FTA /APSA have lodged a submission in response to the draft Regional Standard for Phytosanitary Measures (RSPM): The Safe Movement of Shipping Containers, currently under consultation across the APPPC and PPPO regions.
The submission supports the objective of minimising biosecurity risks associated with container movements, while highlighting the importance of ensuring that future implementation frameworks remain practical, risk-based and operationally achievable across international supply chains.
FTA/APSA note that many elements of the proposed framework are already familiar within the Australian context, particularly through existing container cleanliness requirements and the use of authorised industry participants under Approved Arrangements.
A key concern raised in the submission is that the draft RSPM remains high-level and principles-based, with the real-world impacts to be determined through implementation by individual National Plant Protection Organisations (NPPOs). Without consistent application across jurisdictions, there is a risk of increased complexity, duplication and trade disruption.
Key positions and recommendations advanced by FTA/APSA include:
- ensuring implementation remains risk-based, proportionate and aligned with existing operational frameworks where possible
- avoiding fragmented or country-specific documentation frameworks that could increase administrative burden and supply chain delays
- recognising existing industry controls and practices, including container cleanliness declarations and Approved Arrangement models
- ensuring responsibility for container cleanliness is aligned with parties having the greatest level of operational control over the container at the relevant point in time
- developing practical and scalable implementation guidance prior to adoption
- maintaining ongoing industry consultation to ensure measures reflect real-world supply chain operations and do not unnecessarily disrupt trade flows
The submission also highlights industry concerns relating to inconsistent implementation across NPPOs, increased compliance and certification requirements, allocation of liability across the supply chain, and the potential operational impacts associated with additional inspection, cleaning and audit processes.