FTA / APSA Submission - Simplified Trade System Consultation Paper 2024

Monday, May 6, 2024

The Simplified Trade System (STS) reforms aim to deliver a simpler, more effective and sustainable cross-border trade environment that will ensure Australia remains a globally competitive trading nation. The Federal Government released the STS Consultation Paper 2024, seeking views on 3 draft frameworks:
  1. Trade Identity Policy Framework 
  2. Fit and Proper Person Assessments Reform
  3. Border Controls Policy Framework




FURTHER DETAIL

FORMAL SUBMISSION

 

SUMMARY OF RECOMMENDATIONS

 

RECOMMENDATION 1 - Review and reduce the reliance on costly digital certificates by exploring alternative secure digital identity technologies that can lower costs and simplify processes for businesses.


RECOMMENDATION 2 - Implement a centralised identity management system to eliminate redundant data submissions and streamline cross-border transactions.

RECOMMENDATION 3 - Develop a unified digital identity framework that ensures compliance with the Privacy Act, thereby reducing the risk for businesses related to data breaches and non-compliance.

RECOMMENDATION 4 - Implement digital solutions to replace manual identity verification forms like the B1555, enhancing efficiency and accuracy in the identity verification process.

RECOMMENDATION 5 - Establish clear guidelines and standards for trade identity management that align with international best practices to ensure seamless international trade operations.

RECOMMENDATION 6 - Explore and adopt international innovations to enhance the security and efficiency of trade identity processes.

RECOMMENDATION 7 - Implement a centralised digital platform where businesses can submit necessary FPP information once, which can then be accessed by all relevant agencies. This platform should be designed with robust security measures to protect sensitive information and comply with privacy standards.

RECOMMENDATION 8 - Establish stringent data protection and privacy protocols to govern the sharing and accessing of FPP data across agencies. This should include encryption of data in transit and at rest, rigorous access controls, and regular audits to ensure compliance with privacy standards.

RECOMMENDATION 9 - Include a clear mechanism within the FPP framework for quickly resolving discrepancies and errors in FPP data. This mechanism should involve a straightforward process for businesses to correct or update their information and for agencies to re-evaluate decisions based on the corrected data.

RECOMMENDATION 10 - Implement a system where once an FPP assessment is completed, it is valid for all related applications for a set period, reducing the frequency of assessments needed. Streamline the assessment process by consolidating similar FPP requirements across different licenses and reducing the frequency of assessments for businesses with a proven compliance record.

RECOMMENDATION 11 - Explore opportunities to extend the validity period of FPP assessments and look to synchronise renewal periods where possible across different licenses to reduce the frequency and volume of assessments, thereby lessening the operational and financial burden on businesses.

RECOMMENDATION 12 - Implement FPP assessments that are linked to personnel as well as the business entity. This would allow for continuity in business operations even when there are changes in business structure or management. Such a system should include provisions for swift updates and reassessments that are triggered automatically by changes in key personnel or business structure, thus minimising delays and maintaining continuity.

RECOMMENDATION 13 – Review and potentially revise or eliminate quota systems like the Cheese and Curd Quota System to enhance fairness and operational consistency across businesses.

RECOMMENDATION 14 – Modernise and digitise processes, like the Unaccompanied Personal Effects Statement (B534 Form), to reduce manual entry and speed up customs clearances.

RECOMMENDATION 15 – Consider outsourcing complex compliance tasks to specialised agencies or consultants for efficiency.

RECOMMENDATION 16 – Strengthen collaborative efforts between government agencies and the trade sector to refine and optimise border control processes, including the review and potential revision of HVSO practices and other high-impact areas.

RECOMMENDATION 17 – Establish ongoing feedback mechanisms to monitor the implementation and impact of new principles, ensuring they adapt to evolving trade needs and technologies.

RECOMMENDATION 18 – Conduct a focused review on the regulatory burden faced by customs brokers and other trade participants, aimed at simplifying and reducing the complexity and number of regulations they must navigate.

RECOMMENDATION 19 – Work with industry groups to advocate for more flexible and adaptive regulatory frameworks that can accommodate emerging technologies and reduce redundancies.

RECOMMENDATION 20 – Implement state-of-the-art security measures for handling sensitive trade identity data, ensuring compliance with both national and international standards.

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