with the biosecurity processing delays, is resulting in rapidly escalating supply chain costs directly adding to inflationary pressures and fueling the cost-of-living crisis.

FTA and APSA acknowledge that DAFF is co-designing solutions with industry and notes the significant financial commitment from the federal government to modernise systems.

These longer-term strategies have the potential to set a benchmark of global best practice in safeguarding against biosecurity risk whilst enabling legitimate trade. Whilst applauding and supporting these initiatives, the federal government must introduce immediate relief measures. FTA and APSA fully support the need to protect against biosecurity risks and would be prepared to pay an additional levy or cost recovery fee on the proviso that an appropriate proportion directly translates to commensurate improved and immediate trade facilitation measures.

RECOMMENDATIONS

FTA and APSA have engaged with members and key industry stakeholders in developing the following 3-point plan, recommending the federal government:
  1. does not proceed with the complex proposed levy against producers ($47.5m being 6% of the budgeted Biosecurity Protection Levy);
  2. increase the Full Import Declarations (FID) cost recovery to recoup the above $47.5m shortfall, and additional funds to address interim remedial action to support import processing until additional permanent resources and benefits of modernised systems are realised; and
  3. offset the increased FID cost recovery impost on importers, by regulating against the current incontestable Terminal Access Charge (TAC) regime, currently costing importers and exporters more than $500m per annum.
Paul Zalai - Director FTA | Secretariat APSA | Director GSF