The Australian Peak Shippers Association (APSA) has received the below information from one of its member associations [the Australian Horticulture Exporters and Importers Association (AHEIA)] in terms the cost recovery design of exports certification.

FTA / APSA are looking to support the AHEIA lead on this advocacy activity - please share views direct to me at pzalai@FTAlliance.com.au

Paul Zalai - FTA / APSA

RE: Draft available for public consultation – Export: IAN 2019-46 - Cost Recovery Design – Consultation on cost recovery of exports certification

Link: http://www.agriculture.gov.au/export/controlled-goods/plants-plant-products/ian/2019/2019-46

A Draft 2019/20 Cost Recovery Implementation Statement for plant export cost recovery arrangements has been released by the DoA outlining the costs associated with the delivery of export regulatory activities and provides a set of proposed charging adjustments.

These changes include an increase in charges for:

Establishment Registrations (simple) = $4,327 (up from $3,000): an increase of 44%

Establishment Registrations (complex) = $8,655 (up from $6,000): an increase of 44%

Phytosanitary Certificates = $113 (up from $38): an increase of 197%

Export volume (tonnage fees; non-protocol rates) = $2.45 (up from $0.65): an increase of 277%

Export volume (tonnage fees; protocol rates) = $4.90 (up from $1.30): an increase of 277%

Audit fees = $57 per quarter hour (up from $36): an increase of 58%

Some fees will be reduced:

Electronic documents - $5, down from $12

Manual documents - $31 down from $100

Following implementation of new government policy announced in the 2018/19 Budget, the cost recovery base includes levy charges to recover:

enforcement activities that are directly related to the regulatory function of ensuring industry compliance with international import conditions

scientific and technical advice related to supporting industry to improve, maintain or restore market access

the cost of overseas counsellor networks assisting industry meet export requirements for detained consignments or during trade disruptions

AHEIA will be preparing a detailed submission opposing the proposed increases in charges.

Members who wish to provide feedback on the proposed charging adjustments should make a submission through Have Your Say by 10 December 2019, or alternatively contact AHEIA to communicate your views so we can collate and provide a submission on your behalf.

AHEIA Advocacy:

In 2018, AHEIA actively advocated against the implementation of the proposed cost recovery arrangements and united with HEICC committee members to deliver a joint submission to DoA on concerns surrounding the charging review. This advocacy resulted in a deferment in the implementation of adjusted cost recovery arrangements.

AHEIA members will soon be able to access the 2018 joint industry submission in the member login area of the AHEIA website – if you cannot login, contact Rhoda: admin@horticulturetrade.com.au
Further action, in September 2019, resulted in additional advocacy on behalf of members with a joint industry submission to the Minister of Agriculture – this letter will soon be added to the AHEIA Member area.
AHEIA and multiple industry groups recommended that the government:

should freeze any increases in cost-recovery fees (and waive any historical overspends) until a large and sustainable export industry is established;
should provide additional resources to assist the Department of Agriculture further develop market access for the horticulture sector; and
with regard to any future changes to the cost-recovery model, should appoint an independent advisor to co-design (with industry) the process, with a clear priority on service delivery and efficiency.

The DoA has since committed to commissioning an independent review of their export cost recovery arrangements, conducted by Ernst and Young, which will be conducted in parallel to the public consultation of the Draft 2019/20 CRIS.

Further advocacy:

AHEIA will engage with the independent reviewer to express industry viewpoints on the Draft 2019/20 CRIS.

AHEIA will engage with other industry bodies to develop a joint submission responding to the Draft 2019/20 CRIS

AHEIA will further lobby the Minister's office to express concerns of how the proposed cost recovery arrangements will impact Australia's horticultural exports.